Privacy Policy under General Data Protection Regulations

Cogent Analytics Limited – Data protection privacy notice
(Website, Customers, Suppliers, Potential Customers and
Suppliers)

1. IMPORTANT INFORMATION AND WHO WE ARE

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PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Cogent Analytics Limited (trading as Cogent Governance) collects and
processes your personal data when you visit our website or when we communicate with you, as a customer, potential customer, supplier, potential supplier, for marketing purposes or as part of the performance of our existing or potential contract with you, including any data you may provide through this website when you sign up to our newsletter or purchase a product or service.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER
Cogent Analytics Limited, trading as Cogent Analytics, Cogent Governance, and Cogent, company number 14271700 (the “Company” trading as "Cogent Governance") is a ‘data controller’ and gathers and uses certain information about you.

In this notice, references to ‘we’ or ‘us’ mean the Company.
We have appointed a data privacy manager who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

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CONTACT DETAILS
Our full details are:
Full name of legal entity: Cogent Analytics Limited
Name or title of data privacy manager: Data Privacy Manager
Email address: Enquiry@cgrisk.com

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated in September 2022.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking onthose links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

2. THE DATA WE COLLECT ABOUT YOU 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, job title and gender.

• Contact Data includes billing address, delivery address, company address, email address and telephone numbers.

• Financial Data includes bank account and payment card details (if you have provided those to us).

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered
personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).

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In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;

• create an account on our website;

• subscribe to our service or newsletters or other publications;

• request marketing to be sent to you;

• enter a competition, promotion or survey;

• request to be invited to our events; or

• give us some feedback.

Automated technologies or interactions.

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy.

Third parties or publicly available sources.

We may receive personal data about you from various third parties and public sources as set out below:

 

Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;
(b) advertising networks based inside or outside the EU; and
(c) search information providers based inside or outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and
  delivery services based inside or outside the EU.

• Identity Data and Contact Data from data brokers or aggregators such as Dun
  and Bradstreet based outside the EU.

• Identity and Contact Data from publicly availably sources such as Companies House, government websites and LinkedIn and which our subcontractors outside the EU (such as the Nigeria, Ghana, Philippines, India, Pakistan or South Africa) then aggregate together and/or manage.

• Identity, Contact, Financial, Transaction, Usage, Technical, Profile, Marketing and
  Communications Data from our principals and regional directors who have been
  in contact with you for the delivery or potential delivery of services, invitation to
  our events or subscription for our newsletter and who are based inside or outside
  the EU.

 

 4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

For further information on the types of lawful basis that we will rely on to process your personal data see the section at the end of this document titled ‘Grounds for Processing Personal Data’. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

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PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

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MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, offers, newsletters or events may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you registered for a newsletter or event and, in each case, you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company outside Cogent Analytics Limited for marketing purposes.

OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use please see our Cookie Policy.

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CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in Section 4 above.

• External Third Parties as set out in the Glossary.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
  We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6. INTERNATIONAL TRANSFERS

 We share your personal data within Cogent Analytics Limited. This may involve transferring your data outside the European Economic Area (EEA). Many of our External Third Parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimensiondata-protection/adequacy-decisions_en.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/internationaldimension-data-protection/standard-contractual-clauses-scc_en.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-dataprotection/eu-us-data-transfers_en.

Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

 7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we must keep basic information about our customers (including Contact, Identity,
Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In addition, when we rely on the legitimate interest lawful basis to process your data, we will keep the data while that legitimate interest subsists (unless another lawful basis continues to apply as per Section 4).

In some circumstances you can ask us to delete your data: see Request erasure below for
further information.

In some circumstances we may anonymise your personal data (so that it can no longer be
associated with you) for research or statistical purposes in which case we may use this
information indefinitely without further notice to you. 

 

9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your
personal data. If you wish to exercise any of the rights set out below, please Contact us.

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer of your personal data.

• Right to withdraw consent.

 

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

However, we may charge a reasonable fee if your request is clearly unfounded, repetitive
or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and
ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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10. GLOSSARY

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

We make sure we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal data for our legitimate interests.

We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before
entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

EXTERNAL THIRD PARTIES

Service providers acting as processors based within or outside the EEA who provide IT and system administration services such as Xero, DocuSign and Google Drive.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint
  controllers based in the United Kingdom or in another EEA country, Australia, Canada, China, Hong Kong, India, Mauritius, New Zealand, Singapore, South Africa and the US who require reporting of processing activities in certain circumstances.

• Service providers who provide us with market research services or marketing services such as data research, data management, telemarketing, direct marketing and may be based in Ghana, India, Kenya, Nigeria, Pakistan, South Africa or the Philippines.

 

YOUR LEGAL RIGHTS
You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”).

• This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (orthose of a third party) and there is something about your particular situation which makes youwant to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us toestablish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

Grounds for Processing Personal Data

The following information outlines our legitimate grounds for processing personal data and should be read in conjunction with our Privacy Policy.

 

Data Controller contact information: Cogent Analytics Limited, 167-169 Great Portland street, 5th Floor, London, W1W 5PF

 

Purposes of processing personal data for marketing:

We process personal data for marketing when we come across companies which offer a product or service which lends itself to our style of outbound marketing. Where we believe we can genuinely add value to that company we contact the relevant individuals (Owners, Founders, CEOs, Presidents, MDs and other relevant senior executives) at that company via a mix of letter, email, LinkedIn and phone in order to ascertain whether the company wishes to discuss our service offering. The data we hold is not ‘sensitive data’ as determined by the GDPR and is limited to: 

• First name

• Last name

• Job title

• Company name

• Company registration number

• Website

• Email address

• LinkedIn profile ID

• Company telephone number

• Trading or registered address

• Sector

• Turnover or estimated turnover

• Employee numbers or estimated employee numbers

• Profit or estimated profit

• Growth rate or estimated growth rate

• Year founded

The data is either found within the public domain or sourced through GDPR compliant providers and therefore the risk to the data subject’s fundamental rights and freedoms is extremely limited.

Lawful grounds for processing person data for marketing – ‘Legitimate Interests’
We base our outbound marketing approach on the grounds of Legitimate Interests. In other words, we contact companies where we believe our service can legitimately add value to their business.

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This is based on article 6.1. f) of the GDPR: https://gdpr-info.eu/art-6-gdpr/

 

Lawful grounds for processing person data for marketing – Consent

In the event that data subjects have consented to receive marketing communications from Cogent Analytics Limited the data subject has the right to withdraw that consent at any time either by confirming in writing or by clicking on the unsubscribe links contained in email communications.

 

Data transfers to 3rd countries

The Controller may from time to time transfer data to 3rd countries where the processor within the 3rd country has signed a contract including Standard Contractual Clauses (as stipulated by the GDPR) and where the processor has been subject to data protection training and security controls in order to ensure secure processing of personal data. Details of these security protocols will be made available on request. For certain 3rd countries there has been no adequacy decision by the Commission, but due to the non-sensitive nature of the data and the aforementioned security protocols the risk to the data subject has been deemed as extremely low.

Personal Data Storage
Personal Data will be updated within 4 weeks of contacting any prospect. All personal data will also be audited and updated annually to ensure it is kept up to date. We continue to hold personal data if a data subject asks to be unsubscribed as we need to have a record of the data in order to avoid contacting the unsubscriber again in the future. Data subjects have the right to request we remove their data from our database, which we will of course do, but we do so on the grounds that the data subject understands that removal of their data means that we cannot 100% avoid contacting them again in the future.

The right to lodge a complaint with a supervisory authority

Data subjects have the right to lodge a complaint with a supervisory authority if they reject our grounds for communication.