Privacy policy
Effective date: 21 February 2025 (cookies section updated 27 July 2026)
1. Introduction
Welcome to Cogenta. We value your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you visit our website, use our services, or interact with us in any way.
2. Who we are
Cogenta, based in Brussels, Belgium, offers a range of services including (but not limited to) CRM consulting, process optimization, organizational change management, technology integration, and project management. The specific scope, timelines, fees, and deliverables will be detailed in a relevant SOW or equivalent contract.
3. Information we collect
We collect both personal information and non-personal information in order to deliver our consultancy services effectively, communicate with potential clients, and improve the user experience on our website.
3.1 Personal information you provide.
When you contact us through our website or directly via email, phone, or other channels, we may collect details such as your name, company name, email address, and phone number. This information allows us to respond to inquiries, share relevant service updates, and maintain a professional relationship with you. If you engage our consultancy services, we collect additional business details necessary for invoicing, project management, and ongoing collaboration. These may include business addresses, billing contact details, and references to past projects or services requested.
3.2 Data processed during consultancy services.
In the course of providing CRM consulting and related services, Cogenta may act as a data processor for our clients. This involves processing personal data on behalf of our clients, who are the data controllers. The types of personal data processed can include contact information (name, function, organization, email, phone, address), professional information, interaction history, and communication preferences. These data are typically those recorded in the client's CRM system (such as Salesforce or similar). The categories of data subjects concerned are generally the contacts registered in the client's CRM, such as their clients, prospects, partners, and event participants.
This processing is conducted based on the documented instructions of our clients, as outlined in a Data Processing Agreement (DPA) in accordance with applicable data protection laws, including the GDPR. The purposes of this processing are to maintain and optimize the client's CRM system, manage and structure CRM data, assist with event planning, deploy new functionalities, and provide general maintenance and administration of the CRM. We treat this information as strictly confidential and use it solely to perform the consultancy tasks requested.
3.3 Usage data.
Whenever you visit our website, certain non-personal information may be collected automatically. This data typically includes your Internet Protocol (IP) address, browser type, operating system, referral URLs, and pages visited. We analyze this usage data to understand how visitors interact with our site, identify areas for improvement, and tailor our content to better meet user needs.
3.4 Cookies and similar technologies.
Our website uses a small number of cookies and equivalent forms of browser storage. Nothing beyond what is strictly necessary is used without your consent: on your first visit a banner asks for your choice, and analytics and marketing stay switched off until you make one. Section 9 sets out exactly what is used in each case, and how to change your mind at any time.
3.5 Communications.
If you communicate with Cogenta by email, phone, or other channels, we may record and store those communications, including any accompanying attachments, in order to respond to your inquiries, maintain accurate records, and improve our service delivery.
3.6 Data from third parties.
In certain cases, we may receive information about you from third parties, such as referral partners or publicly available sources. This can include business contact information or details about your professional role within an organization. We use this information to verify the details you have provided and to refine our consulting services.
4. How we use your information
Your information is used to provide and manage our CRM consulting services, communicate with you about your inquiries and projects, enhance our website and service offerings, and ensure compliance with legal and regulatory obligations. When acting as a data processor, we process personal data strictly in accordance with our clients' instructions and the terms of the relevant DPA. If you have given explicit consent, we may also use your contact information for occasional marketing updates regarding our services.
5. Sharing your information
We do not sell your personal data. However, in the course of delivering our services, including when acting as a data processor, we may share your information with trusted service providers who assist in specific areas such as website hosting, analytics, or CRM software partnerships. Any sub-processors are engaged in accordance with the terms of our DPAs and applicable data protection laws. In cases where collaboration with business partners is necessary to execute a project, relevant information may be shared with them. Additionally, we may disclose your information when legally required to regulatory authorities or in compliance with legal processes.
6. Data security
We implement robust security measures to protect your data from unauthorized access, loss, or misuse. These measures include secure storage, access controls, encryption, and regular security audits to ensure compliance with industry standards. When processing data on behalf of our clients, we implement the technical and organizational measures detailed in our Data Processing Agreements.
7. Data retention
Personal data is retained only for as long as necessary to fulfill the purposes outlined in this policy or as required by our agreements with clients (for data processed on their behalf). The duration of retention depends on legal obligations, business relationships, and your specific requests regarding data deletion. When no longer needed, your data is securely deleted or anonymized.
8. Your rights and choices
You have the right to access, correct, or request deletion of your personal data, subject to legal limitations. You may withdraw consent for marketing communications at any time and request restrictions on data processing in certain circumstances. If applicable, you can also request a copy of your data in a structured format. When we are processing your data as a data processor on behalf of a client, your rights should be exercised by contacting the data controller (our client) directly. To exercise your rights regarding data for which Cogenta is the controller, you can contact us at info@cogenta.io.
9. Cookies and similar technologies
9.1 Your choice comes first.
When you first visit this site, a banner asks how you want to be measured. Until you answer, nothing beyond what is strictly necessary runs: no analytics, no advertising, no third-party identifiers. Refusing is offered as plainly as accepting, and you can change or withdraw your choice at any time through the "Cookie settings" link in the footer of every page.
9.2 Strictly necessary storage.
Three small values are kept in your browser regardless of your choice, because the site cannot work correctly without them: your cookie choice itself, your reading-theme preference, and your language preference on these legal pages. They are stored locally, are readable only by this website, are never transmitted to us or to any third party, and are never used to identify or track you.
9.3 Analytics, only with your consent.
If you allow analytics, we use Google Analytics 4 through Google Tag Manager to understand which pages are found and read. This sets Google's "_ga" and "_ga_*" cookies, which expire after two years, and processes your IP address together with your activity on this site. If you do not allow analytics, no such cookie is set and no identifier is created: Google Tag Manager is instructed to store nothing, and only anonymous, aggregated signals are sent.
9.4 Advertising.
We do not currently run advertising, remarketing, or social pixel tags on this site. The banner still offers a marketing category so that your preference is recorded in advance and honoured automatically if that ever changes.
9.5 How the choice is enforced.
We use Google Consent Mode v2. Your answer is translated into four signals (analytics_storage, ad_storage, ad_user_data and ad_personalization), which are set to "denied" before any tag is allowed to load and are updated only when you say so. The default state of this website is therefore that nothing measurable about you is stored.
9.6 Third-party embeds.
Our contact page embeds a booking calendar provided by Cal.com so that you can schedule a call directly. When that calendar loads it may set its own cookies, governed by Cal.com's privacy policy rather than ours. Your browser's own cookie controls remain available to you at all times, in addition to the choices described above.
10. Third-party links
Our website may contain links to third-party sites. We are not responsible for their privacy practices and encourage you to review their policies before sharing any information.
11. International data transfers
If you access our website from outside the European Economic Area (EEA), your data may be transferred and processed in regions with different data protection laws. We take appropriate safeguards to ensure data security in such transfers.
12. Changes to this privacy policy
This Privacy Policy may be updated periodically. The latest version will always be available on our website, and we will notify you of significant changes where required.
13. Contact us
If you have any questions about this Privacy Policy or your data rights, please contact us at info@cogenta.io.