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Privacy Policy

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Cogton — cogton.com 

Last updated: April 2026 

 

1. Who We Are 

Cogton is a packaging optimisation consultancy. The company is operated by Santiago Erreguerena, based in Luxembourg. 

 

  • Website: cogton.com 

 

For the purposes of EU data protection law (GDPR — Regulation (EU) 2016/679), Cogton is the data controller in respect of the personal data collected through this website. 

 

2. What Personal Data We Collect 

2.1 Contact form 

When you submit the contact or cost reduction analysis form on this website, we collect: 

  • Full name 

  • Company name 

  • Work email address 

 

This data is submitted voluntarily by you and is used solely to respond to your enquiry. 

2.2 Booking via Calendly 

If you book a call through the Calendly link on this website, Calendly collects your name, email address, and any other information you provide when scheduling. Calendly acts as a separate data controller for data processed on its platform. You can review Calendly's privacy policy at calendly.com/privacy. 

2.3 Website analytics and cookies 

This website is built on Wix. Wix may collect technical data about your visit including your IP address, browser type, pages visited, and time spent on the site, for the purposes of website analytics and performance monitoring. Wix uses cookies to enable certain website functions. 

 

For more information on how Wix processes data, please refer to Wix's Privacy Policy at support.wix.com/en/article/wix-privacy-policy. 

2.4 Data you send by email 

If you contact us directly by email, we will retain your name, email address, and the contents of your message in order to manage our correspondence with you. 

 

3. How We Use Your Data 

We use the personal data we collect for the following purposes: 

  • To respond to enquiries submitted through the contact form or by email 

  • To schedule and manage introductory or project calls booked through Calendly 

  • To understand how visitors use our website and improve its content and performance 

  • To maintain records of business correspondence 

 

We do not use your personal data for automated decision-making or profiling. 

 

4. Legal Basis for Processing 

We process your personal data on the following legal bases under the GDPR: 

  • responding to your enquiries and managing business communications, where our interests are not overridden by your rights.Legitimate interests:  

  • where you have voluntarily submitted your data through the contact form or booking tool.Consent:  

  • where we are required to retain certain records under applicable law.Legal obligation:  

 

5. How Long We Keep Your Data 

We retain personal data only for as long as necessary for the purposes described in this policy: 

  • Contact form enquiries and email correspondence: retained for up to 3 years from the date of last contact, unless a longer retention period is required by law or necessary for an ongoing business relationship. 

  • Website analytics data: retained in accordance with Wix's data retention policies. 

 

When data is no longer needed, it is securely deleted or anonymised. 

 

6. Who We Share Your Data With 

We do not sell, rent, or trade your personal data. We may share your data with the following third-party service providers, solely to the extent necessary to operate this website and deliver our services: 

  • website hosting and analytics platform.Wix.com Ltd:  

  • appointment scheduling.Calendly LLC:  

  • email communication and document management.Google (Gmail/Workspace):  

 

All third-party providers are required to process your data in accordance with applicable data protection law. Where providers are located outside the European Economic Area (EEA), we ensure appropriate safeguardsare in place, such as standard contractual clauses approved by the European Commission. 

 

7. Your Rights Under the GDPR 

If you are located in the European Union or European Economic Area, you have the following rights in relation to your personal data: 

  • you can request a copy of the personal data we hold about you.Right of access:  

  • you can ask us to correct inaccurate or incomplete data.Right to rectification:  

  • you can ask us to delete your personal data in certain circumstances.Right to erasure:  

  • you can ask us to limit how we use your data.Right to restrict processing:  

  • you can ask us to provide your data in a structured, machine-readable format.Right to data portability:  

  • you can object to processing based on legitimate interests.Right to object:  

  • where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of prior processing.Right to withdraw consent:  

 

To exercise any of these rights, please contact us at santiago@cogton.com. We will respond within 30 days. You also have the right to lodge a complaint with the supervisory authority in your country of residence. In Luxembourg, the relevant authority is the Commission Nationale pour la Protection des Données (CNPD) at cnpd.public.lu. 

 

8. Cookies 

This website uses cookies — small text files stored on your device — to enable website functionality and collect analytics data. Cookies used on this site include: 

  • necessary for the website to function correctly. These cannot be disabled.Essential cookies:  

  • used by Wix to understand how visitors interact with the site. These may be disabled through your browser settings or the Wix cookie consent tool.Analytics cookies:  

 

You can control cookies through your browser settings. Disabling certain cookies may affect the functionality of the website. 

 

9. Data Security 

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. Data submitted through the contact form is stored within Wix's secure infrastructure. Email communications are managed through Google Workspace, which operates under industry-standard security protocols. 

 

No method of transmission over the internet is completely secure. While we take appropriate precautions, we cannot guarantee the absolute security of data transmitted to us electronically. 

 

10. Links to Third-Party Websites 

This website may contain links to external websites, including Calendly and LinkedIn. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing any personal data. 

 

11. Changes to This Privacy Policy 

We may update this privacy policy from time to time to reflect changes in our practices or applicable law. When we do, we will update the 'Last updated' date at the top of this page. We encourage you to review this policy periodically. 

 

12. Contact Us 

If you have any questions about this privacy policy or how we handle your personal data, please contact: 

 

Santiago Erreguerena 

Founder, Cogton 

Email: info@cogton.com 

Website: cogton.com 

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