This Privacy Policy was last modified on 17/6/19

Privacy Policy for use of www.cogito-wealth.com/cogito-wealth.co.uk

Cogito Wealth are committed to ensuring that your privacy is protected.

This Privacy Policy explains how we use the information we collect about you and procedures we have in place to safeguard your privacy.

In this Privacy Policy references to we, us and our, are to Cogito Wealth. References to the Website are to www.cogito-wealth.com

What Information Do We Collect?

The information we collect via the Website may include:

Personal details you give us through completion of forms on the Website, including name, address, telephone number, email address etc.

Your IP address, your preferences and use of email updates.

Data recorded by the Website which allows us to recognise you and your preferred settings.

Such data is recorded locally on your computer through the use of cookies.

Your browser can be programmed to reject cookies or warn you before downloading them.

If you disable cookies it may affect the service you obtain from the Website.

When you use the Website our servers automatically record certain information that your web browser sends whenever you visit any website.

What we do with your Information Any personal information we collect from the Website we use for some or all of the following purposes:

To process your registration and provide you the features and functionality of the Website.

In some cases we may use your email address to send you information on other services.

You will be offered the option to opt out of such service. We may need to pass the information we collect to other companies for administrative purposes.

We may use third parties to carry out certain activities such as processing and sorting data, monitoring use of the Website etc.

Such third parties will not be allowed to use your personal information for their own purposes.

We may use aggregated information for the purpose of monitoring use of the Website. Such aggregated information may be provided to third parties.

These statistics will not include information which can be used to identify any individual. Links The Website may contain links to other sites.

Please note that we are not responsible for the Privacy Policies or practices of other sites.

We encourage users to be aware when they leave the Website and to read the Privacy Policies of other sites.

This Privacy Policy applies solely to information collected on the Website.

Protection of Information The internet is not a secure medium.

However, we have put in place recommended up to data security measures and will review these and keep them updated regularly.

Updating/Modification If any of the details you have provided to the Website changes, please give us correct details by email to learn@cogito-wealth.co.uk.

We reserve the right to change this Privacy Policy without notice. The new Privacy Policy will be posted upon the Website and your continued use of the Website will be considered acceptance of it.

You are advised to check this Privacy Policy regularly.

Your Consent By submitting your information on the Website, you consent to the use of that information as set out in this Privacy Policy.

If we change the Privacy Policy we will post the changes on this page and we may place notices on other pages of the Website so that you may be aware of such change.

Your continued use of the Website will then signify that you agree to such changes. Owing to the global nature of the internet, the information you provide may be transferred to companies outside the European Economic Area (EEA) that do not have similar protections in place to those which apply in the EEA regarding your data and its use as set out in this Policy.

However, we have taken steps outlined in this Policy to protect the security of your information and will keep any transfers outside the EEA to a necessary minimum.

By submitting your information you consent to these transfers. Data Subject Requests We are the Data Controller in respect of personal data submitted to you in respect of the Website for the purposes of the Data Protection Act 1998. If you wish to update the personal information or make a subject access request please email learn@cogito-wealth.co.uk

This Privacy Policy is subject to the Terms and Conditions for use of this Website which are situated elsewhere on the Website. Identity This Website is operated by Cogito Wealth a trading style of POYNTON RYAN LTD registered in England and Wales under number 08632043.

Its registered office and operating address is at 22 Walker Avenue, Wolverton Mill East, Milton Keynes, MK12 5TW.

Privacy Notice and Data Protection Policy Your Personal Data: What data do we need? Cogito Wealth (also referred to herein as We) is what’s known as the ‘Controller’ of the personal data you provide to us. We try and keep data collection to a minimum and only collect basic personal data which does not include any special types of information or location-based information unless a physical product is purchased.

This does, however, include name, address, telephone number, email, cookies. Why do we need it? We need to know your basic personal data to provide you with information about the Cogito Wealth training services and products. We will not collect any personal data from you we do not need to provide and oversee this service to you.

What do we do with it? All the personal data we process is processed by our staff in the UK however for the purposes of IT hosting and maintaining this information is located on servers within the European Union or the US. We do not allow 3rd parties have access to your personal data unless for the purpose of fulfilling an order placed by you.

We do not share your data with third parties outside of these purchases. You can unsubscribe at any time via phone, email or our website. All data relating to you is kept on Kartra, Gmail or GoogleDrive.

When payment or payment information is required, we will direct you to submit credit card information through a third party called Stripe. You can read more on Stripes GDPR practice by clicking HERE

We have a Data Protection system in place to oversee the effective and secure processing of your personal data. For more information on this email learn@cogito-wealth.co.uk How long do we keep it? Under a contractual basis, we are required under UK tax law to keep your basic personal data (name, address, contact details) for a minimum of 7 years after which time it will be destroyed.

The information we use for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information.

What are your rights? If at any point you believe the information we process on you is incorrect you can request to see this information and have it corrected or deleted.

If you wish to raise a complaint about how we have handled your personal data, you can contact our Data Protection Officer (DPO) who will investigate the matter. If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).

Notice—data subjects should be given notice when their data is being collected; email, name and telephone number only in most cases although postal addresses may be collected for physical products.

Purpose— data should only be used for the purpose stated and not for any other purposes; property and business growth training and physical products.

Consent—data should not be disclosed without the data subject’s consent; Your data will not be disclosed or shared with a third party.

Security—collected data should be kept secure from any potential abuses; data is secured by double password and recognised email providers.

Disclosure—data subjects should be informed as to who is collecting their data; DPO is Sarah Poynton, contactable on 07738 278545

Access— data subjects should be allowed to access their data and make corrections to any inaccurate data; Your data may be updated or changed at your request.

Accountability—data subjects should have a method available to them to hold data collectors accountable for not following the above principles.

In the first instance, please contact Keli Doorne Lawfulness, Fairness and Transparency We map data flows and hold information compliant with ICO regulations as a data controller.

We review your consent by providing an unsubscribe link on every email sent. You may withdraw your consent at any time.

Personal data can also be erased at your request at any time by sending an email to learn@cogito-wealth.co.uk The Data Protection Officer (DPO) for the organisation is Sarah Poynton Data is collected on a lawful basis for processing by Cogito Wealth.

Terms and Conditions are separate from Data Protection Policy’s supplied on each email from the business and one the www.cogito-wealth.co.uk website Opt-in boxes are used where appropriate unless data collected was from the phone call or email enquiry.

If any language is not clear, please call Sarah on 07738 278545 for clarification.

Data is specifically used to market training services and business growth services and products. You may consent separately to different types of processing wherever appropriate.

Refusing consent will not affect your statutory rights Consent is not a precondition of service. We send an initial email when data is collected – permission may be withdrawn from initial contact by you.

Data Protection – your data is protected by double passwords on all systems in the business. Your data will not be shared with a third on any occasion. Your data will not be transferred to any party outside of the EU.

The business has effective processes to identify, report, manage and resolve any personal data breaches and will be responded to within 72 hours to the data controller, Sarah Poynton.

An unsubscribe link is provided on each email sent. Collected information on unsubscribes is stored on central data and servers. Where an individual has been entered onto multiple ‘lists’, unsubscribing may be required on each.

Data is sometimes collected by unconscious means, i.e. tracking on social media. When data has been collected this way, an individual can unsubscribe at future emails by clicking the link at the bottom of the email.

Data may be collected by any of the means below. Observed, by tracking people online or by smart devices; You are able to change your preferences by changing your browser settings to disable cookies and other tracking tools. Or by limiting ad tracking and opting out. You can do that HERE. If you have any questions on how we process and control your data please contact learn@cogito-wealth.co.uk