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1. Personally identifiable information (‘Personal Data’) is held only for as long as required to
meet the service provided and in accordance with our retention schedule
2. All personal data supplied to Intuitive Learning Limited (trading as Cognexo) (‘We’, ‘Us’ and ‘Our’) is held securely.
3. Intuitive Learning Limited complies with the Data Protection Act (2018) and the General Data Protection Regulation (UK).
4. Personal Data submitted to Intuitive Learning Limited remains confidential and is used only for the purposes set out in this Privacy
Policy.
5. The Intuitive Learning website (www.cognexo.com) does not use cookies to collect personally identifiable information about you.
By using the Service, you (‘User’) are accepting the terms of this Privacy Policy. In the event of a conflict between the terms of this
Privacy Policy and the customer contract, the Customer contract will prevail.
Intuitive Learning Limited (trading as Cognexo) (Company No: 10605207) is a UK-based private limited company that specialises
in learning and development software.
We are registered as a Data Controller within the requirements of the Data Protection Act (2018) (Reg No. ZA297048).
Cognexo is a micro learning application that uses the power of AI and gamification to help our customers' employees to
understand, reinforce and retain their learning and knowledge.
You have the following rights regarding your Personal Data:
Access – request a copy of your Personal Data
Rectification – request corrections to inaccurate data
Erasure – request deletion of your data (“right to be forgotten”)
Restriction – request limits on how we process your data
Portability – request transfer of your data to another provider
Objection – object to processing based on Legitimate Interests
Withdraw consent – where consent is relied upon (e.g. marketing)
Requests can be made by emailing hello@cognexo.com. We respond within one month.
Your employer or organisation you are affiliated to has appointed Intuitive Learning Limited to provide learning and development
software.
We only collect personal (non-sensitive) data that is essential to our operation as a business and which allows us to support
learning, monitor and report on progress and fulfil our contractual obligations to our customers. We have reviewed all the GDPR
Article Six options for lawful data processing and have identified Our lawful basis for processing is Legitimate Interests (UK GDPR
Article 6(1)(f)), as the processing is necessary to deliver our service to organisations.
Where required (e.g. for direct marketing), we may also rely on Consent (f) or Legal Obligation (c).
Intuitive Learning Limited treat data security extremely seriously and ensure that access to the information is very tightly
controlled. We design our processing with users in mind from the outset, and use a data protection by design and by default
approach. The Intuitive Learning Limited database (which holds personal data) is held electronically on secure cloud servers
(AWS). All data is stored in the AWS EU-WEST-2 region, which is London. All failover sites are within this region. Access to data is
only available to named authorised users via secure login using user name and password to the named account only, which is
issued by Intuitive Learning Limited.
Security measures include:
Encryption of devices and databases
Controlled access for named authorised users
Data protection by design and by default
Prohibition on the use of removable storage
Monitoring and investigation of any security incidents
Any security incident, or near miss, will be investigated as per our data breach procedure.
Absolutely not. Under the contractual agreement between Intuitive Learning Limited and your employer or organisation you are
affiliated to, Intuitive Learning Limited cannot use any personal data that we hold for any other purpose than is contractually
agreed. The contract terms also mean that no personal data can be sold to any other parties. In effect, the personal data cannot
be misused or abused. Were we to misuse or abuse the terms of our contracts, we would risk losing our customers. Any such
breach of trust would lead to Intuitive Learning Limited Data Protection Licence (Reg No. ZA297048) being revoked.
Under the agreement between your employer and Intuitive Learning Limited, we process personal data about our clients,
employees, suppliers and individuals necessary for software development.
Contact details (e.g. business or personal email address)
Employment details (e.g. job role, department, division)
Information necessary for the development and test of software.
Internet Protocol (IP) address and technical usage information
Data relating (i.e. answers given) to Cognexo questions.
We do not collect special category (sensitive) data
Our services are designed for use by organisations and are not intended for children under 16. We do not knowingly process
children’s data without parental or guardian consent.
We will only use information held about you for the following purposes:
To provide, maintain, and improve our services
To deliver learning content and monitor progress
To respond to customer and user enquiries
To notify customers and users about service changes
To fulfil our contractual obligations
We do not sell or misuse Personal Data.
We are committed to protecting and respecting your privacy.
We do not use cookies to collect personally identifiable information about you. If we use non-essential cookies (e.g. analytics), we
will request your consent via a cookie banner and provide details in a separate Cookie Policy.
We do not use fully automated decision making. We use gamification features to deliver tailored learning recommendations that
does not have legal or significant effects on individuals.
We retain Personal Data only for as long as necessary to provide our services and to comply with legal or contractual obligations.
Active user accounts: retained while your employer’s contract is active
Inactive accounts (when a user leaves an organisation): deleted within 90 days of notification
Customer contract data: retained for up to 7 years for legal and tax purposes
Marketing contact details: retained until data subject unsubscribes or opts-out
Yes – under data protection rules, you can request Intuitive Learning Limited to make available all information held about you
personally. Intuitive Learning Limited may charge for this request.
Your employer or organisation you are affiliated to will inform Intuitive Learning Limited and we will delete your personal data from
our records and any requests for information will cease as per our data retention policy.
If you wish to withdraw your consent for us to hold your data, please notify your employer or contact us on hello@cognexo.com
We sometimes need to share the personal data we process with the individual and also with their employer or organisation they
may be affiliated to (e.g. an organisation an individual may be carrying out contract work for). Where this is necessary, we are
required to comply with all aspects of the Data Protection Act (2018) and the General Data Protection Regulation (UK).
What follows is a description of the types of organisations we may need to share some of the personal data we process with for
one or more reasons.
Where necessary or required we share personal data with:
Representatives of the organisation whose personal data we are processing
A named organisation specified by the representatives of the organization
Third-party service providers (e.g. AWS, support tools) who act as data processors under strict contractual obligations
Representatives you authorise us to communicate with
We do not share data for unrelated third-party marketing.
We normally store and process data in the UK/EEA. It may sometimes be necessary to transfer personal data overseas. When
this is needed information is only shared within the European Economic Area (EEA), unless stated in customer contracts. Any
transfers made will be in full compliance with all aspects of the Data Protection Act (2018) and the General Data Protection
Regulation (UK).
We will ensure appropriate safeguards are in place, such as:
UK International Data Transfer Agreements (IDTAs)
EU Standard Contractual Clauses (SCCs)
Adequacy regulations recognised by the UK government
We only contact individuals (via email, phone, post or other mode of communication) within organisations that we believe, based
on their job role, are likely to be interested in our service and have not previously opted-out of receiving communication from
businesses. We do this in line with our legitimate interest (UK GDPR Article 6(1)(f)) to grow our business and PECR regulations.
Where requested, we will remove individuals from all mailing lists. You can opt out at any time by contacting us at
hello@cognexo.com
We reserve the right to amend this Privacy Policy at any time and any updated Privacy Policy will be posted on our website and
notified to you by email, where appropriate.
If you have concerns about how we use your Personal Data, please contact us at hello@cognexo.com.
You also have the right to lodge a complaint directly with the UK Information Commissioner’s Office (ICO): https://ico.org.uk/make-
a-complaint/
Cognexo is the trading name of Intuitive Learning Limited.
Intuitive Learning Limited is a company registered in England and Wales whose company number is 10605207 and whose
registered address is Cognexo, Platform, Office 3.02, New Station Street, Leeds, LS1 4JB
Intuitive Learning Limited is registered as a Data Controller within the requirements of the Data Protection Act (Reg No.
ZA297048).
