Kogenta Privacy Policy
Last Updated: 5 December 2025
Privacy by Design: Aggregated Data You Can Trust
Kogenta Connect is built on a simple principle: powerful insights do not require Personal Data.
The vast majority of our Data Layers—our geospatial grid, movement and busyness layers, contextual indices, POI datasets, survey layers, modelled flows, and AI-enhanced analytics—operate entirely on aggregated, anonymised, or synthetic data. This data is securely anonymised and, therefore, falls outside the scope of the General Data Protection Regulation (GDPR).
We process Personal Data (as defined by the GDPR) only in very specific circumstances. This typically occurs when our client requires one of our Specialist Data Layers. In this case our SDK is integrated into a client’s mobile application. The second scenario is when our Customer and Data Controller instruct us to process their first party data that may contain Personal Data. In both cases, we adhere to strict standards:
- Only the minimum data required is collected;
- All Personal Data is anonymised or pseudonymised as early as technically possible in the processing chain; and
- Users retain full control, including the ability to stop sharing or delete their data at any time.
Privacy is foundational to the Kogenta Connect platform and is embedded into our technology, processes, and culture.
Transparency and User Control
We believe that users should always know what data is being collected and why. Applications that integrate Kogenta technology must clearly present:
- What data may be captured;
- How that data is used (the purposes of processing);
- The benefits of sharing; and
- How users can manage or withdraw consent.
End users can change their preferences or delete all previously collected data directly in the app’s privacy settings—no support request needed.
Roles in the Kogenta Ecosystem (GDPR Roles)
When Personal Data is processed, we distinguish between the following roles in accordance with the GDPR:
Role | Definition | Kogenta’s Function |
End User (Data Subject) | Controls their Personal Data and chooses whether to share it. Consent can be withdrawn at any time. | N/A |
Controller (Application Owner) | Determines the purpose and means of processing (i.e., why data is collected) and holds the direct customer relationship with the End User. Kogenta never processes Personal Data without a Controller. | N/A |
Kogenta (Data Processor) | Acts exclusively as a Data Processor and processes Personal Data strictly on behalf of and under instruction from the Controller. We never determine the purpose of processing. | We are a Data Processor for data collected. |
Location User | May deploy beacons or sensors to support Kogenta Connect services. They only receive aggregated, anonymous insights—never Personal Data. | N/A |
How Kogenta Processes Data
Kogenta processes data in strict compliance with European data protection laws (including the GDPR) and applies rigorous privacy-by-design standards across all products.
When Using Kogenta-Powered Applications
If an End User provides explicit consent, an application may collect:
- Location data;
- Device signals;
- Preferences related to notifications or app functionality.
Lawful Basis for Processing: The legal basis for the processing of this Personal Data is the explicit and informed consent of the End User (GDPR Article 6(1)(a)).
Kogenta, acting as the Data Processor, securely processes this data upon instruction from the Controller to enable the specific features and services the user has opted into. Users may also choose whether data from multiple Kogenta-enabled apps on their device can be combined to improve relevance, provided separate consent is given. Combined datasets are never shared externally.
Geospatial & Analytical Data Layers (Core of Kogenta Connect)
The core of Kogenta Connect—our maps, movement and location data layers, contextual datasets, and derived analytics—do not require Personal Data. These layers are created using aggregated, anonymised, or modelled data sources and can never identify an individual.
Anonymous Insights
Aggregated insights (e.g., footfall, busyness patterns, catchment analysis, OD flows) may be shared with market participants. These datasets contain no personal identifiers and are not classified as Personal Data.
Website Data Collection
- Cookies: Kogenta.com uses cookies to enhance performance and understand how visitors use our site. You may adjust cookie settings in your browser; some functionality may be affected if you disable them.
- Links to Other Websites: Our website may include links to third-party sites, which operate under their own privacy policies. Kogenta is not responsible for their practices.
Your Rights
End users have the full set of rights afforded by the GDPR, including the right to:
- Access their Personal Data;
- Request deletion or correction;
- Withdraw consent at any time;
- Request data portability.
Self-Service Data Access: Our technology, including the SDK, supports automated processes that allow you to directly view the collected and processed Personal Data via the application utilizing Kogenta Connect services.
To exercise your rights (such as access, rectification, or erasure), you must always contact the Controller (Application Owner), as they own the customer relationship and determine the purpose of the processing. Kogenta, as the Data Processor, can only respond to such requests upon instruction from the Controller.
Right to Lodge a Complaint: You also have the right to lodge a complaint regarding the processing of your Personal Data with the relevant Supervisory Authority.
Security and Data Protection
Kogenta employs strong security controls across all infrastructure, including:
- Encrypted data transmission;
- Secure, access-controlled cloud environments;
- Early-stage anonymisation and pseudonymisation;
- Continuous monitoring and privacy-by-design engineering practices.
Data Location and Transfers: All data processing and storage primarily occurs within the European Economic Area (EEA). If any data transfer outside the EEA is necessary, it is conducted only in strict compliance with Chapter V of the GDPR (e.g., using Standard Contractual Clauses).
These safeguards protect Personal Data and ensure the integrity of our anonymised and aggregated products.
Changes to This Policy
We may update this Privacy Policy occasionally. The latest version will always be available on our website, and material changes will be clearly indicated.
Contact Us
If you have questions about this Privacy Policy or how Kogenta processes data, please contact:
Email: privacy@kogenta.com
Contact Page: kogenta.com/contact
We value your feedback and are committed to continuously improving our privacy standards as Kogenta Connect evolves.