Privacy Notice

We take your privacy very seriously. Please read this Privacy Notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or the Regulator if you have a complaint.

This Privacy Notice does not apply to any third-party websites that may have links to our own website.

Who are we?

This Privacy Notice provides information on the processing of personal data by Cogent Breeding Ltd. We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation.

Key terms

It would be helpful to start by explaining some key terms used in this Notice:

We, us, our	Cogent Breeding UK Ltd of Beachin Stud, Lea Lane, Aldford, Chester, CH3 6JQ. We are part of the STgenetics Group, which consists of Inguran LLC and its global subsidiaries.
Personal data	Any information relating to an identified or identifiable individual
Special category personal data	Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic data Biometric data (where used for identification purposes) Data concerning health, sex life or sexual orientation
Data subject	The individual who the personal data relates to

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of our relationship with you.

Personal data we will collect

Your name, address and telephone number Information to enable us to check and verify your identity where required, eg your date of birth or passport details Contact details, eg your email address and mobile phone number Delivery details, such as a contact person and an address Your position and contact details within a company we have, or are seeking, a relationship with Information to enable us to undertake a credit or other financial checks on you Your financial and tax details so far as relevant to our relationship with you Information about your use of our website, IT, communication and other systems Any other personal data you may provide to us from time to time

We collect and use this personal data to provide services/products to you or your employer or to receive services/products from you or your employer. If you do not provide personal data we ask for, it may delay or prevent us from providing or employing those services.

How your personal data is collected

We collect most of the above information from you. However, we may also collect information:

• From your employer
• From publicly accessible sources;

• Directly from a third party, eg:
  • sanctions screening providers;
  • credit reference agencies;
  • customer due diligence providers;

• From a third party with your consent, eg:
  • your bank or building society, another financial institution or advisor;
• Via contacts us on our website
• From other entities within the STgenetics Group
• Via our information technology (IT) systems, eg:
  • via our case management, document management and time recording systems;
  • from door entry systems and visitor logs;
  • through automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems;

How and why we use personal data

Under data protection law, we can only use your personal data if we have a proper reason, eg:

• you have given consent—where we need your consent, we will ask for it separately of this Privacy Notice and you can withdraw consent at any time;
• to comply with our legal and regulatory obligations;
• to fulfil our contract with you/your employer or take steps at your request before entering into a contract; or
• for our legitimate interests.

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You have the right to object to processing based on legitimate interests. We must then stop the processing unless we can demonstrate compelling legitimate grounds which override your interests, rights and freedoms or that the processing is required to establish, exercise or defend legal claims.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Providing services/products to you	To fulfil our contract with you or to take steps at your request before entering into a contract
Receiving services/products from you	To fulfil our contract with you or to take steps at our request before entering into a contract
Providing services/products to your employer	For our legitimate interest, ie as a contact person to facilitate and maintain a business relationship with your employer
Receiving services/products from your employer	For our legitimate interest, ie as a contact person to facilitate and maintain a business relationship with your employer
Preventing and detecting fraud against you/your employer or us/our employees	For our legitimate interests, ie to minimise fraud that could be damaging for you/your employer and/or us/our employees
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, eg under health and safety law or rules issued by a professional regulator	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, ie to protect our business, interests and rights
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests
Ensuring internal business policies are complied with, eg policies covering security and internet use	For our legitimate interests, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information	Depending on the circumstances: —for our legitimate interests, ie to protect trade secrets and other commercially valuable information —to comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, services range or other efficiency measures	For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price
Protecting the security of systems and data used to provide services, preventing unauthorised access and changes to our systems	Depending on the circumstances: —for our legitimate interests, ie to prevent and detect criminal activity that could be damaging for you and/or us —to comply with our legal and regulatory obligations
Updating and enhancing customer records	Depending on the circumstances: —to fulfil our contract with you/your employer or to take steps at your request before entering into a contract —to comply with our legal and regulatory obligations —for our legitimate interests, eg making sure we can keep in touch with our customers about existing and new services
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	Depending on the circumstances: —to comply with our legal and regulatory obligations —for our legitimate interests, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of other companies within the STgenetics Group to existing and former customers and third parties	Depending on the circumstances: —for our legitimate interests, ie to promote our business —consent
Credit reference checks via external credit reference agencies	For our legitimate interests, ie to ensure our customers are likely to be able to pay for our services
External audits and quality checks, such as the audit of our accounts to the extent not covered by ‘activities necessary to comply with legal and regulatory obligations’ above	Depending on the circumstances: —for our legitimate interests, ie to maintain our accreditations so we can demonstrate we operate at the highest standards —to comply with our legal and regulatory obligations
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary	Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets

Where we process special category personal data (see above ‘Key terms’), we will also ensure we are permitted to do so under data protection laws, eg:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent;
• the processing is necessary to establish, exercise or defend legal claims; or
• the processing is necessary for reasons of substantial public interest.

Marketing

We may use your personal data to send you updates (eg by email, text message, telephone, post or social media channels) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. Where this is not the case, we will always ask for your consent.

In all cases, you have the right to opt out of receiving marketing communications at any time by:

• contacting us (see ‘How to contact us’ below);
• using any ‘unsubscribe’ link in emails.

We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

We will always treat your personal data with the utmost respect and never sell it to other organisations outside of the STgenetics Group for marketing purposes.

Who we share your personal data with

We routinely share personal data with:

• companies within the STgenetics Group;
• third parties we use to help deliver our services to you, eg providers of our CRM, finance system and other software platforms, IT service providers including cloud service providers such as data storage platforms, shared service centres and financial institutions in connection with invoicing and payments;
• third party external advisors, eg lawyers, tax advisors, accountancy and technology service providers;
• companies providing services for money laundering checks and other crime prevention purposes and companies providing similar services, including financial institutions and credit reference agencies;
• other third parties we use to help promote our business, eg marketing agencies;
• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
• our insurers and brokers;
• our banks.

We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We ensure all outsourcing providers operate under service agreements that are consistent with our legal obligations.

We or the third parties mentioned above may occasionally also share personal data with:

• our (and their) external auditors, eg in relation to the audit of our (or their) accounts, in which case the recipient of the information will be bound by confidentiality obligations
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers), in connection with a significant corporate transaction or restructuring, including a merger, acquisition or asset sale or in the event of our insolvency. Usually, information will be anonymised but this may not always be possible and the recipient of any of your personal data will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

Where your personal data is held

Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data abroad’.

How long your personal data will be kept

We will not keep your personal data for longer than we need it for the purpose for which it was collected or as required by law.

As a general rule, we will keep your personal data for at least seven years from the conclusion of any contractual relationship we have with you/your employer. However, different retention periods apply for different types of personal data and for different services. Specific retention periods for Personal Data we processes is outlined in our Retention Schedule, a copy of which is available on request (see ‘How to contact us’ below).

Following the end of the of the relevant retention period, we will delete or anonymise your personal data.

Transferring your personal data abroad

It is sometimes necessary for us to transfer your personal data to countries outside the UK. This may include countries which do not provide the same level of protection of personal data as the UK.

We will transfer your personal data outside the UK only where:

• the UK has decided the recipient country ensures an adequate level of protection of personal data (known as an adequacy decision); or
• there are appropriate safeguards in place (eg International Data Transfer Agreements) published or approved by the data protection regulator), together with enforceable rights and effective legal remedies for you; or
• a specific exception applies under data protection law.

We regularly share personal data with our parent company, Inguran LLC in the US and have implemented appropriate safeguards in the form of an International Data Transfer Agreement.

You can contact us (see ‘How to contact us’ below) if you would like a list of countries benefiting from a UK adequacy decision, for copies of any appropriate safeguards we have implemented or for any other information about protection of personal data when it is transferred abroad.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal data.
Rectification	The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations.
Restriction of processing	The right to require us to restrict processing of your personal data—in certain situations, eg if you contest the accuracy of the data.
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object	The right to object: —at any time to your personal data being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.
The right to withdraw consent	If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time. You may withdraw consents by contacting our DPO (see ‘How to contact us’ below). Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn.

If you would like to exercise any of those rights, please:

• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself (eg your full name, address) and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal data secure

We have implemented appropriate technical and organisational measures to keep your personal data confidential and secure from unauthorised access, use and disclosure. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.

We require our business partners, suppliers and other third parties to implement appropriate security measures to protect personal data from unauthorised access, use and disclosure.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are required to do so.

How to complain

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You may also have the right to lodge a complaint with the Regulator, the Information Commissioner, whose contact details can be found at https://ico.org.uk.

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. When we do we will publish the updated version on our website.

Updating your personal data

We take reasonable steps to ensure your personal data remains accurate and up to date. To help us with this, please let us know if any of the personal data you have provided to us has changed, eg your name or contact details—see below ‘How to contact us’.

How to contact us

You can contact us by post, email or telephone if you have any questions about this Privacy Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Our contact details
Cogent Breeding Ltd Beachin Stud, Lea Lane, Aldford, Chester, CH3 6JQ. Tel: 0800 783 7258 privacy@stgen.com

Do you need extra help?

If you would like this Notice in another format (for example audio, large print, braille) or another language please contact us (see ‘How to contact us’ above).