Cogenis Ltd's Privacy Notice

Cogenis Ltd (Company Number: 11494838) (“Company, we, us, our”) is committed to protecting the privacy and security of your and your dependant’s personal data. This Privacy Notice describes how we collect, use and look after your and your dependant’s personal data when you visit our website or use our app (regardless of where you visit or use it from), including when you sign up to our app. It also tells you about your and your dependant’s rights and how the law protects you and your dependant.

Schedule 1
Part 1 Types of personal data

contact data

billing address, email address and telephone number

financial data

bank account and payment card details

identity data

first name, last name, dependant’s first name and last name, username or similar identifier, date of birth, dependant’s date of birth, age and title

marketing and communication data

your preferences in receiving marketing from us and our third parties and your communication preferences

profile data

your username and password, your feedback and survey responses

technical data

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 our website or app

transaction data

details about payments to and from you and other details of the subscription package you have purchased

other

content of your dependant’s social media posts which may include identity data  

Part 2 Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your or your dependant’s personal data are:

consent

you and your dependant (where applicable) have given your express consent for us to process your or your dependant’s personal data for a specific purpose.

For the avoidance of doubt, where your dependant is under the age of 13, you can provide consent on their behalf for us to process their personal data. Where your dependant is aged 13 or above, we will always request/obtain express consent from the dependant for the purposes of processing their data.

contract

the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you.

legal obligation

the processing is necessary for us to comply with legal or regulatory obligation.

legitimate interests

the processing is necessary for our (or a third party’s) legitimate interest e.g. in order for us to provide the best service to you via our website or app. Before we process your or your dependant’s personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your or your dependant’s personal data on this basis where such impact outweighs our interest.

Set out below are specific details of the processing activities we undertake with your or your dependant’s personal data and the lawful basis for doing this.

Purpose/Activity

Type of data

Lawful basis for processing

to register you as a user on our website and/or on our app

identity & contact

to perform our contract with you

to enable the functionality of the AI/machine learning software within the app

your dependant’s social media posts which may include identity and health data

to perform our contract with you

to process and deliver your subscription, manage payments, fees and charges and debt recovery

identity, contact, financial, transaction and marketing & communications

  1. to perform our contract with you;
  2. as necessary for our legitimate interest in recovering debts due to us.

to manage our relationship with you, notifying you about changes to our Terms or Privacy Notice and ask you to leave a review or take a survey

identity, contact, profile and marketing & communications

  1. to perform our contract with you;
  2. as necessary to comply with a legal obligation;
  3. as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services.

to enable you to complete surveys or provide us with feedback

identity, contact, profile, usage and marketing & communications

  1. to perform our contract with you;
  2. as necessary for our legitimate interests in analysing how customers use our products/services, to develop them and grow our business.

to administer and protect our business and our website and app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

identity, contact and technical

  1. as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise;
  2. as necessary to comply with any legal obligations.

to deliver relevant website or app content/ advertisements to you and measure or understand the effectiveness of our advertising

identity, contact, profile, usage, marketing & communications and technical

as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy.

to use data analytics to improve our website, app, products/services, marketing, customer relationships and experiences

technical and usage

as necessary for our legitimate interests to define types of customers for our products and services, to keep our website and app updated and relevant, to develop our business and to inform our marketing strategy.

to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers

identity, contact, technical, usage and profile

as necessary for our legitimate interests to develop our products/services and grow our business.

Part 3 Your and your dependant’s legal rights

You and your dependant have the following legal rights in relation to your or your dependant’s personal data:

access your data

you or your dependant can ask for access to and a copy of your or your dependant’s personal data (as applicable) and can check we are lawfully processing it.

correction

you or your dependant can ask us to correct any incomplete or inaccurate personal data we hold about you or your dependant.

erasure

you or your dependant can ask us to delete or remove your or your dependant’s personal data where:

  1. there is no good reason for us continuing to process it;
  2. you or your dependant have successfully exercised your right to object (see below);
  3. we may have processed your and/or your dependant’s information unlawfully; or
  4. we are required to erase your or your dependant’s personal data to comply with local law.

We may not always be able to comply with your or your dependant’s request for specific legal reasons, which will be notified to you or your dependant at the time of your request.

object

you or your dependant can object to the processing of your or your dependant’s personal data where:

  1. we are relying on our legitimate interest (or those of a third party) as the basis for processing your or your dependant’s personal data, if either of you feel it impacts on your fundamental rights and freedoms;
  2. we are processing your or your dependant’s personal data for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your and/or your dependant’s information which override your and/or your dependant rights and freedoms and, in such circumstances, we can continue to process your or your dependant’s personal data for such purposes.

restrict processing

you or your dependant can ask us to suspend or restrict the processing of your or your dependant’s personal data, if:

  1. either of you want us to establish the accuracy of your or your dependant’s personal data;
  2. our use of your or your dependant’s personal data is unlawful, but you do not want us to erase it;
  3. you need us to hold your or your dependant’s personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or
  4. you or your dependant has objected to our use of your or your dependant’s personal data, but we need to verify whether we have overriding legitimate grounds to use it.

request a transfer

you can request a transfer of your or your dependant’s personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contract with you, to you or a third party. We will provide your or your dependant’s personal data in a structured, commonly used, machine-readable format.

withdraw your consent

you and/or your dependant can withdraw your consent at any time (where we are relying on consent to process your or your dependant’s personal data). This does not affect the lawfulness of any processing carried out before you or your dependant withdraw your consent.

Part 4 Third Parties

service providers

acting as processors who provide IT system, administration and analytics services.

professional advisors

acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities

acting as processors or joint controllers who require reporting or processing activities in certain circumstances.

third parties 

third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your or your dependant’s personal data in the same way as set out in this Privacy Notice.

Part 5 Glossary

aggregated data

information such as statistical or demographic data which may be derived from personal data but which cannot by itself identify a data subject.

controller

a body that determines the purposes and means of processing personal data.

data subject

an individual living person identified by personal data (which will generally be you).

personal data

information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data.

processor

a body that is responsible for processing personal data on behalf of a controller.

special categories of personal data

information about race, ethnicity, political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life or sexual orientation.

ICO

Information Commissioner’s Office, the UK supervisory authority for data protection issues.

Cogenis Ltd Cookies Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the website, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
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Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after 12 months.