Cogent Data Privacy Notice
1. Notice to Data Subjects
The Cogent companies listed at the end of this Notice (“Cogent”, “we”, “us”, “our”) provide Internet access, Internet transit and/or Ethernet transport services to businesses, i.e. our customers, or receive services from businesses, i.e., our vendors (for ease of reference, we refer to both our customers and vendors in this notice as a “Company” or “Companies” and the services provided as “Services”). As part of the provision of these services to or receipt of services from Companies, you, as an employee or representative of a Company, may be asked to disclose limited personal data (e.g. business contact details) to one or more of us, or your Company may disclose your personal data to Cogent, to enable Cogent to communicate with you in order to provide or receive Services. The Cogent company or companies from whom your Company has ordered Services or to whom your Company provides Services will be the data controller(s) of your data for these purposes and the purposes of the General Data Protection Regulation (GDPR).
This notice sets out the basis on which we will process your personal data. Please read this notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this notice in general or any part of it, you should inform your Company or Cogent as soon as possible.
What types of information do we collect and how we use it?
Your Company or you may provide the following types of your personal data to us by contacting us via our customer portal, email, telephone or otherwise:
- name;
- email address;
- telephone number; and
- job role.
Purposes of Processing and Legal Basis for Processing
Cogent will process your personal data for the following purposes:
- to contact and interact with you to perform our obligations under our contract with your Company in order to pursue our legitimate interest of communicating with our customers and running an effective business;
- to monitor and record calls for quality, training, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery; and
- enforce our terms and conditions against your Company in order to pursue our legitimate interests of running an effective business.
Recipients of Data and International Transfers
Cogent does not sell, rent or lease your personal information to others except as described in this notice. We share your information with selected recipients. The categories of recipients include:
- IT Services providers that provide us with SaaS services.
- Cogent will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).
Cogent will also disclose your information to third parties:
- in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
Where do we store your personal data?
Your personal data will be transferred within our group to the United States of America, and stored by Cogent’s United States affiliate, Cogent Communications, Inc., located at 2450 N. St., Washington, DC 20037, United States of America. Your personal data is also processed by staff operating outside the European Economic Area (“EEA”) or the United Kingdom (UK) who work for us or for one of our suppliers. Such staff are engaged in, among other things, communicating with you about the fulfilment of your Company's order and the provision of support services. Such countries may not have the same data protection laws as your country but we will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this notice.
For any transfers of data outside the EEA or the UK, the data transfer will be under the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses) (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities (as applicable) to provide an adequate level of protection for individuals’ rights and freedoms for their personal data.
Please contact our data privacy contact at Diese E-Mail-Adresse ist vor Spambots geschützt! Zur Anzeige muss JavaScript eingeschaltet sein! for copies of the standard contractual clauses.
Retention Period
We may retain your personal data for as long as required to perform the Services and/or the purposes of processing set out above.
We will retain your information until we are notified that you no longer work for your Company or for a period of seven (7) years after your Company has terminated its contractual relationship with Cogent.
Your rights
In certain circumstances you have rights in relation to the personal data we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing reasonably acceptable verification of your identity. To exercise any of your rights, please email Diese E-Mail-Adresse ist vor Spambots geschützt! Zur Anzeige muss JavaScript eingeschaltet sein!. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.
- Access: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
- Correction: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed.
- Erasure: You may request that we erase the personal data we hold about you in the following circumstances: where you believe it is no longer necessary for us to hold the personal data, we are processing your data on the basis of our legitimate interest and you object to such processing, you no longer wish us to use your data to send you marketing or you believe we are unlawfully processing your data.). Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.
- Restriction of Processing to Storage Only: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in the following circumstances: you believe the personal data is not accurate for the period it takes for us to verify whether the data is accurate, we wish to erase the personal data as the processing we are doing is unlawful but you want us to simply restrict the use of that data; we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; and you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
- Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
Objection to Marketing
At any time you have the right to object to our processing of data about you in order to send you marketing or promotional material, including where we build profiles for such purposes and we will stop processing the data for that purpose. Please email us at Diese E-Mail-Adresse ist vor Spambots geschützt! Zur Anzeige muss JavaScript eingeschaltet sein! if you would like to object to receiving marketing communications from us.
Complaints
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at Diese E-Mail-Adresse ist vor Spambots geschützt! Zur Anzeige muss JavaScript eingeschaltet sein! and we will endeavor to deal with your request. This is without prejudice to your right to raise a claim with a supervisory authority.
How to contact us
If you have any questions about our use of your personal data, please contact Diese E-Mail-Adresse ist vor Spambots geschützt! Zur Anzeige muss JavaScript eingeschaltet sein!.
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COGENT EUROPE, S.À.R.L |
COGENT COMMUNICATIONS BELGIUM SPRL |
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COGENT COMMUNICATIONS BULGARIA EOOD |
COGENT INTERNET d.o.o. |
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COGENT COMMUNICATIONS CZECH REPUBLIC s.r.o. |
COGENT COMMUNICATIONS DENMARK ApS |
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COGENT COMMUNICATIONS ESTONIA, OÜ |
COGENT COMMUNICATIONS FINLAND OY |
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COGENT COMMUNICATIONS FRANCE, SAS |
C.C.D. COGENT COMMUNICATIONS |
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Svensk filial till C.C.D. Communications |
COGENT HELLAS INTERNET SERVICES |
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COGENT COMMUNICATIONS HUNGARY, KFT. |
CCE COGENT INTERNET SERVICES LIMITED |
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COGENT COMMUNICATIONS ITALIA S.R.L. |
COGENT LATVIA SIA |
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COGENT LITHUANIA UAB |
COGENT COMMUNICATIONS NETHERLANDS B.V. |
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COGENT NORWAY AS |
COGENT COMMUNICATIONS POLAND Sp. zo. o. |
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COGENT COMMUNICATIONS PORTUGAL, LDA. |
COGENT COMMUNICATIONS ROMANIA SRL |
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COGENT COMMUNICATIONS SLOVAKIA s.r.o. |
COGENT ADRIA, komunikacije, d.o.o. |
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COGENT COMMUNICATIONS ESPAÑA S.L. |
COGENT COMMUNICATIONS UK Ltd |
Last updated: December 1, 2022