Privacy Policy

This Privacy Policy explains how COGNALY LTD ("we", "us", "our"), operating the website cognaly.mobi from 12 Chequers Orchard, IVER, SL0 9NH United Kingdom, collects, uses, stores, shares and protects personal data when providing digital commerce routing, retail software solutions, e-commerce platform development, inventory and order management systems, CRM integrations, payment gateway integration support, web application development, mobile commerce solutions, marketplace platform development and IT consulting services. We process personal data in accordance with the UK GDPR, the Data Protection Act 2018, PECR and other applicable United Kingdom privacy laws. Questions: contact@cognaly.mobi, +44 7701 334455, 12 Chequers Orchard, IVER, SL0 9NH United Kingdom.

Who we are

COGNALY LTD is the controller for personal data collected through cognaly.mobi unless a written agreement states we act only as a processor. Correspondence address: 12 Chequers Orchard, IVER, SL0 9NH United Kingdom. Privacy contact: contact@cognaly.mobi. Telephone: +44 7701 334455. You may complain to the ICO; we encourage contacting us first.

Regarding "Who we are", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Scope

This Policy covers website visits, contact forms, email and telephone correspondence, proposals, contracts, invoicing and support. It does not cover third-party sites. We do not knowingly collect data from children under sixteen via the website.

Regarding "Scope", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Data categories

We may process identity and contact data, communication content, technical logs and cookie identifiers, contractual and billing records, and limited professional profile information you share. Special category data should not be submitted via public forms.

Regarding "Data categories", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Sources

Data comes from you directly, from authorised colleagues who nominate you as a contact, from service providers operating our infrastructure, and occasionally from public professional sources used for legitimate business development you initiated.

Regarding "Sources", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Purposes and lawful bases

We process data to respond to enquiries (pre-contract steps and legitimate interests), to perform contracts, to operate and secure the website (legitimate interests), to send marketing where PECR allows (consent or soft opt-in), to meet legal obligations, and to establish or defend legal claims.

Regarding "Purposes and lawful bases", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Legitimate interests

Legitimate interests include operating COGNALY LTD, preventing abuse, securing systems, measuring aggregated performance and communicating with professional contacts. You may object; we will assess and respond.

Regarding "Legitimate interests", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Cookies

Cookies are described in our Cookie Policy on cognaly.mobi. Essential cookies support core function. Non-essential cookies require consent where PECR requires it.

Regarding "Cookies", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Processor activities

When delivering client systems we may process personal data as a processor under a data processing agreement, following instructions, applying security, assisting with requests and deleting or returning data at end of engagement unless law requires retention.

Regarding "Processor activities", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Sharing

We share data with hosting, email, storage, accounting and advisory providers under confidentiality terms; with banks for payment; with authorities where required; and with successors in a corporate transaction. We do not sell personal data.

Regarding "Sharing", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

International transfers

Primary processing is in the United Kingdom. Transfers outside the UK use adequacy or appropriate safeguards such as the UK IDTA or Addendum to SCCs. Contact contact@cognaly.mobi for safeguard details.

Regarding "International transfers", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Retention

Enquiries are kept up to twenty-four months after last meaningful contact. Contract and billing records are kept at least six years after the relevant financial year. Logs are kept for shorter operational periods. Data is then deleted or anonymised where feasible.

Regarding "Retention", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Security

We apply access controls, secure configuration, encryption in transit where supported, confidentiality instructions and vendor diligence. No system is perfectly secure. We notify the ICO and individuals of qualifying breaches as required.

Regarding "Security", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Your rights

You may have rights of access, rectification, erasure, restriction, portability and objection, and rights regarding automated decisions. Contact contact@cognaly.mobi. We respond within one month, extendable for complex requests. You may complain to the ICO.

Regarding "Your rights", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Automated decisions

We do not use solely automated decision-making producing legal or similarly significant effects. If that changes we will update this Policy.

Regarding "Automated decisions", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Marketing

Professional updates are sent only where lawful. Marketing emails include unsubscribe. Operational project messages may continue as needed for contract performance.

Regarding "Marketing", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Third-party embeds

Google Maps on the contact page showing 12 Chequers Orchard, IVER, SL0 9NH United Kingdom may involve Google processing under its policies.

Regarding "Third-party embeds", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Changes

We may update this Policy and revise the effective date. Material changes will be highlighted or communicated to active clients where appropriate.

Regarding "Changes", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Accountability

COGNALY LTD maintains processing records proportionate to its scale, reviews practices when systems change, and instructs staff to use personal data only for authorised purposes.

Regarding "Accountability", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Contact

Privacy requests: contact@cognaly.mobi. Post: COGNALY LTD, 12 Chequers Orchard, IVER, SL0 9NH United Kingdom. Telephone: +44 7701 334455.

Regarding "Contact", COGNALY LTD identifies necessary data routes, avoids unused processing panels, and closes retention circuits when purposes end. Read this with our Cookie Policy, Terms of Service and Terms and Conditions on cognaly.mobi.

Supplementary transparency note 1

Note 1: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 2

Note 2: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 3

Note 3: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 4

Note 4: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 5

Note 5: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 6

Note 6: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 7

Note 7: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 8

Note 8: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 9

Note 9: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 10

Note 10: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 11

Note 11: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 12

Note 12: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 13

Note 13: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 14

Note 14: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 15

Note 15: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 16

Note 16: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 17

Note 17: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 18

Note 18: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 19

Note 19: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 20

Note 20: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 21

Note 21: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 22

Note 22: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 23

Note 23: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 24

Note 24: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 25

Note 25: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.

Supplementary transparency note 26

Note 26: during e-commerce, inventory, OMS, CRM, payment gateway, web application, mobile commerce, marketplace and consulting engagements, COGNALY LTD treats named project contacts as professional data subjects used to coordinate delivery, workshops, staging credentials and acceptance. Staging access is least-privilege and revoked at role end or environment decommission. Client controllers remain responsible for lawful staff instructions. Monitoring focuses on security and availability unless a SOW expands scope. Third-party payment or marketplace tools remain independent parties. Case studies on cognaly.mobi stay generalised without permission. Breach playbooks cover containment, risk assessment and required notices. Retention is reviewed at close-out and fiscal year end. Requests to contact@cognaly.mobi should include enough detail for proportionate identity checks without unnecessary sensitive content.