Kogenta Privacy Policy

The end user has the control

Kogenta will always focus on being transparent when it comes to data collection and the processing of this data. It’s important to us that our customers and the end users know they are taken care of.

The end user has to actively give their informed acceptance to share information with our technology, and will always have the opportunity to stop sharing, as well as delete all data gathered. We give the end user control over their own data.

As a Kogenta customer (Application Owner) you get access to policies that must be integrated into your application’s Terms and Conditions.

Kogenta has, in cooperation with lawyers specialised within the data privacy field, prepared a set of texts that should be used both in direct communication with the end user of the application, as well as within the company’s Terms and Conditions. This can ensure that the interests of the Application Owner (your company) and the end user (your customer) are safeguarded according to the requirements of privacy and direct marketing legislation.

Three Key Roles

End User, Application Owner & Location User

In our experience there are three main roles that are essential to consider in order to utilise our technology.

END USER

The User of the application is the owner of their own personal information, and is always in charge of the collected data. When the User downloads and installs an application with integrated Kogenta technology, they are asked if they wish to share their information with the Application Owner and our technology. This is where the User will be presented with the terms and conditions that describe how the data is processed, as well as examples on what this data is used for. The User chooses whether they wish to give active informed consent to share information. This acts as an opt-in.

Should the User later wish to stop sharing information, they can do so without uninstalling the application or turning off Bluetooth on their smartphone. This is possible by accessing the settings in the application and turning off data sharing. Should the User also wish to delete data that has already been shared, they can also do so in the application settings.

APPLICATION OWNER

The Application Owner has the responsibility to provide a service to the User, as well as process shared data. They are responsible for the data collected, and our technology has access to process the data that the user has chosen to share.

The Application Owner can communicate directly to the User via the technology when e.g. the User is in close proximity to a beacon connected to the technology network. It is the Application Owner who is in charge of the customer relationship with the user.

LOCATION USER

A Location User is a role that does not have an application, but has placed and utilise beacons that are part of the Kogenta technology infrastructure. The Location User has no immediate access to the data collected from the Application Owner, but can often accesses the anonymised aggregated data provided through our technology.

Our technology is valuable for both Location User and Application Owners, even though the need and functionality can differ.

There are also many actors that possess both the role of the Application Owner, as well as the role of the Location User.

How you control your data within the app

It is very important to us that you are in control of your own data and what you chose to share with our technology. In addition to providing active informed consent to share your information, you always have the opportunity to stop the data sharing and delete existing collected data collected by our technology.

You Decide

The first time you open a mobile application that has integrated the Kogenta technology, you are asked if you want to share your location and if you would like the application to send you push messages. It is very important for us at Kogenta that you have full access to read the Terms and Conditions for the application, which should be shown on the same page.

If you chose to use Kogenta technology in your mobile application, it’s important that you review the terms of use of the application. The terms are quality assured by lawyers, and are primarily created to ensure that you have an immediate overview of who has accessibility to process your data. In addition, it is important to us that you are able to easily understand what the data collected can be used for.

Change Your Mind

As a standard in Kogenta technology, we have made it simple for you to easily access your mobile applications settings and turn data sharing on and off. You can choose ‘Custom Content’ and prevent data collection and/or collection of location data, and consequently no content will be sent to our technology.

In this way, we make it easy for you to make a choice to share your data, along with what type of data you share, and still have the opportunity to change your mind at any time. This will allow you to still use the mobile application without having to turn off Bluetooth or uninstall the application.

Delete Your Data

If you wish to delete all registered data associated with your user profile, you have the opportunity to do so within the ‘Custom Content’ page in the application. At the bottom of the page you have the choice to delete all data by selecting ‘Delete all data about my user profile’. This way you have complete control over what data you share and the power to delete all the data from your user profile. Promptly disallowing the application and Kogenta technology to collect data from your device, without uninstalling the application.

How we process data

Your privacy is important to us

This page covers how we collect, use, disclose, and store your information when you visit our website (kogenta.com), and when using applications based on our technology.

Kogenta processes your data in compliance with applicable European (Norwegian) laws on data protection, information security and consumer protection.

This Privacy Policy does not apply to any links to third party websites and/or services that you may encounter when visiting the website. Please be aware that Kogenta is not responsible for the privacy practices of any third parties.

Collection of information on our website

Use of cookies

Our website, kogenta.com, uses cookies. A cookie is a small data file sent from our website and stored on your computer. We use cookies to improve your user experience by making the website work more efficiently, as well as to provide us with statistical information about the use of our website.

If you wish to manage or opt out of using cookies, you can do so by setting your browser to not accept certain or all cookies. Please check your browser’s information page, or visit the following site on how to manage cookies: aboutcookies.org

If you choose to not accept cookies, Kogenta cannot guarantee that our website will work properly.

Collection of information

Using Kogenta technology

Kogenta has developed and owns the our technology. This technology enables our customers to gain end-customer insights, offer value added services based on sensors and mobile applications, and enables real-time registration of the physical location of the users of the application.

Kogenta will only license our technology to customers who commit to comply with all current and applicable data protection laws, as well as the terms and conditions accepted by the user. As an end-user of applications that utilises Kogenta technology, you will be in control of your own data. All processing of personal data administered by our technology is based on the end-user’s informed consent, and all users are offered an opportunity to opt out.

Roles and responsibilities

Kogenta operates as a data processor for our customers using our technology. That is for the processing of personal data, for providing you with relevant information in the app, and/or through other channels (see more below).

Note that Kogenta is not liable for the processing of personal data carried out by the owner of an application using Kogenta technology.

Collection of data

When an end-user installs an application using Kogenta technology, the app owner will collect information that can be related to a person as an individual (personal data).

The following categories of information may be collected:

Physical location

When you use an app that utilises our technology, Kogenta will register the mobile device’s location. Registration of location will only take place when you have:

  1. Accepted location based services in the mobile device’s operating system (only iOS).
  2. Given your consent in the application to registration of localisation even when the application is not active.

Information collected from the mobile device

The application may request your consent to have access to information/functions on your mobile device, e.g. location and/or notifications. If you have consented to this, Kogenta will – on behalf of the app owner – collect data about your device and internet connection, e.g. about your operative system, device manufacturer and network ID.

Compilation

If you have several applications which use Kogenta technology on your phone, Kogenta may compile personal data collected from all these apps to make information and services even more relevant to you. The technology provides an opt out opportunity with respect to such compilation.

Note that Kogenta will not share the compiled data sets with anyone.

Google Ads

Kogenta uses Google Ads (previously Google AdWords) as an online marketing measure, to advertise our products and services. We use data to tailor our advertising advertising campaigns to reach only those people who are interested in our offers. The data also lets us calculate our cost-benefit-factor, measure the success of individual ad campaigns and thereby optimising our online marketing measures.

Purpose for collecting the data

The purpose of the processing of personal data is partly decided by the owner of the application using Kogenta technology.

A: PROVISION OF SERVICES

Generally the purpose decided by the application owner will be to provide you with relevant information, services and marketing messages / advertisement.

Location based technologies provides several possibilities, e.g.:

      1. When you enter a shop the staff is notified and may extend personalised service, as well as offers tailored to your needs and preferences.
      2. You may be provided with information and offers tailored to the specific location, either through the mobile device or through local digital screens.

B:  MARKETING

Kogenta does not gather data sets such as IDFA or AdID. Hence Kogenta does not offer services related to retargeting of app users or similar marketing features.         

C: STATISTICS

Anonymous data sets (statistics) may be used towards market players who want to gain insights into customer behaviour, for example the number of visitors to a specific sales outlet or public transport stop. These data sets are completely anonymous (meaning they only exist on an aggregated level).

Legal basis for collection of data

Processing of personal data administered by Kogenta technology for the purpose of providing you with relevant information in the app (ref. point A above) is based on your informed and explicit consent. You may at any time withdraw your consent in the app using Kogenta technology.

  1. At any time, you – as an end user – have the right to opt-out of the use of personal data for this purpose.
  1. Kogenta removes all information that can directly identify you as a person. This renders the data sets anonymous. Anyone who would want to try to re-identify the person behind the data would have to put a considerable effort into this.
  1. The information is stored in a secure cloud environment, which is only accessible to Kogenta employees.
  1. Applicable data protection laws do not cover processing of anonymous data (ref. point C above). Accordingly no legal basis is required for this purpose.

Access, rectification and deletion of data

You have the right to request access to your personal data held by any app using our technology, as well as exercising other rights, such as the right to data portability. Access requests or other rights requests regarding personal data held by apps, must be directed to the relevant application owner. Accordingly, access to de-identified data held by Kogenta is not possible, unless you provide us with additional information enabling your identification.

Your personal data will be retained as long as necessary to fulfil the purpose of the processing of the personal data on behalf of the app owner. Normally this is six months. Unless there is a mandatory statutory requirement to store the data for a longer period, the data will then be deleted.

You have the right to request that your personal data are deleted or rectified at any time. Deletion of data can be carried out by choosing ‘Delete all data related to my profile’ in the application settings. This functionality is provided by Kogenta technology.

Data protection by design

Kogenta uses several security technologies to protect personal data against unauthorised access, inter alia, by storing personal data on servers with limited access in security-monitored locations, and by use of a third-party service for the purpose of effective de-identification of data sets. Transfer of personal data over the Internet is always protected by use of encryption.

Changes to the Privacy Policy

We may update this Privacy Policy from time-to-time by posting a new version on our website. You should revisit this page occasionally to ensure that you are happy with any potential changes.

Contact

If you have questions to this Privacy Policy, or other questions related to the our technology, please send an email to: privacy@kogenta.com 

Or contact Kogenta here.

We appreciate your feedback and will do our best to answer your questions and adapt the services to the expectations of our users. 

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