Privacy Policy

Contents

1. About us
2. What personal data do we collect?
3. How do we collect personal data?
4. Cookies
5. How & why we use your personal data
6. Marketing
7. Use of external tools on our website
8. Children
9. How we share personal data
10. International transfers
11. How do we keep your information secure?
12. How long we keep personal data
13. Third party links
14. Your rights
15. Changes to this policy or your data

1. About us

This Application is operated by Cognitive Credit Limited (referred to in this privacy policy as "Cognitive Credit", "we", "us" and "our"). We are the data controller of any information you provide to us in the course of using our Services.

Cognitive Credit is a company registered in England and Wales with its registered office at Suite 8, 2nd Floor, 43-44 High Road, Bushey Heath, WD23 1E. You can contact us at this address, or by emailing support@cognitivecredit.com

We are registered as a data controller with the UK Information Commissioner's Office under number A8411531.

2. What personal data do we collect?

'Personal data' means any data which can be associated with you as an individual, either directly or indirectly. We collect different information depending on how you use our Services and how you interact with us.

The personal data we may collect includes:

• Your identity and contact information, including your name, your login details, email address, your organisation (if you are accessing our Services on behalf of a company or other organisation), and the address of that organisation, and your office telephone number and mobile phone telephone number.
  
  
• Usage data, which includes information about how you use our Services, including when you have logged in and out of the Services.
  
  
• Technical data, such as the device you are using to access our Application, your unique device ID, your internet protocol (IP), browser type and version, time zone and location, display settings, browser plug-in types and versions, operating system and Application and other technology on the devices you use to access our Application.

Please note that should you include any personal data in your notes when using our Application (“Notes”), and we need access to this personal data when providing you with technical support, we are a processor of this personal data. This Privacy Policy does not govern how we process personal data contained in your Notes.

Our Services are not intended for collecting or transmitting 'special categories' of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, gender orientation, political opinions, trade union membership or health information. We do not collect data about actual or alleged criminal offences.

3. How do we collect personal data from you?

a) Personal data you provide to us

We collect personal data from you when you create an account with us, subscribe to our Services, or interact with us in any other way (such as via email, post, telephone or social media).

We may record or monitor calls and emails that you receive from us or make to us. We do this for security and training purposes and to improve the services we provide to you.

b) Personal data we collect as you use our Services

We automatically collect your technical and usage data, as described above, as you interact with our Services. We collect this personal data by using cookies, server logs and other similar technologies. Please see section 4 below, for further details.

4. Cookies

a) Cookies and other similar technologies

A cookie is a small data file that is placed on your computer or mobile device by your web browser when you visit a website. It is a tool that stores information about website visits, recognises you and your preferences each time you visit us, and ensures website functionality and generally improves your website experience. A cookie file can contain information such as a user ID that the site uses to track the pages you have visited, but the only personal data a cookie can contain is information you supply yourself. A cookie cannot read data off your hard disk or read cookie files created by other sites. Cookies can be persistent by remaining on your computer until you delete them or be based on your browsing session where they are deleted once you close your browser.

You can find more information about cookies from these websites: www.allaboutcookies.org and www.aboutcookies.org

b) Cookies used on our website

We use the following cookies:

We store data locally (including via session tokens) in the browser Application to pass on user credentials between our server and the Application, which allows users to stay logged in. We also use IndexedDB, which stores Application specific data, network requests, and the user’s identification token.

We use the following categories of cookies:

• Strictly necessary cookies: these cookies are essential in order to enable you to use our Services. Without them, you would not be able to use basic services such as logging into the Application.
  
  
• Functionality cookies: these cookies allows you to customise your user preferences and can therefore be used to provide you more personal services.

Strictly necessary cookies are necessary to provide the Application to you. We use such cookies without your prior consent. All other cookies are dropped after you have consented via the cookie banner on our Website.

c) Opting out of Cookies

You have the right to decide whether to accept or reject cookies. If you do not want to receive cookies, you can modify your browser so that it notifies you when cookies are sent to it or you can refuse cookies altogether. You can also delete cookies that have already been set. If you wish to restrict or block web browser cookies which are set on your device then you can do this through your browser settings; please visit your browser's help menu for further details. If cookies are disabled you will still be able to access the Application, however some content may not function correctly.

5. How and why we use your personal data

We will only use your information where:

a) We need the information to fulfil our contract with you.

If we have entered into a contract to provide you with our Services (for example, if you have subscribed to our Services, whether on your own behalf or on behalf of an organisation), we will need your personal data in order to do so. The personal data that we use will depend on the service(s) we have agreed. For example:

• We will use your identity and contact details so that we can communicate with you about the Services we provide, send you software and content updates, to facilitate providing any Services you have requested, and to respond to any requests, queries, issues or concerns you may have.
  
  
• We will use your technical information to ensure that our Services display and function correctly on your device.

b) We have a legitimate interest (reasonable business purpose) in doing so.

We will use your information for our legitimate business reasons where our doing so will not unduly affect your rights.

We will use your identity, contact and usage information to keep our records up to date.

We will use your usage and technical information to:

• provide and make improvements to our Services, system maintenance, support, reporting and hosting of data, and troubleshooting;
• optimise the performance of our Services;
• ensure that our Services are secure;
• analyse how users interact with our Services; and
• develop new products and services.

We may also use any or all of the information above to administer and manage our business in general, to detect and prevent misuse of our Services, and to enforce our terms and conditions or any other contract to which we may be a party. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.

c) You have given us your consent.

We ask you to consent to collecting your personal data before we install cookies on your machine. Please see section 4 above for further information on the cookies we use.

d) We need to comply with a legal or regulatory obligation.

In certain circumstances, we may need to retain or use your personal data to comply with regulations and/or the law.

6. Marketing

We may contact you to provide you with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you.

You may opt out of receiving our marketing communications at any time by contacting us at support@cognitivecredit.com or by using the unsubscribe link in any of our communications.

We will continue to contact you for non-marketing related purposes where we need to issue a field corrective or safety notice or where we need to send certain information to you under a legal, regulatory, or ethical requirement.

7. Use of external tools on our website

We have integrated various tools from different companies into our website, which allow us to evaluate user behavior or to establish links with other websites.

Google Analytics

The controller has integrated the component Google Analytics (with anonymisation function) on this website.

Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Among other things, a web analysis service collects data on which website a data subject has come to a website from (so-called referrers), which subpages of the website were accessed or how often and for which period of time a subpage was viewed. A web analysis is mainly used to optimize a website and for the cost-benefit analysis of Internet advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.

Google Analytics uses cookies. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. Google might transfer the personal information collected via this technical procedure to third parties. As IP anonymization is activated on our website, your IP address will be shortened by Google within Member States of the European Union or other states in agreement with the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by a Google server in the USA. On behalf of the operator of the website, Google will use this information to evaluate your use of the website, compile reports on website activity and to provide further services related to website and internet use to us. The IP address transferred through your browser to Google Analytics will not be combined with other data held by Google.

In addition, this website uses the Analytics feature UserID to track interaction data. This User ID will be additionally anonymized and encrypted and will not be linked with other data. You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of this website to the fullest extent possible.

In addition, you may prevent the collection of the data generated by the cookie and related to your use of the website (including your IP address) by Google as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics.

In addition, a cookie already set by Google Analytics can be deleted at any time via the Internet browser or other software programs.

Further information and Google‘s applicable privacy regulations can be found at https://policies.google.com/privacy?hl=en

The following link provides a further explanation of Google Analytics: https://marketingplatform.google.com/about/

8. Children

Our Services are not intended to be used by children under the age of 18 years, and we do not knowingly collect children's personal data.

9. How we share personal data

We will share your personal data with our trusted third party service providers. These include:

• our information technology providers, such as our cloud storage provider (Amazon Web Services), and our website and mailing list hosts; and
• analysts, consultants and other professional advisors whom we retain for advice in respect of our business operations.

We will only disclose your personal data to third party service providers under terms of confidentiality, and they will only use your personal data for the purposes stated in this privacy policy.

If you are using our Services on behalf of a company or other organisation, we may share certain details with that company or organisation.

Your personal data may be disclosed or transferred to potential or actual buyers of, investors into or lenders to, our business or any of our assets, or any of the advisors or representatives of the above. If so, we will ensure that appropriate confidentiality terms are in place.

On rare occasions, we may share personal data when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government inquiry); to enforce or apply our terms of use or other agreements; in the context of a company reorganisation or restructuring exercise; or to protect the rights, property, or safety of Cognitive Credit, our personnel, our users, or others.

10. International transfers

The Application is hosted on servers located within the European Economic Area (EEA).

11. How do we keep your information secure?

We will take reasonable steps (including appropriate technical and organisational measures) to ensure your personal data is processed securely to protect the confidentiality, integrity and availability of your personal information in accordance with this privacy policy. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet and any transmission is at your own risk.

If a password is used to help protect your accounts and personal information, it is your responsibility to keep your password confidential. You should update your password periodically to help reduce the risk of unauthorised access to your account with us. When you do, you should strengthen your password with the combination of uppercase and lowercase letters, numbers, punctuation and other symbols. Do not share this information with anyone. If you are sharing a computer with anyone you should always log out before leaving a site or service to protect access to your information from subsequent users.

12. How long we keep personal data

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.

13. Third party links

Our Application, or our other Services, may contain links to third party sites whose information practices may be different than ours. Please consult all third party sites' privacy notices, as we have no control over information that is submitted to, or collected by, third parties.

14. Your rights

You may have the right to:

• require us to rectify the personal data we hold about you, where that data is incorrect;
• require that we restrict the processing of your personal information in certain circumstances;
• request access to the personal data that we hold about you;
• require that, in certain circumstances, we delete the personal information we hold about you;
• object to the processing of personal information we hold about you;
• require that we provide you with the information that we hold about you in a structured, commonly used and machine-readable format
• or have such personal data transmitted to another company; and/or
• withdraw your consent to our using your personal data for marketing purposes at any time.

You also have the right to lodge a complaint with the Information Commissioner’s Office, which is the UK supervisory authority for data protection issues ( www.ico.org.uk ). We would, however, be grateful if you would contact us in the first instance so we can endeavour to deal with your concerns direct.

If you wish to exercise any of these rights, please contact us at support@cognitivecredit.com.

To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

15. Changes to this policy or your data

We may amend or modify this privacy notice from time to time. We will post any revised notice on this Application, and if the changes are significant, we will notify our members by email.

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.

This privacy statement was last updated on 26 March 2024.