Privacy Policy

1. About Us

Cognoscent operates as a data controller for personal data collected through this website and in the course of client engagements. Registered address: 182 Cecil Street, #17-01, Frasers Tower, Singapore 069547. Contact email for data matters: [email protected].

2. Personal Data We Collect

We collect personal data in the following circumstances:

• Contact form submissions: Name, email address, phone number (if provided), and the content of your message.
• Email correspondence: Name, email address, and the content of communications.
• Engagement onboarding: Business contact details, role, and organisational information necessary to scope and conduct the engagement.
• Website analytics: Anonymised data on page visits and browser type if analytics cookies are accepted (see Section 6).

3. How We Use Your Data

• To respond to enquiries and assess whether an engagement is appropriate
• To conduct and deliver the commissioned engagement
• To send engagement-related communications (updates, requests for information, deliverable delivery)
• To comply with legal obligations under Singapore law
• To improve the website based on anonymised usage data (only with analytics consent)

We do not use personal data for marketing without your explicit consent. We do not sell or rent personal data to third parties.

4. Legal Basis for Processing

• Consent: For optional cookies and marketing communications.
• Contract performance: Data necessary to conduct commissioned engagements.
• Legitimate interest: Responding to initial enquiries, maintaining business records.
• Legal obligation: Retention of records as required by Singapore law.

5. Data Retention

• Enquiry data (no engagement): Retained for 12 months from last contact, then deleted.
• Engagement records: Retained for 7 years from engagement close to meet business record-keeping obligations under Singapore law.
• Client data shared for analysis: Deleted within 30 days of engagement close unless a different period is agreed in writing.
• Analytics data: Aggregated and anonymised; no individual-level retention beyond 26 months.

6. Cookies

This website uses cookies. Essential cookies are required for the website to function and cannot be disabled. Optional analytics and preference cookies require your consent. For full details, see our Cookie Policy.

7. Data Security

We implement the following security measures:

• Data transmitted to and from this website is encrypted via TLS
• Access to personal data is restricted to team members who require it for the relevant engagement
• Client data received for analysis purposes is stored in encrypted form
• In the event of a data breach affecting your personal data, we will notify you and the Personal Data Protection Commission (PDPC) as required by the PDPA mandatory breach notification obligations

8. Data Sharing

We share personal data with third parties only in the following circumstances:

• Service providers: Website hosting and email services. These providers act as data processors and are bound by data processing agreements.
• Legal compliance: Where required by Singapore law or a valid legal order.
• Business transfer: In the event of a merger or acquisition, data may transfer to the successor entity under equivalent protections.

We do not share personal data with advertising networks, data brokers, or marketing platforms.

9. Your Rights

Under the PDPA, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete data.
• Withdrawal of consent: Withdraw consent for optional data processing at any time, without affecting processing carried out before withdrawal.
• Data portability: Request your data in a commonly used, machine-readable format (where applicable).
• Complaint: Lodge a complaint with the Personal Data Protection Commission of Singapore (PDPC) at www.pdpc.gov.sg.

To exercise any of these rights, contact us at [email protected]. We will respond within 10 business days.

10. Third-Party Links

This website may contain links to third-party websites. We are not responsible for the privacy practices of those sites. We recommend reviewing their privacy policies independently.

11. Children's Privacy

Our services are intended for professional and organisational use. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that data has been collected from a minor, we will delete it promptly.

12. Changes to This Policy

If we make material changes to this policy, we will update the "Last updated" date at the top of this page. We recommend checking this page periodically. Continued use of the website following a material change constitutes acceptance of the updated policy.

13. Contact

For all data-related matters, contact: