Privacy notice
Privacy notice
This notice covers the cogentbase.ai website only. The site sets no cookies and runs no analytics, and the only personal data we hold about a visitor is what that visitor sends us.
Who we are and what this notice covers
Cogent Base Ltd. is a private company registered in the Astana International Financial Centre (AIFC), Republic of Kazakhstan, BIN 260740901499. We are the controller of the personal data described in this notice.
This notice covers the cogentbase.ai website and the enquiries people send us through it.
It does not cover documents or data a client gives us to process. Those are governed by the engagement contract and the data processing agreement signed with that client, not by this notice. Where we deploy our software for a client, it runs inside the environment agreed with that client.
The governing framework is the AIFC Data Protection Regulations No. 10 of 2017 and the AIFC Data Protection Rules No. 1 of 2018.
What we collect, why, and for how long
We collect three things, and nothing else.
| Information | Where it comes from | Why we use it | How long we keep it |
|---|---|---|---|
| Name, firm, role, email address | The demo request form on cogentbase.ai | To reply to you and arrange a briefing | 24 months after our last contact with you, unless we enter into an engagement |
| The content of your emails to us and our replies | Email correspondence | To answer your enquiry and discuss a possible engagement | 24 months after our last contact with you, unless we enter into an engagement |
| IP address, browser type, pages requested, date and time | Technical logs kept automatically by our hosting and content delivery providers | To deliver the site and protect it from attack and abuse | Under those providers’ own retention periods; we do not copy these logs into our systems or use them to identify visitors |
We use this information because you asked us to respond to you, to take steps towards a possible engagement at your request, and because we have a legitimate interest in running and protecting our own website. You are not obliged to give us anything; if you do not complete the form, write to us instead.
If you send us sample or illustrative documents while we are talking, we will tell you before we open them what we will do with them and when we will delete them. Do not send us confidential client material before an agreement is in place.
What we do not do
This site is deliberately plain. We think the shortest privacy notice is the one with the least to explain.
- The site sets no cookies. There is no analytics, no tag manager, no advertising pixel, no session recording and no cross-site tracking.
- All fonts, scripts and styles are served from our own domain. Loading the site does not send your IP address to a third-party font or script provider.
- We do not use anything collected through this website to train, fine-tune or evaluate any model.
- We do not sell personal data, and we do not share it with anyone for advertising or marketing.
- We do not make automated decisions about you, and we do not profile visitors.
- We do not run a marketing mailing list. If you ask for a briefing, we reply about that briefing.
Who else handles it, and where
Three kinds of provider, all acting on our instructions.
- Hosting and content delivery. Serves the site to your browser and keeps the technical logs described above.
- Form handling. Receives what you submit through the demo request form and emails it to us.
- Email. Receives and stores the correspondence between us.
We will name these providers on request. We do not disclose personal data to anyone else except where the law or a competent authority requires it, and we will tell you if that happens unless we are prohibited from doing so.
These providers may process the information outside the AIFC and outside the Republic of Kazakhstan. Where we transfer personal data out of the AIFC, we do so on a basis permitted by the AIFC Data Protection Regulations.
Your rights
Under the AIFC Data Protection Regulations you may ask us to:
- confirm whether we hold personal data about you, and give you a copy of it;
- correct it, if it is wrong or incomplete;
- erase it;
- stop processing it, where you have a justified objection.
We will also give you a copy of what you sent us in a portable format if you ask for one.
Write to info@cogentbase.ai. We aim to respond within 30 days and will tell you if we need longer. We do not charge for this.
If you are outside the AIFC, your local law may give you further rights. We will honour a request for access, correction or erasure wherever you are.
Security
The site is served over HTTPS. Access to enquiry correspondence is limited to the people at Cogent Base who need it in order to reply.
We do not hold a third-party security certification, and nothing in this notice should be read as claiming one. No system is completely secure and we do not say otherwise.
If your firm’s onboarding process requires a security questionnaire, a diligence call or specific contractual commitments before you share anything with us, write to us and we will complete it.
Contact and complaints
For anything in this notice, or to exercise a right, write to info@cogentbase.ai.
If you are not satisfied with our response, you may complain to the Commissioner of Data Protection of the Astana International Financial Centre: dataprotection@aifc.kz, Office 336, 55/18 Mangilik El Avenue, block C3.3, Astana, Republic of Kazakhstan.
We will post any change to this notice on this page. Last updated: .