Privacy Policy

Purpose of this privacy policy

This privacy policy aims to give you information on how Cognition collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or request materials.

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Controller

Cognition is the controller and responsible for your personal data (collectively referred to as “Cognition”, “we”, “us” or “our” in this privacy policy).

Cognition trades as Emergence Partners Limited is registered in England & Wales with company number 12171041. Registered address: Tennyson House, Cambridge Business Park, Cambridge, Cambridgeshire, England, CB4 0WZ.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO:

Email address: dop@cognitionhq.com

Postal address: Cognition, 1 Old Queen Street, London,SW1H 9JA

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 20^th February 2024.

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 on those 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 policy of every website you visit.

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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 as follows:

Identity Data includes first name, last name, username or similar identifier, title, and your job title.
Contact Data includes your address, email address and telephone numbers.
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 this website.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We might also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.

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 offenses.

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 and contact details 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 services or products;
create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will 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 (see more below).

Third parties or publicly available sources. Cognition uses third party analytics tools, such as Google Analytics, to help understand use of the Service. Many of these tools collect the information sent by your browser as part of a web page request, including cookies and your IP address. These analytics tools also receive this information and their use of it is governed by their privacy policy.

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

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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, in a table format, 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 in the table below.

‍ privacy policy table

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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 and offers 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 services from us and you have not opted out of receiving that marketing.

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Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

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Opting out

You can ask us or third parties to stop sending you marketing messages at any time 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 your use of our services.

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.

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Disclosure of your personal data

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.

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International Transfers

We do not transfer your personal data outside the UK except as stated in the section above.
Whenever we transfer your personal data out of the UK, 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 under European or UK law to provide an adequate level of protection for personal data.

Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

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

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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.

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Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

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

In some circumstances we will 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.

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Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

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 (or those of a third party) and there is something about your particular situation which makes you want 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:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
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.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer using the details above.

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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 could 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.

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Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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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Use of Cookies

This website uses cookies to improve your experience while visiting the website. As required by legislation, this website uses a cookie control system, allowing you to give explicit permission or to deny the use of /saving of cookies on your computer/device.

Cookies are small files saved to your computer’s hard drive that track, save and store information about your interactions and use of the website. This allows the website to provide you with a tailored experience. If you wish to deny the use and saving of cookies from this website you can use your web browser’s security settings to block all cookies from this website and its external serving vendors, or use the cookie control system if available upon their first visit.

This website uses tracking software to monitor its visitors to better understand how they use it. The software will save a cookie to track and monitor your engagement and usage of the website, but will not store, save or collect personal information.

Terms of use

Acceptance of these terms of use

These Terms of Use (« ToU ») state the terms and conditions governing your use of and access to the Cognition website (the « Site ») and constitute a legally binding contract between you and Cognition (« Cognition » or “we” or “us”). By accessing and browsing the Site or by using and/or downloading any content from same, you agree and accept the ToU as set forth below.

If you are an individual, you represent and warrant that you have reached the age of majority in the jurisdiction in which you reside.

If you are an individual accessing or using the Site on behalf of, or for the benefit of, any corporation, partnership or other entity with which you are associated (an “Organization”), then you are agreeing to these ToU on behalf of yourself and such Organization, and you represent and warrant that you have the legal authority to bind such Organization to these ToU. References to “you” and “your” in these ToU will refer to both the individual using the Site and to any such Organization .

If you do not accept to be bound by these ToU, then you must not use or access the Site.

Your agreement with Cognition is made up of these ToU, together with any additional terms and conditions posted on the Site or otherwise made available to you by Cognition.

Cognition reserves the right, at its sole discretion, to modify or delete all or portions of these ToU at any time without further notice. If we do this, we will indicate at the top of this page the date these ToU were last revised. Your use of the Site after any such changes constitutes your acceptance of the new ToU.

These ToU apply to www.cognitionhq.com and any other Cognition website on or accessible via www.cognitionhq.com (collectively, the “Cognition Sites”). The Cognition are operated by subsidiaries of Cognition.

Some Cognition Sites may be subject to different or additional terms. By accessing any of these Cognition Sites, you agree to be bound by any additional terms that govern use of each such Cognition Site.

Purpose of the Site

All the materials contained in the Site are provided for informational purposes only and shall not be construed as a commercial offer, a license, an advisory, fiduciary or professional relationship between you and Cognition. No information provided on this Site shall be considered a substitute for your independent investigation.

The information provided on this Site may be related to products or services that are not available in your country and/or will not be available at any time.

Links to third-party websites

Links to third-party websites are provided for convenience only and do not imply any approval or endorsement by Cognition of the linked sites, even if they may contain Cognition’s logo, as such sites are beyond Cognition’s control. Thus, Cognition cannot be held responsible for the content of any linked site or any link contained therein. Therefore, you should protect yourself against viruses, worms, Trojan horses and other potentially destructive programs that may be present on third-party websites. And you are responsible for checking and complying with terms of use applicable to these third-party websites.

You acknowledge that framing the Site or any similar process is prohibited.

Information you post on the Site

Cognition does not assume any obligation to monitor the information that you may post on its Site.

You warrant that any information, Materials (the term “Material” is intended to cover all projects, files or other attachments sent to us) or comments other than personal data, that you may transmit to Cognition through the Site does not infringe intellectual property rights or any other applicable law. Such information, Materials or comments, will be treated as non-confidential and non proprietary. You warrant that any information, Materials or comments, that you may transmit to Cognition through the Site do not affect the integrity and/or the security of the Site, and in particular, do not contain any virus, worms, Trojan horses and other potentially destructive programs.

By submitting any information or material, you give Cognition an unlimited and irrevocable license to use, copy, execute, show, display, modify and transmit such information, Material or comments, including any underlying idea, concept or know-how, in whole or in part, in any manner or medium. Cognition reserves the right to use such information in any way it chooses.

Social Media House Rules

We aim to keep our social media channels a pleasant experience and ensure our communities are positive, constructive, and supportive. To this end we reserve the right to remove any posts in breach of our house rules and to block any individual who violates them repeatedly.

We will remove comments that:

Defame abuse, harass, stalk, threaten or otherwise violate the legal rights of others.

Are racist, sexist, homophobic, sexually explicit, abusive or otherwise objectionable

Contain swear words or other language likely to offend.

We know or suspect may break the law or condone or encourage unlawful activity. This includes publishing, posting, distributing or disseminating any defamatory, infringing, obscene, indecent, misleading or unlawful material or information.

Advertise products or services for profit.

Are made to appear as if they have been posted by someone else.

Repeatedly post the same message, or are unrelated to Cognition and its brands – ‘spam’.

We reserve the right to adjust these rules as needed and to delete content for reasons not stated in this list.

By using our social channels, you agree to comply with these house rules and the platform’s own terms and conditions.

Comments and other material posted by users of our social channels do not reflect the opinions of Cognition, nor does Cognition confirm their accuracy.

If you would like to alert us to any inappropriate use of this Site as specified, please contact us

Intellectual Property

This Site is protected by intellectual property rights including but not limited to trademarks, copyright, designs, sui generis right of the database producer, etc. and is the exclusive property of Cognition.

Any material that it contains, including, but not limited to, texts, data, graphics, pictures, sounds, videos, logos, icons or html code is protected under intellectual property law and remains Cognition or third party’s property.

You may copy, download and print off this material for personal and non-commercial purposes only and in accordance with the principles governing intellectual property laws. You must not modify any material copied, downloaded or printed off from the Site in any way. Any other use of the content of the Site without Cognition’s prior written authorization is prohibited.

Non-compliance with the above-mentioned prohibitions may constitute an act of counterfeiting and/or unfair competition engaging your civil and/or criminal liability.

All other trademarks not owned by Cognition that appear on the Site are the property of their respective owners, who may or may not be affiliated with, connected to, or sponsored by Company. You should require specific authorization to use for any purpose any of the trademarks owned by Cognition or any third party.

Warranty and Liability

All materials contained in the Site are provided «as is» and without warranty of any kind to the extent allowed by the applicable law. While Cognition will use reasonable efforts to provide reliable information through its Site, Cognition does not warrant that this Site is free of inaccuracies, errors and/or omissions, or that its content is appropriate for your particular use or up to date, and Cognition reserves the right to change the information at any time without notice. Cognition does not warrant any results derived from the use of any material. You are solely responsible for any use of the materials contained in this Site. Any use of the website is at your own risk. You must comply with all applicable laws, rules and regulations.

The information contained in this site does not extend or modify the warranty that may apply to you as a result of a contractual relationship with Cognition.

Cognition will not be liable for damages of any kind including indirect, consequential or incidental damages, lost profits or revenues, business interruption, loss of goodwill, work stoppage, security breaches, viruses, computer failure or malfunction, loss of data arising out of or in connection with the use, inability to use or reliance on any material contained in this Site or any linked site, even if any of the parties to these ToU are advised of the possibility of such losses.

Nullity of a provision

If any term in these ToU is, for any reason whatsoever, held invalid, illegal or unenforceable in any respect, such invalidity, illegality or unenforceability shall not affect any other provision of these ToU.

Waiver of rights

The failure by Cognition to exercise, or delay in exercising, a legal right or remedy provided by these ToU or by law shall not constitute a waiver of Cognition’s right or remedy. If Cognition waives a breach of these ToU, this shall not operate as a waiver of a subsequent breach of the ToU.

Applicable law and jurisdiction

Any controversy or claim arising out of or related to the ToU shall be governed by UK law. The courts of London, UK will have exclusive jurisdiction.

There are certain regulation that apply depending on the country you are based. Please review the additional information to your jurisdiction when applicable.

USA https://www.congress.gov/bill/117th-congress/house-bill/8152/text

UE https://commission.europa.eu/law/law-topic/data-protection/data-protection-eu_en

ARG https://www.argentina.gob.ar/aaip/datospersonales

BR https://www.gov.br/anpd/pt-br