Privacy Policy

1. Who we are (data controller)

CogRank is the business name of Matanie Bogdan Constantin, an independent consultant registered as an autónomo in Spain, who acts as the data controller for personal data processed through this website and our outreach.

• NIF/NIE: Y9371555N
• Registered address: Avda. Hispanidad (PM) Nº 1 R, Esc. 1, Planta 02, Pta. D, 11360 San Roque (Cádiz), Spain
• Correspondence address: 15 Queen Square, Bristol, BS1 4NT, United Kingdom
• Contact: [email protected]

2. The personal data we collect

• Enquiry form: your name, email address, clinic name (optional) and the message you send.
• B2B outreach contacts: business contact details (name, role, work email, practice) sourced from professional and business directories for B2B outreach.
• Server logs: technical data such as IP address and browser type, processed by our hosting provider for security and reliability.

3. How and why we use your data (lawful basis)

• Responding to enquiries — to reply to and act on your enquiry (performance of, or steps towards, a contract, and our legitimate interest in responding to business enquiries).
• B2B outreach — to contact dental practices about relevant services, relying on legitimate interest. We keep a Legitimate Interest Assessment and honour all opt-outs immediately.

4. Cookies & analytics

This website does not set any cookies and does not use third-party analytics or tracking scripts. No consent banner is required because no non-essential cookies are placed on your device.

5. Who we share data with (processors)

We use the following processors, each under appropriate contractual terms:

• Cloudflare — hosts the site (Cloudflare Pages), serves it via its CDN, and runs the serverless function that receives contact-form submissions.
• Google (Google Workspace / Gmail) — delivers contact-form enquiries to, and stores them in, our email inbox.
• Apollo.io — used to source and manage B2B outreach contacts.

6. International transfers

As the controller operates from Spain (EU/EEA) serving UK clients, data may be transferred between the EU/EEA and the UK. These transfers are covered by the EU–UK adequacy decisions (June 2021), which recognise both jurisdictions as providing an adequate level of data protection. Transfers to other processors rely on standard contractual clauses or equivalent safeguards.

7. How long we keep it

• Enquiry data: retained for up to 24 months after our last communication, then deleted.
• B2B outreach contacts: retained until you opt out, plus 30 days to process the suppression.
• Server logs: retained by Cloudflare for a maximum of 30 days.

8. Your rights

Under UK GDPR and the EU GDPR, you have the right to access, rectify, erase, restrict or object to processing of your personal data, to data portability, and to opt out of marketing at any time. To exercise any of these rights, email[email protected]. Every outreach email also contains a one-click opt-out.

9. Complaints

If you have a concern, please contact us first so we can resolve it. You also have the right to complain to a supervisory authority — in the UK the Information Commissioner's Office (ICO, ico.org.uk), and in Spain the Agencia Española de Protección de Datos (AEPD,aepd.es).

10. Changes to this policy

We may update this policy from time to time. The "last updated" date above reflects the most recent change.