Privacy & Cookies Policy

1. Introduction

1.1  Cogent Content is committed to safeguarding the privacy of our website visitors and service users.

1.2  This privacy policy explains when and why we collect personal information about our clients, including visitors to our website and anyone else who we collect data from. It explains how we use this data, under what circumstances we may share it with a third party and how we keep it secure. 

1.3  By using our website, you’re agreeing to this privacy policy.

1.4  This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

1.5  We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

2. How do we collect data from you?

2.1 We collect information about you when you use the online contact form on our website, contact us by email or phone regarding information about our services. 

3. What data is collected from you?

3.1 The personal data we collect from you is the minimum required that will enable us to provide you with the service requested, and we only pass your information to third parties for the fulfilment of the service requested and in the manner outlined in this policy.

3.2 The personal information we may collect might include your name, email address, postal address and telephone number. 

4. How we use your personal data

4.1 In this Section 4 we have set out:

(a)     the general categories of personal data that we may process;

(b)     in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)     the purposes for which we may process personal data; and

(d)     the legal bases of the processing.

4.2    We may process usage data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Squarespace analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is part of our legitimate interest, namely monitoring and improving our website and services.

4.3 We may process correspondence data (information contained in or relating to any communication that you send to us). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you:

a.    To maintain records of our client and fulfil our contractual obligations to provide you with the service requested.

b.    To notify you of changes to our privacy and cookies policy.

c.    To provide you with additional services or information that has been specifically requested by you.

 The legal basis for this processing is our legitimate interest, namely the proper administration of our website and business and communications with users.

4.4 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4.5 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interest, namely the proper protection of our business against risks.

4.6 Please do not supply any other person's personal data to us, unless we prompt you to do so.

5. The legal basis for processing your personal data

5.1 Under GDPR, the main grounds that we rely upon to process your account data (the account data includes your name, email address, postal address and telephone number) are as follows:

5.2 To comply with a contractual obligation as part of the performance of a contract between ourselves and/or taking steps, at your request to enter into such a contract. This includes your account data including name, email address, postal address and telephone number.

5.3 For the purposes of legitimate interests.  This includes responding to requests or enquires from you, or to send information or services which you have expressed an interest in. 

5.4 We may also be obliged by law to disclose your data to a regulatory body or law enforcement agency.

6. Providing your personal data to others

6.1 We may disclose personal data including name, email address, postal address and telephone number to our suppliers or subcontractors insofar as reasonably necessary for to fulfil contractual purposes. As stated in section 8, as part of your legal rights, the identity of our suppliers and subcontractors will be shared with you at your request within one calendar month.

6.2 We may disclose your personal data to my insurers and professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6.3 Cogent Content will not sell your data to third parties and will only share your data with government organisations if required, or where a third party (e.g. sub-contractor) is required to be engaged in order to meet client obligations for the delivery of services as necessary. 

6.4 We will not pass your details to any third party for direct mailing purposes.

7. Cogent Content Service Providers

7.1 If necessary, we may engage the use of third parties (e.g. suppliers and sub-contractors) to process and deliver client services.  In all cases, we will only provide the necessary data to these third parties to enable them to perform their role. 

7.2 We use third party data managers like LinkedIn and Squarespace to provide services to securely store the data for operational and back up purposes.

7.3 We only use processors who themselves are GDPR compliant.

8. Your data preferences

 8.1 We will contact you by email or telephone for information directly related to your client details.  You have the right to request and amend your preferences. We will carry out the request within one calendar month of receiving the valid request.

9. Your rights

9.1    In this Section 8, we have summarised the rights that you have under data protection law.

9.2    Your principal rights under data protection law are:

(a)     the right to access;

(b)     the right to rectification;

(c)     the right to erasure;

(d)     the right to restrict processing;

(e)     the right to object to processing;

(f)      the right to data portability;

(g)     the right to complain to a supervisory authority; and

(h)     the right to withdraw consent.

9.3    You have the right to request confirmation from Cogent Content as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. We will provide you with the requested information within one calendar month of receiving the valid request.

9.4    You have the right to request that any inaccurate personal data about you held by Cogent Content is rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. We will carry out the request within one calendar month of receiving the valid request, which may include verifying your identity and we may request proof of the correct data.

9.5    In some circumstances you have the right request that Cogent Content erases your personal data without undue delay. Those circumstances include: The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. If this is the case then we will explain this in our response to the request. We will process such requests within one calendar month of receiving the valid request, which may include verifying your identity.

9.6   In some circumstances you have the right to request that Cogent Content restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.7   You have the right to object to Cogent Content processing your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

9.8    You have the right to object to Cogent Content processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will consider and cease to process your personal data for this purpose within one calendar month of valid request received, which may include verifying your identity.

9.9    You have the right to object to us processing your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

9.10  To the extent that the legal basis for us processing your personal data is:

(a)     consent; or

(b)     that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

9.11  If you consider that us processing your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

9.12  To the extent that the legal basis for us processing your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.13  You may exercise any of your rights in relation to your personal data by written notice to us.

10. Retaining and deleting personal data

10.1 This section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

10.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

10.3 We will retain your personal data as follows:

(a)     Any personal data will be retained for a minimum period of 2 years from the date your contract is terminated with us.

10.4 Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject to, or in order to protect your vital interests or the vital interests of another natural person.

11.    Cookies that we use

11.1  We use traffic log cookies for the purpose of analysis. We use cookies to identify which pages you visit when navigate our website. This helps us to analyse the use and performance of our website and by doing so, we are able improve the website and your customer journey.

12.    Cookies used by our service providers

12.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

12.2  We use Squarespace Analytics to analyse the use of our website. Squarespace Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Squarespace privacy policy is available at: https://www.squarespace.com/privacy/.

12.3  We use Squarespace as a service provider to host our website. This service uses cookies to customize, evaluate, improve and protect their service.  You can view the privacy policy of this service provider at https://www.squarespace.com/privacy/.

13.    Managing cookies

13.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)     https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)     https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(d)     https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)     https://support.apple.com/kb/PH21411 (Safari);

14. Links to other websites

14.1 Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit.

14.2 We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

14.3 In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the policy of that third-party site.

15. Our details – Data Controller Contact Information

 15.1 The website is owned and operated by Andy Furlong.

15.2 The Data Controller for Cogent Content is Andy Furlong.

15.3  Our head office is registered at 29 Hawthorne Drive, Thornton, Leicestershire, LE67 1AW.

15.4  For all correspondence in relation to this privacy policy, please contact the Data Controller for Cogent Content on the details provided below

(a)     by post, to the postal address given above;

(b)     using our website contact form at www.cogentcontent.co.uk/contact.

(c)     by telephone on +44 (0)788 1922 293

(d)     by email - office@cogentcontent.co.uk.

16. Complaints

16.1 We aim to resolve all complaints about how we handle your personal information directly with you, but you also have the right to lodge a complaint with the Information Commissioner’s Office via the contact details at:

https://ico.org.uk/make-a-complaint

Helpline - 0303 123 1113

17. Amendments to this policy

17.1 We keep our privacy policy under regular review. The latest version of this policy was published on 26 August 2020.

17.2  We may update this policy from time to time by publishing a new version on our website.

17.3  You should check this page occasionally to ensure you are happy with any changes to this policy.

17.4  We will notify you of changes to this policy by email.

18. Credit

15.1 This document was created using a template from SEQ Legal (https://seqlegal.com).