Legal

Privacy Policy

Last updated: 18 August 2026

Cognaire Pty Ltd (ABN 75 686 937 726) and COGNAIRE LIMITED (UK company number 16674230) are members of the Cognaire group. In this Privacy Policy, "Cognaire", "we", "us" or "our" refers to the relevant Cognaire entity that collects or processes personal information in connection with your interaction with us or our products and services.

Cognaire is committed to protecting privacy and handling personal information responsibly.

This Privacy Policy explains how we collect, use, store, process and disclose personal information when you visit our website, communicate with us, or access or use Cognaire products and services, including Cognaire Respond (the "Services").

Where Cognaire processes personal information on behalf of a business customer, the applicable customer agreement and any Data Processing Agreement ("DPA") may contain additional or more specific obligations relating to that processing. Those contractual arrangements apply alongside this Privacy Policy, subject to applicable law.


1. Who We Are

Cognaire provides AI-powered software-as-a-service and related technology services to business customers.

The Cognaire group currently includes:

  • Cognaire Pty Ltd — Australian company, ABN 75 686 937 726.
  • COGNAIRE LIMITED — United Kingdom private limited company, company number 16674230, registered office at 7 Oakley Street, London, England, SW3 5NN.

The Cognaire entity responsible for a particular business relationship may be identified in the applicable customer agreement, order form or other contractual documentation.

We handle personal information in accordance with privacy and data protection laws that apply to the relevant processing. Depending on the circumstances, these may include the Privacy Act 1988 (Cth) and the Australian Privacy Principles to the extent applicable, the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 (UK), and other applicable privacy and data protection laws.

For personal information collected directly by Cognaire for our own business purposes, such as website enquiries, account administration, sales, billing or support, the relevant Cognaire entity generally determines the purposes of processing. Where we process Customer Data on behalf of a customer, the customer generally determines the purposes of that processing and Cognaire acts as a processor, service provider or equivalent role under applicable law.


2. Personal Information We Collect

The personal information we collect depends on how you interact with us and may include:

Information you provide

  • Name, email address, phone number, job title and organisation.
  • Account registration, login and authentication-related information.
  • Billing and payment contact details.
  • Communications with us, including support requests, enquiries and feedback.

Information collected through use of the Services

  • User account identifiers and authentication data.
  • Usage data, logs, audit information and service metadata.
  • Content, documents, files, text, prompts, instructions and other information submitted to or generated through the Services on behalf of a customer.
  • Information required to operate integrations, connectors and workflows configured by a customer.

Information received from customers and connected systems

Where a customer connects the Services to another business system, data source or third-party service, Cognaire may receive personal information from that system on the customer's instructions. Depending on the customer's use case, this may include candidate, employee, client, supplier, contact, questionnaire, document or other business records.

Website and technical information

  • IP address.
  • Browser, device and operating-system information.
  • Cookies, analytics information and website usage data.

Sensitive or special-category information

The Services are not designed to require sensitive or special-category personal information unless it is necessary for an authorised customer use case. Customer Data may nevertheless contain such information where it is supplied by a customer, contained in source records, or otherwise processed on the customer's instructions.

Where we process sensitive or special-category information, we do so in accordance with applicable law and the relevant customer agreement.


3. How We Collect Personal Information

We may collect personal information:

  • Directly from you when you create an account, contact us, use the Services or interact with our website.
  • From the organisation that has authorised your use of the Services.
  • From business systems, data sources and third-party services connected to the Services by or on behalf of a customer.
  • Automatically through the operation, security and monitoring of the Services and website.
  • From service providers, business partners and publicly available sources where lawful and relevant to our business activities.

4. How We Use Personal Information

We may use personal information to:

  • Provide, operate, maintain and support the Services.
  • Create and manage user accounts and authenticate users.
  • Process customer instructions and generate requested outputs.
  • Operate customer-configured integrations, connectors and workflows.
  • Respond to enquiries and provide customer support.
  • Communicate about the Services, including service, security and administrative notices.
  • Monitor security, performance, reliability, usage and capacity.
  • Improve and develop our products and Services using information we are permitted to use for those purposes.
  • Protect Cognaire, customers, users and the Services from misuse, fraud, security threats or unlawful activity.
  • Comply with legal, regulatory and contractual obligations.

Where Cognaire processes Customer Data on behalf of a customer, the purposes and permitted uses of that data are additionally governed by the applicable customer agreement and DPA.


5. Legal Bases Where UK Data Protection Law Applies

Where the UK GDPR applies and Cognaire acts as a controller, our legal basis for processing personal information will depend on the circumstances and may include:

  • Performance of a contract — where processing is necessary to provide Services or take steps requested before entering into a contract.
  • Legitimate interests — where processing is reasonably necessary for our business operations, security, service administration, product development, customer support or communications, and those interests are not overridden by the rights and interests of individuals.
  • Legal obligations — where processing is necessary to comply with applicable law or regulatory requirements.
  • Consent — where we rely on consent for a particular processing activity, including certain marketing or cookie activities where required by law.

Where Cognaire acts as a processor on behalf of a customer, the customer is generally responsible for determining the lawful basis for the underlying processing of Customer Data.


6. Customer Data and AI Processing

Where Cognaire processes personal information on behalf of a customer as part of providing the Services ("Customer Data"), Cognaire generally acts as a processor, service provider or equivalent role under applicable data protection law.

Customer Data may be processed to:

  • Provide, operate, maintain, support and secure the Services.
  • Generate outputs, analyses or recommendations requested by a customer.
  • Perform actions or workflows requested or authorised by a customer.
  • Operate integrations and exchange information with connected systems.
  • Troubleshoot, monitor and maintain the reliability and security of the Services.
  • Meet other purposes permitted by the applicable customer agreement, DPA and applicable law.

AI processing may be performed using managed cloud and model-provider environments selected and configured by Cognaire. Contractual rights and restrictions relating to the processing and use of Customer Data are governed by the applicable customer agreement and DPA, subject to applicable law.

Customer Data is not disclosed to other Cognaire customers except where expressly authorised by the relevant customer or otherwise permitted by law.


7. AI-Assisted Processing and Automated Workflows

The Services may use artificial intelligence and automated processing to analyse information, generate content, identify or rank relevant information, make recommendations, or assist with the execution of multi-step workflows.

Depending on the customer's use case, this may include analysis relating to business documents, questionnaires, recruitment information, candidate information or other business processes.

Cognaire provides technology that customers configure and use within their own business processes. Customers are responsible for determining how outputs, recommendations, rankings or workflow results are used and for applying appropriate human review where required by law, contract, policy or the nature of the decision.

AI-generated or automated outputs may contain errors, inaccuracies or omissions.

Where applicable law imposes specific transparency, human-review or other requirements in relation to profiling or automated decision-making, Cognaire and the relevant customer are responsible for complying with their respective obligations.


8. Disclosure of Personal Information

We may disclose personal information to:

  • Cognaire personnel and contractors who require access to provide or support the Services.
  • Other Cognaire group entities where reasonably necessary to operate our business or provide the Services.
  • Trusted service providers and subprocessors, including cloud hosting, infrastructure, AI inference, security, analytics, communications and support providers.
  • Professional advisers, including legal, accounting, insurance and security advisers.
  • Business counterparties in connection with a corporate transaction, financing, reorganisation or similar event, subject to appropriate confidentiality protections.
  • Government authorities, regulators, courts or other parties where required or authorised by law.

We do not sell personal information.


9. International Hosting, Processing and Transfers

Cognaire provides cloud-based Services and uses infrastructure and subprocessors in multiple jurisdictions.

Depending on the customer environment, configuration and services used, Customer Data and other personal information may be hosted or processed in:

  • Australia, including AWS Asia Pacific (Sydney) (ap-southeast-2);
  • the United States, including AWS US East (N. Virginia) (us-east-1);
  • the United Kingdom; and
  • other jurisdictions in which approved service providers or subprocessors operate.

AI inference and related processing may use regional, cross-region or global service endpoints. As a result, information may be processed in one or more approved locations, including multiple regions within the United States, depending on the service, model, customer environment and contractual arrangements.

Where a customer has agreed data-location or data-residency requirements with Cognaire, those requirements are governed by the applicable customer agreement, DPA or order form.

Where an international transfer is subject to specific legal requirements, we take steps designed to ensure an appropriate level of protection. These may include contractual protections, recognised transfer mechanisms, security measures, transfer assessments and other safeguards required by applicable law.


10. Data Security

We implement reasonable administrative, technical and organisational measures designed to protect personal information against unauthorised access, misuse, interference, loss, and unauthorised modification or disclosure.

Measures are selected having regard to the nature of the information, the Services and the risks associated with the processing.

While no system is completely secure, we regularly review and improve our security practices.


11. Data Retention and Deletion

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected or processed, or as otherwise required or permitted by law.

Customer Data processed on behalf of customers is retained and deleted in accordance with the applicable customer agreement, DPA and customer configuration.

Limited copies may remain in backups or records retained for legal, security, fraud-prevention, audit or operational-continuity purposes, subject to applicable retention requirements and access controls.


12. Your Privacy Rights

Depending on the laws that apply to you, you may have rights in relation to your personal information. These may include rights to:

  • Request access to personal information.
  • Request correction of inaccurate or incomplete personal information.
  • Request deletion of personal information in certain circumstances.
  • Object to or request restriction of certain processing.
  • Request portability of certain personal information.
  • Withdraw consent where processing is based on consent.
  • Raise concerns about certain automated processing or profiling where applicable.

To exercise a right in relation to personal information for which Cognaire is responsible, contact us using the details below. We may need to verify your identity before responding.

Where Cognaire processes Customer Data solely on behalf of a customer, requests concerning that Customer Data should generally be directed to the relevant customer. We will provide reasonable assistance to the customer where required by applicable law or contract.


13. Cookies and Analytics

Our website and Services may use cookies and similar technologies to operate the site and Services, remember preferences, maintain security, analyse usage and improve user experience.

Where required by applicable law, we will request consent before using non-essential cookies or similar technologies.

You can also control cookies through your browser settings and, where available, through cookie-management controls we provide.


14. Privacy Questions and Complaints

If you have a question, concern or complaint about how we handle personal information, please contact us using the details below.

We will assess the matter, may request additional information where reasonably necessary, and will seek to respond within a reasonable period.

Where applicable, you may also have the right to complain to a privacy or data protection regulator, including:

  • the Office of the Australian Information Commissioner (OAIC) in Australia; or
  • the Information Commissioner's Office (ICO) in the United Kingdom.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our Services, business practices, legal obligations or technology.

The current version will be available on our website and identified by the "Last updated" date.


16. Contact Us

For privacy enquiries, requests or complaints, contact:

Privacy Officer
Cognaire
Email: contact@cognaire.com

If your organisation has entered into a customer agreement with a specific Cognaire entity, you may also use the legal, privacy or notice contact details stated in that agreement.

See also our Terms of Service.