Cogs AI Limited – Privacy Notice
1. Our approach to privacy
1.1. Cogs AI Ltd ("Cogs", "we", "our", or "us") is committed to protecting and respecting yours and your child’s privacy. This privacy notice sets out how we collect, store, process, transfer, share and use data that directly or indirectly identifies you and your child ("personal information"), when you access and browse our website ("Website"), or use our mobile app (the "Mobile App") (together our "Services") together with information regarding our use of cookies and similar technologies.
1.2 Before accessing or using our Services please ensure that you have read and understood our collection, storage, use and disclosure of yours or your child’s personal information as described in this privacy notice.
1.3 If you have any questions, comments and requests regarding this privacy notice, please contact: felix@cogs-ai.com
2. Who is responsible for yours and your child’s personal information?
Cogs is the data controller of the personal information we hold about you or your child. This means that we determine and are responsible for how yours or your child’s personal information is used.
3. Personal information we collect about you and how we use it
Personal information you submit to us
3.1 We collect personal information that you submit directly to us, via our Website or which you input into the Mobile App. This information may include yours or your child’s name, email address or such other contact information as is necessary to communicate with you about our services.
3.2 The table at Annex 1 sets out in detail the categories of personal information we collect about you or your child and how we use that information, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.
3.3 We will indicate to you if the provision of certain personal information is mandatory or optional. If you choose not to provide any personal information which is mandatory, we may not be able to provide our services to you.
Personal information we collect automatically
3.4 We may also automatically collect personal information about how you use our Services from yours or your child’s device including your IP address, details about the type of device and browser you use and device’s telephone number (if applicable). We typically collect this information through a variety of tracking technologies, including cookies and similar tracking technologies.
3.5 The table at Annex 2 sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information. For more information on cookies and other tracking technologies, please see the following section 4.
4. Cookies and similar technologies
4.1 We use cookies and similar tracking technologies. Cookies are pieces of code that we transfer to your device for record-keeping purposes. This helps us to provide certain functionalities on our Website, and the Mobile App as well as to monitor and improve our Services.
4.2 We use the following types of cookies:
a) Strictly necessary cookies. These are cookies that are required for the operation of our Services such as cookies that allow you to log in to your account on the Mobile App. Without these cookies, certain elements of our Services would not work.
b) Analytical cookies. These allow us to recognise and count the number of visitors, to see how visitors move around our Services and to monitor performance of certain features on our Services which helps us to improve our Website and Mobile App.
c) Functionality cookies. These are used to recognise you as you move around our Services and to remember information that you enter on the site, such as when you fill out a form.
4.3 Other than cookies that are required to operate our Services, we will only place cookies on your device with your consent. If you would like to withdraw your consent to non-essential cookies, you can do this by deleting the cookies for the Cogs Mobile App from your device through your browser settings or mobile device settings and rejecting non-essential cookies the next time you access our website. The following links contain further information about how to delete cookies from popular browsers:
4.4 Most browsers will also allow you to disable all cookies through your browser or mobile settings. These settings will typically be found in the "options" or "preferences" menu of your browser. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Services.
5. How long we keep your personal information
5.1 We will store the personal information we collect for no longer than necessary for the purposes set out and in accordance with our legal obligations and legitimate business interests.
5.2 If you have signed up or attempted to sign up as a user of the Cogs Mobile App, upon your request, we will delete or anonymise yours and / or your child’s personal information (which we are permitted to delete) within sixty (60) days.
6. Recipients
6.1 As required in accordance with how we use your personal information, we may share your personal information with the following:
Companies in the same group as us: We may share personal information with other entities owned by or under common ownership with Cogs. We do this to coordinate our group-wide strategy for providing services and communicating with prospective users.
Service providers and advisors. We may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include messaging and email services and web hosting.
Law enforcement, regulators and other parties for legal reasons. We may share you or your child’s personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Cogs, its users or others.
For further specific information about who we may share personal information with, please refer to the Annexes.
7. Storing and transferring your personal information
7.1 Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers.
7.2 International Transfers of your personal information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are located in the United Kingdom ("UK") or European Economic Area ("EEA"), your personal information may be processed outside of the UK or EEA, including in the United States. We will ensure that these international transfers of your personal information are made pursuant to appropriate safeguards, such as:
ensuring that the personal information is only transferred to countries recognised as offering an equivalent level of protection as compared to the level of protection in the country you are located; or
the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission or UK Secretary of State (as applicable).
7.3 We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy notice regardless of where it is processed.
7.4 If you wish to enquire further about the safeguards we use, please contact us using the details set out above.
8. Your rights in respect of your personal information
8.1 If you are resident in the UK or EEA, in accordance with applicable privacy law you have the following rights in respect of your personal information that we hold:
Right of access. You have the right to obtain:
confirmation of whether, and where, we are processing your personal information;
information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
information about the categories of recipients with whom we may share your personal information; and
a copy of the personal information we hold about you.
Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
Right to object. You have the right to object to any processing based on our legitimate interests. There may, depending on the particular circumstances, be compelling reasons for continuing to process your personal information despite your objection, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.
8.2 If you wish to exercise one of these rights, please contact us using the contact details at the top of this privacy notice. We will not charge you a fee for complying with your request to exercise one of these rights, other than where the request is manifestly unfounded or excessive (such as if you submit a number of repeated requests), in which case we may charge you a reasonable fee to cover our administrative costs.
8.3 You also have the right to lodge a complaint to your national data protection authority. If you are in the EEA, further information about how to contact your local data protection authority is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are in the UK, your local data protection authority is the Information Commissioner's Office, which can be contacted using the details at https://ico.org.uk/global/contact-us/.
9. Links to third party sites
Our Services may from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
10. Our policy towards children
Our services are designed to be used by children (anyone under 18). If you are under 18, our Child Privacy Notice can be found here.
11. Changes to this notice
We may update this privacy notice from time to time and so you should review this page periodically. When we change this privacy notice in a material way, we will update the "last modified" date at the end of this privacy notice. Changes to this privacy notice are effective when they are posted on this page.
12. Notice to you
If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Services.
13. Last modified
13.1 This privacy notice was last modified on 22nd March 2023.
| ANNEX 1 – PERSONAL DATA YOU PROVIDE TO US | |||
|---|---|---|---|
| Category of personal data | How we may use it | Legal basis for the processing | Recipients of personal data |
| Contact Information when you make an enquiry about our service on our Website via the Contact Us section, such as your first name, last name, and e-mail address and any comments you add in the message field | ●We use this information to enable you and your child to utilise our products and Services, and to respond to any queries, issues or concerns you and your child may have. | ●The lawful bases we rely on for processing this personal information is i) that processing is necessary for our legitimate interests, namely providing the best access to our products and Services. | ●Cogs or any group companies. We may also share this information with our service providers. |
| Your preferences, such as preferences set for notifications, marketing communications, how the Cogs AI Website is displayed. | ● We may use this information to contact you regarding our products and any updates to our Services. | ● The lawful bases we rely on for processing this personal information is i) that processing is necessary for our legitimate interests, namely providing the best access to our products and services. | ●Cogs or any group companies. We may also share this information with our service providers. |
| Personal and Contact Information when you use our Mobile App such as yours and your child’s name, date of birth, and email address. | ● We use this information to enable you and your child to utilise our products and Services, and to respond to any queries, issues or concerns you and your child may have. | ● The lawful bases we rely on for processing this personal information is i) that processing is necessary for our legitimate interests, namely providing the best access to our products and services and ii) the processing is necessary for the performance of a contract and to take steps prior to entering into a contract. | ●Cogs or any group companies. We may also share this information with our service providers. |
| Contact Information when you use our Mobile App such as your username and password and your notification preferences (e.g. the time you want to receive notification reminders) | ●We use this information to enable you or your child to utilise our products and Services, and to respond to any queries, issues or concerns you or your child may have. | ●The lawful bases we rely on for processing this personal information is i) that processing is necessary for our legitimate interests, namely providing the best access to our products and services and ii) the processing is necessary for the performance of a contract and to take steps prior to entering into a contract. | ●Cogs or any group companies. We may also share this information with our service providers. |
| Comments, Opinions and Behavioural Data when you use our Mobile App: such as your chat history, your mood data (e.g. description of the mood which you or your child is feeling and an explanation of why they are feeling that way),reflection data (e.g. journal entries, explanation of events / problems they are experiencing),their feelings and reflections on their mental health. | ● We use this information to enable you or your child to utilize our products and Services to ensure they receive tailored support from our App | ● The lawful bases we rely on for processing this personal information is i) that processing is necessary for our legitimate interests, namely providing the best access to our products and services and ii) the processing is necessary for the performance of a contract . | ● Cogs or any group companies. We may also share this information with third parties as required by law or if we reasonably believe that such action is necessary to protect the safety of you or your child. |
| ANNEX 2 – PERSONAL DATA COLLECTED AUTOMATICALLY | |||
| Category of personal data | How we may use it | Legal basis for the processing | Recipients of Personal Data |
| Information about how you access and use the Cogs AI. For example, how frequently you access the Cogs AI Website, the time you access the Cogs AI Website and how long you use it for, the approximate location that you access the Cogs AI Website from, the site from which you came and the site to which you are going when you leave Cogs AI’s Website, the pages you visit, the links you click, and other actions you take on the Cogs AI Website. | ●We use this information to allow you to navigate around our Services. ●We use or may use the data collected through these technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) recognise and contact you across multiple devices; (c) provide and monitor the effectiveness of our Services; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Services; (e) diagnose or fix technology problems; and (f) otherwise to plan for and enhance our Services. | ● The lawful basis we rely on for processing personal information in this way is that processing is necessary for the performance of a contract with you. ● For analytics purposes we will only use your personal information in this way to the extent you give us your consent to do so. | ● Cogs and any of our service providers. |
| Approximate location information or your IP address. We may collect general geographic location based on your IP address or more precise geolocation with your permission when accessing our online services through a mobile device. | ● We may use this information to tailor our products to you. | ● The lawful basis we rely on for processing personal information in this way is that processing is necessary for the performance of a contract with you. ● For analytics purposes we will only use your personal information in this way to the extent you give us your consent to do so. | ●Cogs and any of our service providers. |
| Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to connect to the Cogs AI Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Cogs AI Website through the device, your mobile network, your IP address and your device’s telephone number (if it has one). | ●We use this information to allow you to navigate around our Services. | ● The lawful basis we rely on for processing personal information in this way is that processing is necessary for the performance of a contract with you. ● For analytics purposes we will only use your personal information in this way to the extent you give us your consent to do so. | ●Cogs and any of our service providers. |