Privacy Policy
This Privacy Policy explains how CGN American Tech Institute, a division of CGN Research World LLC, a limited liability company organised under the laws of the State of Wyoming, United States of America ("CGN", "the Institute", "we", "us" or "our"), collects, uses, discloses, transfers, retains and protects personal information when you visit cgni.us (the "Website"), create an account, enrol in a programme, sit an examination at one of our assessment centres, or engage us for corporate training and consulting services (together, the "Services").
By accessing the Website or using any of the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the Website or the Services.
1. Scope of This Policy
This Policy applies to all personal information processed by CGN in connection with:
- the Website cgni.us, including all sub-domains, learning portals and applicant forms;
- online, blended and instructor-led courses, certifications and professional development programmes;
- proctored examinations, practice tests and other services delivered through the CGN assessment centre, including services delivered on behalf of third-party certification and testing bodies;
- corporate training, cohort-based enterprise programmes, and advisory or consulting engagements;
- marketing, events, webinars, newsletters and enquiry handling.
This Policy does not apply to third-party websites, learning platforms, payment gateways or certification bodies that operate under their own privacy notices. Where a third party acts as the controller of your information (for example, a certification sponsor whose examination you sit at our centre), that party’s own privacy notice governs its use of your data.
2. Information We Collect
2.1 Information you provide to us
Identity and contact data: full name, postal address, email address, telephone number, date of birth, and government-issued photo identification presented for examination admission.
Academic and professional data: prior qualifications, transcripts, certificates, employment history, curriculum vitae, statements of purpose, references and English-language or aptitude test results.
Enrolment and account data: username, password (stored in hashed form), programme and cohort selections, learner identification number, and communication preferences.
Assessment data: examination registrations, responses, scores, score reports, accommodation requests, incident reports and appeal records.
Payment and billing data: billing name and address, invoice details, purchase-order references, tax identifiers, and the last four digits and expiry of a payment card. We do not collect or store complete payment-card numbers; card data is captured directly by our payment processors.
Corporate engagement data: employer name, sponsor contacts, delegate lists, statements of work and related correspondence.
Voluntary submissions: survey and feedback responses, forum or discussion-board posts, assignment and project files, and testimonials.
2.2 Information collected automatically
Device and connection data: IP address, browser type and version, operating system, device identifiers, language and time-zone settings.
Usage data: pages viewed, referring URLs, dates and times of access, course and lesson progress, video-playback events, login history and click paths.
Cookies and similar technologies, as described in Section 7.
2.3 Examination and proctoring data
Where you register for a proctored examination, we may additionally collect a photograph or facial image captured at check-in, a scan or image of your identity document, a signature, a biometric-style verification record used solely to confirm identity, seat and session assignment, CCTV footage of the testing floor, and — for remotely proctored sessions — webcam video, audio, screen recordings and records of applications running on your device. This information is collected to protect examination integrity, to satisfy the security requirements of certification sponsors, and to investigate suspected misconduct.
Examination and proctoring data is treated as sensitive. It is accessible only to authorised assessment personnel, is used exclusively for identity verification, invigilation, incident investigation and audit, and is retained for the period required by the relevant certification sponsor or by law.
2.4 Information from third parties
- Certification and testing bodies, where you register for an examination through them.
- Employers and training sponsors who nominate you for a programme.
- Education agents, counsellors and referral partners.
- Payment processors, for transaction confirmation and chargeback handling.
- Publicly available professional sources, used only to verify the credentials you have submitted.
3. How We Use Personal Information
We use your personal information for the purposes described below, relying on the specified legal bases under applicable data protection laws:
| Purpose of Processing | Categories of Personal Information | Legal Basis for Processing |
|---|---|---|
| To process applications, verify eligibility, and manage enrolment. | Identity and contact data; Academic and professional data. | Performance of a contract; Legal obligation. |
| To deliver educational programmes, facilitate learning, and track progress. | Identity and contact data; Enrolment and account data; Usage data. | Performance of a contract. |
| To administer proctored examinations and issue certifications. | Identity and contact data; Assessment data; Examination and proctoring data. | Performance of a contract; Legitimate interests (integrity of certification). |
| To process payments and manage financial records. | Identity and contact data; Payment and billing data. | Performance of a contract; Legal obligation. |
| To provide technical support and respond to enquiries. | Identity and contact data; Device and connection data; Voluntary submissions. | Legitimate interests (customer service). |
| To send marketing communications and newsletters. | Identity and contact data; Communication preferences. | Consent. |
| Improving programmes, content and platform performance | Usage, feedback (aggregated where possible) | Legitimate interests |
| Marketing, newsletters and event invitations | Contact, preferences | Consent; legitimate interests |
| Security, fraud prevention and misconduct investigation | Device, usage, proctoring | Legitimate interests; legal obligation |
| Regulatory reporting, accreditation review and audit | Identity, academic, assessment | Legal obligation; legitimate interests |
We do not sell or share your personal information for advertising purposes.
4. Disclosure of Personal Information
We disclose personal information only as described below:
- Service providers and processors: learning-management and hosting providers, email and communication platforms, proctoring technology vendors, payment processors, analytics providers, and professional advisers. Each is bound by contract to process information only on our instructions and to apply appropriate safeguards.
- Certification and examination sponsors: registration, identity-verification and result data, where you sit an examination administered on their behalf.
- Employers and sponsors: attendance, progress and completion information, where your participation is funded or nominated by an employer, and only to the extent agreed in the sponsorship arrangement.
- Accrediting and regulatory bodies: records required for accreditation review, quality assurance, licensing or statutory reporting.
- Credential verification: confirmation of a credential’s authenticity to a person or organisation you have directed to us, or through a public credential-verification facility you have consented to.
- Legal and protective disclosures: where required by law, court order, subpoena or lawful request, or where necessary to establish, exercise or defend legal rights, prevent fraud, or protect the safety of any person.
- Corporate transactions: in connection with a merger, acquisition, financing or transfer of all or part of our business, subject to the recipient honouring this Policy.
5. International Transfers
CGN is established in the United States and may process personal information in the United States, India and other countries where we or our service providers operate. Data-protection laws in those countries may differ from those in your own. Where personal information is transferred out of a jurisdiction that restricts such transfers, we rely on appropriate safeguards — including the European Commission’s Standard Contractual Clauses, equivalent contractual protections, or your explicit consent — and we apply the protections described in this Policy regardless of where the information is processed.
6. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and applicable legal requirements.
| Record Type | Indicative Retention Period |
|---|---|
| Academic and credential records (enrolment, results, certificates) | Permanently or as required for credential verification |
| Application records for unsuccessful or withdrawn applicants | 2 years from decision |
| Examination response and score data | As required by the certification sponsor; otherwise 5 years |
| Proctoring video, audio and screen recordings | 90 days, unless retained longer for an open investigation or as the sponsor requires |
| Identity-document images | 12 months from the examination date |
| Financial, invoicing and tax records | 7 years |
| Marketing contact records | Until you unsubscribe, plus 24 months of inactivity |
| Website and security logs | 12 to 24 months |
When personal information is no longer required, we will either delete it, anonymise it (so it can no longer be associated with you), or, if deletion is not possible (for example, because it is stored in backup archives), securely store it and isolate it from further processing until deletion is possible.
7. Cookies and Tracking Technologies
The Website uses cookies and similar technologies to operate the platform and to understand how it is used. We use:
- Strictly necessary cookies, which enable login, session management, security and load balancing. These cannot be disabled without impairing the Website.
- Functional cookies, which remember preferences such as language, course progress and display settings.
- Analytics cookies, which help us measure traffic, navigation patterns and content performance.
- Marketing cookies, which may be used to measure campaign effectiveness, where you have consented.
You may manage cookies through your browser settings or, where presented, through the cookie-preference control on the Website. Disabling cookies may affect the availability of certain features. We honour recognised opt-out preference signals, including Global Privacy Control, where technically feasible.
8. Your Privacy Rights
8.1 Rights available to all users
Subject to verification and applicable law, you may request to:
- access the personal information we hold about you and obtain a copy;
- correct information that is inaccurate, outdated or incomplete;
- delete information that is no longer required for a lawful purpose;
- restrict or object to certain processing, including profiling;
- receive your information in a portable, machine-readable format;
- withdraw consent where processing is based on consent;
- opt out of marketing communications at any time; and
- lodge a complaint with us or with a competent supervisory authority.
8.2 United States — state privacy rights
Residents of California and other states with comprehensive privacy laws have the right to know the categories and specific pieces of personal information collected, the purposes of collection, and the categories of third parties to whom it is disclosed; to request deletion or correction; to opt out of any sale or sharing of personal information and of targeted advertising; to limit the use of sensitive personal information; and not to be discriminated against for exercising these rights. CGN does not sell personal information and does not use sensitive personal information for purposes other than those permitted under applicable law. An authorised agent may submit a request on your behalf with proof of authority.
8.3 Student education records
Where CGN maintains education records in respect of an enrolled learner, those records are handled in line with recognised student-privacy standards. Learners may inspect and review their own education records, request the correction of information believed to be inaccurate or misleading, and control the disclosure of personally identifiable information from those records except where disclosure is permitted without consent (for example, to accrediting bodies, in response to a lawful order, or as directory information you have not restricted).
8.4 European Economic Area, United Kingdom and Switzerland
Where the General Data Protection Regulation or the UK GDPR applies to our processing, CGN acts as controller for the purposes described in Section 3 and relies on the legal bases stated there. You have the rights of access, rectification, erasure, restriction, portability and objection, and the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you. You may also complain to your local supervisory authority.
8.5 India
Where our processing is subject to Indian data-protection law, learners and applicants may access, correct, complete, update and erase their personal data, nominate another individual to exercise their rights, and raise a grievance with our Grievance Officer using the details in Section 13. Consent, where relied upon, may be withdrawn at any time; withdrawal does not affect processing already carried out.
8.6 How to exercise your rights
Send your request to privacy@cgni.us with the subject line "Privacy Rights Request", stating the right you wish to exercise and enough information for us to locate your records. We will acknowledge your request within 10 business days and respond substantively within 30 days, or within 45 days where an extension is permitted and necessary — in which case we will tell you why. We may decline a request where verification fails or where an exemption applies, and we will explain our reasons.
9. Information Security
We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorised access, alteration, disclosure or destruction. These include encryption of data in transit and, where appropriate, at rest; role-based access control and least-privilege provisioning; multi-factor authentication for administrative accounts; hashed password storage; network segmentation and firewalling; monitoring and logging; controlled physical access to assessment centres and server facilities; vendor due diligence and contractual data-protection terms; periodic access reviews, vulnerability assessment and staff training; and documented backup and incident-response procedures.
No method of transmission or storage is entirely secure. You are responsible for keeping your account credentials confidential and for notifying us immediately at support@cgni.us if you suspect unauthorised use of your account. Where a security incident affecting your personal information occurs and applicable law requires notification, we will notify you and the relevant authorities without undue delay.
10. Children’s Privacy
The Services are intended for individuals aged 18 and over, and for younger learners only where enrolled through a school, institution or parent or guardian who has provided verifiable consent. We do not knowingly collect personal information directly from children under 13. If we learn that we have collected such information without the required consent, we will delete it promptly. A parent or guardian may contact privacy@cgni.us to review, correct or request deletion of a minor’s information.
11. Automated Decision-Making
Automated tools may assist in scoring objective examination items, flagging potential examination irregularities, and recommending learning content. Where an automated flag could affect your result or standing, the matter is reviewed by a qualified member of staff before any adverse decision is taken, and you may request an explanation and submit an appeal under our assessment appeal procedure.
12. Changes to This Policy
We may update this Policy to reflect changes in our Services, technology or legal obligations. The revised version will be posted at cgni.us with an updated effective date. Where changes are material, we will provide prominent notice on the Website or by email to registered users at least 14 days before they take effect. Your continued use of the Services after the effective date constitutes acceptance of the revised Policy.
13. Contact Us
Questions, requests and complaints relating to this Policy should be directed to:
| Channel | Details |
|---|---|
| Privacy enquiries and rights requests | privacy@cgni.us |
| Learner and technical support | support@cgni.us |
| Data Protection / Grievance Officer | privacy@cgni.us |
| Postal address | CGN American Tech Institute, a division of CGN Research World LLC, Wyoming, USA |
| Website | cgni.us |
If you are not satisfied with our response, you may escalate your complaint to the data-protection or consumer-protection authority with jurisdiction over your place of residence.