Cogent Data Privacy Notice

1. Notice to Data Subjects

The Cogent companies listed at the end of this Notice (“Cogent”, “we”, “us”, “our”) provide Internet access, Internet transit and/or Ethernet transport services to businesses, i.e. our customers, or receive services from businesses, i.e., our vendors (for ease of reference, we refer to both our customers and vendors in this notice as a “Company” or “Companies” and the services provided as “Services”).  As part of the provision of these services to or receipt of services from Companies, you, as an employee or representative of a Company, may be asked to disclose limited personal data (e.g. business contact details) to one or more of us, or your Company may disclose your personal data to Cogent, to enable Cogent to communicate with you in order to provide or receive Services. The Cogent company or companies from whom your Company has ordered Services or to whom your Company provides Services will be the data controller(s) of your data for these purposes and the purposes of the General Data Protection Regulation (GDPR). 

This notice sets out the basis on which we will process your personal data. Please read this notice 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 notice in general or any part of it, you should inform your Company or Cogent as soon as possible.  

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

Your Company or you may provide the following types of your personal data to us by contacting us via our customer portal, email, telephone or otherwise: 

  • name;
  • email address;
  • telephone number; and
  • job role. 

Purposes of Processing and Legal Basis for Processing

Cogent will process your personal data for the following purposes:

  • to contact and interact with you to perform our obligations under our contract with your Company in order to pursue our legitimate interest of communicating with our customers and running an effective business;
  • to monitor and record calls for quality, training, analysis and other related purposes in order to pursue our legitimate interest to improve service delivery; and
  • enforce our terms and conditions against your Company in order to pursue our legitimate interests of running an effective business.

Recipients of Data and International Transfers

Cogent does not sell, rent or lease your personal information to others except as described in this notice. We share your information with selected recipients. The categories of recipients include:

  • IT Services providers that provide us with SaaS services, including Salesforce located in the United States of America who we use to store our customer relationship management information.
  • Cogent will share your information with law enforcement agencies, public authorities or other organizations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
  • comply with a legal obligation, process or request;
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Cogent will also disclose your information to third parties:

  • in the event that we sell any business or assets, in which case we will disclose your data to the prospective  buyer of such business or assets; or
  • if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

Where do we store your personal data?

Your personal data will be transferred within our group to the United States of America, and stored by Cogent’s United States affiliate, Cogent Communications, Inc., located at 2450 N. St., Washington, DC 20037, United States of America. Your personal data is also processed by staff operating outside the European Economic Area (“EEA”) who work for us or for one of our suppliers. Such staff are engaged in, among other things, communicating with you about the fulfilment of your Company's order and the provision of support services. Such countries may not have the same data protection laws as your country but we will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this notice.

All suppliers that process personal data outside of the EEA are required to execute the Standard Contractual Clauses for the transfer of personal data or be certified as complying with the US Department of Commerce's EU-US Privacy Shield. Where a transfer of personal data within the Cogent Group involves a transfer of personal data outside the EEA, Cogent and its group companies have entered into Standard Contractual Clauses adopted pursuant to European Commission Decisions 2004/915/EC and 2010/87/EU.

Please contact our data privacy contact at This email address is being protected from spambots. You need JavaScript enabled to view it. for copies of the standard contractual clauses.

Retention Period

We may retain your personal data for as long as required to perform the Services and/or the purposes of processing set out above.

We will retain your information until we are notified that you no longer work for your Company or for a period of seven (7) years after your Company has terminated its contractual relationship with Cogent. 

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 by providing reasonably acceptable verification of your identity.  To exercise any of your rights, please email This email address is being protected from spambots. You need JavaScript enabled to view it.. 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 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.
  • Restriction of Processing to Storage Only: You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in the following circumstances: you believe the personal data is not accurate for the period it takes for us to verify whether the data is accurate, we wish to erase the personal data as the processing we are doing is unlawful but you want us to simply restrict the use of that data; we no longer need the personal data for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims; and you have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data whilst we determine whether there is an overriding interest in us retaining such personal data.
  • Objection: You have the right to object to our processing of data about you and we will consider your request.  Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

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 or promotional material, including where we build profiles for such purposes and we will stop processing the data for that purpose. Please email us at This email address is being protected from spambots. You need JavaScript enabled to view it. if you would like to object to receiving marketing communications from us.

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. This is without prejudice to your right to raise a claim with a supervisory authority.

How to contact us

If you have any questions about our use of your personal data, please contact This email address is being protected from spambots. You need JavaScript enabled to view it..

 

COGENT EUROPE, S.À.R.L
2-4 Rue du châteaux d’Eau, «Immeuble Edeleck»,
L-3364 Leudelange, Luxembourg
2000 2406 137

 

COGENT COMMUNICATIONS BELGIUM SPRL
l’Avenue du Port 86C box 204,
1000 Brussels, Belgium
0472324276

COGENT COMMUNICATIONS BULGARIA EOOD
17A Tzar Osvoboditel Blvd., floor 3, apartment 6,
Sofia 1504, Bulgaria
BULSTST No. 175401467

 

COGENT INTERNET d.o.o.
Radnička cesta 80, Zagrebtower 5th floor,
10000 Zagreb, Croatia (MBS)
080647612

COGENT COMMUNICATIONS CZECH REPUBLIC s.r.o.
Pobřežní 394/12, 186 00
Prague 8, CZECH REPUBLIC
281 74 933

 

COGENT COMMUNICATIONS DENMARK ApS
Holbergsgade 14, 2 tv. ,
1057 København K, DENMARK
(CVR no.) 31260884

COGENT COMMUNICATIONS ESTONIA, OÜ
Põhja pst 25,
10415 Tallinn, Eesti Vabariik
11484142

 

COGENT COMMUNICATIONS FINLAND OY
c/o Accounting Services Tilmatic, Malminkatu 16,
(Voimatalo) 6th floor,
FI-00100 Helsinki Finland
2175172-7

COGENT COMMUNICATIONS FRANCE, SAS
77, Boulevard de la République
92250 La Garenne Colombes
B 429 165 541

 

C.C.D. COGENT COMMUNICATIONS
DEUTSCHLAND GMBH

ATRICOM BUILDING, Lyoner Strasse 15,
60528 Frankfurt/Main, GERMANY
HRB 73 632

Svensk filial till C.C.D. Communications
Deutschland GmbH

Bird & Bird Advokat KB, Norrlandsgatan 15,
Box 7717,
103 95 Stockholm
516404-2037

 

COGENT HELLAS INTERNET SERVICES
SOLE MEMBER LIMITED LIABILITY COMPANY

1 Patroklou St. & Paradeisou St., Maroussi,
Athens, 15125 Greece
275366

COGENT COMMUNICATIONS HUNGARY, KFT.
Fő u. 14-18, H-1011
Budapest, HUNGARY

 

CCE COGENT INTERNET SERVICES LIMITED
6th Floor, 2 Grand Canal Square,
Dublin 2
448246

COGENT COMMUNICATIONS ITALIA S.R.L.
Via Elenora Duse 35,
00197 ROMA
09478421002

 

COGENT LATVIA SIA
Krisjana Valdemara iela 21-11,
Riga, LV-1010, LATVIA
40103312778

COGENT LITHUANIA UAB
Jogailos 4,
Vilnius, LT-01116, LITHUANIA
302547003

 

COGENT COMMUNICATIONS NETHERLANDS B.V.
Haarlemmerstraatweg 135,
1165 MK Halfweg, The Netherlands
27191337 Blad 00002

COGENT NORWAY AS
c/o TMF Norway AS, Tollbugata 27, 0157
Oslo, NORWAY
992 968 664

 

COGENT COMMUNICATIONS POLAND Sp. zo. o.
c/o Accace, Cybernetyki 10, 02-677
Warszawa
0000298149

COGENT COMMUNICATIONS PORTUGAL, LDA.
Epimetheus - Serviços de Gestão, S.A.
Rua Luciana Stegagno Picchio, nº 3 – 1º Esq.
1500 – 912 Lisboa
3716-8062-8729

 

COGENT COMMUNICATIONS ROMANIA SRL
Bucureşti Sectorul 4, Calea Şerban Vodǎ,
Nr. 133, Central Business Park, ClǎdireA, Etaj 2,
Secţiunea A 2.36
J40/9634/2008

COGENT COMMUNICATIONS SLOVAKIA s.r.o.
AUPARK TOWER, Einsteinova 24, 851 01
Bratislava, Slovak Republic
Commercial Register, District Court Bratislava I.,
Section Sro, File # 48636/B

 

COGENT ADRIA, komunikacije, d.o.o.
Cesta V. Mestni Log 88A,
1000 Ljubljana
3312399000

COGENT COMMUNICATIONS ESPAÑA S.L.
C/ José Bardasano Baos, nº9, Edificio Gorbea lll,
28016 MADRID
N.I.F. B-82708231

 

COGENT COMMUNICATIONS UK Ltd
2 Temple Back East, Temple Quay,
Bristol BS1 6EG
04014628

 

Last updated: May 16, 2018

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Cogent is one of the world's largest Internet Service Providers, delivering high quality Internet, Ethernet and Colocation services to over 78,300 Enterprise and NetCentric customers. Cogent serves over 201 markets in 43 countries across its facilities-based, all-optical IP network.

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