Privacy Policy
Last updated: 1 March 2026
1. Data Controller
The Data Controller is COGNIQUITY (hereinafter "we", "our", "the Company"), reachable at rolando@cogniquity.com.
2. Data Collected
We collect and process the following categories of personal data:
| Category | Examples | Purpose |
|---|---|---|
| Identification data | Name, surname, email address | Account creation and management |
| Usage data | Sessions, messages, timestamps | Service delivery and improvement |
| Cognitive data | Calibration onboarding responses | Experience personalisation |
| Technical data | IP address, browser type | Security and diagnostics |
3. Legal Basis for Processing
The processing of your personal data is based on:
- Contractual performance (Art. 6(1)(b) GDPR): to provide the requested services.
- Consent (Art. 6(1)(a) GDPR): for optional communications.
- Legitimate interest (Art. 6(1)(f) GDPR): for security and fraud prevention.
4. Purposes of Processing
We use your data to:
- Create and manage your user account
- Deliver the cognitive sparring service
- Improve and personalise the user experience
- Ensure platform security
- Comply with legal obligations
5. Data Retention
Your data is retained for the period necessary to pursue the purposes described, or for the time required by applicable law. Upon account deletion, data is erased within 30 days, unless a legal retention obligation applies.
6. Data Transfers
Data may be transferred to third-party service providers (e.g. Supabase, Anthropic) acting as data processors under appropriate contractual agreements. Where data is transferred outside the European Economic Area, we ensure that adequate safeguards are in place (e.g. Standard Contractual Clauses).
7. Your Rights
You have the right to:
- Access: obtain confirmation of processing and a copy of your data
- Rectification: correct inaccurate or incomplete data
- Erasure: request deletion of your data ("right to be forgotten")
- Restriction: limit processing in certain circumstances
- Portability: receive your data in a structured, machine-readable format
- Objection: object to processing based on legitimate interest
- Withdrawal of consent: at any time, without affecting the lawfulness of prior processing
To exercise your rights, write to rolando@cogniquity.com.
8. Complaints
You have the right to lodge a complaint with the competent supervisory authority (in Italy: the Garante per la protezione dei dati personali — www.garanteprivacy.it).
9. Changes to This Privacy Policy
We reserve the right to update this Privacy Policy. Material changes will be communicated via email or an in-platform notice.