Cogna Privacy Policy
**Last updated: September 16th, 2024**
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 80 Cheapside, London, England, EC2V 6EE. 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.
- Technical Data: Metadata and IP address when you visit our Website or social media accounts.
- Usage Data: Information about how you use our Website and services, including preferences.
- Marketing and Communications Data: Marketing preferences and communication choices.
- Survey Data: Data from research surveys conducted on the Website, if you choose to participate.
- Application Data**: Information in your resume/CV, provided by recruitment agencies, and shared on social media like LinkedIn.
- Recruitment Data: Performance data from the application process, references, criminal records (if applicable), and test results.
- Equal Opportunities Data: Ethnicity, gender, socio-economic background, orientation, religion, disabilities, and other monitoring information.
- Business Data: Business contact details, references (if required), data for anti-money laundering checks (if applicable), and insurance documents.
- Other Information: Where you register for newsletters, events, or Website inquiries.
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 use the data collected or provided by you for these purposes:
- 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.
- Financial management.
- Presenting Website content effectively.
- Notifying you of Website changes.
- Keeping the Website safe and secure.
- Providing marketing information about services that may interest you.
4. Lawful basis for processing
We process your personal data only with a lawful basis, depending on the purpose for which we collected and used your data. This lawful basis may include:
- Legitimate Business Interests: For our business operations and internal administration, including survey purposes.
- Performance of an Agreement: For fulfilling contracts or preparing to enter into agreements with you.
- Legal Compliance: Where necessary to meet our legal obligations.
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:
- Service research, evaluation, and analysis.
- Business or asset sales, where data may be shared with prospective buyers.
- Legal or regulatory obligations.
- Protecting rights, property, or safety (including fraud protection).
Third parties are required to maintain the security and confidentiality of your data and only process it according to our instructions.
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.
7. Cookies
Our Website uses cookies for better user experience and functionality, categorized as:
- Strictly Necessary Cookies: Essential for the Website’s core operations.
- Analytical or Performance Cookies: Helps us improve Website performance.
- Functionality Cookies: Personalizes content and remembers preferences.
- Targeting Cookies: Records visited pages and links followed.
Managing Cookies: You can set your browser to refuse cookies; however, some Website features may not function properly.
8. Where we store your personal data
Typically, data is stored within the UK and EEA. In cases of international transfer, we ensure data security by using approved mechanisms, like EU Standard Contractual Clauses, to protect your privacy.
9. Your Rights
Cogna respects your privacy rights, including:
- Accessing or confirming data processing.
- Correcting inaccurate data.
- Erasing data or transmitting it to another company, in certain cases.
- Withdrawing consent at any time for consent-based processing.
- Objecting to or restricting certain data processing.
- Complaining to the ICO if necessary.
For data rights requests, please contact support@cogna.co.
10. Data Security
We have implemented security measures to protect personal data from unauthorized access, loss, or disclosure. However, internet transmission remains at your risk. Access to your data is restricted to employees or third parties with a business need.
Links to Other Sites: We are not responsible for external sites’ privacy practices; please review those policies independently.
11. Data Retention
We retain personal data as necessary for its original purpose and to meet legal or regulatory requirements. When no longer required, we destroy or anonymize data, unless stored in an aggregated format post-relationship.
12. Information Relating to Children
Cogna’s services are not intended for individuals under 18. If data from a minor is mistakenly collected, please contact us at support@cogna.co.
Complaints
To make a complaint regarding our data processing, contact us at support@cogna.co, or reach out to the relevant data protection authority.
Changes
Please review this policy periodically for updates. Continuing engagement with us signifies acceptance of the updated policy; if not agreed, discontinue engagement.
