CogniClick Privacy Notice
We are committed to protecting and respecting your privacy.
This Privacy Notice sets out how we collect, use, maintain and disclose Personal Data, including any information provided through our website cogniclick.com (the “Website”).
Your privacy is of the utmost importance to us. Please read this Privacy Notice carefully to understand our views and practices regarding your Personal Data and how we will treat it.
Whenever you provide Personal Data, we are legally obliged to use it in accordance with the laws concerning the protection of Personal Data.
We do not provide services to children and we do not market to children. If you are under 18, we do not recommend that you use the Website.
Who we are
COGNICLICK LIMITED is a company incorporated and registered in England and Wales with company number 10977288 whose registered office address is 183 Westcombe Hill, London, England, SE3 7DR (“CogniClick”).
For the purposes of the Data Protection Act 2018, the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), CogniClick will be the ‘data controller’ for all Personal Data that we determine the means and purpose of processing. CogniClick will be a data processor for any Personal Data that the Client captures, stores and otherwise processes through the CogniClick platform.
We are registered with the Information Commissioner’s Office under registration number ZA496232.
By “Personal Data” we refer to information collected or held by CogniClick, that identifies and relates to you as an individual.
Information we may collect
We may collect Personal Data about you when you use our website (“Website User”), use any of our services and/or our platform (“Client”) or partake in benchmarking campaigns.
The CogniClick services include the use of our technology and applications to provide Clients with the ability to engage with benchmark respondents (“End User”) via a URL link. CogniClick facilitates the transfer of benchmarking campaign data (including
Personal Data) from End Users to its Clients.
PLEASE NOTE: When a Client collects Personal Data via the CogniClick platform by using benchmarking campaigns, End Users must review the Client’s Privacy Notice (which will be included in the relevant benchmarking campaign) as this governs the Client’s intended use and processing of the End User’s Personal Data. In such circumstances, CogniClick is purely acting as processor on of the End User’s Personal Data pursuant to the Client’s instructions.
We have broken down the Personal Data categories below:
Personal Data is captured when you visit the Website or contact us via the contact form, telephone or by email. This may include your:
- email address;
- telephone number; and
- any supplementary information that you provide us about yourself when contacting us.
We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
Personal Data is captured when you use our services and where you are provided with access to the CogniClick Platform. This will include use of your business email.
Personal Data is captured when you complete a benchmark opt-in sign-up form on behalf of a Client. The nature of the Personal Data is determined by the relevant Client and End Users should read the relevant Client’s Privacy Notice in addition to this Privacy Notice.
Our Clients may also seek to capture the following types of Personal Data in a benchmarking campaign:
- job title;
- email address;
- telephone number; and
- such other information specified in the relevant benchmark.
Please note that you can opt to remain anonymous in the CogniClick Platform without disclosing any of your Personal Data to the relevant Client.
What do we do with the information we collect?
We will use your Personal Data for a number of purposes including:
- to respond to your enquiries;
- to improve our services;
- to allow us to operate the Website efficiently;
- internal record keeping;
- to ensure that the content from our Website is presented in the most effective manner for you and your computer;
- any relevant troubleshooting, testing or statistical analysis as appropriate; and
- to keep the Website secure.
- to fulfil our obligations in respect of any contracts entered into between you and us;
- to generate marketing and sales information for you;
- to send you emails relating to benchmark reports;
- to identify you for security access purposes;
- provide you with suggestions and advice on products, services and how to obtain the most from using our application; and
- to notify you about changes to our services.
- to share the Personal Data with our Clients, for us in accordance with their Privacy Notice; and
- to generate marketing and sales information for our Clients.
Please note that we may use any aggregated and anonymised data for our commercial purposes. Such data does not identify you as an individual and therefore will not be 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.
In relation to End User Personal Data, this is retained for the duration of the Client relationship (for the Client that initiated the relevant benchmark(s)) and we delete all End User Personal Data at the end of our contract with the Client.
Legal basis of processing
We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the contractual services you have requested from CogniClick or if you have provided us with adequate consent to process your information for other purposes.
We use contractual necessity as the legal ground for processing Client Personal Data. We use consent as the legal ground for processing End User Personal Data.
If we choose to process your information under the legal basis of legitimate interests, we will always inform you of our legitimate business interest and your right to object.
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 at firstname.lastname@example.org.
Protecting your information
We are committed to ensuring that your information is secure and we have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect online. We have ISO 27001 accreditation, as well as certification with IASME Governance and Cyber Essentials.
All the Personal Data collected by us and stored electronically is held on a secure server in the United Kingdom only. Where required, this information is encrypted for additional security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Data only for those employees who require it to fulfil their job responsibilities.
However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.
Data Protection Officer
To ensure we continue to monitor our obligations under Data Protection Legislation, CogniClick has appointed Helen Kensett as its data protection officer (DPO). If you wish to contact the DPO regarding any specific elements of CogniClick’s data handling, please send your enquiries, marked for attention of the DPO, to email@example.com.
Transfer of data outside of the EU
We shall not transfer any personal data to any country outside of the European Economic Area unless we ensure that such personal data is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation.
Sharing your information with others
Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies. We will not otherwise share End User Personal Data with any third parties, other than the relevant Client that commissioned the relevant benchmarking campaign(s).
However, sometimes we may share your information with third parties in the following ways:
- we may use carefully selected sub-processors to help us collect, store or manage your information. This will be managed under the terms of a data processing agreement;
- analytics and search engine providers that assist us in the improvement and optimisation of the Website; and
- if CogniClick is acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets. We process your Personal Data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Data in this way, the relevant seller or buyer of our business may not be able to provide services to you.
Access to your Personal Data
You have rights in relation to any Personal Data that we hold about you. If you wish to access your Personal Data you may make a formal subject access request by contacting CogniClick.
The information you request must relate to you or another person that you have authority to act on their behalf. CogniClick will require a confirmation of your ID (consisting of photo identification and proof of address) prior to providing any information about the data we hold. If you are unable to provide sufficient information to prove your ID, CogniClick reserves the right to refuse your request for access to Personal Data. The rights you have in relation to the Personal Data we hold regarding you are:
- the right to rectify any inaccuracies in the information we hold;
- the right to erasure of information in specific circumstances;
- the right to request transfer of your information to another controller; and
- the right to object to processing in certain circumstances.
If you have provided us with consent to process your information, you always reserve the right to withdraw this consent via the method detailed in the paragraph below. We are committed to ensuring that your wishes are respected and upon notification that you wish to withdraw your consent, CogniClick will immediately cease processing the information in question.
Please send your request to CogniClick by emailing firstname.lastname@example.org. 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.
Changes to this Privacy Notice
We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Data.
Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Data handling practices. The date of the changes will be listed in the ‘Last updated’ section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.
We recommend that you print a copy of this page for your reference.
How can you make a complaint?
Please note that if you are not satisfied with the processing of your Personal Data as set out in this Privacy Notice, please contact us at email@example.com.
You have the right to issue a complaint directly with the Information Commissioner’s Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/). We recommend that you raise any issues with us directly in advance to see if we can address your concerns before making such a complaint to the ICO.
Please contact us at firstname.lastname@example.org if you have any questions, comments or requests regarding this Privacy Notice.
Last updated April 2021