Legal Stuff.
Terms that are important at Cogent Connective.
Privacy Policy
Last updated: 26 October 2026
Who we are
Cogent Connective Limited ("Cogent", "we", "us") is a HubSpot implementation and integration consultancy. We are registered in Scotland (company number SC774434) with our registered office at Unit 9 Main Street, Glencarse, Perth, Scotland, PH2 7LX. We are registered with the Information Commissioner's Office (ICO) under number ZB663537.
We are the controller of the personal data described in this policy, which means we decide how and why it is used.
What this policy covers
This policy explains how we handle personal data about:
- visitors to cogentconnective.com and owsync.io;
- people who contact us, attend our events or webinars, or sign up to our emails;
- prospects we contact about our services;
- people who work for our clients, partners and suppliers, as our business contacts;
- applicants and contractors.
It does not cover personal data we process on behalf of our clients as part of our services (for example their customers and contacts in HubSpot or their ERP). Our clients control that data, and our Data Processing Schedule sets out how we handle it. If your data is in one of our clients' systems, please contact that client.
The data we collect
- Identity and contact: name, job title, company, work email, phone number, address.
- Relationship and transaction: enquiries, meetings, proposals, quotes, contracts, invoices and payments.
- Communications: emails, messages, call and meeting recordings or notes (we tell you when a call is recorded).
- Marketing: email preferences, which emails you open and click, event attendance.
- Website and technical: IP address, browser and device, pages visited and how you arrived (see our Cookie Policy).
- Professional profile: information you publish professionally, such as your LinkedIn profile and company details.
- Applicants and contractors: CV, work history and the details needed to engage and pay you.
We do not ask for special category data (such as health or ethnicity) and ask you not to send it.
How we collect it
- From you: when you fill in a form, email or call us, book or attend a meeting, sign a quote or work with us.
- Automatically: through cookies and similar technology on our websites and in our emails.
- From others: from your colleagues, from partners such as HubSpot that refer you to us, and from business information providers and public sources such as LinkedIn and Companies House.
How and why we use it
| What we use it for | Lawful basis |
|---|---|
| Replying to enquiries, holding meetings and preparing proposals | Steps before a contract, or our legitimate interests in responding |
| Delivering services, managing projects and support | Performing our contract with your organisation (our legitimate interests where the contract is with your employer) |
| Invoicing, payments and accounts | Contract and legal obligation |
| Marketing our services to business contacts (see below) | Legitimate interests; consent where the law requires it |
| Running and improving our websites and measuring campaigns | Consent for non-essential cookies; legitimate interests otherwise |
| Finding and researching prospective clients | Legitimate interests in growing our business, balanced against your rights |
| Recruiting staff and engaging contractors | Steps before a contract, contract and legal obligation |
| Security, preventing fraud and keeping records | Legal obligation and legitimate interests |
| Legal claims and complying with the law | Legal obligation and legitimate interests |
Where we rely on legitimate interests, we have balanced our interests against yours. You can ask us for details.
Marketing
We send business emails about our services, events and insights to people at organisations we work with or that may benefit from them. Where the law requires it we ask for consent first. Every email has an unsubscribe link, and you can opt out at any time by emailing support@cogentconnective.com. We never sell your data.
Who we share it with
We share personal data only where needed, with suppliers that act for us under contract and protect it:
| Supplier | What for |
|---|---|
| Google (Workspace) | Email, documents and file storage |
| HubSpot | Our CRM, website, forms, email marketing and support tickets |
| FreeAgent | Accounting and invoicing |
| Zoom | Video calls, recordings and transcripts |
| Anthropic | AI assistance with drafting and analysis, on business terms with no training on your data |
| Business data providers (such as LinkedIn and Baseloop) | Researching and enriching prospect details |
| Our bank, accountants and professional advisers | Payments, accounts, legal and tax advice |
We may also share data with our subcontractors where needed to deliver services, with regulators, courts or law enforcement where the law requires, and with a buyer of all or part of our business (with appropriate protections).
International transfers
Most of our data is held in the UK or the European Economic Area. Some suppliers (such as HubSpot, Zoom and Anthropic) are based in the US or may access data from there. Where data leaves the UK we rely on UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework) or on the UK International Data Transfer Agreement or Addendum. You can ask us for details.
How long we keep it
| Data | How long |
|---|---|
| Client and supplier contracts, invoices and accounting records | 6 years after the end of the financial year they relate to |
| Business contact and project records | The relationship plus 6 years |
| Prospect and marketing data | Until you opt out, or 2 years after we last had meaningful contact |
| Call recordings and transcripts | [12 months] unless needed for a project or dispute |
| Unsuccessful job applications | 6 months |
| Website analytics | Up to 26 months |
We then delete or anonymise it.
Your rights
You have the right to:
- ask for a copy of your personal data;
- have inaccurate data corrected;
- have your data deleted, in some circumstances;
- restrict or object to how we use it, including objecting to marketing at any time;
- receive data you gave us in a portable format, in some circumstances;
- withdraw consent where we rely on it.
We do not make decisions about you based solely on automated processing that have legal or similarly significant effects. To use your rights, email support@cogentconnective.com. We will reply within one month and may ask you to confirm your identity.
Keeping it secure
We use two-factor authentication, encryption, access controls and staff training to protect personal data, and limit access to people who need it. We have a procedure for handling suspected breaches and will tell you and the ICO where the law requires.
AI
We use AI tools to help draft, summarise and analyse information. We use them on business terms under which the provider does not train its models on our data, and a person reviews AI output before we rely on it.
Complaints
Please contact us first so we can try to put things right. You can also complain to the Information Commissioner's Office at ico.org.uk/make-a-complaint or on 0303 123 1113.
Changes to this policy
We update this policy when our practices change. The date above shows when it was last changed, and we will tell you about significant changes where we can.
Contact us
Cogent Connective Limited, Unit 9 Main Street, Glencarse, Perth, Scotland, PH2 7LX. Email support@cogentconnective.com. Telephone 01738 210218.
If you need this policy in another format, please ask.