Privacy Policy

Privacy Policy

Last updated on August 10, 2022.

Welcome to Kognito. This privacy policy (“Privacy Policy”) explains how Kognito Solutions, LLC (“Kognito”, “we”, “us” and “our”) collects, uses, shares and protects personal information of users of our websites, products and services.



  1. Our commitment to privacy
  2. Our products and services
  3. Consent to the collection, use and sharing of personal information
  4. Description of our users
  5. How we collect data
  6. What information we collect
  7. How we may use your information
  8. How we DO NOT use your information
  9. How we may share your information
  10. FERPA and HIPAA
  11. Student data
  12. Data security measures and disclaimer of liabilities
  13. Correction of your personal information
  14. Cookies and tracking devices
  15. Links from our Websites
  16. Data retention
  17. Telephone Consumer Protection Act notice
  18. California privacy rights
  19. Applicable law
  20. Dispute resolution
  21. Class action waiver
  22. Applicable language
  23. Job applicants
  24. Choice/opt-out and contact information
  25. Feedback
  26. Revisions to this Privacy Policy
  1. Our commitment to privacy

Kognito is committed to respecting your privacy and dedicated to protecting the personal information we collect.

Our goal in this Privacy Policy is to make clear what information we collect about you and your interactions with our websites, products and services, and what you can expect from us.

For information specific to how we treat Simulation User Data (as described below), please review Sections 6-9.

  1. Our products and services

To help you better understand our Privacy Policy, this section describes our websites, products and services.

We are a health simulation company. We provide our clients – schools and school districts, institutions of higher education, government agencies, non-profit organizations and businesses – with access to professional development, student curriculum and public education simulations on topics such as mental health, substance use, chronic disease, family relations, medication adherence, and patient-provider communication. Our simulations combine the science of learning, the art of conversation, and the power of game technology to 1) engage users in role-play conversations with virtual humans, allowing them to try different approaches, get personalized feedback and gain the confidence and skills to lead similar conversations in real-life; or 2) experience an encounter with a virtual coach who can help guide the learning experience on a particular topic.

We describe and market our products and services through, and we provide our simulations through or a custom URL for your institution. In this Privacy Policy, these, websites, including their content, and our mobile products and services, are our “Websites,” and our products and services are our “Services.”

  1. Consent to the collection, use and sharing of personal information

This Privacy Policy applies to our Websites, Services and the other ways in which we interact and collect information from you as described in the “How we collect data” section below.

By visiting or using our Websites or Services, or otherwise interacting with us (such as by email, chat, posting, etc.), you consent to the collection, use and sharing of your information as described in this Privacy Policy.

In addition, when you register an account with Kognito or for any Kognito product, the Terms of Use and User Agreement provide that you consent to this Privacy Policy.

If you are located outside the United States, your provision of personal information to us through the use of the Websites, Services or otherwise constitutes your consent to the transfer of your personal information into the United States and its collection and use as provided in this Privacy Policy. Although we do not require that you provide any sensitive personal information (such as ethnicity or race, religious beliefs or medical conditions), your provision of any such sensitive information is your express consent to the collection, use and transfer of such information.

  1. Description of our users

Our users are people who connect to our Services through our Websites.

Users who register for and utilize our simulation products through or a custom URL for your institution in connection with our agreements with our customer organizations are described herein as the “Simulation Users.”

All other users who are not logged in to a registered account for our simulation products are our “Visitors“.

  1. How we collect data

Kognito and its vendors may collect information directly from you or from a third party who is authorized by you or otherwise permitted by applicable law to share information with us (for example, your school or employer).

We collect personal information in the following ways:

  • Visit to the Websites.  When you browse or request information about our Services through our Websites, these actions typically require that you provide us with contact information (name, address, phone numbers and email addresses).
  • Registration. When you create an account for our Services, register, or login to access or use functions or features, these actions typically require that you provide us with your contact information, user ID and password, and, in some cases, your employer or school, and title.
  • Make a Purchase. When you make a purchase from our online store, you provide us with your contact information (Kognito uses a third party to process credit card transactions and we do not collect, use or store credit card information).
  • Communications. When you communicate with us for support, or by email, phone, through the Websites or otherwise, you might provide us with personal information.
  • Learning Activities.  When you use our simulation Services, we collect information about your grades and scores, your personal learning behaviors, and various metrics related to your learning of particular subject matters.
  • Surveys and Research. If you participate in our research studies about our products or the industries and professions we support, or our market research surveys or programs, you might provide us with contact or other personal information.
  • Forums. If you participate in our forums, blogs, intranets, chat rooms, “wikis” or other similar features, you might provide us with personal information.
  • Subscriptions. If you subscribe to one of our newsletters or request text alerts, you provide us with contact and preference information.
  • Social Media. If you interact with us on social media and networking pages and applications, such as Facebook, Instagram, LinkedIn, or post to our webpages, you might provide us with personal information.
  • Outside Sources.  We might receive information about you from outside sources, including personal information provided to us by your organization, and from other sources such as our service providers.
  • Automated Sources.  We collect certain information by automated means when you access or use our Websites and Services. This information may include, for example, usage details, Internet Protocol (“IP”) address, browser type, browser language, devices you use, access times, the sites linked from, pages visited, applications downloaded or accessed, links and features used, content viewed or requested, and other information collected through cookies. (To learn more, please see our “Cookies and tracking devices” section below.)
  1. What information we collect

We distinguish between the information we collect from Simulation Users and data that we collect from Visitors.

From Simulation Users, we collect “Simulation User Data” provided to us through or custom URL for your institution, including:

  • Registration information: your contact information (name, address, phone numbers and email addresses), user ID and password, your employer or school, and title.
  • Learning Activities information: the information generated by the Simulation User when interacting with the simulation, such as the user’s responses, choices, outcomes, scores and data related to the user’s learning behaviors.
  • Outside Sources information: your organization might provide us with your name in connection with you registering for our simulations.
  • Automated Sources information: certain data collected through automated means, such as browser information, but we do not use Targeting cookies as part of our simulations. (To learn more about cookies, please see our “Cookies and tracking devices” section below.)

How we use, and how we limit the use and sharing of, Simulation User Data is described below.

From Visitors, we collect personal information provided to us outside of our simulation services through the channels described above (“Visitor Data”).  This might include contact information, data provided to us through surveys, automated sources information, information you post through a forum, chat, on our social media, etc. or provide to us by email or other means of communication to, for example request information from us.  How we use and share Visitor Data also is described below.

  1. How we may use your information

We may use your personal information, either directly or through a third party, in the following ways:

  • To provide our Services to you.
  • To fulfill your requests for Services and communicate with you about those requests.
  • To set up your account and verify your identity when you register for our Services.
  • To monitor, record, analyze and report on your activity, interactions and engagement with our Services.
  • To track, analyze and report on your progress, success, results, performance, registrations, incomplete attempts, and results in connection with our Services.
  • To perform research and analysis to learn about our users’ interests, to further develop and improve our Services, and regarding the industries and professions we serve.
  • To perform benchmarking, analytics and general metrics about your performance.
  • To assess your organization’s performance as compared to other schools, organizations or Kognito customers after anonymizing and aggregating the data.
  • To analyze technical data such as cookies, content viewed, IP address, device use, site volume and load to improve our Websites and Services.
  • To verify compliance with our license terms.
  • To support and personalize our Services, Websites and advertising.
  • To inform you of new products, services or promotions we may offer.
  • To engage you on our social media platforms.
  • To protect the security and integrity of our Services, Websites, content and our business.
  • To respond to reviews, comments, or other feedback you provide us.
  • To comply with applicable legal or regulatory requirements and our policies, and protect against unlawful activity, claims and other liabilities.
  • For any other lawful purpose for which the information is provided.

We also may collect, use, process, transfer, and store any data about you in an anonymous, aggregated format.

  1. How we DO NOT use your information

We collect, use, process and store Simulation User Data separately from Visitor Data in our systems.

In addition:

  • We DO NOT use Simulation User Data for marketing purposes or permit such data, if shared with others (as described in the next section), to be used for marketing purposes.
  • We DO NOT combine Simulation User Data with personal information about you from other sources, except for personal information about you provided to us by your organization.
  • We DO NOT sell, rent, lease or otherwise provide any personal information to others for monetary or other valuable consideration.

For additional restrictions on the use of student data, please review Section 11.

  1. How we may share your information

We may share your personal information with the following groups or for the following reasons:

  • Corporate Affiliates and Business Partners. We may share Visitor Data with our corporate affiliates and business partners as necessary to provide you with the Services and for their marketing or other business purposes. Our corporate affiliates and business partners are under the same obligations as Kognito to protect the confidentiality of your information and protect your privacy. 
  • Your Organization. We may share your personal information, including Simulation User Data, for purposes of analysis, reporting and analytics with you, your organization (including other parties required by your organization), and your instructor(s) or supervisor(s) from your organization.
  • Research Organizations. We may share your personal information, including anonymized and aggregated Simulation User Data, with researchers or third parties in the industries or fields that we support to better understand changes and trends in such industries or fields.
  • Technical Support.  We may share your personal information, including Simulation User Data, to provide technical support to you, your organization, and its instructor(s) or staff.
  • Service Providers. We may share your personal information, including Simulation User Data, with third-party service providers that may access, process or store personal data in the course of providing, for example, payment processing, database monitoring, data storage and hosting services, and customer support.
  • Fraud Prevention.  We may share Visitor Data  with third-party service providers to confirm your identity to ensure only authorized users are accessing our Services and for general security.  We may share Simulation User Data with your organization in cases of suspected fraud, illegal activity, abuse or testing misconduct.
  • Advertising and Marketing. We may share Visitor Data with third parties for marketing, advertising, promotions, contests, or other similar purposes.
  • Mergers, Acquisitions, Divestitures. We may share, disclose or transfer your personal information, including Simulation User Data, to a buyer, investor, new affiliate, or other successor in the event Kognito, its parent companies or affiliates, or any portion, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of any assets or during steps in contemplation of such activities (e.g., negotiations and due diligence).
  • Law Enforcement. We may share your personal information, including Simulation User Data, to comply with any law or directive, judicial or administrative order, legal process or investigation, warrant, subpoena, government request, regulatory request, law enforcement or national security investigation, or as otherwise required by law.
  • Protection of Rights, Property or Safety. We may share your personal information, including Simulation User Data, if, in our sole discretion, we believe disclosure is necessary or appropriate to protect the rights, property or safety of any person, or if we suspect fraud, illegal activity, abuse or testing misconduct.
  • To Fulfill Your Requests.  We may share Visitor Data with third parties as necessary to fulfill a request you make to us.
  • To Enforce Our Legal Rights.  We may share Visitor Data to enforce our contractual rights, including for billing and collection purposes.
  • For Other Lawful Purposes.  We may share Visitor Data for other reasons permitted under applicable law.
  1. FERPA and HIPAA

In addition to the privacy and data security safeguards we take with your information, we also comply with other protections for your information.

In providing our Services, we are not directly covered by the Federal Educational Rights and Privacy Act (“FERPA”) or the Health Insurance Portability and Accountability Act (“HIPAA”).  However, to the extent we are required to do so by contract with an organization that provides your personal information to us, or with which we share your information, and to the extent that such personal information provided to us is subject to FERPA, HIPAA or equivalent laws or regulations for your state or country of residence, we will comply with such applicable law as required by such contract.

  1. Student data

We recognize the importance of protecting the privacy and safety of children. Our Websites and Services are not intended for children under 13 years of age.

We do provide limited Services directly to schools that enter into agreements with us for their educational purposes, and which might be used by children under 13 years of age at the direction of their school. When the school, district administrator or teacher registers its students, we rely on the school’s or district’s consent as an agent of the student user’s parent or legal guardian, as permitted by law. We limit the use of personal information collected pursuant to the terms of these agreements, and treat such information at least as restrictively as Simulation User Data.  We do not use student data for any commercial purpose, targeted advertising, profiling, or onward disclosure.

If you are under 13 and not using the Websites and Services at the direction of your school, district administrator or teacher, do not use the Websites and Services and do not send any information about yourself to us. If we learn we have collected or received personal information from a child under 13 without verification of parental consent or verification that the provision of such information was at the direction of the child’s school, district administrator or teacher, we will delete that information. If you believe we might have any information from or about a child under 13 that was not provided to us consistent with the foregoing, please contact us.

What Information Do We Collect About Students

As part of our engagements with some schools, we collect personal information directly and automatically from students, including those who might be under 13, related to their use of our simulations through

From all students, we directly collect the following information:

  • First Name
  • Last Name
  • Email address


For certain simulations, we may also collect the following demographic information:

  • Student ID
  • Class Grade
  • Birth Year


We use this information to track a student’s progress in our courses or to reset passwords.  We will not contact a student by email address for anything except the Services and the specific simulation the student participated in.

We may also collect additional demographic information from students through our post-simulation surveys including:

  • Class Grade
  • Student Athlete
  • Gender
  • Age
  • Race


We do not associate this survey information with the student’s name or other personal information, and we use it only to compile aggregated information about participants in our courses.

In addition to the information we directly collect, we automatically collect information about the student’s performance, scores, choices and activities in our simulations through  This information is used for internal purposes and by the student’s school, and is not disclosed to other entities.  We also may use this information in anonymized form for non-commercial research and analysis, to better understand how users use our simulations, and to improve and our simulations.

We also collect information automatically through the use of cookies and other technologies as described in Section 14.

We use automatically collected data to support the security, integrity and internal operations of and to authenticate users of our simulations.  We do not use identifiers to collect information about a student outside of

How We Use Student Data

We use personal information collected from students to provide our simulation services, respond to customer service and technical support issues and requests, and to provide the information to the student’s school for its educational purposes.

How We Share Student Data

We protect and share students’ personal information at least as restrictively as Simulation User Data, as described above.  We only share personal information student data with the student’s school.

Review, Deletion and Control of Student Data

Schools and parents have a right to review the information we have collected about their students/children, and to request its deletion.  Parents may ask us to stop collecting personal information from their child by emailing us at  In such cases, the child will not be able to take or complete our simulations.  To exercise these rights, you will be required to authenticate yourself as the child’s parent.  Please note that copies of information may remain in cached or archived form on our systems after you request us to delete it.

  1. Data security measures and disclaimer of liabilities

Security of your personal information is of the utmost importance to us. We use administrative, technical and physical safeguards to protect the security of your personal information from unauthorized disclosure.

We take reasonable security measures to secure your personal information against unauthorized access, loss, use, disclosure, or alteration by third parties and unauthorized employees, and review our security procedures periodically to consider appropriate new technologies and updated methods. However, no method of transmitting or storing electronic information is ever completely secure. Therefore, despite our efforts, we cannot guarantee the security of your personal information during its transmission or its storage in our systems. Accordingly, we make no warranty, express, implied, or otherwise, that your information will never be accessed, used or released in a manner that is inconsistent with this Privacy Policy. We are not responsible for any damages or liabilities relating to any security incidents, and we disclaim all representations and warranties regarding such matters to the fullest extent permitted by law. Where required under law, we will notify you of any loss, misuse or alteration of personal information so that you can take appropriate actions.

If information is transmitted to us using a means that is outside our systems, or if you transmit information to a third party, we cannot guarantee the security of information during transmission. Any such unsecured transmission is at your own risk. We recommend that you use appropriate security measures to protect the transmission of your information.

  1. Correction of your personal information

Accuracy is a top priority for us and you have the ability to correct, update or delete certain of your information.

You can ensure that any contact data is current and accurate either by logging into your account to review and maintain your information or by contacting customer service.

In other situations, depending on the type of information, you may need assistance from customer service in making a change. To protect your privacy, we may require you to prove your identity before granting access to, or agreeing to update, correct or delete your personal information.

We will attempt to answer all requests that we correct the data if it is inaccurate, or delete it as long as we are not required to retain it by law or for legitimate business purposes.  We will respond to your request to make changes to your records as soon as reasonably possible.

However, not all of your personal information can be changed. For example, we may have records about how much time you spent working in a training module. Although this information is linked to you, it cannot be changed. Similarly, learning data, completion status and other data kept in Kognito systems may not be changed by you, although you should contact us if you believe such data is not accurate.

  1. Cookies and other tracking devices

When you visit our Websites, you are offered an opportunity to accept our placement of cookies. Although you are not required to accept cookies from us, if you block or reject them, you may not have access to all of the features available through our Websites or Services, such as tests, trainings or other activities.

We may use cookies and similar technologies to operate and improve our Services, as well as to simplify our interactions with you.

A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and preferences, and recognize you as a return visitor to the websites. In addition, we may use log files, pixel tags, web bugs, web beacons, clear GIFs, Local Storage Objects (LSOs) such as HTML5 and Flash, or other similar technologies to collect information about the ways you interact with and use our Services, to support and enhance features and functionality, to monitor performance, to personalize content and experiences, for marketing and analytics, and for other lawful purposes as described above.

We may use the following types of cookies:

  • Strictly necessary cookies required for the operation of our Websites and Services. They include, for example, cookies that enable you to log into secure areas.
  • Analytical/performance cookies that collect information about how you use our Websites and Services. They allow us to recognize and count the number of visitors and to see how visitors move around our Websites. This helps us to improve the way our Websites work. These cookies are sometimes placed by third party providers of web traffic analysis services, such as Google Analytics. For information on how Google processes and collects your information regarding Google Analytics and how you can opt-out, please see
  • Functionality cookies that remember choices you make and recognize you when you return. This enables us to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies that collect information about your browsing habits such as the pages you have visited and the links you have followed. We use this information to make our Websites more relevant to your interests, and, where utilized, make advertising more relevant to you, as well as to limit the number of times you see an ad. These cookies are usually placed by third-party advertising networks. They remember the other websites that you visit and this information is shared with third-party organizations, such as, for example, advertisers. We do not use Targeting cookies as part of our simulation services.

Most internet browsers accept cookies by default. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies, or to alert you to when a cookie is placed on your computer, tablet or mobile device. For more information, visit the help page for your web browser, or or which have further information about behavioral advertising and online privacy.

We may use third-party advertisers to serve or track advertisements on our Websites or relating to the Services. These third parties may use cookies and other tracking and analytical technologies to, for example, record which ads your browser has loaded and which pages you were viewing when ads were delivered or accessed. Information collected by third parties is subject to the privacy policies of those third parties. We recommend that you carefully read their policies.

Cross Device Tracking

When you use your mobile device to interact with us, we may receive information about your mobile device, including a unique identifier for your device. We, and our service providers, including ad networks, may use cross-device/cross-context tracking. For example, you might use multiple browsers on a single device, or use various devices (such as desktops, smartphones, and tablets), which can result in your having multiple accounts or profiles across these various contexts and devices. Cross-device/cross-context technology may be used to connect these various accounts or profiles and the corresponding data from the different contexts and devices.

We do not acknowledge browser “do-not-track” indicators.

  1. Links from our Websites

Our Websites or Services may contain links to third-party websites, platforms, products, services or applications that are independent of Kognito. We provide such links to you only as a convenience, and the inclusion  of any link does not imply affiliation, endorsement or adoption by Kognito of any site or any information contained therein.

When you leave our Websites, Kognito’s policies will no longer govern your Internet browser session. It is your sole responsibility to review the applicable policies of other websites as the information collection practices and privacy policies of those websites will govern and may differ from ours. We recommend that you carefully read their policies.

  1. Data retention

To the extent permitted by applicable law, we may retain your information for as long as your account is active, for at least twenty-four (24) months thereafter, as long as is reasonably necessary to provide you with our Services, as needed for other lawful purposes, or as required by applicable law. We may retain cached or archived copies of your information. We also will retain your information as long as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

  1. Telephone Consumer Protection Act notice

By providing us with your telephone number, including cellular or mobile device number, as part of your account or in registering for any of our Services, you expressly agree that we may use your information to make non-advertising and non-telemarketing business, informational and collections calls to you. You agree such calls may be pre-recorded messages or placed with an automatic telephone dialing system.

In addition, you agree that we may send service- or account-related text messages to cellular phone numbers you provide to us, and you agree to accept and pay all carrier message and data rates that apply to such text messages.

If you choose to provide an email or other electronic address on your account, you acknowledge and consent to receive business and informational messages relating to our Services at such address, including collections messages, and you represent and warrant that such address is your private address and is not accessible or viewable by any other person.

  1. California privacy rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) and California’s “Shine the Light” law (Civil Code Section § 1798.83) may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our Privacy Notice for California Residents.  This Notice supplements and is incorporated in this Privacy Policy.

  1. Applicable law

The laws of the State of Massachusetts, without regard to principles of conflicts of laws, will govern this Privacy Policy and any disputes arising out of or relating to this Privacy Policy, the Websites or Services.

  1. Dispute resolution

Any dispute arising out of or relating to this Privacy Policy, the Websites or Services shall be solely adjudicated in the state or federal court located in New York County, New York.  You consent and submit to exclusive jurisdiction and venue in such courts and agree to accept service of process by electronic mail. Without limiting the foregoing, any claim that you may have in connection with this Privacy Policy, the Websites or Services must first, and before taking any other legal action, be submitted to Kognito in the form of a complaint (to:, to enable the parties to resolve the claim in a friendly and effective manner. If the parties fail to resolve the claim in this manner in a reasonable timetable, it shall be resolved in the exclusive jurisdiction and venue as specified above. Notwithstanding the foregoing, Kognito may seek injunctive or other equitable relief to protect its intellectual property rights in any court of competent jurisdiction.

  1. Class action waiver


  1. Applicable language

If you are in Canada, Kognito and you confirm that it is their respective wish that this Privacy Policy and all other related documents be drawn up in English.  (Translation in French: Kognito et vous reconnaissent avoir exigé la rédaction en anglais du présent document ainsi que tous les documents qui s’y rattachent.)

  1. Job applicants

In connection with a job application or inquiry, you may provide us with data about yourself, including your educational background or résumé and other information, including your ethnicity where required or permitted by law. We may share this information with our parent corporations and their affiliates for the purpose of employment consideration. We may keep the information for future consideration unless you direct us not to do so.

  1. Choice/opt-out and contact information

For Visitors only, we may send you mail or e-mails to inform you of new products, services and special offers. If you would prefer not to receive these communications, you may opt-out by clicking on the Unsubscribe link in our emails or by notifying us at:

  • Email
  • Call us: 212-675-9234
  • Mail us: 25 Mall Road, 6th Floor, Burlington, MA 01803, USA

We will honor all opt-out requests.

  1. Feedback

Please contact us with any questions, concerns or inquiries about this Privacy Policy or data about you that we maintain at:

  • Email us:
  • Call us: 212-675-9234
  • Mail us: 25 Mall Road, 6th Floor, Burlington, MA 01803, USA

All feedback will be evaluated and a reply will be sent as soon as appropriate. In some instances, we may cease providing Services to you if, in our sole discretion, we deem it necessary to satisfy your request or if required under applicable law.

  1. Revisions to this Privacy Policy

We may modify this Privacy Policy from time-to-time by posting a revised version on our Websites. If we make material changes to our Privacy Policy, we will seek to provide you notice through our Services or by other means. You can see when the Privacy Policy has changed from the date of the latest revision above. By continuing to use our Websites or Services after we publish or send a notice about our changes to these terms, you consent to the updated terms following their “effective date.” If you object to any changes, you must stop using or accessing the Websites or Services. We will not retroactively change our Privacy Policy. Please review this Privacy Policy frequently for updates.

Scroll to Top