Privacy Policy

Privacy Policy

Introduction

Cogency is committed to protecting and respecting your privacy.  We wish to be transparent on how we process your data.  It is the intention of this privacy statement to explain to you the information practices of Cogency in relation to the information we collect about you.

This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR), which came into force on 25 May 2018.  From that date, the GDPR, together with applicable Irish requirements, amended existing data protection law and placed enhanced accountability and transparency obligations on organisations when using your information.  The GDPR introduced changes which give you greater control over your personal information, including a right to object to processing of your personal information where that processing is carried out for our business purposes.

Please read this statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to Cogency, will be processed by Cogency.  If you have any questions about how we use your information, please contact our us at the details below.

  1. Who we are

Throughout this document, “we”, “us’, “our” and “ours’ refer to Cogency.   Your information is held by Cogency.

  1. The information we collect about you

We will hold:

  • Data to identify you, including your contact information.
  • Information related to Google Analytics such as your IP address.
  • Information which you have consented to providing and us using.
  1. When we collect your information

We collect information:

  • You give us.
  • Information provided to us by third parties.
  1. Purpose for processing your data

The information that you provide ('data') will be used for the administration of any existing business conducted through us, or to administer any enquiries or future services as requested by you.  We may share your data with our agents and service providers in order to provide an efficient service to our clients.

Our reason for processing your data under the GDPR is:

  • Consent– You have given consent to process your data for one or more specific purpose.
  • Contract- The processing of data is essential to service and monitor existing business, or because you have asked for something to be done.
  • Legal basis– We may need to process your data as this is necessary in relation to a contract to which you have entered into or because you have asked for something to be done so you can enter into a contract.
  • Vital Interests– It is necessary to protect your vital interests in exceptional circumstances.
  • Legitimate Interests– such as conducting marketing activities or training and strategic planning.

In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.  Data is at all times treated as confidential and the appropriate measures are taken to ensure it is secure. Cogency is subject to the requirements of the Data Protection Acts 1988-2003 and will hold your data in accordance with all applicable data protection laws and principles.

  1. How will Cogency use the personal data it collects?

We will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR).  We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

  1. Special Categories of personal data

If we collect any special categories of personal data we will obtain your explicit consent.

  1. Who we are sharing your data with

We may pass your personal data on to third-party service providers contracted to Cogency in the course of dealing with you.  Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf.  When they no longer need your data to fulfil this service, they will dispose of the details in line with Data Protection Laws.

If we wish to pass your personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.

The third parties that we pass your personal data to are:

  • Authorised representatives.
  • Third parties with whom: we need to share your information to facilitate transactions such as payment processing or other services which you have requested, and you ask us to share your information.
  • Service providers who provide us with support services.

We will ensure all third party processors we use are GDPR compliant.

  1. Data Subjects Rights:

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access– you have the right to request a copy of the information that we hold about you.
  • Right of rectification– you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten– in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing– where certain conditions apply to have a right to restrict the processing.
  • Right of portability– you have the right to have the data we hold about you transferred to another organisation.
  • Right to object– you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling– you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review -in the event that Cogency refuses your request under rights of access, we will provide you with a reason as to why.

If you wish to exercise any of your data rights, you can contact us at jimmy@cogency.ie by mail to Cogency, Danesfort House, Ballynagar, Abbey, Loughrea, Co. Galway or by contacting 087 6479104.

  1. Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained.  We will process personal data in accordance with our retention schedule.

  1. Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Cogency, or how your complaint has been handled, you have the right to lodge a complaint directly to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at: Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231 Fax: +353 57 868 4757 E-mail: info@dataprotection.ie Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.

11.Failure to provide further information

If you do not wish to provide us with your information we may not be able to:

  • Provide requested services or products to you.
  • Efficiently review suitability of existing services or products held.
  • Provide new services/ products or renew existing services/ products held.
  • Make a sound business recommendations.
  1. Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.

  1. Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

  1. How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

  1. Marketing

Cogency would like to send you information about services and products of ours that we think you might like. You have the right at any time to stop Cogency from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please email Jimmy Healy on jimmy@cogency.ie

  1. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

  1. How to Contact Us

If you have any comments or questions regarding this statement, please contact Jimmy Healy on jimmy@cogency.ie or 087 6479104.

  1. Privacy policy statement changes

Cogency may change this Privacy Statement from time to time.  When such a change is made, we will post a revised version on our website.  Changes will be effective from the point at which they are posted.  It is your responsibility to review this privacy policy periodically so you’re aware of any changes.  By using our services you agree to this privacy policy.

This privacy policy was last reviewed in July 2019. 

 

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