Data Privacy and Security

DATA PRIVACY & SECURITY POLICY

Policy brief & purpose

 

This Policy outlines proportionate measures designed to achieve and maintain compliance with the General Data Protection Regulation. These measures have been designed to minimise the risk of breaches and uphold the protection of personal data. This Data Protection Policy refers to our commitment to treat information of employees, customers, stakeholders and all other interested parties with the utmost care and confidentiality. With this policy, we ensure that we gather, store and handle data fairly, transparently and with respect towards individual rights.

This policy should be considered along with our Privacy Policy and Cookie Policy.

Scope.

 

Your privacy is important to us. This Data Privacy and Security Policy applies to the website www.cogniclick.com or to other websites we operate as outlined from time to time.

We also provide a software platform for our customers (the “Service”).

We are responsible for the processing of personal data we receive in providing the Service, and subsequently transfer to a customer acting as an agent on its behalf.

The Service includes technology and applications we provide to our customers that enable them to engage with end users. When our customers collect information from their end users through our Service, our Privacy Policy and this Data Privacy and Security Policy does not apply to that collection of information. This is because our customers are directing the collection of said information and we have no direct relationship with our customers’ end users, and do not control our customers’ collection and/or use of the end users’ information. To learn how our customer (the Data Controller) uses the information it collects in this way, please see that customer’s privacy policy. To access data controlled by our customers, if you are an end user who seeks access, or who seeks to correct, amend, or delete inaccurate data, or if you are an end user of one of our customers and would no longer like to be contacted by one of our customers that use our Service please contact them directly. If requested to remove data we will respond within a reasonable timeframe. We may transfer personal information to companies that help us provide our Service.

Who is covered under the Data Protection Policy?

Employees of our company and its subsidiaries must follow this policy. Contractors, consultants, partners and any other external entity are also covered. Generally, our policy refers to anyone we collaborate with or acts on our behalf and may need occasional access to data.

Policy principles

As part of our operations, we need to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, social security numbers, financial data etc.

Our company collects this information in a transparent way and only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply.

Our data will be:

  • Compliant with EU General Data Protection Regulation (GDPR)
  • Accurate and kept up-to-date
  • Collected fairly and used for lawful purposes only
  • Processed by the company within its legal and moral boundaries
  • Protected against any unauthorised or illegal access by internal or external parties
  • Process securely within the European Union
  • Encrypted in storage and transfer

Our data will not be:

  • Store insecurely in any way
  • Communicated informally
  • Stored for more than a specified amount of time
  • Transferred to organisations or countries outside of the European Union
  • Distributed to any party other than the ones agreed upon by the data’s owner, except where required to do so by law.

In addition to ways of handling the data the company has direct obligations towards people to whom the data belongs. We will:

  • Let people know which of their data is collected
  • Inform people about how we’ll process their data
  • Inform people about who has access to their information
  • Have provisions in cases of lost, corrupted or compromised data
  • Allow people to request that we modify, erase, reduce or correct data contained in our databases

To exercise data protection we are committed to:

  • Restrict and monitor access to sensitive data
  • Develop transparent data collection procedures
  • Train employees in online privacy and security measures
  • Maintain secure networks to protect online data from malware and cyberattacks
  • Establish clear procedures for reporting privacy breaches or data misuse
  • Ccommunicate statements on how we handle data
  • Establish data protection practices
    • data encryption
    • frequent backups
    • access authorisation
    • document shredding

Disciplinary Consequences:

All principles described in this policy must be strictly followed. A breach of data protection guidelines will invoke disciplinary and possibly legal action.

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Effective Date 1 June 2020.