This Privacy Notice explains how Cogrion collects, uses, discloses, retains and protects personal data when individuals visit our websites, communicate with us, attend our events, request information, apply for a role, or interact with us in connection with our products and services (collectively, the “Services”).
This Notice is a transparency statement and does not create contractual warranties, service levels or obligations beyond those imposed by applicable law or expressly agreed in a written contract.
This Notice does not govern Customer Data that Cogrion processes on behalf of a customer under the Cogrion Master Cloud Services Agreement (“MCSA”) and Data Processing Addendum (“DPA”). For that data, the customer determines the purposes and means of processing and should provide its own privacy information to relevant individuals.
1. Who we are
“Cogrion”, “we”, “us” and “our” refer to the Cogrion entity that provides the relevant website, communication or Service. Cogrion operates globally through affiliated entities. The applicable contracting entity is identified in the relevant Order or commercial document.
Questions or requests concerning this Notice may be sent to admin@cogrion.com.
2. Personal data we collect
- Contact and account information, such as name, business email address, telephone number, employer, role, account identifiers and authentication information.
- Commercial and relationship information, such as enquiries, meeting details, event registrations, contract contacts, product interests, communications and support interactions.
- Website and device information, such as IP address, browser and device type, operating system, referring pages, pages viewed, timestamps and cookie or similar identifiers.
- Service telemetry associated with authorised users, such as login events, feature use, configuration events, usage volumes and diagnostic information. We do not use Customer Data for advertising.
- Recruitment information, such as resumes, employment history, qualifications, interview notes and information supplied by referees or recruitment providers.
- Other information that an individual chooses to provide to us.
Please do not submit sensitive personal data unless it is necessary and we have requested it through an appropriate channel.
3. How we collect personal data
We collect personal data directly from individuals, from their employer or organisation, through use of our websites and Services, from event and channel partners, and from lawful public or commercial sources. We may also receive limited account and transaction information from authorised marketplace or technology partners.
4. How we use personal data
- Provide, secure, administer and support the Services and user accounts.
- Respond to enquiries, schedule demonstrations, manage proposals, Orders, billing and business relationships.
- Monitor performance, prevent misuse, troubleshoot issues and improve our websites and Services.
- Send operational notices and, where permitted, relevant business communications. Recipients may opt out of non-essential marketing communications.
- Plan and administer events, partner programmes and recruitment activities.
- Comply with law, enforce agreements, establish or defend legal claims, and protect people, systems and property.
- Create aggregated or de-identified information that does not reasonably identify an individual.
5. Legal grounds
Where applicable law requires a legal basis, we process personal data with consent, to perform or take steps relating to a contract, to comply with legal obligations, or for legitimate interests that are not overridden by the individual’s rights. The relevant basis depends on the context and jurisdiction.
6. How we disclose personal data
We may disclose personal data to Cogrion affiliates; service providers that support hosting, communications, security, analytics, customer relationship management, support, billing, events or recruitment; authorised marketplace and channel partners; professional advisers; and public authorities or other recipients where required by law or necessary to protect rights and security. Providers may use personal data only for the authorised purpose and subject to appropriate obligations.
We do not sell personal data. We do not disclose personal data for third-party cross-context behavioural advertising.
7. International transfers
Cogrion and its providers may process personal data in countries other than the country in which it was collected. Where required, we use contractual, organisational or other recognised safeguards intended to provide a comparable standard of protection for transferred personal data.
8. Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Notice, including to provide Services, maintain appropriate business and security records, comply with law and resolve disputes. Retention periods vary according to the type of information, the relationship and applicable requirements. We delete or de-identify personal data when it is no longer required, subject to lawful backups and records-retention obligations.
9. Security
We maintain reasonable administrative, technical and organisational measures designed to protect personal data against unauthorised access, use, alteration, disclosure or loss. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
11. Individual rights
Depending on applicable law, an individual may have rights to request access, correction, deletion or restriction; object to certain processing; withdraw consent; receive portable data; or lodge a complaint with a regulator. Rights may be subject to legal conditions and exceptions. To make a request, contact admin@cogrion.com. We may verify identity before acting on a request.
12. Children
Our websites and business Services are not directed to children, and we do not knowingly collect children’s personal data through them. If you believe a child has provided personal data to us, contact admin@cogrion.com.
13. Third-party sites
Our websites may link to third-party sites or services. Their privacy practices are governed by their own notices, and Cogrion is not responsible for those practices.
14. Changes to this Notice
We may update this Notice to reflect changes in law, technology or our practices. We will publish the revised Notice with a new effective date and, where required, provide additional notice.