Cogitatus Privacy Policy

Cogitatus Privacy Policy
Version #1.1 May 2019

The Privacy Policy describes the Cogitatus approach to managing your per personal data when you visit our sites, physical, electronic or otherwise choose to interact with us. Cogitatus will review this Policy periodically to ensure that any changes may be captured and amended accordingly

Irrespective of how you choose to interact with us, we are Cogitatus Limited, a company registered in England. When we use the words “we” or “us” in this policy we are referring to Cogitatus. Our head office is located at Unit 36, Silk Mill Industrial Estate, Brook Street, Tring. HP23 5EF. The Company number is  1193 4611.

Our Commitment to Privacy and of manging Personal Data

We will comply with all applicable laws and regulations with respect to personal data protection, including GDPR, and absolutely respect your right to privacy

We will not lease, sell, loan, rent or otherwise make available, any of your personal data to third parties unless necessary and then only after we have obtained your consent. We must make you aware that we will make all such data available to the relevant authorities if complied to do so by legislation or by legal ruling and that this may be done without prior consent being sought or further acknowledgement. 

Your ability to make informed choices about how we process personal data is important to us. This Privacy Policy describes how you can make choices about how we use or otherwise process your personal data.

1. What is Personal Data?

Personal data means any information relating to an identified or identifiable natural person (‘data subject’)

2. What Personal data does Cogitatus collect?

Data will be collected from visitors who sign up to receive, or make use of, a provided service, this will encompass and such new service in the future but includes Blog, Newsletter and Case Study Materials at this time. Personal Data may be collected during business transaction, including but not limited to, Placing of purchase orders/contracts and all requirements for running the company payroll.

For the purposes set out in this Privacy Policy, we may collect the following personal data:

• Contact data, such as address,      email address, phone number/ mobile phone or and any other provided phone      number for contact purposes.
• Electronic data, which      includes the IP address used to access our website, mobile device ID, type      of browser and activity on our website, here cookies are used. 

3. How do Cogitatus use the personal data?

In general, we use personal data to process your requests and transactions, provide you with high-quality service, tell you about opportunities we think will be of interest and administer any service that you may subscribe to. The specific purposes for which we process your personal data are set out below:

• To respond to enquiries from      you about us or our services, (the legal basis for this processing being      your consent);
• To provide you with news,      recommendations, promotional information, advice or other such      communications about Cogitatus. 
• To comply with any legal      obligation, including our tax obligations; the prevention of fraud and/or      money laundering.
• To analyse the use of the website      (the legal basis for this processing is our legitimate interest in      improving our website and better understanding user needs and      expectations);
• For internal management      purposes, including planning, resource allocation, policy development,      quality improvement, monitoring, audit, evaluation and reporting (the      legal basis for this processing is our legitimate interest in      understanding usage patterns and exploring ways to develop and enhance our      business)

4. How does Cogitatus share personal data with third parties? 

We do not share personal data about you with third parties except as follows:

• Where      you specifically request Cogitatus to make a formal introduction to a      third party.
• Compliance with Law, where we disclose personal data when we are      legally authorised or required to do so to comply with applicable law or      legal process (including requests from authorities and courts), to respond      to claims or to protect the rights, property or personal safety of Cogitatus companies, employees or the      public.

5. Does Cogitatus transfer data outside the EEA?

Your personal data will not knowingly be transferred to any countries outside of the European Economic Area (“EEA”), including the UK. We do however utilise Microsoft  services, know as O365 and/Azure services, and note the location of these data centres as found at : https://azure.microsoft.com/en-us/global-infrastructure/regions/.

6. How does Cogitatus protect personal data?

Physical, administrative and technical security measures in place to help protect personal data from damage, loss, amendment, destruction or unauthorised access, processing or use while it is under our control. 

7. How long does Cogitatus retain personal data?

We will retain your personal data for as long as necessary to achieve the purposes for which such data was collected, unless a longer retention period is required under applicable law. 

For example, we need to keep records of any purchase and subsequent invoices for reasons of complying with UK law and directives from the tax and VAT authorities, therefore we will maintain such data for a period of no longer than 6 years plus current trading year. Contracts data will be held for the same period.

When you have opted to take a service feed or alert, we will expunge any data within 10 business days (being business days in UK) of your consent being revoked.

8. Third Party Services

Cogitatus do not currently offer any third party services. 

9. What Personal data rights do you have?

Subject to certain limitations and exceptions, you have a number of legal rights in relation to the processing of your personal data, including:

• A right to obtain      information: You      have the right to request information about how we process your personal      data.
• A right of access: You have the right to      request access to, or a copy of, the personal data we process about you.
• A right of rectification: You have the right to      request that we correct or supplement inaccurate or incomplete personal      data we process about you.
• A right of erasure: You have the right to      request that we delete personal data about you.
• A right to restriction of      processing: You      have the right to request that we restrict processing of your personal      data, so that we can store such data but not further process it.
• A right to data portability: You have the right to      request that we provide the personal data which you provided to us in a      structured, commonly used and machine-readable format, and you have the      right to transmit such data to another controller without hindrance from Cogitatus.
• A right to object to      processing: You      have the right to request that we stop processing personal data about you      at any time by writing to contactus@cogitatus.co.uk 
• A right to revoke your      consent:     When our processing is based on your consent, you have the right to revoke      such consent at any time.
• The right to file a      complaint: You      have the right to file a complaint regarding our data protection practices      with a supervisory authority. You can do so by contacting the Information      Commissioner’s Office (www.ico.org.uk).

10. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and if we make material changes, we will provide you with additional notice. We encourage you to review this Privacy Policy frequently to make sure you understand how your personal data will be processed and the choices available to you.

11. QUESTIONS OR CONCERNS

If you have any questions or concerns about this Privacy Policy or would like to contact us for any reason, including the possibility of submitting a claim, you can write to contactus@Cogitatus.co.uk.