Privacy Policy

1. Data Controller

The data controller for purposes of this policy is Cogniful, operating from 1 Raffles Place, #28-10, Tower 2, Singapore 048616. For all data-related enquiries, contact us at privacy@cognifinas.

2. What Personal Data We Collect

We collect personal data that you provide directly through our contact form or during the course of an engagement:

• Full name and job title
• Email address and phone number
• Organisation name and sector
• Information you share in messages or during discovery calls
• Technical and usage data collected automatically (IP address, browser type, pages visited) via cookies and analytics tools

We do not collect sensitive personal data (such as financial account information, identification numbers, or health information) through our website.

3. How We Collect Data

We collect data through the following means:

• Contact forms on our website, when you submit an enquiry
• Email correspondence in the course of discussing or delivering an engagement
• Cookies and analytics tools that track site usage (subject to your consent)
• Engagement delivery — during a paid engagement, we may process client data provided to us as part of service delivery (e.g., sample documents for the Document Intelligence Pipeline)

4. Legal Basis for Processing

We process your personal data on the following bases:

• Consent — when you submit a contact form or accept cookies
• Contractual necessity — to perform the services you have engaged us for
• Legitimate interests — to respond to enquiries, maintain business records, and improve our services
• Legal obligation — to comply with applicable Singapore law

5. How We Use Your Data

Your personal data may be used for the following purposes:

• Responding to your enquiries and scheduling discovery calls
• Delivering services you have engaged us to perform
• Sending relevant updates about our services (with your consent)
• Analysing website usage to improve our content and user experience
• Meeting legal and regulatory obligations

We do not sell, rent, or trade your personal data. We do not use client data provided during engagements (e.g., documents for the Document Intelligence Pipeline) for any purpose other than delivering that specific engagement.

6. Data Sharing

We do not share your personal data with third parties except in the following circumstances:

• Service providers assisting in our operations (e.g., email and hosting services) — bound by confidentiality obligations and data processing agreements
• Analytics providers (e.g., Google Analytics) — subject to your cookie consent
• Legal requirements — where required by Singapore law, court order, or regulatory authority

7. Data Retention

We retain personal data for as long as necessary for the purposes described above:

• Enquiry and contact form data: up to 24 months
• Engagement delivery records: up to 7 years (to meet legal and business requirements)
• Cookie and analytics data: as per the cookie durations described in our Cookie Policy

Client-provided documents or data shared for the Document Intelligence Pipeline are deleted within 30 days of engagement completion unless otherwise agreed in writing.

8. Data Protection Measures

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

• Encrypted transmission of data (TLS/HTTPS)
• Access controls limiting who within Cogniful can access personal data
• Confidentiality obligations for all team members
• Regular review of data handling practices

In the event of a data breach affecting your personal data, we will notify you and the Personal Data Protection Commission (PDPC) in accordance with the PDPA's mandatory breach notification requirements.

9. Cookies

Our website uses cookies for essential functionality and, with your consent, for analytics purposes. For full details on the types of cookies we use and how to manage your preferences, please see our Cookie Policy.

10. Your Rights Under the PDPA

Under Singapore's Personal Data Protection Act, you have the right to:

• Access — request a copy of the personal data we hold about you
• Correction — request that inaccurate data be corrected
• Withdrawal of consent — withdraw consent for processing at any time (note: this may affect our ability to provide services)
• Data portability — request that your data be provided in a portable format (where technically feasible)
• Complaint — lodge a complaint with the Personal Data Protection Commission at pdpc.gov.sg

To exercise any of these rights, contact us at privacy@cognifinas. We will respond within 30 days.

11. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

12. Children's Privacy

Our services are directed at professionals and organisations. We do not knowingly collect personal data from individuals under 18 years of age. If you believe we have collected such data, please contact us promptly.

13. International Data Transfers

We primarily process and store data within Singapore. Where any processing occurs outside Singapore (for example, through international cloud service providers), we ensure that appropriate safeguards are in place consistent with the PDPA's cross-border transfer obligations.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law or our practices. Material changes will be communicated via a notice on our website. The "Last Updated" date at the top of this page reflects the most recent version.

15. Contact

For any questions about this Privacy Policy or our data practices, please contact:
Cogniful
1 Raffles Place, #28-10, Tower 2, Singapore 048616
Email: privacy@cognifinas
Phone: +65 6492 7381