Welcome to Cogitality (https://cogitality.net). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your information when you visit our website, register an account, purchase products or services, contact us, or subscribe to our communications.

1. DATA CONTROLLER (WHO WE ARE)

The entity responsible for processing your personal data (the “Data Controller”) is:

Company Name: Cogitalnost Ltd
VAT Number: BG202644437
Country of Registration: Bulgaria (European Union)
Contact Email: hello@cogitality.net

2. THE DATA WE COLLECT ABOUT YOU

We may collect and process different types of personal data, depending on how you interact with our website and services:

• Identity & Account Data: First name, last name, username, and password created when you register an account or enroll in the Cogitality Academy.
• Contact Data: Email address and phone number provided through contact forms, registration, newsletter subscriptions, or other direct communications.
• Transaction Data: Information relating to products or services you purchase from us, including books, audio content, guided experiences, and Academy courses.
• User Content: Comments, testimonials, feedback, and messages you voluntarily submit through the website or directly to us.
• Technical & Usage Data: IP address, browser type, operating system, device information, and information about how you interact with our website, including information collected through cookies and similar technologies.

We do not intentionally request or collect special categories of personal data through our standard website forms and services. If you voluntarily provide such information in a message, testimonial, or other content, we will handle it in accordance with applicable data protection law.

3. HOW WE COLLECT YOUR DATA

We collect data through several methods:

• Direct Interactions: You provide data when you complete a form, create an account, make a purchase, subscribe to our newsletter, submit a testimonial or other content, or contact us directly by email.
• Automated Technologies: As you interact with our website, we may automatically collect certain technical and usage information through cookies and similar technologies.

4. HOW WE USE YOUR PERSONAL DATA

We use your personal data only where permitted by applicable law and for purposes such as:

• To create and manage your user account or Academy enrollment.
• To provide products, services, digital content, and other resources you request or purchase.
• To process and manage transactions.
• To respond to questions, requests, and other communications.
• To send newsletters, updates, and marketing communications where you have provided the required consent or where otherwise permitted by law.
• To maintain the security, functionality, and performance of our website.
• To understand how our website and marketing perform and to improve our services and user experience, where permitted by applicable law.

Legal Bases for Processing

Depending on the purpose, we process personal data on one or more of the following legal bases under the GDPR:

• Performance of a contract: where processing is necessary to create and manage accounts, process purchases, or provide products and services you request.
• Legal obligations: where processing is necessary to comply with applicable tax, accounting, or other legal requirements.
• Consent: where you have given consent for a specific processing activity, such as certain newsletter or non-essential cookie and tracking activities.
• Legitimate interests: where processing is necessary for purposes such as operating, securing, maintaining, and improving our website and services, provided that our interests are not overridden by your rights and freedoms.

5. PAYMENT PROCESSING & THIRD-PARTY PROVIDERS

We do not store or directly collect your full payment card details. Payment information is processed by our third-party payment providers, whose processing of personal data is governed by their own privacy policies and terms.

We may work with payment providers including:

• Stripe
• PayPal

We may also share personal data with trusted service providers that process data on our behalf where necessary to operate our website and services. These may include:

• website hosting and infrastructure providers;
• payment processors;
• email and CRM providers;
• analytics and advertising providers;
• technical, security, and website service providers.

Where required, we use appropriate contractual and technical measures to protect personal data when working with such providers.

6. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar technologies to provide essential functionality, maintain login sessions, manage shopping carts, improve security, and support the operation of the website.

We may also use non-essential analytics and advertising technologies, including the Meta Pixel, to understand website activity, measure marketing performance, and improve our services.

Where consent is required by applicable law, non-essential cookies and tracking technologies are used only after the relevant consent has been obtained through our cookie controls. You may withdraw or change your cookie preferences through the available cookie controls at any time.

You can also configure your browser to refuse or delete some or all cookies. Please note that disabling essential cookies may affect certain website functionality.

7. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including where necessary to comply with legal, accounting, tax, reporting, or other legal obligations.

Account information is generally retained while your account remains active, unless a longer retention period is required or permitted by law.

Newsletter data is retained until you unsubscribe or otherwise withdraw your consent, subject to any legal obligations that may require continued retention.

Where specific retention periods are required by law, we retain the relevant data for the period required by those legal obligations.

8. YOUR DATA PROTECTION RIGHTS

Depending on the applicable circumstances and legal requirements, you may have the following rights under the GDPR:

• Right of Access: You may request confirmation as to whether we process your personal data and request access to that data.
• Right to Rectification: You may ask us to correct inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data under certain conditions.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in certain circumstances.
• Right to Object: You may object to certain types of processing, including direct marketing.
• Right to Data Portability: Where applicable, you may request certain personal data in a structured, commonly used, and machine-readable format and request its transfer to another controller.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. For example, you can unsubscribe from our newsletter using the unsubscribe link provided in our emails.

The exercise of these rights is subject to the conditions and limitations set by applicable law.

To exercise your rights, please contact us at hello@cogitality.net.

You also have the right to lodge a complaint with a competent data protection supervisory authority if you believe that your personal data has been processed unlawfully.

In Bulgaria, the competent supervisory authority is the Commission for Personal Data Protection (CPDP):

Website: https://cpdp.bg/
Email: kzld@cpdp.bg

9. INTERNATIONAL DATA TRANSFERS

As an international project, some of our service providers may process personal data outside the European Economic Area (EEA).

Where personal data is transferred outside the EEA, we rely on an applicable legal mechanism under the GDPR, such as an adequacy decision or appropriate safeguards, where required.

Where applicable, information about the relevant safeguards may be obtained by contacting us at hello@cogitality.net.

10. DATA SECURITY

We take reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

However, no method of transmission or storage can be guaranteed to be completely secure. We therefore cannot guarantee absolute security of your data.

11. THIRD-PARTY WEBSITES AND SERVICES

Our website may contain links to third-party websites, platforms, payment services, or other external resources.

We are not responsible for the privacy practices, content, or security of third-party websites. We encourage you to review the privacy policies of any third-party service before providing personal data to them.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our services, data-processing practices, technology, or applicable legal and regulatory requirements.

When we make changes, we will post the updated Privacy Policy on this page and revise the “Last Updated” date above.

13. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we process your personal data, please contact us:

Cogitalnost Ltd
Email: hello@cogitality.net