Welcome to www.cognitivecredit.com. Cognitive Credit markets a
web-based application to global institutional credit investors (our
Cognitive Credit is committed to respecting your privacy. This privacy
policy sets out how we use and protect any information that you
provide us when you use this Application or correspond with us
"Services"). It also tells you about your privacy rights and
how certain laws may apply to you.
If you have any queries about this policy or how we use your personal
information, please contact us at
- About us
- What personal data do we collect?
- How do we collect personal data from you?
- How and why we use your personal data
- Use of external tools on our website
- How we share personal data
- International transfers
- How do we keep your information secure?
- How long we keep personal data
- Third party links
- Your rights
- Changes to this policy or your data
1. About us
This Application is operated by Cognitive Credit Limited (referred to
"us" and "our"). We are the data controller of any
information you provide to us in the course of using our Services.
Cognitive Credit is a company registered in England and Wales with its
registered office at 46 Marville Road, London, Greater London, United
Kingdom, SW6 7BD. You can contact us at this address, or by emailing
We are registered as a data controller with the UK Information
Commissioner's Office under number A8411531.
2. What personal data do we collect?
'Personal data' means any data which can be associated with you as an
individual, either directly or indirectly. We collect different
information depending on how you use our Services and how you interact
The personal data we may collect includes:
- Your identity and contact information, including your name,
your login details, email address, your organisation (if you are
accessing our Services on behalf of a company or other
organisation), and the address of that organisation, and your office
telephone number and mobile phone telephone number.
- Usage data, which includes information about how you use our
Services, including when you have logged in and out of the Services.
- Technical data, such as the device you are using to access
our Application, your unique device ID, your internet protocol (IP),
browser type and version, time zone and location, display settings,
browser plug-in types and versions, operating system and Application
and other technology on the devices you use to access our
Our Services are not intended for collecting or transmitting 'special
categories' of personal data, such as details about your race or
ethnicity, religious or philosophical beliefs, gender orientation,
political opinions, trade union membership or health information. We
do not collect data about actual or alleged criminal offences.
3. How do we collect personal data from you?
a) Personal data you provide to us
We collect personal data from you when you create an account with us,
subscribe to our Services, or interact with us in any other way (such
as via email, post, telephone or social media).
We may record or monitor calls and emails that you receive from us or
make to us. We do this for security and training purposes and to
improve the services we provide to you.
b) Personal data we collect as you use our Services
We collect your technical and usage data, as described above, as you
use our Services.
As you use the Application, we will collect technical data including
your browser type, the Internet Protocol (IP) address used to connect
your computer to the internet, and your usage habits. We collect this
data using cookies.
We use the following cookies:
|Cookie name ||What it is used for|
|CloudFlare via Amazon CloudFront ||Identifies the browser session of a given user|
|Google Analytics ||Website traffic analysis (see section 5)|
We store data locally (including via session tokens) in the browser
Application to pass on user credentials between our server and the
Application, which allows users to stay logged in. We also use
IndexedDB, which stores Application specific data, network requests,
and the user’s identification token.
If cookies are disabled you will still be able to access the
Application, however some content may not function correctly.
4. How and why we use your personal data
We will only use your information where:
a) We need the information to fulfil our contract with you.
If we have entered into a contract to provide you with our Services
(for example, if you have subscribed to our Services, whether on your
own behalf or on behalf of an organisation), we will need your
personal data in order to do so. The personal data that we use will
depend on the service(s) we have agreed. For example:
We will use your identity and contact details so that we can
communicate with you about the Services we provide, send you
software and content updates, to facilitate providing any Services
you have requested, and to respond to any requests, queries, issues
or concerns you may have.
We will use your technical information to ensure that our Services
display and function correctly on your device.
b) We have a legitimate interest (reasonable business purpose) in
We will use your information for our legitimate business reasons where
our doing so will not unduly affect your rights.
We will use your identity, contact and usage information to keep our
records up to date.
We will use your usage and technical information to:
provide and make improvements to our Services, system maintenance,
support, reporting and hosting of data, and troubleshooting;
optimise the performance of our Services;
ensure that our Services are secure;
analyse how users interact with our Services; and
develop new products and services.
We may also use any or all of the information above to administer and
manage our business in general, to detect and prevent misuse of our
Services, and to enforce our terms and conditions or any other
contract to which we may be a party. If you feel that your interests
and fundamental rights outweigh our business purposes, and that we
should therefore stop processing your data, please let us know.
c) You have given us your consent.
We ask you to consent to collecting your personal data before we
install cookies on your machine. Please see section 3b) above for
further information on the cookies we use.
d) We need to comply with a legal or regulatory obligation.
In certain circumstances, we may need to retain or use your personal
data to comply with regulations and/or the law.
5. Use of external tools on our website
We have integrated various tools from different companies into our
website, which allow us to evaluate user behavior or to establish
links with other websites.
The controller has integrated the component Google Analytics (with
anonymisation function) on this website.
Google Analytics is a web analytics service. Web analysis is the
gathering, collection and analysis of data about the behavior of
visitors to websites. Among other things, a web analysis service
collects data on which website a data subject has come to a website
from (so-called referrers), which subpages of the website were
accessed or how often and for which period of time a subpage was
viewed. A web analysis is mainly used to optimize a website and for
the cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Inc., 1600
Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA.
about your use of this website is usually transmitted to a Google
server in the USA and stored there. Google might transfer the personal
information collected via this technical procedure to third parties.
As IP anonymization is activated on our website, your IP address will
be shortened by Google within Member States of the European Union or
other states in agreement with the European Economic Area. Only in
exceptional cases, the full IP address is sent to and shortened by a
Google server in the USA. On behalf of the operator of the website,
Google will use this information to evaluate your use of the website,
compile reports on website activity and to provide further services
related to website and internet use to us. The IP address transferred
through your browser to Google Analytics will not be combined with
other data held by Google.
In addition, this website uses the Analytics feature UserID to track
interaction data. This User ID will be additionally anonymized and
encrypted and will not be linked with other data. You can prevent the
storage of cookies by a corresponding setting of your browser
software; however, please note that if you do this, you may not be
able to use all the features of this website to the fullest extent
In addition, you may prevent the collection of the data generated by
the cookie and related to your use of the website (including your IP
address) by Google as well as the processing of this data by Google by
downloading and installing the browser plug-in available under the
data and information about website visits may be transmitted to Google
In addition, a cookie already set by Google Analytics can be deleted
at any time via the Internet browser or other software programs.
Further information and Google‘s applicable privacy regulations can be
The following link provides a further explanation of Google Analytics
Our Services are not intended to be used by children under the age of
18 years, and we do not knowingly collect children's personal data.
7. How do we share your personal information?
We will share your data with our trusted third party service
providers. These include:
our information technology providers, such as our cloud storage
provider (Amazon Web Services), our web analytics service provider
(Google), and our website and mailing list hosts; and
analysts, consultants and other professional advisors whom we retain
for advice in respect of our business operations.
We will only disclose your data to third party service providers under
terms of confidentiality, and they will only use your personal data
for the purposes stated in this policy.
If you are using our Services on behalf of a company or other
organisation, we may share certain details with that company or
Your personal data may be disclosed or transferred to potential or
actual buyers of, investors into or lenders to, our business or any of
our assets, or any of the advisors or representatives of the above. If
so, we will ensure that appropriate confidentiality terms are in
On rare occasions, we may share personal data when we believe it is
necessary to comply with the law, regulation or legal request
(including a court order or government inquiry); to enforce or apply
reorganisation or restructuring exercise; or to protect the rights,
property, or safety of Cognitive Credit, our personnel, our users, or
8. International transfers
The Application is hosted on servers located within the European
Economic Area (EEA).
9. How do we keep your information secure?
We are committed to ensuring that your information is secure in order
to prevent unauthorised access or disclosure, and we have put in place
appropriate physical, electronic and managerial procedures to
safeguard and secure your information.
However no transmission of information via the Internet or electronic
storage is ever completely secure. Although we take appropriate
measures to safeguard against unauthorised disclosures of information,
we cannot guarantee the security of your data.
10. How long we keep personal data
We will only retain your personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we
consider the amount, nature, and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data
and whether we can achieve those purposes through other means, and the
applicable legal requirements.
11. Third party links
Our Application, or our other Services, may contain links to third
party sites whose information practices may be different than ours.
Please consult all third party sites' privacy notices, as we have no
control over information that is submitted to, or collected by, third
12. Your rights
You have the right to:
require us to rectify the personal data we hold about you, where
that data is incorrect;
require that we restrict the processing of your personal information
in certain circumstances;
- request access to the personal data that we hold about you;
require that, in certain circumstances, we delete the personal
information we hold about you;
require that we provide you with the information that we hold about
you in a structured, commonly used and machine-readable format;
withdraw your consent to our using your data for marketing purposes
at any time.
You also have the right to lodge a complaint with the Information
Commissioner’s Office, which is the UK supervisory authority for data
protection issues (
www.ico.org.uk ). We would, however, be grateful if you would contact us in the
first instance so we can endeavour to deal with your concerns direct.
If you wish to exercise any of these rights, please contact us at
To protect your privacy and security, we will take reasonable steps to
help verify your identity before granting access or making
13. Changes to this policy or your data
We may amend or modify this privacy notice from time to time. We will
post any revised notice on this Application, and if the changes are
significant, we will notify our members by email.
It is important that the personal data we hold about you is accurate
and current. Please keep us informed if your personal data changes
during your relationship with us.
This privacy statement was last updated on 27 September 2019.