Privacy Policy and Cookie Notice
Cognitrio LLC ("Cognitrio," "we," "us," or "our") respects your privacy and is committed to protecting personal data.
This Privacy Policy explains how we collect, use, disclose, and protect personal data when you:
- (a) visit or interact with our websites; or
- (b) contact us, request information, book a consultation, attend a consultation, or apply for a role via our Website.
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1. DOMAINS AND SCOPE
This Privacy Policy applies to:
- (a) cognitrio.com and cognitrio.co.uk;
- (b) any subdomains associated with those domains (for example, portal.cognitrio.com or careers.cognitrio.com); and
- (c) any other website or web page operated by Cognitrio that expressly links to this Privacy Policy (collectively, the "Website").
If you later become a Cognitrio customer under a signed services agreement, additional privacy and data handling terms may apply to customer data processed under that agreement.
2. BUSINESS USERS; IMPORTANT UK NOTICE
Business users: The Website is intended for business and professional users. Data protection laws (including the UK GDPR) still protect individuals, including employees and representatives engaging with us in a professional capacity.
UK notice (international processing): Cognitrio is established in the United States. Personal data collected via the Website, consultations, and recruitment is processed and stored in the United States. See Section 12 (International Transfers).
3. WHO WE ARE (CONTROLLER) AND HOW TO CONTACT US
Controller: Cognitrio LLC
USA Mailing Address:
135 W 41st, New York, NY 10036, USA
UK Mailing Address:
167-169 Great Portland Street, London, W1W 5PF, United Kingdom
Email: legal@cognitrio.com
For the purposes of the UK General Data Protection Regulation ("UK GDPR"), Cognitrio LLC is the controller of personal data processed in connection with the Website, inquiries, recruitment, and consultations, unless a separate written agreement states otherwise.
4. PERSONAL DATA WE COLLECT
We collect (A) data you provide and (B) data collected automatically when you use the Website.
A) Personal data you provide
Inquiries and consultation booking:
- Identity and business contact data: first and last name, company name, job title/role, work email address, and optional phone number
- Consultation/booking details: requested date/time and scheduling details, and information you provide about goals, context, and topics you want to cover
- Communications: the content of messages you send us via forms or email (including attachments you choose to provide)
AI-assisted booking workflow (transcripts + structured fields):
If you interact with our automated booking workflow (including an AI-assisted agent), we may collect:
- conversation transcripts from the booking interaction; and
- structured fields you provide or that are extracted during the interaction (e.g., goals, preferred times, constraints).
Initial consultations (audio/video recordings, transcripts, AI notes):
Where enabled and with appropriate notice (and consent where required), we may record audio and video of initial consultations and generate:
- audio/video recording files;
- transcripts; and
- AI-generated notes and summaries, action items, and follow-up materials derived from the consultation.
Careers and recruitment:
We currently only accept applications for New York City-based roles. If you apply via our Careers section or email careers@cognitrio.com for a New York City-based role, we may collect:
To support data minimization, please do not submit application materials unless you are applying for a New York City-based role.
- CV/resume and cover letter;
- employment and education history;
- portfolio links and LinkedIn URL (if provided); and
- any other information you choose to submit as part of your application.
B) Personal data collected automatically
When you use the Website, we (and our service providers) may automatically collect:
- Device and browser data: IP address, approximate region (derived from IP), browser type and settings, operating system, device type, and user agent
- Usage data: pages viewed, time and date of visits, interactions with the Website, and referring/source pages
- Security and diagnostic data: logs and signals used to detect abuse, spam, fraud, or security incidents
Bot protection:
We use Google reCAPTCHA Enterprise to help protect the Website from spam and abuse. reCAPTCHA Enterprise may process device and browser signals and related data for risk analysis and abuse prevention.
5. SENSITIVE DATA / SPECIAL CATEGORY DATA
We do not ask for sensitive personal data (such as health information, biometric identifiers used for identification, or precise location data) through the Website.
Please do not submit:
- Protected Health Information (PHI) or medical information;
- special category data; or
- trade secrets or other highly confidential information
through Website forms, booking flows, or standard application channels, unless we have expressly agreed in writing and provided a secure method for doing so.
6. HOW WE USE PERSONAL DATA
We use personal data for the following purposes:
A) Provide and operate the Website
- to deliver Website content, maintain functionality, and improve performance.
B) Respond to inquiries and take steps at your request
- to respond to your messages, provide requested information, schedule and manage consultations, and discuss potential engagements.
C) Operate the booking workflow (including AI-assisted scheduling)
- to capture the information you provide, generate a booking transcript (where applicable), propose or schedule meeting times, and maintain booking records.
D) Conduct and document initial consultations (including recordings where enabled)
- to hold the consultation, create accurate notes/records, generate transcripts and summaries, prepare follow-up materials, and support internal planning and quality review;
- to use consultation outputs (including notes/summaries) for legitimate business development and prospecting follow-up related to your inquiry.
E) Security, abuse prevention, and fraud detection
- to protect the Website and our business, prevent spam and abuse, and investigate suspicious activity (including via reCAPTCHA Enterprise).
F) Analytics (basic traffic measurement)
- to understand how visitors use the Website and improve Website performance and content.
We do not use Google Analytics advertising features (such as remarketing or Google Signals) for targeted advertising.
G) Recruitment and hiring
- to process applications for New York City-based roles, communicate with candidates, evaluate suitability, and manage our hiring pipeline (including via our internal applicant tracking system).
H) Legal and compliance
- to comply with legal obligations, enforce our Terms of Use, and establish, exercise, or defend legal claims.
7. LEGAL BASES (UK GDPR)
Where the UK GDPR applies, we rely on one or more of the following legal bases depending on context:
- Legitimate interests: for operating the Website, responding to business inquiries, maintaining security, preventing fraud/abuse, improving the Website, managing recruitment, and maintaining business records (balanced against your rights and expectations).
- Taking steps at your request prior to entering a contract: for scheduling and managing consultations and communicating about potential services.
- Consent: where required by law, such as for non-essential cookies (e.g., analytics cookies), and where we request consent for certain optional activities (such as consultation recording where applicable).
- Legal obligation: where we must comply with applicable laws.
If you choose not to provide certain information (for example, required booking fields), we may be unable to schedule a consultation or respond effectively.
10. DATA SECURITY
We implement industry-standard technical and organizational safeguards, including encryption, access controls, and least-privilege practices, to protect personal data from unauthorized access, loss, misuse, alteration, or disclosure.
11. DATA RETENTION
We retain personal data only as long as necessary for the purposes described in this Policy.
Standard retention (Website, prospecting, recruitment, and consultations):
- Website inquiries and related communications: up to twelve (12) months
- Consultation booking records, booking transcripts, and structured fields: up to twelve (12) months
- Recorded initial consultations (audio/video), transcripts, and AI-generated notes/summaries: up to twelve (12) months
- Job applications (including CV/resume and related communications): up to twelve (12) months after the hiring decision
We may retain certain records longer where necessary to comply with legal obligations, resolve disputes, or establish, exercise, or defend legal claims.
12. INTERNATIONAL TRANSFERS (UK)
Cognitrio is based in the United States and processes and stores personal data in the United States. If you are located in the UK, this means your personal data is transferred to and processed in a country outside the UK.
Where UK transfer rules apply, we use appropriate safeguards as required by law, such as the UK International Data Transfer Addendum to the EU Standard Contractual Clauses (or another UK-approved transfer mechanism), as appropriate for transfers to service providers.
13. YOUR RIGHTS (UK)
If you are located in the UK, you may have rights including:
- Access
- Rectification
- Erasure
- Restriction
- Objection (including to direct marketing and certain legitimate interests processing)
- Data portability (in certain circumstances)
- Withdrawal of consent (where processing is based on consent, such as analytics cookies and, where applicable, consultation recording)
To exercise these rights, contact legal@cognitrio.com. We may request information to verify your identity.
You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO): https://ico.org.uk/
14. U.S. STATE PRIVACY DISCLOSURES
Depending on your U.S. state of residence, you may have privacy rights under applicable state law. Based on our current revenue levels, we may not be subject to certain comprehensive state privacy laws that apply above specific revenue thresholds.
Even where those laws may not apply, we respect your privacy and will consider verifiable requests to access, correct, or delete your personal data. You can submit a request by contacting legal@cognitrio.com.
Our Website currently does not respond to browser "Do Not Track" (DNT) or Global Privacy Control (GPC) signals where we are not required by applicable law to do so.
We do not sell or share personal information (as defined by applicable state laws) and do not use personal information for targeted advertising; therefore, GPC signals do not change how we process personal data at this time.
15. CONSULTATION RECORDINGS - NOTICE AND CHOICES
Where we record initial consultations, we will provide notice (for example, in the meeting invitation, at the start of the call, or both). If you do not want a consultation to be recorded, you may request a non-recorded consultation by contacting us at legal@cognitrio.com. We will attempt to accommodate where feasible.
16. AUTOMATED PROCESSING
Our booking workflow and consultation processing may use automated tools (including AI) to help capture information you provide, generate transcripts, summarize discussions, and create internal notes.
We do not use these processes to make solely automated decisions that produce legal or similarly significant effects on you.
17. THIRD-PARTY LINKS
The Website may link to third-party websites (e.g., LinkedIn). We are not responsible for their privacy practices. Please review their privacy policies before providing personal data.
18. CHILDREN
The Website is intended for Business Users and is not directed to children. We do not knowingly collect personal data from children under 18. If we learn we have collected personal data from a child, we will take steps to delete it.
19. UK REPRESENTATIVE (UK GDPR ARTICLE 27)
Cognitrio LLC is established outside the United Kingdom and may process personal data of individuals in the UK in connection with the Website. We have appointed a UK representative under Article 27 of the UK GDPR.
UK Representative: C. Koh
Address: 167-169 Great Portland Street, London, W1W 5PF, United Kingdom
Email: legal@cognitrio.com
Phone: 020 30512 990 (international: +44 20 30512 990)
20. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. The "Last Updated" date indicates when changes are made. Continued use of the Website after updates are posted means you acknowledge the updated Policy.
21. CONTACT US
Questions, requests, or concerns: legal@cognitrio.com
Mail:
Cognitrio LLC, 135 W 41st, New York, NY 10036, USA