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1.Introduction

CogniQal ("we", "us", or "our") is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect information you provide when visiting our website at www.cogniqal.com, downloading resources, booking a consultation, or otherwise engaging with our services.

CogniQal operates as a corporate learning and development company with offices in Greece and the United Kingdom. As a company based within the European Union, we are subject to the EU General Data Protection Regulation (GDPR) (Regulation 2016/679) and, where applicable, the UK GDPR. We act as the Data Controller for all personal data processed in connection with our website and services.

2.Who We Are — Data Controller

The Data Controller responsible for your personal data is:

For any questions or requests related to your personal data, please contact us at the email address above.

3.What Personal Data We Collect

We collect personal data only when you voluntarily interact with specific features of our website. The categories of data we collect include:

3.1 Contact and Identity Data

• Full name
• Business email address
• Phone number (where provided)

3.2 Professional and Organisational Data

• Name and size of your organisation (number of employees)
• Your role or job title
• Industry sector
• Whether your organisation currently uses a Learning Management System (LMS) and, if so, which platform
• Any other information you voluntarily provide in contact or inquiry forms

3.3 Technical and Usage Data

• IP address and approximate geographic location
• Browser type and version
• Pages visited on our website and time spent
• Referring URLs and click behaviour
• Device type and operating system

This data is collected automatically through cookies and analytics tools when you browse our website. Please refer to Section 7 for further information on cookies.

4.How and Why We Use Your Data

We process your personal data on the following legal bases under Article 6 of the GDPR:

4.1 To Fulfil a Request You Have Made (Legitimate Interest / Contractual Necessity)

When you book a discovery call, request a proposal, or fill in a contact form, we use your data to respond to your inquiry, schedule your appointment, and provide you with the information or services requested.

4.2 To Deliver Downloadable Resources (Legitimate Interest)

When you submit a form to access a PDF resource, guide, or other downloadable content, we process your data to deliver the requested material and understand how our resources are used by different types of organisations.

4.3 Marketing Communications (Consent)

Where you have explicitly given your consent, we may use your email address and professional details to send you relevant updates about our services, educational content, webinars, or industry insights. You may withdraw your consent at any time by clicking the "unsubscribe" link in any marketing email or by contacting us directly.

4.4 Website Analytics and Improvement (Legitimate Interest)

We use analytics tools (including Google Analytics) to understand how visitors interact with our website. This helps us improve user experience, optimise content, and measure the effectiveness of our pages. This processing is based on our legitimate interest in maintaining and improving our digital presence. Where required by applicable law, we obtain your consent via our cookie banner before placing analytics cookies.

4.5 CRM and Booking Management (Legitimate Interest / Contractual Necessity)

We use Zoho's suite of tools (including Zoho Bookings and Zoho CRM) to manage appointment scheduling and maintain records of our business interactions. Your data in these systems is used solely for managing our relationship with you and your organisation.

5.Third-Party Tools and Data Processors

We use a limited number of carefully selected third-party platforms to operate our website and deliver our services. These providers act as data processors on our behalf and are contractually obligated to process your data only according to our instructions and in compliance with applicable data protection law.

• Google Analytics: Google Analytics (Google LLC) — website traffic analysis and user behaviour reporting. Data may be transferred to the United States under the EU–U.S. Data Privacy Framework.
• Zoho: Zoho Corporation — appointment booking (Zoho Bookings) and customer relationship management (Zoho CRM). Zoho is ISO 27001 certified and GDPR compliant.
• Email Marketing: Email marketing platform (e.g. Mailchimp or equivalent) — used to send marketing communications to subscribers who have given consent. Data is processed in accordance with the provider's data processing agreement.
• Meta Pixel: Meta Pixel (Meta Platforms, Inc.) — used to measure the effectiveness of advertising and to deliver relevant ads to users who have visited our website. This cookie is placed only with your prior consent via our cookie banner.

We do not sell your personal data to any third party, nor do we share it with third parties for their own independent marketing purposes.

6.How Long We Retain Your Data

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

• Inquiry and contact form data: retained for up to 3 years from the date of last contact, unless a business relationship is established.
• CRM and booking records: retained for the duration of our business relationship and up to 5 years thereafter for legitimate business purposes.
• Email marketing subscriber data: retained until you withdraw consent or unsubscribe.
• Analytics and cookie data: as set by the respective third-party tool (typically 13–26 months for Google Analytics).

Upon expiry of the relevant retention period, your data will be securely deleted or anonymised.

7.Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and gather statistical information. Cookies are small text files placed on your device when you visit a website.

We use the following types of cookies:

• Essential / Strictly Necessary Cookies: These are essential for the website to function properly and cannot be disabled. They do not store any personal data.
• Analytics / Performance Cookies: These cookies (including Google Analytics) allow us to count visits and understand how users interact with our site. All data is aggregated and anonymous where possible.
• Marketing / Targeting Cookies: These cookies (such as the Meta Pixel) are placed by our advertising partners to show you relevant ads. They require your explicit consent.

You can manage your cookie preferences at any time via the Cookie Settings option in the footer of our website. You may also control cookies through your browser settings; however, disabling certain cookies may affect the functionality of the site.

8.Your Rights Under the GDPR

As a data subject under the GDPR (or UK GDPR, where applicable), you have the following rights in relation to your personal data:

• Right of Access: You have the right to request a copy of the personal data we hold about you.
• Right to Rectification: You have the right to request that we correct any inaccurate or incomplete data.
• Right to Erasure: You have the right to request deletion of your personal data, subject to applicable legal obligations.
• Right to Restriction of Processing: You have the right to request that we limit how we use your data in certain circumstances.
• Right to Data Portability: You have the right to receive your data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority. In Greece, this is the Hellenic Data Protection Authority (HDPA — www.dpa.gr). In the UK, this is the Information Commissioner's Office (ICO — www.ico.org.uk).

To exercise any of these rights, please contact us at hello@cogniqal.com. We will respond to your request within 30 days.

9.International Data Transfers

Some of our third-party service providers may process your data outside the European Economic Area (EEA) or the United Kingdom. Where such transfers occur, we ensure that appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions issued by the European Commission or UK government
• Participation in approved frameworks such as the EU–U.S. Data Privacy Framework

10.Data Security

We take the security of your personal data seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised access, disclosure, alteration, or destruction. These measures include encrypted data transmission (HTTPS), access controls, and regular review of our data handling practices.

While we strive to protect your personal data, no method of transmission over the internet is completely secure. We encourage you to contact us immediately if you believe your data has been compromised.

11.Data Relating to Minors

Our website and services are directed exclusively at business professionals and organisations. We do not knowingly collect personal data from individuals under the age of 16. If you believe a minor has submitted personal data to us, please contact us so that we can delete it promptly.

12.Links to Third-Party Websites

Our website may contain links to external websites operated by third parties. This Privacy Policy applies only to our website. We are not responsible for the privacy practices of any third-party sites and encourage you to review their respective privacy policies.

13.Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. The date at the top of this document indicates when the policy was last revised. We encourage you to review this page periodically. Where changes are material, we will make reasonable efforts to notify you.

14.Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact us:

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