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Cogency Labs Ltd Privacy Policy

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This policy sets out the basis on which any personal data is collected, including how is it collected and processed, who has access to it and what are your rights with respect to any of your data that Cogency processes.

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Definitions

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Cogency Labs Ltd trades as Cogency and furthermore may be referred to as “Cogency”.

Any mention of “Data” in this policy will refer to personal data in particular, meaning any information relating to a natural person (known as a “data subject”). This can include, among others: name, location, ID numbers, email addresses, as well as online identifiers relating to a data subject.

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“Processing” of data means any action relating to collection, alteration, storing, retrieving, adapting, using, disclosing as well as erasing and destroying any data. This includes both automated and manual processing, as per the GDPR (see below).

 

The General Data Protection Regulation (“GDPR”), (EU) 2016/679, is a regulation which came into effect on 25th May 2018. It aims to give more control to individuals with respect to their personal data and to provide a stricter framework within which commercial organisations can operate within the EU.

 

What data about you is being collected?

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Cogency only collects essential personal identification information for contacting people, such as first and last name, email address and phone number. We might process certain business-related information such as the business name, job function or business address. We will never collect data belonging to special categories of personal data.

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What is the legal justification for processing my data?

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Under the General Data Protection Regulation, there are six different bases for legal justification for processing personal data. Cogency’s lawful basis for processing your personal data is mostly based on the Legitimate Interests, where we believe that our services are of interest to you and your business. We will also rely on the Lawful Basis of Consent when you clearly consent to us processing your personal data for a specific purpose; or on the Legal Obligation via which our processing of your data is necessary to fulfil any legal obligations we might have.

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Given the fact that Cogency partially relies on the Legitimate Interests Legal Basis, it has performed the Legitimate Interest Assessment (LIA), as advised by the Information Commissioner’s Office (ICO).

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Direct marketing to the data subjects in Cogency’s database is necessary in order to promote Cogency to relevant individuals and organisations. This could not in turn be achieved without processing the necessary contact details of the individuals. Cogency filters data subjects that it may contact according to their job function, business organization and personal data purely within the context of business environment. Based on this, it is deemed that these data subjects would reasonably expect such processing of their data. It is also believed it is in their legitimate interests to be sent correspondence from Cogency that is relevant to them in their professional capacity. The rights and freedoms of these data subjects are not overridden by Cogency’s correspondence with them and there is no way in which any data subject would be harmed as a result of Cogency processing their data.

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As per the Information Commissioner’s Office guidance, Cogency can confirm that:

  • We have checked that Legitimate Interests is the most appropriate basis for Cogency processing personal data

  • We understand our responsibility to protect the individual’s interests

  • We have conducted a legitimate interests assessment (LIA) and kept a record of it, to ensure that we can justify our decision

  • We have identified the relevant legitimate interests

  • We have checked that the processing is necessary and there is no less intrusive way to achieve the same result

  • We have performed a balancing test, and are confident that the individual’s interests do not override those legitimate interests

  • We only use individuals’ data in ways they would reasonably expect

  • We are not using people’s data in ways they would find intrusive or which could cause them harm

  • We do not process children’s data

  • We have considered safeguards to reduce the impact where possible

  • We offer an opt-out

  • Our LIA did not identify a significant privacy impact

  • We keep our LIA under review, and repeat it if circumstances change

  • We include information about our legitimate interests in our privacy information

 

Who processes your data?

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Any data collected by Cogency is only ever processed by Cogency and the data is not transferred internationally outside of the UK, save for if it is requested by authorities outside of the UK for legal purposes. We do not share data we have collected with any other organisations or individuals.

 

How do we collect your data?

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Most of the data we collect is provided directly by you when you contact us through our website, via email or by phone. However, we might also procure data in other ways, based on the “Legitimate Interests” lawful basis.

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Any data we collect will have been obtained in one of the following ways:

  • You have shared your contact details with our team via any of e-mail, social media or in personal communication, with the express purpose of receiving information from Cogency

  • You have voluntarily signed up to our newsletter, completed a customer survey or provided feedback on any of our online channels or via email

  • You have previously made contact with a member of Cogency

  • You have willingly given us your contact details at an event or when signing up to attend a Cogency event

  • One of our employees has found your business or personal contact details online, believing our services would be of interest to you, based upon the information you have provided online and these aligning with our customer profile

  • We also occasionally work with Winmo, a GDPR compliant third party. You can review their privacy policy here.

 

How will we use your data?

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Cogency collects your data so that we can email you with updates on Cogency products and services that we believe will be of interest to you in your professional capacity, as well as to share some pieces that we have written on topics which are relevant to you.

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If you have provided us with your contact details in order to receive marketing, you may always opt out at a later date. If you no longer wish to be contacted for marketing purposes, please email our Data Protection Officer at ben@cogencylabs.co.uk.

 

How do we store your data?

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Cogency securely stores your data on an online remote storage system, i.e. the cloud, provided by Microsoft and via our CRM Hubspot. Cogency will keep your personal data for two years. Once this period has expired, we will delete your data from our databases.

 

What are your data protection rights?

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Cogency would like to make sure you are fully aware of all of your data protection rights. Under the GDPR, every user is entitled to the following:

  • The right to access – You have the right to submit a request to Cogency for copies of your personal data

  • The right to rectification – You have the right to request that Cogency correct any information you believe is inaccurate or incomplete

  • The right to erasure – You have the right to request that Cogency erase your personal data where there is no good reason and legal obligation for us to continue processing it

  • The right to restrict processing – You have the right to request that Cogency restrict the processing of your personal data, under certain conditions

  • The right to object to processing – You have the right to object to Cogency’s processing of your personal data, under certain conditions

  • The right to data portability – You have the right to request that Cogency transfer the data that we have collected to another organisation, or directly to you, under certain conditions.

 

If you make a request regarding your data, we have one month to respond to you. If you would like to exercise any of these rights, please get in touch with our Data Protection Officer by either:

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Calling us at: +44(0) 7763 348739

Or writing to us: ben@cogencylabs.co.uk

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To find out more about your data subject rights, visit: https://gdpr-info.eu/chapter-3/

 

What are Cookies and how do we use them?

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Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit https://allaboutcookies.org

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Cogency uses cookies in a range of ways to improve your experience on our website, including anonymous amalgamated reports of website traffic and usage. We do not collect any personal data through Cookies.

 

What types of cookies do we use?

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There are multiple different types of cookies, however, our website uses:

Functionality – Cogency uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.

Analytics – Cogency uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device and location.

 

How do I manage cookies?

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You can set your browser to not accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

 

Changes to our privacy policy

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Cogency regularly reviews its privacy policy and puts any updates on this web page. This privacy policy was last updated on 08/03/2021.

 

How to contact us?

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If you have any questions about Cogency’s privacy policy, the data we hold on you, or you would like to exercise any of your data subject rights, please do not hesitate to contact us.

 

Email our Data Protection Officer at: ben@cogencylabs.co.uk

Call us: +44(0) 7763 348739

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