Privacy Policy

Last Updated: [September 2025]

Kognitiv is a global professional services consulting firm, specialising in Workday services (HR and financial systems). At Kognitiv, we are committed to protecting the privacy and information including personal information detailed below relating to you ("Personal Data"). This Privacy Notice ("Notice") is intended to explain how your Personal Data will be handled by Kognitiv and sets out the Personal Data that will be collected and processed by Kognitiv and/or on its behalf by its third-party service providers in the context of your engagement and interactions with us.

1. Application of This Notice

This Notice sets out how Kognitiv processes your Personal Data when:

• You access, engage with and browse our websites, (such as https://kognitivinc.com) or social media pages (e.g. LinkedIn, X, Facebook ("Site(s)");
• You, or the organisation with which you are connected, are a customer (or potential customer) of our products and services;
• [You attend and register for our events ("Events");]
• [You visit our offices;]
• [You engage with, receive or subscribe to, our newsletters or other marketing communications or initiatives ("Marketing").]

This Notice does not apply:

• to job applicants. If you are a job applicant, please visit the [Kognitiv Candidate Privacy Notice]; or
• to Personal Data we process on behalf of our customers when we provide our professional services.  If you are a customer, please visit the Kognitiv Customer Data Processing Addendum and associated professional services agreement.

2. Who We Are

The controller of your Personal Data is Kognitiv, a global professional services firm specializing in Workday services. Depending on your relationship with us, references to Kognitiv in this Notice mean:

• [Kognitiv Inc, 1340 Centre St. 208 Newton, MA 02459, US];
• [Kognitiv Inc, 161 Bay Street, Office 2610, Suite 2700, Toronto, ON M5J 2S1, Canada]
• Kogtech Ireland Limited, Fifth Floor, Block D, Iveagh Court, Harcourt Road, Dublin 2, D02 VH94, Ireland; or
• any other entities in the Kognitiv group from time to time.

We are required to provide you with the information in this Notice which explains how your Personal Data will be processed by Kognitiv and your data protection rights under: (1) the General Data Protection Regulation ("GDPR"); (2) the Personal Information Protection and Electronic Documents Act ("PIPEDA"); (3) the California Consumer Privacy Act ("CCPA") and (3) any other state, federal or applicable laws (together, "Applicable Data Protection Laws"). Please be aware that some rights and protections under the Applicable Data Protection Laws may only apply to individuals resident in Europe (i.e. the European Union). If you have any questions about how we use your Personal Data or to exercise your data protection rights contact [email protected].

3. What Personal Data Do We Collect About You

IMPORTANT: Please note that the below list of Personal Data we collect about you, is intended to be as complete and accurate as reasonably possible but it may be updated from time to time in accordance with section 11 of this Notice. We collect Personal Data either directly from you when you provide it to us (e.g. Marketing Data, Event Data, Relationship Data, Query and Contact Data) and or indirectly when we generate it from engaging with you (e.g. Site and Device Data, Professional Services Usage Data). The Personal Data we will process about you is as follows:

Category of Personal Data	Details
Site and Device Data	When you visit the Sites or avail of services related to the Sites, we will collect Personal Data relating to: [your visits and interactions with the Sites including which webpages you visit, time and date of access, what you click on, when you perform these actions; your device data including your IP address, location data, device type and language, browser type and other related information; and linked websites that you access through the Sites.] Most of this Personal Data is collected indirectly from you using cookies on our Sites. Please see our [Cookies Policy] for more information about how our Sites use cookies.
Relationship Data	We collect or generate the following types of Personal Data from you when you are a customer (or a representative of a customer): [name, e-mail address, phone number, job title/role,  testimonials/feedback, and marketing preferences].
Contact and Query Data	When you contact us via our Sites and/or submit queries to us by e-mailing [email protected], we will collect Personal Data relating to: [your name, e-mail address, title, company/employer details and other details (which may or may not include Personal Data, depending on the nature of your communication to us).]
[Marketing Data]	[When we carry out marketing activities or you engage with such activities, we process the following Personal Data about you: [marketing preferences, name, e-mail address, phone number, company name, job title and marketing preferences.]]
[Event Data]	[We will collect the following Personal Data about you directly or indirectly (via an event organiser) when you register for and/or attend one of our events (e.g. on-site, at dedicated locations or webinars, etc.): [name, e-mail address, phone number, company name, job title, photo image, and (if applicable) dietary requirements.]]
[Office Visits Data]	[We collect the following types of Personal Data about you when you visit one of our offices: [name, e-mail address, phone number, job title/role, signature, photo or video image.]]

5. How and Why We Process Your Personal Data

The following table details the key context for which ("Legal Basis") we collect your Personal Data. It also explains how ("Nature of Processing") and why ("Purposes") we obtain and otherwise process your Personal Data. We will only use your Personal Data for the purposes for which we collect it (as outlined in this section 5), unless we reasonably consider that we need to use it for another reason and that reason is incompatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the Legal Basis which allows us to do so.

Legal Basis	Nature of Processing and Purposes	Categories of Personal Data
Legitimate Interests Depending on our business needs, it is necessary to process your Personal Data where we have legitimate business interests to do so. IMPORTANT: When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests. For more information on exercising this right please see section 9 of this Notice, Your Data Protection Rights. Perform our contract with you It is necessary to process your Personal Data in order to enter into and perform our contract with you. IMPORTANT: It is a contractual requirement for us to collect your Personal Data for these purposes and, in the event that you do not provide us with your Personal Data, we will not be able to enter into or perform our contract with you or provide you with the requested services.	Manage and Respond to Queries or Requests: We will process your Personal Data to assess and respond to any requests you make or queries you raise with us. For example, when you: [e-mail a query or send a request to us (e.g. to [email protected]); request to talk to our sales team; and request a demo of our services.]	Relationship Data Contact and Query Data Site and Device Data
	Directly engage and connect via marketing or other activities: We will process your Personal Data for marketing purposes: when you choose to receive our marketing communications (e.g. our monthly newsletter) or when you subscribe to our mailing lists; when you listen read our blog; and when you express an interest in receiving a copy of any of our publications or reports.	Marketing Data Site and Device Data Office Visits Data
	Organise, partner and/or host events: We will process your Personal Data to: invite you to events or webinars; register you for events or webinars (where you ask us to do so); generate your feedback after an event or webinar; record your attendance at webinars or events; and use your photo for media campaigns before or after an event or webinar.	Event Data Site and Device Data
	Office visits: When you visit one of our offices, we may process your Personal Data to: sign you in/out of our buildings; and monitor our offices (using CCTV) to ensure the security, safety and protection of our staff, vendors and visitors.	Office Visits Data
	Site improvements & functionality: We will process your Personal Data to: provide you with use of the Sites and allow you to optimally browse the Sites; improve, test and monitor the effectiveness of the Sites; monitor metrics such as total number of visitors, traffic data and demographic patterns; and ensure the content on the Site is presented in the most effective manner for you and your device.	Site and Device Data
Consent We can process your Personal Data if you provide us with consent to do so. If you give consent, you agree to the processing of your Personal Data for the specific purposes outlined. IMPORTANT Your consent is voluntary, and you have the right to withdraw it at any time. If you choose not to provide your consent or withdraw it, we will not be able to process your Personal Data for the purposes specified.	Cookies and tracking technologies: Where we collect your Personal Data by using cookies on our Sites, which are not essential for the Site to operate, we require your consent to do so. Please see our Cookies Policy for more information.	● Site and Device Data
Compliance with Legal Obligations It is necessary for us to collect and process your Personal Data in order to comply with the legal obligations imposed on us under EU and Irish law (as implemented or amended from time to time). When we process Personal Data to comply with non-EU/Irish laws, we will rely on our legitimate business interests to comply with such laws.	Comply with applicable laws and regulations: We will process your Personal Data to comply with applicable laws and regulations to which we are subject. This may include: complying with legal obligations under European laws; responding to, and cooperating with, requests or orders from public and government authorities, courts or regulators in accordance with our obligations.	Site and Device Data Professional Services Usage Data Relationship Data Contact and Query Data Marketing Data Events Data Office Visits Data

6. Who We Share Your Personal Data With

Depending on Kognitiv's reasons for processing your Personal Data, we may share your Personal Data with some or all of the following recipients ("Recipients"):

Kognitiv	[Kognitiv group companies. Internal business units such as sales, marketing, legal, product, IT, managers, system administrators and support staff; Our Board of Directors. Any other group companies which form part of Kognitiv from time to time.]
Third Party Service Providers	External service providers who provide services to the operation of our business [e.g. ZoomInfo, HubSpot, Salesforce, Google, LinkedIn Gatsby Inc., Microsoft, Meta]; Advertising partners; Service providers who provide support services or require your Personal Data to perform the services requested by us (e.g. IT systems, event organisers and business-related applications).
Third Party Advisors / Professionals	External advisors e.g. tax or legal advisors, consultants, accountants and auditors (as necessary to protect our legitimate and legal interests).
Business Transactions	Parties to transactions or potential transactions (and their legal and professional advisors) involving Kognitiv;
Legal / Regulatory Bodies	Regulatory authorities and law enforcement agencies (where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request) such as government authorities and bodies, law enforcement, courts and out-of-court administrative bodies.

 7. International Data Transfers

As a global company, our operations will be carried out within Europe and outside Europe (e.g. in Canada, the United States and India). If you are resident in Europe, we may share or transfer your Personal Data to Recipients in, or store your Personal Data in, countries with laws and practices which may not have equivalent data protection and privacy rules to those that apply under Applicable Data Protection Laws in Europe. Where these transfers occur, we ensure that a transfer mechanism is in place and appropriate safeguards protect your Personal Data:

• For transfers (including, onwards transfers) of your Personal Data to Recipients within Kognitiv, we rely on the EU Standard Contractual Clauses ("SCCs") (e.g. United States).
• For transfers (including, onward transfers) of your Personal Data to other Recipients, we rely on the SCCs, adequacy decisions of the European Commission (e.g. for transfers to Canada) or other transfer mechanisms under the GDPR.

8. Third Party Sites

This Notice, together with our Terms and Conditions and our Cookies Policy, applies to your use of the Sites. We are not responsible for the content or privacy practices of other websites. The Sites may contain links to other websites and resources (“Linked Website(s)”) provided by third parties for your information and convenience only. Kognitiv is not responsible for the privacy/data protection notices or practices of any Linked Website and does not accept liability in connection with any Linked Website. This Notice only governs the Personal Data collected by Kognitiv on Sites and not Linked Websites. When accessing Linked Websites, you should read the privacy/data protection notice published on the relevant Linked Website. We have no control over the contents of Linked Websites and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.

9. Retention of Your Personal Data

Generally, your Personal Data will not be retained for long periods of time and, in most instances, it will be kept in line with the retention periods set out below:

Personal Data	Retention Period
Site and Device Data	[See Cookies Policy.]
Contact and Query Data	[The length of time it takes to address or conclude your query or request and, in some cases, a reasonable period of time after that to allow for follow-up actions.]
Event Data	[The length of time until the event or webinar take places plus a reasonable period of time afterwards.]
Marketing Data	[Generally, 12 months but this period may be longer or shorter depending on whether you unsubscribe.]
Relationship Data	[Billing/invoicing and onboarding: The length of time you use and engage with Kognitiv and a reasonable period afterwards. Customer support: The length of time it takes to address your query and a reasonable period afterwards. Legal claims: The length of time it takes to establish, exercise or defend a claim plus a reasonable period of time after that to allow for follow-up actions; and/or Legal obligation compliance: The period specified by the legislation (if any) or a reasonable period of time to demonstrate compliance with the legal obligation.]

10. Your Data Protection Rights

Depending on Applicable Data Protection Laws in your country of residence, you may have a number of rights in relation to Personal Data, some of which are set out below for personnel in Europe. In particular, these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that these rights are not absolute. We will aim to respond to any data protection rights request within one month of receiving it. We may be required to extend the timeline of our response by 2 further months if necessary, however, we will contact you if this need arises. Please also note that we may need to verify your identity when you exercise your data protection rights.

Right	Details
Right to Information	You have a right to be provided with clear, transparent and easily understandable information about how we process your Personal Data. We give effect to this right by making this Notice available to you.
Right to Object	You have a right to object to our processing of your Personal Data where we rely on our legitimate business interests to process such data. You can request that we stop processing your Personal Data, and we will do so, unless we can demonstrate compelling legitimate grounds to continue processing your Personal Data or if we need your Personal Data in connection with any legal claims. This applies to the Right to opt-out or unsubscribe.
Right to opt-out or unsubscribe	You have the right to opt-out of marketing communications we send you at any time. If you no longer wish to receive our newsletter and similar communications, you may opt-out of receiving them by clicking on the "unsubscribe" or "opt-out" link in the communications we send you. Please note, however, that it may not be possible to opt-out of certain service-related communications which are necessary to send you. You can contact us to exercise this right at any time.
Right to Withdraw Consent (Cookies)	You have a right to withdraw your consent to our processing of your Personal Data at any time. You can withdraw your consent by updating your cookies preferences and/or unsubscribing using the “unsubscribe” link in any e-mails we send you or by clicking on the Cookies Banner/Settings on our website.
Right of Access	You have the right to access the Personal Data we process about you. If you exercise this right, you will receive confirmation about whether we process your Personal Data and, if so, a copy/copies of your Personal Data.
Right to Rectification	You have the right to correct the Personal Data we process about you if the Personal Data we hold about you is accurate or incomplete.
Right to Erasure	You have a right to request, in certain circumstances, the deletion of your Personal Data - for example if you exercise the right to object and we do not have an overriding reason to continue processing your Personal Data or if we no longer need to process your Personal Data.
Right to Restriction	You have the right, in certain circumstances, to restrict our processing of your Personal Data – for example, if you contest the accuracy of the Personal Data we hold about you or you object to us processing your Personal Data.
Right to Lodge a Complaint	You have the right to lodge a complaint with the Data Protection Commission (“DPC”) or another applicable data protection authority about our processing of your Personal Data. To do so with the DPC, use the DPC’s “Raise a Concern” form . We encourage you to contact us before raising a concern with the DPC to see if we can resolve any concerns you have about our processing of your Personal Data. Contact details for other data protection authorities in the EU are available here. We encourage you to engage with us before filing any complaints so that we can seek to amicably resolve your specific concerns or complaints.

To exercise these rights or ask questions, please contact [email protected].

11. Changes to This Notice

We may review, revise and update this Notice periodically as necessary in response to changing legal, technical or business developments. Updated versions will be posted to www.kognitivinc.com. If we amend this Notice, in whole or in part, at our sole discretion, any changes will be effective immediately upon making the revised Notice available to you.

12. Contact Us

Contact Us For any data protection-related inquiries or concerns about the way your Personal Data are being used or processed by Kognitiv, please contact: Email:  [email protected]