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The effective date of this disclosure is January 1, 2021. This is a first-time disclosure.

The purpose of this document is to provide information regarding Network Management Practices, Performance Characteristics, and Commercial Terms as they apply to broadband Internet access services provided by Cogent Communications, Inc. (Cogent) in accordance with the Federal Communications Commission's (FCC's) transparency rule 47 CFR § 8.1(a). Cogent’s Filer Registration Number (FRN) with the FCC is 0019898303. Cogent provides broadband internet access to its customers over our fiber optic, IP data-only network.

Cogent practices net neutrality. Cogent treats all traffic equally, without discrimination, restriction or interference, and irrespective of the sender and receiver, the content accessed or distributed, the applications or services used or provided, or the terminal equipment used. Customers have the right to access and distribute lawful information and content, use and provide applications and services, and use terminal equipment of their choice, as long as the equipment is technically compatible with the applicable service interface, irrespective of the Customer’s or Cogent’s location or the location, origin or destination of the information, content, application or service.

Network Management Practices

Blocking.
Cogent does not block, slow down, alter, restrict, interfere with, degrade or discriminate between specific content, applications or services, or specific categories thereof, except as necessary, and only for as long as necessary, in order to: (a) comply with applicable law, including with orders by courts or public authorities vested with relevant powers; (b) preserve the integrity and security of the Cogent network, of services provided via the Cogent network, and of the terminal equipment of Customers; (c) prevent impending network congestion and mitigate the effects of exceptional or temporary network congestion, provided that equivalent categories of traffic are treated equally.

Throttling.
Cogent does not throttle traffic, does not block, slow down, alter, restrict, interfere with, degrade or discriminate between specific content, applications or services, or specific categories thereof, except as necessary, and only for as long as necessary, in order to: (a) comply with applicable law, including with orders by courts or public authorities vested with relevant powers; (b) preserve the integrity and security of the Cogent network, of services provided via the Cogent network, and of the terminal equipment of Customers; (c) prevent impending network congestion and mitigate the effects of exceptional or temporary network congestion, provided that equivalent categories of traffic are treated equally.

Affiliated Prioritization.
All Internet access traffic is treated equally on the Cogent network. No traffic is favored, directly or indirectly, over other traffic. Cogent does not utilize any Affiliated Prioritization.

Paid Prioritization.
All Internet access traffic is treated equally on the Cogent network. Cogent does not utilize any Paid Prioritization. Cogent does not prioritize packet transmissions on the basis of the content of the packet, the customer or network that is the source of the packet, or the customer or network that is the recipient of the packet.

Congestion Management.
Where there are network problems such as congestion at interconnection points or fiber cuts, Cogent implements automated reasonable traffic management measures that will go in effect only during such congestion or fiber cuts to minimize harm to the users of our network. Such measures are transparent, non-discriminatory and proportionate, do not monitor the specific content, are only maintained as long as they are necessary and are not based on commercial considerations, but on objectively different technical quality of service requirements of specific categories of traffic. The restrictions of the services may impact the quality of the services and, in particular, may consist of limitation of the speed, volume, latency, bandwidth, jitter, packets transmitted and/or impact other parameters of the services, which may for as long as necessary lead to extend downloading or uploading time and reduce the customer’s possibility to access internet or use content, applications and services over the internet.

Application-Specific Behavior.
Cogent does not apply any application specific behavior.

Device Attachment Rule.
Within the constraints set forth in our Terms of Service Cogent will allow customers to connect any device to our network, provided that said device or its usage does not cause harm to our network. We cannot guarantee the compatibility of any particular device. Otherwise, Cogent does not have device restriction rules.

Security.
Cogent employs firewalls and other protective measures to protect and secure its internal administrative and network management networks. Cogent does not provide end user security and it is the responsibility of the customer to deploy network elements at appropriate network locations to protect their networks. We encourage all of our customers to protect themselves from malicious and unwanted content by a number of means, including a host of commercially available anti-virus, firewall, anti-malware, and other similar products. We also encourage strong password management to prevent unauthorized access to customers’ accounts and equipment. The customer is ultimately responsible for their security while utilizing our network.

Performance Characteristics

Service Description.

Cogent is one of the world's largest Internet Service Providers, delivering high quality Internet, Ethernet and Colocation services to over 118,279 Enterprise and NetCentric customers. Cogent serves over 302 markets in 57 countries across its facilities-based, all-optical IP network. Cogent does not provide any specialized services, only dedicated Internet Access. Cogent’s dedicated Internet access service is dedicated and non-oversubscribed and is based on dedicated symmetrical connectivity, fiber-based Ethernet technology, and reliable service backed by local customer support centers and an industry leading Service Level Agreement (SLA). The specifications of the service are laid out in the applicable product rider. With dedicated Internet access service, a port on the Cogent network is reserved just for each customer to ensure that they always get a dedicated symmetrical connection. Cogent’s network is engineered so that all of customer’s bandwidth is available all of the time, both for download and upload.

COGENT offers FastE, 10GigE and 100GigE speeds to customers in both On-Net and Off-Net locations:
- On-Net Internet Access - In buildings directly connected to Cogent’s fiber network: Fast Ethernet (100 Mbps and 200 Mbps - 1 Gbps) and 10 Gigabit Ethernet (2 Gbps - 10 Gbps)
- Off-Net Internet Access - Cogent connects you to its fiber network via local loop: Fast Ethernet (50 Mbps - 100 Mbps); Gigabit Ethernet (200 Mbps - 1 Gbps) and 10 Gigabit Ethernet (2 Gbps - 10 Gbps)

The minimum, maximum, normally available and advertised download and upload speed of the service ordered is the same and is specified on the order form, i.e. if customer orders 100 Mbps circuit, the minimum, maximum, normally available and advertised speed is 100 Mbps.

Cogent’s network is layer-3-protected and built in a series of rings. In the event of a fiber cut, data is rerouted away from the cut, reaching the customer from the other direction and keeping customer connected. Cogent proactively monitors customer services from Cogent’s Network Operations Centers (located in Washington, D.C. and Herndon, Virginia as well as in Europe in Frankfurt, Germany; Madrid, Spain and Paris, France) and answers support calls quickly. Local support teams and online account management are available 24x7x365.

Our network latency is disclosed on our website under the following link: https://cogentco.com/en/network/performance-tools

Impact of Non-Broadband Internet Access Service Data Services.
Cogent does not offer non-broadband Internet access service data services.

Commercial Terms

Price.

Cogent prices its services on an individual case basis, based on the regional market and the specific needs of the potential customer ;regarding the type of service, bandwidth selection and the initial term ranging from one to five years. The available speed and price packages are disclosed and agreed to at time of contract negotiation. If customer orders burstable services, we also charge usage-based fees. Otherwise, customers pay flat monthly recurring fee for their service. Cogent also charges a one-time installation charge for the service. Cogent’s standard Terms and Conditions include provisions for early termination fees. The standard service early termination fee is 100% of the remaining term monthly recurring charge. Additional charges may apply for related network services such as static IPv4 addresses. Current customers, as well as prospective customers can obtain current pricing information by contacting us via any of the contact methods on our website.

Privacy Policies.

Cogent provides a utility-like service for transit of data. Cogent does not inspect customer traffic.  Cogent does not store, access or manipulate data at any point on our network. We accept the data packets (encrypted or not encrypted) and deliver those packets over the Internet to the designated recipient. Cogent does not provide any end user software, and data security is the responsibility of Customers including the encryption of any data that is pushed on to the Internet at the demarcation point with Cogent’s network. Customer’s privacy is very important to us.  Cogent does not intend to process personal data for the purpose of ensuring net neutrality. To the extent that Cogent’s traffic management measure entails processing of personal data, Cogent shall only process them to the extent that processing is necessary and such processing is carried out in accordance with applicable legislation. Personal information that our customers provide to Cogent is governed by Cogent’s Privacy Policy, which is subject to change from time to time. Cogent’s Privacy Policy is stated on our website under: https://cogentco.com/en/privacy-policy and Cogent California Privacy Policy is available under the following link: https://cogentco.com/en/ccpa.

Redress Options.

For any questions regarding this disclosure you can email This email address is being protected from spambots. You need JavaScript enabled to view it. or call our headquarter office at (202)-295-4200. For customer service questions, Cogent's support group is available to you 24 hours a day. Please visit our Support Desk page for full contact information: https://cogentco.com/en/customer-service. Our support engineers will respond and open a trouble ticket to keep track of your inquiry until resolution. You may also elect to visit Cogent's online account management portal eCogent, which allows you to open a ticket with our support team, perform online configuration updates, such as DNS change requests, and update your contact information. If you need to report an abuse complaint, please contact our This email address is being protected from spambots. You need JavaScript enabled to view it. team (This email address is being protected from spambots. You need JavaScript enabled to view it.). For billing questions and issues, you can send an email to This email address is being protected from spambots. You need JavaScript enabled to view it.. Cogent’s obligations and Customer’s exclusive remedies for a delayed or failed installation of a service or the failure of performance of Cogent’s network or any service are stated in the Cogent Service Level Agreement available at: http://www.cogentco.com/files/docs/network/performance/global_sla.pdf. In order to initiate a claim for service credit, Customer must contact Cogent’s customer service group via email or phone. (Contacts available at http://www.cogentco.com/en/customer-service). Service Credit claim process is detailed in the Service Level Agreement. Cogent Escalation Procedures have been established for notifying upper management of customer service and operational system problems. Cogent Escalation Procedures and escalation contacts are provided to customers in a document called Cogent Customer User Guide, which is provided to Customer upon signature of the contract. Cogent tries to resolve all customer complaints expeditiously and amicably. In the event that a customer is not satisfied with the resolution of potential dispute with Cogent, the customer may bring an action against Cogent in the court of and in accordance with the laws of the state stated in our Terms and Conditions for the service.

Cogent reserves the right to amend these Open Internet Access Disclosures at any time, effective upon posting on the Cogent website.

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This statement is made on behalf of Cogent Communications Holdings, Inc. pursuant to section 54(1) of the Modern Slavery Act 2015 (the "Act") and constitutes our slavery and human trafficking statement.

Cogent Communications UK, Ltd. is a UK corporation registered with Commercial Registry under No.: HRB 73 632, with principal place of business located at 20 Mastmaker Court, Mastmaker Road, London, E14 9UB, UK and with VAT #: GB766151326. Cogent Communications UK, Ltd. is part of the Cogent group of companies operating in North America, Europe and Asia and is managed and ultimately owned by Cogent Communications Holdings, Inc.

Cogent Communications Holdings, Inc. is a Delaware corporation with registration number 5504601 and with its headquarters at 2450 N Street, N.W. Washington, DC, 20037. Cogent Communications Holdings, Inc. is a publicly traded corporation with its shares traded on NASDAQ Stock Exchange under symbol CCOI.

Cogent Communications Holdings, Inc. is a facilities-based provider of low-cost, high-speed Internet access and other communications services. We deliver our services primarily to small and medium-sized businesses, communications service providers and other bandwidth-intensive organizations in North America, Europe and Asia. Further information about Cogent Communications UK, Ltd. and Cogent Communications Holdings, Inc. can be found on our website www.cogentco.com.

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or in our supply chains.

We are an internet service provider that predominantly employs professionally qualified and highly skilled people. We consider the risk of Modern Slavery occurring within our business to be low. We select suppliers that have the same values as us, including a commitment to the highest professional standards and ethical conduct in their business dealings.

All of our employees are required to comply with our internal policies, procedures and code of conduct. Every employee is expected to practice high standards of business ethics in every business relationship – with each other, with Cogent, with our customers, with our business partners, and with our competitors. Failure to comply with the law or our policies is subject to disciplinary measures and possible termination.

We have in place a policy and procedures for whistleblowing, which are posted on our Intranet and which ensure that employees can confidentially report concerns regarding our compliance with laws, ethical business practices or compliance with our codes of conduct.

Our third party supply chain consists mainly of equipment and services suppliers: suppliers of telecom equipment, suppliers of IT and technology services, office supplies, cleaning, catering facilities, professional services, fiber vendors and owners of buildings in which we operate, etc. We believe that our supply chain is, therefore, low risk as regards slavery and/or human trafficking. We have not identified an immediate need to take any additional action with regard to such relationships.

We review our procurement and supply chain management procedures regularly with a view to further reinforcing our commitment to the ethical conduct of our business.

We intend to raise more awareness internally of this Statement and in relation to modern slavery across all staff by publishing this statement internally on our intranet.

The Cogent Board of Directors approved this statement on behalf of the members on November 5, 2025.

/s/ David Schaeffer
Dave Schaeffer,
Chairman and Chief Executive Officer

Introduction

Cogent and its subsidiaries and affiliates (“we”, “our”, “us”) are committed to protecting and respecting your privacy.

Effective January 1, 2020, the California Consumer Privacy Act of 2018 (as it may be amended, “CCPA”) provides new privacy rights to consumers who are residents of California, including rights to access and delete their own personal information upon receipt of a verifiable request.  The CCPA also gives consumers the right to opt out of the sale of their personal information.   For now, the CCPA does not apply to the personal information of a business’s employees or other members of their workforce, nor does it include personal information exchanged in a business-to-business communications or transactions, including provision of services.

This policy sets out the basis on which we will process any personal information or usage information we collect from you, or that you provide to us, in connection with your use of the different Cogent websites that link to this policy (the “Websites”) or with your use of our services.

Please read this policy carefully so that you understand your rights in relation to your personal information, and how we will collect, use and process your personal information.

What types of information do we collect and how we use it?

Information you give us. You may provide information by contacting us via our Websites, email, telephone or by creating an account in our customer portal, eCogent.

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organization, we will use your information to:

  • communicate with you via email or telephone;
  • administer and provide services and customer support to our customers; or
  • enforce our Website terms and conditions.

Technical usage information. When you visit the Website, we collect the information sent to us by your computer, mobile phone, or other access device. This information includes:

  • your IP address;
  • device information including, but not limited to, identifier, name, and type of operating system;
  • mobile network information; and
  • standard web information, such as your browser type and the pages you access on our Website.

We collect this information in order to:

  • personalize our Website to ensure content from the Website is presented in the most effective manner for you and your device;
  • monitor and analyze trends, usage and activity in connection with our Website and services to improve the Website;
  • administer the Website and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
  • keep the Website safe and secure; or
  • measure and understand the effectiveness of the content we serve to you and others.

Do we use cookies?

We use cookies to collect information about your browsing activities over time and across different portions of the Website. They allow us to recognize and count the number of users and to see how users move around the Website when they are using it. This helps us to improve the services we provide to you and the way the Website works. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/

We also use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

Sensitive Information

We ask that you not send us, and you not share, any sensitive Personal Information (e.g., government-issued or financial account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

How do we share your personal data?

Provide Services and Support.  We do not sell, rent or lease your personal information to others except as described in this Privacy Policy. We share your information with selected recipients. These categories of recipients include:

  • Cogent-affiliated companies in the United States which store your personal data, to provide for disaster recovery, as well as for the performance of any contract we enter into with you; and
  • IT Services providers that provide us with SaaS services, including Salesforce who we use to store our customer relationship management information.

Comply with Legal Requirements and Corporate Transactions. Cogent may disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.

The security of your personal data

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal data against loss, theft and unauthorized use, access or modification.

We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

Your rights

In certain circumstances you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email This email address is being protected from spambots. You need JavaScript enabled to view it., call toll free phone number: 1-800-621-1822 or contact our Information Privacy contact at Cogent Communications, Inc., 2450 N. Street, NW, 4th Floor, Washington, DC 20037.  In your request, please make clear what Personal Information you would like to have changed, or whether you would like to have your Personal Information that you have provided to us deleted from our database. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

 

Right to Know: You have the right to request that we disclose to you the following:

(1) The categories of personal information we have collected about you.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting or selling personal information.
(4) The categories of third parties with whom we share personal information.
(5) The specific pieces of personal information we have collected about you.

We will comply upon receipt of a verifiable request from you.

 

Right to Deletion. You may request that we delete the personal information we hold about you by sending us a verifiable request. We have no obligation to comply with your request to delete your personal information if it is necessary for us to maintain your personal information in order to:

(1) Complete the transaction for which the personal information was collected, provide the service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between the business and you.

(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.

(3) Debug to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.

(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.

(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if you have provided informed consent.

(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.

(8) Comply with a legal obligation.

(9) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

 

Right to opt-out.  You have the right, at any time, to direct a business that sells personal information about you to third parties not to sell your personal information. We do not sell your personal information, so this right does not apply to you.

 

Non-Discrimination.  We will not discriminate against you because you exercised any of your rights stated herein, including, but not limited to, by:

(1) Denying services to you.
(2) Charging different prices for services, including through the use of discounts or other benefits or imposing penalties.
(3) Providing a different level or quality of services to you.
(4) Suggesting that you will receive a different price for services or a different level or quality of services.

Nothing prohibits us from charging you a different price or rate, or from providing a different level or quality of services to you, if that difference is reasonably related to the value provided to you by your information. We do not offer any financial incentives, including payments to you as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information.

 

Changes

We may update this policy from time to time.  Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.

Contact Us

Questions, comments and requests regarding this policy are welcomed and should be addressed to This email address is being protected from spambots. You need JavaScript enabled to view it., toll free phone number: 1-800-621-1822 or by mail to Cogent’s corporate headquarters located at:

Information Privacy Contact
Cogent Communications, LLC.
2450 N. St., NW
Washington, DC 20037

You can also review our general privacy practices and commitments at https://www.cogentco.com/en/privacy-policy.

Last updated: April 10, 2024

Introduction

Cogent and its subsidiaries and affiliates (“we”, “our”, “us”) are committed to protecting and respecting your privacy. For the purpose of the General Data Protection Regulation (the “GDPR”), Cogent’s EU Subsidiaries are the data controller.

This policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of the different Cogent websites that link to this policy (the “Websites”). Please read this policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Website in question.

What types of information do we collect and how we use it?

Information you give us.  You may provide information by contacting us via our Websites, email, telephone or by creating an account in our customer portal, eCogent.

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organization, we will use your information to:

  • communicate with you via email or telephone;
  • administer and provide services and customer support to our customers; or
  • enforce our Website terms and conditions.

Technical usage information. When you visit the Website, we collect the information sent to us by your computer, mobile phone, or other access device. This information includes:

  • your IP address;
  • device information including, but not limited to, identifier, name, and type of operating system;
  • mobile network information; and
  • standard web information, such as your browser type and the pages you access on our Website.

We collect this information in order to:

  • personalize our Website to ensure content from the Website is presented in the most effective manner for you and your device;
  • monitor and analyze trends, usage and activity in connection with our Website and services to improve the Website;
  • administer the Website and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
  • keep the Website safe and secure; or
  • measure and understand the effectiveness of the content we serve to you and others.

Do we use cookies?

We use cookies to collect information about your browsing activities over time and across different portions of the Website. They allow us to recognize and count the number of users and to see how users move around the Website when they are using it. This helps us to improve the services we provide to you and the way the Website works. You can find more information about cookies and how to manage them at http://www.allaboutcookies.org/

We also use Google Analytics which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

Sensitive Information

We ask that you not send us, and you not share, any sensitive Personal Information (e.g., government-issued or financial account numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

How do we share your personal data?

Provide Services and Support.  We do not sell, rent or lease your personal information to others except as described in this Privacy Policy. We share your information with selected recipients. These categories of recipients include:

  • Cogent-affiliated companies in the United States which store your personal data, to provide for disaster recovery, as well as for the performance of any contract we enter into with you; and
  • IT Services providers that provide us with SaaS services, including Salesforce who we use to store our customer relationship management information.

Comply with Legal Requirements and Corporate Transactions. Cogent may disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes; (d) to enforce our terms and conditions; and (e) to allow us to pursue available remedies or limit the damages that we may sustain. Additionally, in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we may transfer the Personal Information we have collected to the relevant third party.

Where do we store your personal data?

Cogent has operations in countries throughout the world.  For users outside of the United States, the information that we collect from you will be transferred to, stored at, and processed in the United States. Your personal data may also processed by staff operating outside of your country who work for us or for one of our suppliers. Such staff are engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.

Cogent has implemented appropriate safeguards for transfers of personal information originating from the European Economic Area (“EEA”) to Cogent affiliates and unaffiliated third parties located outside the EEA.

The security of your personal data

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Website or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organizational measures to safeguard your personal data against loss, theft and unauthorized use, access or modification.

We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

How long do we store your personal data?

We will retain your Personal Information for as long as our Customer account is active and for a set period afterwards; as needed to provide our Customer products or services; as needed for the purposes outlined in this Policy or at the time of collection; as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; or to the extent permitted by law.  In general, we will retain your Personal Information for a period of seven years after the termination of service to our Customer.

Your rights

In certain circumstances you have rights in relation to the personal data we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights. To exercise any of your rights, please email This email address is being protected from spambots. You need JavaScript enabled to view it. or contact our Data Privacy contact at 2450 N. St, NW, Washington, DC 20037.   In your request, please make clear what Personal Information you would like to have changed, or whether you would like to have your Personal Information that you have provided to us erased from our database. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case.

  • Access: You have the right to know whether we process personal data about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
  • Correction: You have the right to require us to correct any personal data held about you that is inaccurate and have incomplete data completed.  
  • Erasure: You may request that we erase the personal data we hold about you in the following circumstances:  where you believe it is no longer necessary for us to hold the personal data, we are processing it on the basis of your consent and you wish to withdraw your consent, we are processing your data on the basis of our legitimate interest and you object to such processing, you no longer wish us to use your data to send you marketing or you believe we are unlawfully processing your data.).  Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

Objection to Marketing

At any time you have the right to object to our processing of data about you in order to send you marketing materials, including where we build profiles for such purposes and we will stop processing the data for that purpose.

Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at This email address is being protected from spambots. You need JavaScript enabled to view it. and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with regulatory authority in the country in which you live or work where you think we have infringed data protection laws.

Changes

We may update this policy from time to time.  Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.

Contact Us

Questions, comments and requests regarding this policy are welcomed and should be addressed to This email address is being protected from spambots. You need JavaScript enabled to view it. or by mail to Cogent’s corporate headquarters located at:

Data Privacy Contact
Cogent Communications, LLC.
2450 N. St., NW
Washington, DC 20037

Last updated: April 10, 2024