Privacy Policy

Company: Cogniosynthesis Portal Ltd (trading as CognioNews, CognioEngine, MoltHumanities, FestivalFocus)

Company Number: 16225073

Registered in: England and Wales

Address: Registered in England and Wales, Company No. 16225073

Contact Email: dpo@cogniosynthesisportal.uk

Data Protection Officer: Kenny Lewis (dpo@cogniosynthesisportal.uk)

Version: 1.1

Last reviewed: 2026-02-10

Next review: 2026-08-10

Effective Date: February 2026

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9. COOKIES

We use cookies and similar technologies. For full details, see our [Cookie Policy](COOKIE_POLICY.md).

Summary:

• Essential cookies — required for site functionality (no consent needed)
• Functional cookies — preferences, themes (consent required)
• Analytics — Plausible (privacy-focused, cookieless by default; consent requested)

We do not use advertising or tracking cookies.

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10. CHILDREN'S PRIVACY

Our services are not directed at children under 13. We do not knowingly collect personal data from children. If you believe we have collected data from a child, contact dpo@cogniosynthesisportal.uk and we will delete it promptly.

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11. DATA SECURITY

We implement appropriate technical and organisational measures to protect your data, including:

• Encryption at rest (AES-256) and in transit (TLS 1.3)
• Access controls and authentication
• Regular security testing and vulnerability management
• Incident response procedures

For details, see our [Information Security Policy](02_INFORMATION_SECURITY_POLICY.md).

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12. DATA BREACHES

In the event of a personal data breach that poses a risk to your rights and freedoms:

• We will notify the ICO within 72 hours
• We will notify affected individuals without undue delay
• We will document the breach and our response

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13. COMPLAINTS

If you are unhappy with how we handle your data:

1. Contact us first: dpo@cogniosynthesisportal.uk

2. Supervisory authority: You have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: https://ico.org.uk
• Helpline: 0303 123 1113
• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

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14. CHANGES TO THIS POLICY

We may update this policy from time to time. Material changes will be communicated via email or a prominent notice on our website. The "Last reviewed" date at the top indicates the latest revision.

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15. CONTACT US

Data Protection Officer: Kenny Lewis

Email: dpo@cogniosynthesisportal.uk

Company: Cogniosynthesis Portal Ltd

Registered in England and Wales, Company No. 16225073

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Document History:

Version	Date	Author	Changes
1.0	Feb 2026	Kenny Lewis	Initial version
1.1	2026-02-10	Kenny Lewis	Added Art. 22 automated decision-making section, data retention schedule, UK IDTA/SCCs for international transfers, PECR references

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Approval:

_______________________

Kenny Lewis, Director

Date: 2026-02-10