This website is owned by Cogni.Dx Limited of 86-90 Paul
Street London EC2A 4NE and we are the "controller" as defined in the Data
Protection Act 2018 ("the Act").
Important: When
you submit personal data to us and/or use our website, your personal data may
be processed by us in the manner and for the purposes described below.
1. Scope of privacy notice
1.1 We are committed to
maintaining the privacy and confidentiality of information provided by you to
us. The terms 'personal data' and ‘special category data’ are defined in the
Act.
2. Notification of changes to
privacy notice
2.1 We are continually
improving our methods of communication and adding new features to this website
so if we change our data protection practices, we will notify you on this page,
so we encourage you to check this page frequently.
3. Collection of personal data
including email addresses
3.1 When you contact us, we may
request or process personal information about you such as your name, postal
address, email address and telephone number. We will also receive special
category data if you indicate your religious or philosophical beliefs, racial
or ethnic origin or health information and we will also process special
category data as part of our Cogni services. The information which you provide
are either manually or electronically stored.
4. Use of personal data
4.1 We will use your personal
data to fulfil our services with you and to respond to your other instructions
and requirements and we will ask only for data that is adequate, relevant and
not excessive for those purposes. Where we send you information for any
purpose, it may be sent by email or post. When we ask you for personal data it
may be for any of the following purposes:
4.1.1 to contact you to inform
you of our services;
4.1.2 to send you regular updates
on issues we think will be of interest to you;
4.1.3 to send you requested
information on our people and services;
5. Unsubscribe
5.1 We use your postal and
email addresses to communicate with you and whilst you have the right to
unsubscribe from either postal or email marketing communications, we will
continue to use your contact details to send service messages and to communicate
membership news and benefits.
5.2 You may unsubscribe from
either postal or email marketing communications by emailing support@cognidx.co.uk or writing to
Cogni.Dx Limited at 86-90 Paul Street London EC2A 4NE and include “unsubscribe from marketing” in the subject heading.
6. Anonymous data collected
through this website
6.1 In addition to the personal
data that we collect as described above, we use technology to collect anonymous
information about the use of our website. For example, our web server
automatically logs which pages of our website our visitors view, their IP
addresses and which web browsers they use. This technology does not personally
identify you - it simply enables us to compile statistics about our visitors
and their use of our website.
6.2 Our website may contain
hyperlinks to other pages on our website. We may use technology to track how
often these links are used and which pages on our website our visitors choose
to view. Again, this technology does not identify you personally – it simply
enables us to compile statistics about the use of these hyperlinks.
7. Cookies
7.1 In order to collect the
anonymous data described in the preceding paragraph, we may use session 'cookies'
that remain in the cookies file of your browser until the browser is closed.
7.2 Cookies by themselves
cannot be used to discover the identity of the user. A cookie is a small piece
of information which is sent to your browser and stored on your computer's hard
drive. You can set your browser to
notify you when you receive a cookie. This enables you to decide if you want to
accept it or not. For more information
about cookies, including how to set your browser to reject them, please go to
www.allaboutcookies.org.
7.3 We may also use your IP
address to help diagnose problems with our server and to administer our
website. An IP address is an assigned number, similar to a telephone number,
which identifies your computer on a network. Your IP address is also used to
gather broad demographic information.
7.4 We may also perform IP
lookups to determine the domain you are coming from (e.g. aol.com,
yourcompany.com) to gauge more accurately our users' demographics.
8. Disclosure of your personal
data
8.1 We do not share, sell or
distribute your personal data with unrelated third parties, except as otherwise
provided for in this privacy notice and under these limited circumstances:
8.1.1 In order to provide you
with the information or services which you have requested, personal data may
occasionally be transferred or shared with third parties, who act for or with
us, for further processing in accordance with the purposes for which the data
was originally collected or for purposes to which you have consented.
8.1.2 We may share, transfer or
disclose the information in our databases and server logs to comply with a
legal requirement, to protect your vital interests, to protect the security or
integrity of our databases or this website, to take precautions against legal
liability, or in the event of a joint venture, collaboration, financing, sale,
merger, reorganisation, change of legal form, dissolution or similar event.
8.1.3 Where appropriate, before
disclosing personal data to a third party, we contractually require the third
party to take adequate precautions to protect that personal data and to comply
with applicable law.
9. Our lawful
ground for processing your personal data
9.1 In order to comply with
applicable data privacy laws, we are required to set out the legal basis for
the processing of your personal data. In accordance with the purposes for which
we collect and use your personal data, as set out above, the legal basis for
processing your personal data will typically be one of the following:
9.1.1 our own or our third
parties' legitimate business interests where we have carried out a legitimate
interest assessment and have established an existing legitimate interest;
9.1.2 the performance of a
contract that we have in place with you;
9.1.3 your consent where
appropriate;
9.1.4 to protect your vital
interests; or
9.1.5 compliance with our legal
obligations.
10. Records retention
10.1 We will keep your personal data no longer than is
necessary or as further detailed in our data retention policy.
11. Data subject rights
11.1 Data subjects in the UK and
other jurisdictions may have rights in relation to their personal data which
include: 11.1.1
Right to rectification
. Data subjects may request that we
rectify any inaccurate or incomplete personal data. 11.1.2
Right to withdraw consent. Data subjects may at any time withdraw
their consent to the processing of their personal data carried out by us on the
basis of their previous consent. Such withdrawal will not affect the lawfulness
of processing based on such previous consent.
11.1.3
Right to make a subject access request (SAR)
. Data subjects
may request in writing copies of their personal data. However, compliance with such
requests is subject to certain limitations and exemptions and the rights of
other individuals. Each request should make clear that a SAR is being made. You
may also be required to submit a proof of your identity
and any payment permitted by law, where applicable.
11.1.4
Right to object to processing including automated processing and
profiling
. We do make automated decisions about data subjects where
they have consented to use of our Cogni services. Profiling may also be
carried out for business administration purposes, such as monitoring trends in
user visits of our website and in order to deliver relevant ads to users'
devices. We will comply with valid objection requests unless we have a
compelling overriding legitimate ground for the continuation of our processing
or we have another lawful reason to refuse such request. We will comply with
each valid opt-out request in relation to marketing communications.
11.1.5
Right to erasure
. Data subjects may request that we erase
their personal data. We will comply, unless there is a lawful reason for not
doing so. For example, there may be an overriding legitimate ground for keeping
the personal data, such as, our business record retention obligations that we
have to comply with.
11.1.6
Restriction
. Data subjects may request that we restrict our
processing of their personal data in various circumstances. We will comply,
unless there is a lawful reason for not doing so, such as, a legal obligation
to continue processing your personal data in a certain way.
11.1.7
Right to data portability
. In certain circumstances, data
subjects may request the controller to provide a copy of their personal data in
a structured, commonly used and machine-readable format and have it transferred
to another provider of the same or similar services. We do not consider that
this right applies to our Services. However, to the extent it does, we will
comply with such transfer request. Please note that a transfer to another
provider does not imply erasure of the data subject's personal data which may
still be retained for legitimate and lawful purposes.
11.1.8
Right to lodge a complaint with the supervisory authority
. We
suggest that data subjects contact us about any questions or complaints in
relation to how we process their personal data. However, each data subject has
the right to contact the relevant supervisory authority directly.
12. Links to other websites
12.1 This website may contain
hyperlinks to websites that are not operated by us. These hyperlinks are
provided for your reference and convenience only and do not imply any
endorsement of the activities of such third-party websites or any association
with their operators. We do not control these websites and are not responsible
for their personal data practices. We urge you to review any privacy policy
posted on any site you visit before using the site or providing any personal
data about yourself.
13. Governing Law
13.1 This privacy notice forms
part of our website Terms of Use
14. Feedback
14.1 We welcome comments about
this privacy notice. If you have any questions about this notice or any part of
our service, you may contact us by emailing support@cognidx.co.uk or writing to Cogni.Dx
Limited at 86-90 Paul Street
London EC2A 4NE