Your Texas Privacy Rights (TDPSA)
As a Texas resident, you have specific rights under the Texas Data Privacy and Security Act (effective July 1, 2024). This policy complies with TDPSA requirements.
Your rights include:
- Right to Know: What personal data we collect and why
- Right to Access: Obtain a copy of your data
- Right to Correct: Fix inaccurate information
- Right to Delete: Request deletion of your data
- Right to Portability: Export your data in a usable format
- Right to Opt-Out: Of targeted advertising or data sales (we don't sell data)
To exercise these rights: Submit Privacy Request
Transparency Note: What's Active vs. Planned
This privacy policy covers our full intended system. Here's the current status:
Currently Active:
- Email collection & communications
- DLI assessment data
- Analytics via Plausible (no cookies)
- Cohort application data
Not Yet Active:
- Revenue sharing/payouts
- Notion/Todoist integrations
- Payment processing
- Ad-based revenue
We'll update this note as features launch. Check the "Last Updated" date above.
1. Introduction
Welcome to the CTE Research Initiative ("we," "our," or "us"), operated by Cognitive Thought Engine LLC, a Texas limited liability company. We are committed to protecting your privacy and personal information in compliance with the Texas Data Privacy and Security Act (TDPSA) and other applicable laws.
This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website (cognitivethoughtengine.com) and services.
2. Information We Collect
We collect the following categories of personal data:
| Category | Examples | Purpose |
|---|---|---|
| Identifiers | Email address, name | Account creation, communications |
| Assessment Data | DLI scores, productivity metrics | Provide service, track progress |
| Commercial Info | Subscription status, payment method (via Stripe) | Process payments, revenue sharing |
| Usage Data | Pages visited, features used, time on site | Improve service, analytics |
| Communication Data | Emails, support requests | Customer support |
2.1 Sensitive Data
We do NOT collect sensitive personal data including:
- Social Security numbers
- Health or medical information
- Financial account numbers (Stripe handles payment data)
- Precise geolocation
- Biometric data
- Racial or ethnic origin
- Religious beliefs
3. How We Use Your Information
We use the information we collect for these specific purposes:
- Service Delivery: Provide, maintain, and improve our services
- Assessment: Calculate your DLI score and productivity metrics
- Payments: Process revenue share payments to you (when active)
- Communications: Send transactional emails (welcome, DLI results, payouts)
- Marketing: Send promotional emails (only with your consent)
- Support: Respond to your questions and requests
- Analytics: Monitor trends and usage patterns (aggregate only)
- Security: Detect and prevent fraud or abuse
4. Information Sharing and Disclosure
We do NOT sell your personal information. Under TDPSA, you have the right to opt out of data sales - but we don't engage in data sales.
We may share your information only with:
| Recipient | Purpose | Data Shared |
|---|---|---|
| Stripe | Payment processing | Email, payment method |
| SendGrid | Email delivery | Email address, name |
| Plausible Analytics | Privacy-friendly analytics | Aggregate page views only (no personal data) |
| Anthropic | AI-powered features | Anonymized usage patterns |
We may also disclose information when required by law or to protect our legal rights.
5. Your Privacy Rights and How to Exercise Them
Actionable Rights Request Process
To exercise any of your privacy rights, use one of these methods:
Option 1: Email Request
Send an email to privacy@cognitivethoughtengine.com with:
- Subject line: "TDPSA Privacy Request - [Your Request Type]"
- Your name and email address associated with your account
- Specific request: Access, Correction, Deletion, or Portability
Option 2: Submit Request Online
Alternative: You can also email privacy@cognitivethoughtengine.com directly.
Response Timeline
- Acknowledgment: Within 10 business days
- Verification: We may request identity verification
- Response: Within 45 days of verified request
- Extension: Up to 45 additional days if necessary (we'll notify you)
- Appeal: If denied, you may appeal within 60 days
5.1 Right to Appeal
If we deny your privacy request, you have the right to appeal. Send your appeal to privacy@cognitivethoughtengine.com with subject "TDPSA Appeal" within 60 days of our response. We will respond within 60 days.
If you are unsatisfied with our appeal response, you may file a complaint with the Texas Attorney General at texasattorneygeneral.gov.
6. Email Communications and Consent
We send two types of emails:
| Type | Examples | Opt-Out |
|---|---|---|
| Transactional | Welcome email, DLI results, password reset, payment confirmations | Cannot opt out (required for service) |
| Marketing | Productivity tips, product updates, promotions | Unsubscribe link in every email |
To unsubscribe from marketing emails: Click the "Unsubscribe" link at the bottom of any marketing email, or email privacy@cognitivethoughtengine.com with subject "Unsubscribe".
7. Cookies and Tracking Technologies
We use Plausible Analytics, a privacy-friendly analytics tool that:
- Does NOT use cookies
- Does NOT collect personal data
- Does NOT track individual users
- Is fully GDPR, CCPA, and TDPSA compliant
We do NOT use:
- Third-party advertising trackers
- Cross-site tracking cookies
- Fingerprinting technologies
Your browser's "Do Not Track" signal is respected.
8. Data Security
We implement appropriate technical and organizational security measures:
- Encryption in transit (HTTPS/TLS)
- Encryption at rest (database encryption)
- Access controls (role-based permissions)
- Regular security audits
- Secure payment processing via Stripe (PCI DSS compliant)
While we implement reasonable safeguards, no system is 100% secure. If we experience a data breach affecting your personal information, we will notify you as required by law.
9. Data Retention
We retain your personal information:
- Active accounts: As long as your account is active
- After deletion request: Removed within 30 days (except legal requirements)
- Backup systems: Purged within 90 days
- Legal obligations: Financial records retained 7 years per IRS requirements
10. Children's Privacy
Our services are not intended for children under 13. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at privacy@cognitivethoughtengine.com.
Upon verification, we will delete the child's information within 30 days.
11. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of external sites. We encourage you to read the privacy policies of any linked websites.
12. Revenue Sharing Transparency
As part of our business model, we share 70% of eligible revenue with our users. Your earnings are calculated based on your DLI score and engagement. All revenue calculations are transparent and you can request an audit of your earnings at any time.
13. Changes to This Privacy Policy
We may update this Privacy Policy periodically. When we make material changes:
- We will update the "Last Updated" date at the top
- We will notify you by email for significant changes
- We will provide a summary of changes
Your continued use of our services after changes constitutes acceptance of the updated policy.
14. Contact Us
For Privacy Inquiries:
Email: privacy@cognitivethoughtengine.com
Subject: "Privacy Inquiry" or "TDPSA Request"
Response Time: Within 10 business days
Mailing Address:
Cognitive Thought Engine LLC
Attn: Privacy Officer
16403 Cretian Point Ct
Cypress, TX 77429
United States
For Complaints:
If you are unsatisfied with our response, you may file a complaint with the Texas Attorney General: