Privacy Policy

Last Updated: June 1, 2024

1. Introduction

This Privacy Policy explains how CogMotion Solutions B.V. ("we," "our," or "us") collects, uses, and shares your personal data when you visit our website, use our services, or otherwise interact with us. We are committed to protecting your privacy and processing your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

2. Data Controller

CogMotion Solutions B.V. is the data controller responsible for your personal data. We are established in The Netherlands with company registration number KVK 1234567890 and registered address at Korfoedreef 155, 3562 SJ Utrecht, The Netherlands.

3. Personal Data We Collect

We may collect the following types of personal data:

  • Identity and Contact Data: Name, email address, phone number, company name, job title, and other contact details.
  • Technical Data: Internet protocol (IP) address, 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.
  • Usage Data: Information about how you use our website and services.
  • Marketing and Communications Data: Your preferences in receiving marketing from us and our third parties and your communication preferences.

4. How We Collect Your Personal Data

We collect your personal data through various methods, including:

  • Direct interactions: When you fill in forms on our website, correspond with us by email, phone, or otherwise, or when you meet us at events.
  • Automated technologies: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this data by using cookies, server logs, and other similar technologies.
  • Third parties: We may receive personal data about you from various third parties, such as analytics providers like Google, based outside the EU.

5. How We Use Your Personal Data

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We use your personal data for the following purposes:

  • To provide and maintain our services
  • To notify you about changes to our services
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our services
  • To monitor the usage of our services
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

6. Legal Basis for Processing

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal data. In almost all cases, the legal basis will be one of the following:

  • Consent: You have given us explicit consent to process your personal data for a specific purpose.
  • Contract: The processing is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
  • Legal obligation: The processing is necessary for us to comply with the law.
  • Legitimate interests: The processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests.

7. Disclosure of Your Personal Data

We may share your personal data with the following parties:

  • Service providers: Who provide IT and system administration services.
  • Professional advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
  • Regulators and other authorities: Who require reporting of processing activities in certain circumstances.
  • Third parties: To 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 personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International Transfers

We may transfer your personal data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

9. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your personal data, and whether we can achieve those purposes through other means.

11. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent where we are relying on consent to process your personal data.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

12. Cookies

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. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.

13. Changes to This Privacy Policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.

14. Contact Us

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at:

CogMotion Solutions B.V.
Korfoedreef 155
3562 SJ Utrecht
The Netherlands
Email: privacy@cogmotion-solutions.com

You have the right to make a complaint at any time to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), the Dutch supervisory authority for data protection issues (www.autoriteitpersoonsgegevens.nl). We would, however, appreciate the chance to deal with your concerns before you approach the Authority, so please contact us in the first instance.