Cognition Foundry Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers, suppliers, employees and consultants and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Information About Us
Cognition Foundry, a limited company, registered in England and Wales under company number 07376035
Registered address: 10 Western Road, Romford, Essex, England, RM1 3JT
Main trading address: 3 The Meads, Cranham, Essex RM14 3YP
VAT number: 115422256
- What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
- What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
(a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
(b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
(c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
(d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
(e) The right to restrict (i.e. prevent) the processing of your personal data.
(f) The right to object to us using your personal data for a particular purpose or purposes.
(g) The right to data portability. If you have provided personal data to us directly then we are using it with your consent. If that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business
(h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way
(i) For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us):
- Email address;
- Telephone number;
- Business name;
- Job title;
- Payment information;
Your personal data (name, email address, contact number, business name, job title) may be obtained from the following third parties:
- Our Suppliers
- Our Distributors
- Our Partners and Collaborators
- Our Customers
A detailed list is available on request – please contact us using the details provided in Part 11.
- How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Providing and managing your account.
- Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and services for you.
- Communicating with you. This may include responding to emails or calls from you.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods:
- For five years after last business activity;
- How and Where Do You Store or Transfer My Personal Data?
We normally only store or transfer your personal data in the UK. This means that it will be fully protected under the GDPR.
We may share your data within the group of companies of which we are a part. Where this involves the transfer of personal data outside the European Economic Area (EEA), our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”. More information on binding corporate rules is available from the European Commission.
Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
- Do You Share My Personal Data?
We may share your personal data with other companies in our group related to supplying products and/or services to you. This includes subsidiaries.
We may sometimes contract with trusted third parties to supply products and/or services to you on our behalf. The trusted third parties include:
- Our Suppliers
- Our Distributors
- Our Partners and Collaborators
- Our Customers
A detailed list is available on request (see section 11)
The personal data shared may include details required for payment processing, delivery, and marketing. In some cases, the third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and request a copy of it (where any such personal data is held). This is known as a “Subject Access Request (SAR)”.
All SARs should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use (Appendix 1). You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a SAR. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including making a subject access request, please use the following details:
Email address: firstname.lastname@example.org
Postal Address: 10 Western Road, Romford, Essex, England, RM1 3JT.
- Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
Any changes will be made available on the Company website www.cognitionfoundry.com
- Roles and Responsibilities
The Company’s Chief Executive Officer has overall responsibility for the company policies and procedures
- Implementation of Privacy Notice
This Privacy Notice shall be deemed effective as of 25th May 2018. No part of this Privacy Notice shall have retroactive effect and shall thus apply only to matters occurring on or after this date.
[Your full address]
Cognition Foundry Ltd
10 Western Road
Dear Sir or Madam
Subject access request
[Your full name and address and any other details to help identify you and the information you want.]
Please supply the information about me I am entitled to under the Data Protection Act 1998 relating to: [give specific details of the information you want, for example
- your personnel file;
- emails between ‘A’ and ‘B’ (between 1/6/11 and 1/9/11);
- copy of statement of account
If you need any more information from me, or a fee, please let me know as soon as possible.
It may be helpful for you to know that a request for information under the Data Protection Act 1998 should be responded to within 40 days.
If you do not normally deal with these requests, please pass this letter to your Data Protection Officer. If you need advice on dealing with this request, the Information Commissioner’s Office can assist you and can be contacted on 0303 123 1113 or at ico.org.uk