Privacy Notice
- We collect the details you give us when you book a call, plus basic technical data needed to run the site.
- Analytics cookies run only if you click "Accept" on our cookie banner.
- We use your data to arrange the call and follow up about Cogito AI. We do not sell it or use it for advertising.
- You can ask to see, correct or delete your data, or withdraw consent, at any time by emailing privacy@commverseglobal.com.
1. Who we are
Cogito AI is a product of Commverse Pvt. Ltd ("Commverse", "we", "us"), a company registered in India with its office at WeWork Embassy TechVillage, Block L, Devarabisanahalli, Outer Ring Road, Bellandur, Bengaluru, Karnataka 560103, India.
We decide how and why the personal data collected through cogitoai.tech (the "Site") is used. That makes us the "data controller" under European and UK law and the "Data Fiduciary" under India's Digital Personal Data Protection Act, 2023.
Privacy contact: privacy@commverseglobal.com, at the address above.
2. What this notice covers
This notice covers personal data we collect when you visit the Site, book a call, use our calendar page, download our briefs or white paper, or contact us.
It does not cover data that our customers process in the Cogito AI software. That data is handled under the customer's contract with us, where we act on the customer's instructions.
3. The personal data we collect
| Data | What it includes | Where it comes from |
|---|---|---|
| Call request | Full name and work email (required). Phone number, designation, organization and the process you want to see (optional). | You, through the "Book a call" form |
| Meeting booking | Name, email, time slot and any notes you add | You, through our Microsoft Bookings calendar page |
| Correspondence | What you send us by email, phone or LinkedIn | You |
| Technical data | IP address, browser and device type, pages requested, date and time | Your browser, collected by our hosting provider to run and secure the Site |
| Analytics (only with your consent) | Pages viewed, how you reached the Site, approximate location, and the organization your network belongs to, inferred from your IP address. If you also submit the form, your visits can be linked to your request. | HubSpot cookies, set only after you click "Accept" |
We only need your name and work email to reply to a call request. Everything else is optional. We do not ask for sensitive data (such as health, financial account, biometric or government ID data). Please do not send it to us.
4. Why we use it, and our legal basis
| Purpose | Legal basis (EU, UK and similar laws) | Legal basis (India) |
|---|---|---|
| Reply to your call request, arrange and hold the call | Steps you asked for before a possible contract; our legitimate interest in answering business enquiries | Your consent, given when you submit the form |
| Follow up by email or phone about Cogito AI and related Commverse services | Legitimate interest in business-to-business marketing, or your consent where the law requires it. You can opt out at any time. | Your consent. You can withdraw it at any time. |
| Understand how the Site is used and which organizations show interest (HubSpot analytics) | Your consent, through the cookie banner | Your consent, through the cookie banner |
| Keep the Site secure, stop spam and fix faults | Legitimate interest in running a secure site | Your consent to use the Site, and uses the law permits |
| Meet legal, tax and regulatory duties, and defend legal claims | Legal obligation; legitimate interests | Compliance with law |
We do not sell your personal data. We do not share it for cross-context behavioral advertising. We do not use it to make automated decisions that have legal or similarly significant effects on you. We do not use personal data collected on this Site to train AI models.
5. Who we share it with
We share personal data only with service providers that process it for us under contract and on our instructions:
- Wix.com: hosts the Site, receives form submissions, keeps our contact list and sends confirmation emails.
- Microsoft: business email and the Microsoft Bookings calendar page.
- HubSpot, Inc.: website analytics and identifying visiting organizations, only if you accept analytics cookies. HubSpot stores this data in the United States.
We may also share data with other Commverse group companies that help deliver Cogito AI, with our professional advisers, with a buyer or successor if our business is sold or reorganized, and with authorities where the law requires it.
6. International transfers
Our service providers may store and process data outside your country, including in India, the United States and the European Union.
When data leaves the EU, the UK or Switzerland, we rely on an adequacy decision or on safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum and their Swiss equivalent. Transfers out of India follow the DPDP Act and any restrictions the Government of India notifies. You can ask us for a copy of the safeguards we use.
7. How long we keep it
- Call requests, bookings and correspondence: 24 months after our last contact with you, unless you become a customer, in which case your organization's contract applies.
- Analytics data: for the periods shown in the Cookie Policy and under HubSpot's retention settings.
- Records we must keep by law: for as long as the law requires.
We delete or anonymize data sooner if you ask and we have no legal reason to keep it.
8. How we protect it
The Site runs over an encrypted (HTTPS) connection. Our hosting provider holds ISO 27001 and SOC 2 Type 2 certifications. Only the people who need your request can see it, and their accounts use two-step sign-in.
If a data breach affects you, we will tell you and the relevant regulators where the law requires it.
9. Your rights and how to use them
Depending on where you live, you can ask us to:
- tell you what personal data we hold about you and how we use it, and give you a copy
- correct, complete or update it
- delete it
- stop or restrict how we use it, or object to our use of it (you can always object to marketing)
- give it to you, or to another organization, in a portable format
- withdraw consent at any time, as easily as you gave it. This does not affect what we did before.
- let another person act for you, including someone you nominate in case of death or incapacity
How: email privacy@commverseglobal.com. We may ask you to confirm your identity first. We reply within one month, or sooner where the law sets a shorter time. If we need longer, we will tell you why. Using your rights is free, and we will not treat you differently for using them.
Marketing: every marketing email has an unsubscribe link, and you can ask us at any time to stop calling you.
If you are not satisfied with our answer, you can appeal by replying to it, and you can complain to the data protection authority where you live or work (see section 10).
10. Extra information for your country or region
We give everyone the rights above. The laws below add specific points.
India
Law: Digital Personal Data Protection Act, 2023 and the DPDP Rules, 2025.
- We process your data on the basis of your consent, or for uses the Act permits. Your consent covers only the purposes listed in section 4.
- You can withdraw consent, and ask for a summary of your data, for correction, completion, updating or erasure, by emailing privacy@commverseglobal.com. You can also nominate a person to act for you.
- Grievances: email privacy@commverseglobal.com. We will acknowledge your grievance promptly and resolve it within 30 days. If you are not satisfied, you can complain to the Data Protection Board of India.
- You can ask for this notice in English or in any language listed in the Eighth Schedule to the Constitution of India.
European Union and European Economic Area
Law: General Data Protection Regulation (GDPR) and national laws on electronic communications (ePrivacy).
- You have all the rights in section 9, including the right to object to processing based on legitimate interests and an absolute right to object to direct marketing.
- Providing your name and work email is needed to answer your call request. Everything else is optional.
- You can complain to the data protection authority in the country where you live, work or think an infringement happened.
United Kingdom
Law: UK GDPR, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations (PECR), as amended by the Data (Use and Access) Act 2025.
- You have the same rights as under the EU GDPR, and you can complain to us first and then to the Information Commissioner's Office (ico.org.uk).
Switzerland
Law: Federal Act on Data Protection (FADP).
- You can ask for information about your data, its correction or deletion, and you can object to processing. You can complain to the Federal Data Protection and Information Commissioner (FDPIC).
United States
Laws: the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA), similar laws in other states such as Colorado, Connecticut, Virginia, Texas and Oregon, and the CAN-SPAM Act.
Notice at collection. In the last 12 months we have collected these categories of personal information, from the sources and for the purposes in sections 3 and 4:
- identifiers (name, email, phone, IP address)
- professional information (designation, organization)
- internet activity (pages viewed on the Site, only with consent)
- inferences (the organization your network belongs to, only with consent)
We disclose these only to the service providers in section 5, for business purposes. We do not sell or share personal information, and we do not collect sensitive personal information. We keep it for the periods in section 7.
- You can ask to know, correct or delete your personal information, and to opt out of sale, sharing or targeted advertising (we do none of these).
- Our cookie banner treats a Global Privacy Control (GPC) signal as an opt-out.
- An authorized agent can make a request for you, with your signed permission. We will verify the request.
- If we decline a request, you can appeal by replying to our answer. If the appeal is refused, you can contact your state Attorney General.
- We will not discriminate against you for using these rights.
- Our marketing emails identify us, include our postal address and have a working unsubscribe link.
Canada
Laws: Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act respecting the protection of personal information in the private sector, and Canada's Anti-Spam Legislation (CASL).
- You can access and correct your information and withdraw consent. You can complain to the Office of the Privacy Commissioner of Canada, or in Quebec to the Commission d'accès à l'information.
- We send commercial emails only with your express or implied consent, and every email lets you unsubscribe.
Singapore
Law: Personal Data Protection Act 2012 (PDPA).
- Our privacy contact in section 1 acts as our Data Protection Officer. You can ask for access to and correction of your data, and withdraw consent. You can complain to the Personal Data Protection Commission.
- We call or message you only on numbers you give us for that purpose.
United Arab Emirates and Saudi Arabia
Laws: UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the DIFC Data Protection Law 2020 and ADGM Data Protection Regulations 2021 (if you are in those free zones), and Saudi Arabia's Personal Data Protection Law.
- You have the rights of access, correction, deletion, objection and withdrawal of consent. You can complain to the relevant authority: the UAE Data Office, the DIFC Commissioner of Data Protection, the ADGM Office of Data Protection, or the Saudi Data and AI Authority (SDAIA).
Australia
Law: Privacy Act 1988 and the Australian Privacy Principles.
- Your data may be disclosed to recipients overseas, as described in sections 5 and 6. You can ask for access and correction, and complain to us first and then to the Office of the Australian Information Commissioner (OAIC).
Brazil
Law: Lei Geral de Proteção de Dados (LGPD).
- Our privacy contact in section 1 is our data protection officer (encarregado). You can confirm whether we process your data, access, correct, anonymize, delete or port it, and withdraw consent. You can complain to the National Data Protection Authority (ANPD).
Japan and Hong Kong
Laws: Japan's Act on the Protection of Personal Information (APPI) and Hong Kong's Personal Data (Privacy) Ordinance (PDPO).
- You can ask for access to and correction of your data, and ask us to stop using it for marketing. You can complain to Japan's Personal Information Protection Commission or Hong Kong's Privacy Commissioner for Personal Data.
South Africa
Law: Protection of Personal Information Act, 2013 (POPIA).
- You can access, correct and object to the use of your information, and complain to the Information Regulator.
Other countries
If you live elsewhere, you have the rights your local law gives you. Contact us and we will help.
11. Children
The Site is for business users. It is not directed at anyone under 18, and we do not knowingly collect children's data. If you believe a child has sent us personal data, contact us and we will delete it.
12. Changes to this notice
We may update this notice. The date at the top shows the latest version. If a change is significant, we will flag it on the Site, and where the law requires it we will ask for your consent again.