Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how personal data is collected and processed when you visit or browse cogniveil.ai, interact with pages or content on the website, submit a contact, demo, business enquiry or similar website form, or consent to the use of analytics, measurement or advertising technologies.

This Privacy Policy applies to the public-facing Cogniveil website.

It does not govern personal data processed within the Cogniveil platform or services on behalf of Cogniveil customers. Such processing may be governed by separate contractual terms, data processing agreements, customer privacy documentation or other applicable notices.

2. Who is responsible for your personal data?

The data controller responsible for the processing described in this Privacy Policy is:

TheFutureCats Advisory S.A.

trading through the Cogniveil brand

Registered office: 56 Panepistimiou St. 10678 Athens, Greece

G.E.MI. / Registration No.: 162496006000

Country: Greece

Privacy contact: privacy@cogniveil.ai

In this Privacy Policy, references to “Cogniveil”, “we”, “us” or “our” mean the above entity.

For questions concerning this Privacy Policy or the exercise of data protection rights, you may contact us using the details above.

3. Personal data we may collect

The personal data we process depends on how you interact with the website.

3.1 Information you provide directly

If you submit a contact form, request information, book a demonstration, or otherwise communicate with us, we may process various types of information, including your name, business email address, and any telephone number you choose to provide. We may also collect details about your company or organisation, professional role or job title, and country or business location, if requested. Additionally, we may process the content of your message or enquiry, information regarding your organisation's interest in Cogniveil, our correspondence and subsequent communications, as well as any other information you choose to provide.

Please do not submit special-category or highly sensitive personal data through ordinary website enquiry forms unless specifically requested by Cogniveil for a legitimate and identified purpose.

3.2 Technical and website information

When you access the website, limited technical information may necessarily be processed by our hosting, network and security infrastructure in order to deliver the website and maintain its security.

Depending on the circumstances, this may include your IP address, date and time of access, browser and device information, operating system, requested URL, referring URL, technical error and security information, and server or network logs.

We use such information only to the extent necessary for website delivery, security, fraud prevention, troubleshooting, system integrity and related legitimate operational purposes.

3.3 Analytics and advertising information

We do not activate optional analytics or advertising tracking before you provide consent.

If you choose to accept optional tracking, information relating to your use of the website may be collected through technologies operated by Google Analytics, Meta, LinkedIn and HubSpot.

Depending on the technology and your browser, this information may include browser or device identifiers, cookie or similar identifiers, pages viewed, page interactions, approximate visit timing and duration, navigation path through the website, referring source, advertising or campaign attribution information, conversion events, interactions with website content, repeat visits, and information connecting website activity with a business enquiry where you subsequently identify yourself and have consented to the relevant tracking.

We do not intentionally use these technologies to collect sensitive personal data through the Cogniveil website.

4. Why we process personal data and our legal bases

We process personal data only where we have an appropriate legal basis.

Website operation and security

We process limited technical data to operate, secure and maintain the website, protect against misuse, investigate technical incidents and ensure the integrity of our systems.

Legal basis: our legitimate interests under Article 6(1)(f) GDPR in operating and protecting our website and digital infrastructure.

Responding to enquiries and demo requests

Where you contact us regarding Cogniveil, request information, ask for a demonstration or initiate discussions concerning our products or services, we process the information necessary to respond and manage the relationship.

Depending on the circumstances, the legal basis is:

Article 6(1)(b) GDPR, where processing is necessary in order to take steps at your request before entering into a contract; or

Article 6(1)(f) GDPR, where we have a legitimate interest in receiving and responding to legitimate business enquiries and communicating with representatives of organisations interested in Cogniveil.

Compliance with legal obligations and protection of legal interests

We may retain or process information where necessary to comply with applicable legal, regulatory, accounting or other obligations or to establish, exercise or defend legal claims.

Legal basis: Article 6(1)(c) GDPR and, where applicable, Article 6(1)(f) GDPR.

Website analytics

If you consent, we use analytics technologies to understand how visitors use the website, how they move between pages, which content performs effectively and how the website can be improved.

Legal basis: your consent under Article 6(1)(a) GDPR and the applicable rules governing the storage of or access to information on a user's terminal equipment.

Advertising measurement and attribution

If you consent, we may use advertising and measurement technologies to understand whether advertising campaigns result in visits or enquiries, measure campaign effectiveness and obtain audience and attribution insights.

Legal basis: your consent under Article 6(1)(a) GDPR and the applicable rules governing tracking technologies.

You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Cookies, local storage and similar technologies

The website distinguishes between strictly necessary storage and optional tracking technologies.

5.1 Storage used before consent

Before you consent to optional tracking, Cogniveil uses a local browser storage item called:

cogniveil-cookie-consent

Its sole purpose is to:

This storage mechanism is not used for advertising, behavioural profiling, traffic analysis or cross-site tracking.

Because it is required to remember and implement your privacy choice, it is treated as strictly necessary.

We recommend that the consent choice be retained for six months, unless you change your preference or clear your browser storage earlier, after which the website may ask you to make a new choice.

5.2 No optional tracking before consent

Unless you actively consent, Cogniveil's optional analytics and advertising technologies are configured not to activate.

In particular, declining optional tracking does not prevent you from:

Where you submit a form without accepting optional tracking, we process the information contained in the form in order to respond to you, but optional browser tracking identifiers are not intentionally attached to that enquiry.

5.3 Optional technologies used after consent

If you provide consent, the following technologies may be activated.

Provider / Technology

Purpose

Typical identifiers

Typical duration

Google Analytics 4

Website traffic analysis, page usage, engagement and visitor journey analysis

_ga, _ga_<container-id>

Up to approximately 2 years, subject to browser and provider limitations

Meta / Facebook Pixel

Advertising performance, conversion measurement and campaign attribution

_fbp and, where applicable, _fbc

Approximately 3 months

LinkedIn Insight Tag

Campaign measurement, conversion attribution and audience insights

May include li_fat_id, bcookie, bscookie, lidc, AnalyticsSyncHistory and UserMatchHistory

Depending on the identifier, from the browser session or approximately one day up to approximately one year

HubSpot

Website analytics, visitor journey measurement, form-related analytics and, where consent has been given, association of website activity with an identified business enquiry

May include hubspotutk, __hstc, __hssc, __hssrc and related consent or analytics technologies

Depending on the identifier, from the browser session or approximately 30 minutes up to approximately 6 months

Cookie names, technical identifiers and retention periods may occasionally change as providers update their technologies or as browser restrictions change. Cogniveil will periodically review its tracking configuration and update this Policy where material changes occur.

• remember whether you accepted or rejected optional tracking
• record when that choice was made and
• enable the website to respect that choice on subsequent pages or visits.
• browsing the website
• accessing its ordinary content or
• submitting a Cogniveil contact, demo or business enquiry form.

6. Google Tag Manager

Cogniveil uses Google Tag Manager (“GTM”) as a technical tag-management mechanism.

GTM enables Cogniveil to manage the deployment of technologies such as Google Analytics, Meta Pixel and LinkedIn Insight Tag.

GTM is not used by Cogniveil as an independent advertising purpose in itself.

Our intended configuration is based on prior consent blocking: optional analytics and advertising tags must remain inactive until the visitor has provided the relevant consent.

Where consent is refused, optional analytics and advertising tags should remain blocked.

7. HubSpot and website enquiries

Cogniveil may use HubSpot to manage website analytics, enquiry journeys and business communications.

A distinction is made between:

the information you intentionally provide in a form, and optional behavioural tracking of your activity on the website. Submitting a business enquiry does not require you to consent to optional tracking.

If tracking has been declined, the information you voluntarily submit may still be transmitted to and processed through HubSpot so that Cogniveil can receive, manage and respond to the enquiry. However, Cogniveil's intended configuration is that optional tracking identifiers and browsing history are not associated with that submission unless the relevant tracking consent has been provided.

Where tracking has been accepted, HubSpot may use a browser identifier to recognise visits and may associate the consenting visitor's previous or subsequent website journey with a contact record after the visitor identifies themselves through a form.

8. Consent and your choices

When you first visit the website, you are given a choice regarding optional analytics and advertising technologies.

You may:

Accept optional tracking; Reject optional tracking; or manage your preferences, where separate categories are offered.

No optional tracking should be treated as accepted merely because you continue browsing, scroll through a page, close the consent interface or fail to make a selection.

You may withdraw or change your consent at any time using the “Cookie Settings” or equivalent privacy preference control made available on the website.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Where technically possible, withdrawing consent will prevent further use of the relevant optional technologies and will remove first-party cookies or identifiers controlled through the Cogniveil consent mechanism. Certain identifiers previously placed by third parties may also need to be managed through your browser or through the relevant provider's privacy settings.

9. Who may receive personal data?

Personal data may be disclosed, strictly to the extent necessary for the relevant purpose, to categories of recipients including:

We do not disclose personal data to third-party advertising or analytics providers through the optional website tracking technologies described above unless the relevant consent requirements have been satisfied.

• website hosting, infrastructure and security providers
• cloud and technology service providers
• HubSpot and related CRM or business communication service providers
• Google in connection with Google Analytics and tag-management services where applicable
• Meta in connection with Meta Pixel where consent has been given
• LinkedIn in connection with LinkedIn Insight Tag where consent has been given
• professional advisers, auditors or legal advisers where necessary
• public authorities, courts or regulatory bodies where disclosure is legally required and
• other service providers acting on our behalf under appropriate contractual and data protection obligations.

10. International transfers

Some of the technology providers used by Cogniveil operate internationally and may process personal data outside Greece or the European Economic Area (“EEA”), including in the United States.

Where personal data is transferred outside the EEA, Cogniveil seeks to ensure that the transfer is made in accordance with Chapter V of the GDPR.

Depending on the recipient and destination, the applicable transfer mechanism may include:

Further information about safeguards relevant to a specific transfer may be requested from Cogniveil using the contact details in this Policy.

• an adequacy decision adopted by the European Commission or
• appropriate safeguards such as the European Commission's Standard Contractual Clauses (“SCCs”), together with supplementary measures where required.

11. How long we keep personal data

Cogniveil does not retain personal data for longer than reasonably necessary for the purposes for which it was collected.

Retention depends on the type of information and the relevant processing purpose.

Website consent preferences are intended to be retained for approximately six months, unless changed or deleted earlier by the visitor.

Cookies and similar identifiers are retained for the periods described in this Policy or for shorter periods imposed by browser settings, user deletion or provider configuration.

Information submitted through a business enquiry is retained for as long as reasonably necessary to respond to and manage the enquiry and, where appropriate, subsequent commercial discussions.

Recommended internal retention rule: where an enquiry does not result in an ongoing customer, partner or other business relationship, Cogniveil should ordinarily delete or anonymise the enquiry data no later than 24 months after the last substantive interaction, unless there is a legitimate reason or legal requirement to retain it for longer.

Where an enquiry develops into a contractual or other ongoing business relationship, information may be retained for the duration of that relationship and subsequently for any period required by applicable legal, accounting, contractual or limitation requirements.

Technical and security information is retained only for an appropriate period having regard to the operational, security and legal purpose for which it was collected.

12. Security

Cogniveil applies appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or other unlawful processing.

Measures are selected having regard to the nature of the processing, the available technology and the risks presented by the processing.

However, no internet transmission or information system can be guaranteed to be completely secure.

13. Your rights

Subject to the conditions and limitations provided by applicable data protection law, you may have the right to:

Where you object to processing based on our legitimate interests, we will cease the relevant processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or processing is required for the establishment, exercise or defence of legal claims.

To exercise your rights, contact:

privacy@cogniveil.ai

We may request information reasonably necessary to verify your identity before responding to a request.

• request confirmation as to whether Cogniveil processes personal data concerning you
• access your personal data
• request correction of inaccurate or incomplete personal data
• request deletion of personal data
• request restriction of processing
• object to processing based on legitimate interests
• receive certain personal data in a structured, commonly used and machine-readable format and, where applicable, request its transmission to another controller
• withdraw consent at any time where processing is based on consent and
• lodge a complaint with a competent data protection supervisory authority.

14. Complaints and supervisory authority

If you have concerns about the way Cogniveil processes your personal data, we encourage you to contact us first so that we can investigate and respond.

You also have the right to lodge a complaint with the competent supervisory authority.

For a controller established in Greece, the competent supervisory authority is:

Hellenic Data Protection Authority Athens, Greece (ΑΠΔΠΧ)

You may also contact another competent supervisory authority where the GDPR permits you to do so.

15. Automated decision-making

Cogniveil does not use the tracking technologies described in this Privacy Policy to make decisions concerning website visitors that are based solely on automated processing and produce legal effects or similarly significant effects on them.

Analytics and advertising technologies may contribute to statistical analysis, audience measurement or advertising attribution, but they are not used by Cogniveil through this website to make legally or similarly significant automated decisions about individual visitors.

16. Children's privacy

The Cogniveil website is primarily intended for businesses, organisations and professional users.

It is not directed at children, and Cogniveil does not knowingly seek to collect personal data from children through ordinary website forms or tracking technologies.

If we become aware that personal data has been submitted by a child in circumstances where its processing is not appropriate, we will take reasonable steps to delete or otherwise address the information.

17. Third-party websites

The Cogniveil website may contain links to websites, platforms or services operated by third parties.

Cogniveil is not responsible for the privacy practices of independent third-party websites. When you leave cogniveil.ai, you should review the privacy information provided by the relevant third party.

18. Changes to this Privacy Policy

We may update this Privacy Policy where necessary to reflect changes to our website or services, our technologies, or our processing activities. Additionally, we may update it to address legal or regulatory developments or changes in guidance issued by competent authorities.

The most recent version will be made available on cogniveil.ai and will show its latest update date.

Where a change materially affects processing based on consent, Cogniveil will obtain a new consent where required.

19. Contact

For questions about this Privacy Policy, the processing of personal data through cogniveil.ai or the exercise of your rights, please contact:

TheFutureCats Advisory S.A. / Cogniveil

Address: 56 Panepistimiou St. 10678 Athens, Greece

Email: privacy@cogniveil.ai