1. Introduction
1.1 In this policy, “we”, “us” and “our” refer to Cognitive.Business Ltd. (Cognitive)
1.2 We are committed to safeguarding the privacy of our website visitors.
1.3 This policy applies where we are acting as a data controller with respect to the personal data of website visitors, in other words, where we determine the purposes and means of the processing of that personal data.
1.4 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.5 Our website incorporates privacy controls which affect how we will process and retain your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications.
1.6 For more information about us, see Section 13.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your visit. The source of the usage data is obtained by an approved analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
2.3 We may process information contained in any enquiry you submit to us regarding products and/or services (“<strong>enquiry data</strong>”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.4 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“<strong>notification data</strong>”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.5 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.6 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject to.
4. Retaining and deleting personal data
4.1 This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject to.
5. Security of personal data
5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
5.2 Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy where you have provided your email address.
7. Your rights
7.1 You may instruct us to provide you with any personal information we hold about you, subject to the supply of appropriate evidence of your identity.
7.2 You may instruct us at any time not to process your personal information for marketing purposes.
7.3 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 If we have reason to believe that we hold personal data of a person under the age of 18 in our databases, we will delete that personal data.
10. Updating information
10.1 Please let us know if the personal information you have previously supplied to us needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
12.1 We use cookies for the following purposes:
(a) Authentication – we use cookies to identify you when you visit our website and as you navigate our website.
(b) Analysis – we use cookies to help us to analyse the use and performance of our website and services.
(c) Cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
13. Our details
13.1 This website is owned and operated by Cognitive.
13.2 We are registered in England and Wales under registration number 11457650, and our registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.
13.3 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by email, using cco@cognitive.business
14. Data protection registration
14.1 We are registered as a data controller with the UK Information Commissioner’s Office.
14.2 Our data protection registration number is A8867673.
15. Data protection enquiries
15.1 For personal data and data protection enquiries, please contact the Corporate Compliance Officer at cco@cognitive.business
