Cogna Privacy Policy

Welcome to Cogna's privacy policy.

We are Cogna Ltd (“Cogna”, “we” or “us”). Our company registration number is 14854153, and our registered address is Lg02 Chancery House, 53-64 Chancery Lane, London, England, WC2A 1QS. For UK data protection laws, Cogna is the data controller, and we are registered with the UK Information Commissioner’s Office (ICO): ZB632661.

This privacy policy applies to individuals who visit our website at https://cogna.co/ or any https://cogna.app/ subdomains (the “Website”), as well as our social media accounts, and in connection with any customer engagements or other business matters. It also covers our business contacts, including contractors, suppliers, employees, and agents (such as when you apply to work for us as an employee, consultant, or contractor). Please read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we collect or process personal data about you to ensure you understand how and why we use your data.

**Cogna – Privacy Statement**

At Cogna, we prioritize the privacy of individuals. We take a responsible, proactive approach in handling personal information. This policy outlines how and why we collect, store, use, and share personal information, our commitment to protect it, your rights regarding your personal information, and how to contact us or supervisory authorities in case of a complaint. If you have questions about how we use your personal data, please contact us at support@cogna.co.

1. The types of personal data we collect

We collect and use the following information about you:

• Identity Data: First name, surname, national insurance number (if applicable), passport photos, and recent utility bills.
• Contact Data: Billing address, postal address, email address, and phone numbers.
• Financial Data: Bank account and payment card details.
• Transactional Data: Information on our business dealings and interactions with you.
• Marketing and Communications Data: Marketing preferences and communication choices.

We indicate where requested personal information is mandatory and explain the consequences if you decide not to provide it. In some cases, this may prevent us from delivering certain services.

2. If you fail to provide personal data

Where we need to collect personal data by law or under the terms of an agreement with you, failing to provide the requested data may prevent us from fulfilling that agreement. If this occurs, we may need to cancel a service, and we will inform you at that time.

3. How we use personal data

We collect and use the following information about you:

• Responding to your queries.
• Fulfilling customer engagement terms.
• Ensuring legal and regulatory compliance.
• Handling complaints and disputes.
• Day-to-day business operations.
• Processing applications (including onboarding) and pre-employment checks.

Where we need to collect personal data by law or under the terms of an agreement with you, failing to provide the requested data may prevent us from fulfilling that agreement. If this occurs, we may need to cancel a service, and we will inform you at that time.

4. Lawful basis for processing

We collect and use the following information about you:

• Responding to your queries.
• Fulfilling customer engagement terms.
• Ensuring legal and regulatory compliance.
• Handling complaints and disputes.
• Day-to-day business operations.
• Processing applications (including onboarding) and pre-employment checks.

Where we need to collect personal data by law or under the terms of an agreement with you, failing to provide the requested data may prevent us from fulfilling that agreement. If this occurs, we may need to cancel a service, and we will inform you at that time.

5. How we share your personal data with third parties

We may share personal data with suppliers and business partners involved in marketing, advertising, or service provision. Third parties may only process personal data per our instructions and under confidentiality obligations. We may also disclose data in cases such as:

• Responding to your queries.
• Fulfilling customer engagement terms.
• Ensuring legal and regulatory compliance.
• Handling complaints and disputes.
• Day-to-day business operations.
• Processing applications (including onboarding) and pre-employment checks.

Where we need to collect personal data by law or under the terms of an agreement with you, failing to provide the requested data may prevent us from fulfilling that agreement. If this occurs, we may need to cancel a service, and we will inform you at that time.

6. Marketing

We may send marketing materials relevant to your interests. If you’ve requested information or purchased services without opting out, you may receive marketing communications.

• Opting Out: You may stop receiving marketing messages by contacting us anytime. Opting out will not affect data used for service or transaction-related purposes.