Privacy Policy

Effective Date: 07.28.2025
Last Updated: 08.08.2025

Who we are

Cogitation Ltd is a healthcare technology company headquartered in London, United Kingdom, operating globally to provide innovative healthcare solutions. Our website address is: https://www.cogitationltd.com.

Contact Information:

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

  • Contact Information: Name, email address, phone number, postal address
  • Health Information: Health data you choose to share through our services (with explicit consent)
  • Account Information: Username, password, and account preferences
  • Professional Information: Job title, organization, professional credentials (for healthcare providers)
  • Technical Information: IP address, browser type, device information, usage patterns

2.2 How We Collect Information

  • Directly from you: When you create an account, fill out forms, or contact us
  • Automatically: Through cookies, analytics tools, and similar technologies
  • From third parties: With your consent, from healthcare providers or integration partners

3. How We Use Your Information

We use your personal information for the following purposes:

  • Service Provision: To provide, maintain, and improve our health technology services
  • Communication: To respond to inquiries, provide customer support, and send service updates
  • Health Services: To deliver personalized health insights and recommendations (with explicit consent)
  • Compliance: To comply with legal obligations and regulatory requirements
  • Security: To protect against fraud, unauthorized access, and security threats
  • Research: To conduct anonymized research for improving healthcare outcomes (with appropriate safeguards)

4. Legal Basis for Processing (GDPR)

We process your personal data based on:

  • Consent: For health data and marketing communications
  • Contract: To provide services you’ve requested
  • Legitimate Interest: For service improvement, security, and business operations
  • Legal Obligation: To comply with healthcare regulations and legal requirements

5. Data Sharing and Disclosure

5.1 We may share your information with:

  • Healthcare Providers: With your explicit consent, for care coordination
  • Service Providers: Third-party vendors who assist in service delivery (under strict data protection agreements)
  • Legal Authorities: When required by law or to protect rights and safety
  • Business Partners: For integrated services (with your consent)

5.2 We do not:

  • Sell your personal information to third parties
  • Share health information without explicit consent
  • Use your data for advertising by third parties

6. International Data Transfers

As a UK-based company operating globally, we may transfer your data internationally. We ensure adequate protection through:

  • Adequacy Decisions: Transferring to countries with adequate data protection laws
  • Standard Contractual Clauses: Using EU/UK-approved contractual protections
  • Certification Schemes: Partnering with certified service providers

7. Data Security

We implement comprehensive security measures including:

  • Encryption: Data encryption in transit and at rest
  • Access Controls: Role-based access with multi-factor authentication
  • Regular Audits: Security assessments and compliance reviews
  • Staff Training: Regular data protection training for all personnel
  • Incident Response: Procedures for handling potential data breaches

8. Cookies and Similar Technologies

8.1 Types of Cookies:

  • Essential Cookies: Required for website functionality
  • Analytics Cookies: To understand website usage (anonymized)
  • Preference Cookies: To remember your settings and preferences
  • Security Cookies: To protect against unauthorized access

8.2 Managing Cookies:

  • You can control cookies through your browser settings. Note that disabling certain cookies may affect website functionality.
  • If you fill up form on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
  • If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
  • When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

9. Data Retention

We retain your data for as long as necessary to:

  • Provide our services and support your account
  • Comply with legal and regulatory requirements
  • Fulfill the purposes outlined in this policy

Specific Retention Periods:

  • Account Data: Retained while your account is active plus 7 years after closure
  • Health Data: Retained according to healthcare regulations (typically 7-25 years)
  • Communication Records: 3 years from last interaction
  • Analytics Data: 2 years in anonymized form

10. Your Rights

Under applicable data protection laws, you have the right to:

  • Access: Request copies of your personal data
  • Rectification: Correct inaccurate or incomplete data
  • Erasure: Request deletion of your data (subject to legal requirements)
  • Portability: Receive your data in a structured, machine-readable format
  • Restriction: Limit how we process your data
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: For consent-based processing

To exercise these rights, contact us at privacy@cogitationltd.com.

11. Children’s Privacy

Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal information from children under 16 without parental consent.

12. Health Data Special Protections

For health-related information, we implement additional protections:

  • Explicit Consent: Clear, informed consent for health data processing
  • Purpose Limitation: Health data used only for specified healthcare purposes
  • Enhanced Security: Additional encryption and access controls
  • Professional Standards: Compliance with medical confidentiality requirements

13. Data Protection Officer

Our Data Protection Officer can be contacted at:

14. Complaints

If you have concerns about how we handle your personal data, you can:

  1. Contact us directly at privacy@cogitationltd.com
  2. File a complaint with your local data protection authority:
    • UK: Information Commissioner’s Office (ICO) – ico.org.uk
    • EU: Your national data protection authority

15. Changes to This Policy

We may update this privacy policy periodically. We will notify you of significant changes by:

  • Email notification to registered users
  • Prominent notice on our website
  • In-app notifications where applicable

16. Contact Us

For any questions about this privacy policy or our data practices:

Cogitation Ltd
Email: privacy@cogitationltd.com
Address: London, UK

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