Privacy Policy

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Version: 3 September 2026

Introduction

This Privacy Policy explains how Cognism Limited and its affiliates protect personal data in its care. This Privacy Policy describes: (i) what personal information or personal data (“personal data”) we collect, (ii) how and why we use, store, or share personal data and (iii) the rights and options to individuals in relation to exercising their rights under applicable data protection laws.

If you have any questions or comments about this Privacy Policy, please contact us at:

Email: privacy@cognism.com
Registered address: Cognism Limited, C/O Worldwide Corporate Advisors, 30–34 New Bridge Street, London EC4V 6BJ, United Kingdom

Updates from previous versions:

We have updated and clarified Cognism’s acting in role of “Joint Controllers” – in this update we have clarified that “Cognism” refers to several legal entities in a joint controllership of personal data.
We have highlighted the channels for exercising of your data subject rights;
We have updated information on the sources of personal data;
We have updated information on recipients in “Who we share data with” section.
We have added a section on Indicative Data Retention periods.
Overall updates and clarifications to improve readability and understanding

PLEASE NOTE: IF YOU ARE A RESIDENT OF UNITED STATES WITH PRIVACY LAWS CLICK HERE FOR OUR US STATE-SPECIFIC PRIVACY POLICY TO FIND OUT MORE ABOUT YOUR PRIVACY RIGHTS UNDER THE APPLICABLE STATE LAW(S).

Applicability

This Notice is intended to provide an explanation of Cognism Limited and affiliates (jointly hereinafter “Cognism” or “we”) handling of personal data.

We provide a suite of products and services pursuant to the respective order document to our customers (“Customers”) on a software-as-a-service basis, such as our sales intelligence platform (the “Cognism Platform”) or our applications (e.g. browser extensions) (collectively referred to as the “Services”). This Privacy Policy applies to personal data that we collect, use, disclose and otherwise process in connection with the Services, our website(s) (including https://www.cognism.com/) (“Website”), and any other products and/or services that specifically link to this Privacy Policy.

Our Services are designed for businesses and are not intended for personal, family, or household use. Accordingly, we treat all personal data covered by this Privacy Policy as pertaining to individuals acting as business representatives, rather than in their personal capacity.

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us and exercising your rights under the applicable laws.

You can exercise your data subject rights, including the right to opt-out at any time from the Cognism Platform in the Cognism Privacy Centre or contacting us at privacy@cognism.com. For more information, please refer to Sections 8 and 9.

Cognism has separate notices with regards to how we process personal data that apply to employees (those employed or work on behalf of Cognism); applicants (those looking to be employed or work on behalf of Cognism); customers (those to whom we provide a service); and supplemental notice to end users (those who are employed or work for our customers). Please contact our Privacy Team at privacy@cognism.com if you have questions about the scope and applicability of this notice to you.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Cognism and Affiliates (“Cognism”) act as Joint Controllers

Cognism Limited, a company registered in England and Wales (company number 9392705), registered office c/o Worldwide Corporate Advisors, 30–34 New Bridge Street, London EC4V 6BJ, United Kingdom

and
Cognism d.o.o., a company registered in Croatia (PIN: 72843059121, with registered office at Ulica Nikole Tesle 12B, Zadar, Croatia,

act as joint controllers.

Cognism legal entities act as joint data controllers, as described in this Privacy Policy, when we collect and use information about data subjects who are visitors to our Website and Services, as well as when we collect and use information about data subjects for purposes of creating, providing and maintaining our Services.
To exercise your rights, please contact Cognism UK, which has internally been designated as the primary contact point. You may also exercise your rights by contacting the other joint controller using the contact details provided in this policy.
Cognism legal entities act as joint controllers with an agreement that outlines their respective responsibilities for decisions on data usage and collaborated compliance regarding data protection. This arrangement is available on request from the Privacy Team.

Our Customers, as data controllers

- When our Customers use our Services, they are acting as the data controller, with separate and distinct purposes and are contractually responsible for ensuring independent compliance with data protection regulations, specifically:
  - ensuring that personal information collected about data subjects is being processed lawfully;
  - determining whether and how they wish to use our Services, and for ensuring that all end-users have been provided with adequate notice regarding the processing of their personal information, have given informed consent where such consent is necessary or advised, and that all legal requirements applicable to the collection, use, or other processing of personal information through our services have been met by such Customers;
  - handling data subject rights requests under applicable law, by end-users and other individuals whose data they process through the services.

In the context of and depending on the Services provided to our Customers, Cognism may either be controller or processor. Where Cognism is acting as a processor a Data Processing Agreement with customers is in place and we act on the Customer’s instructions. Thereby the Customer’s privacy notice provides information on such personal data processing, and you may be directed to the Customer if/when taking actions under your data protection rights.

2. WHAT TYPES OF PERSONAL DATA DO WE PROCESS (FOR OUR WEBSITES VISITORS AND CUSTOMER END-USERS)?

Types of data	Examples of data	Data sources
Enquiry data (information we receive when you contact us about our Services or request a demo on our Website)	Full name, Location and contact details (such as email address), The organisation on behalf of whom you are contacting us (e.g. prospective client), Other personal data you may provide us in your email or contact form.	We collect this information from you or the Customer (your employer)
Account and Usage data (information we receive when the Customer enters into a relationship with us, and when your account on our Services is set-up)	Username, Full name, Employer/Customer, Contact details (such as email address, phone and address details), Login details (such as IP address, product usage)	We collect this information from you or the Customer (your employer)
Marketing data (information we process about you to send you/the Customer marketing communications)	Full name, Employer/Customer, Contact information (such as email address) Consent and preference records	We collect this information from you or the Customer (your employer)
Analytics data (information we collect and process about how you interact with our Website and Services	Number of visitors, pages visited, time spent per page; Page interaction information, such as scrolling, clicks and browsing methods; Approximate location or country indicating traffic on the website; Websites where visitors have come from and where they go afterwards; Page response times and any download errors; Other technical information relating to end user device, such as browser type, IP address or browser plug-in, or to the use of the Services (access or event logs, metadata etc.). For more information about the use of cookies and other trackers on our Website and to adjust your cookie preferences, please see our Cookie Policy.	Automatically collected by our Website and Services

3. WHAT TYPES OF PERSONAL DATA IS PROCESSED IN THE PROVISION OF OUR SERVICE (FOR PERSONAL DATA IN OUR COGNISM PLATFORM)?

Types of data

Examples of data

Data sources

Data relating to professional activity (business contact and similar information related to individuals when they are acting in their professional or employment capacity)

Full name;
Professional contact information (telephone number, email);
Information on your Employer;
Information on your Approximate employer or office location (e.g. country, state or city);
Job title (where you have moved jobs, we may hold your employment history: previous employers and previous titles) and information about skills which may be published through professional networking services and other sources;
LinkedIn URL.

Cognism does not seek to collect any non-business-related data for the Cognism Platform such as date of birth, home address, personal email or home telephone number and Cognism does not collect sensitive personal data.

We collect this information from:

Third-party data vendors who license or supply business contact data (list available on request);
Our Customers based on data sharing agreements, in cases where the Customers opted to share your personal data with us;
Correspondence directly with you.

As Cognism requires a business email address to be recorded against profiles in its Cognism Platform, Cognism may generate an approximate business email address based on the common business email structure of your Employer.

4. FOR WHICH PURPOSES IS YOUR DATA PROCESSED BY COGNISM?

Data regarding our Website visitors and Customer End-Users

Purposes	Examples of use of your personal data	Legal bases
Online requests, communications and advertising
Managing your enquiries	to process your enquiries (demo or contact requests, etc.) to reply and provide support, including providing you and/or your organisation with information about the Services.	Our legitimate interest to manage our users, prospective clients and Customers enquiries
Direct marketing communications and advertising	to send postal, phone, electronic or email communications to our Customers and prospective Customers, including via our mailing list with information on news, offers, and updates about Cognism. Please see Section 10 of this Privacy Policy for how to unsubscribe); to conduct remarketing for Cognism, which allows us to show Cognism ads to people who’ve previously visited our website; to conduct advertising on social networks for Cognism, which means that if you link to one of our social media platforms you may be subject to targeted marketing displaying Cognism ads via that site.	Our legitimate interest to develop our business activities with professionals. If required by applicable law, we will request your consent for electronic marketing communications. For more information on your opt-out rights, please refer to section 9 and 10 of this Privacy Policy. For more information on how we work with the third-party advertising networks and social media platforms, please refer to our Cookie Policy. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.
Promotions and sweepstakes	to facilitate contests, sweepstakes, and promotions, process entries, and deliver reward.	Our legitimate interest to organize promotions for our prospective clients and Customers
Providing our Services
Providing our Services	to administer our Website and deliver our Services to our Customers or their customers under the agreed terms of service, including support; to send technical notices, updates, and support and administrative messages.	Our legitimate interest to provide our Services in compliance with the agreements with our Customers

Data regarding the professional and business capacity of data subjects in our Cognism Platform

Purposes	Examples of use of your personal data	Legal basis
Providing our Services to our Customers	to provide, maintain and build our Cognism Platform with professional data; to verify, cleanse, update and maintain professional data provided through our Services; to deliver, maintain and improve our Services.	Cognism legitimate interest to provide our Services, and Customers’ legitimate interests to (including Cognism’s legitimate interest to enable its Customers to) obtain up-to-date and complete information about potential business customers organized in one searchable data, to identify the individual that occupies a certain role within a B2B lead, to only reach out to relevant contacts, to generate and contact potential B2B leads in order to undertake forms of B2B marketing.
Conduct studies, research and statistical analyses	to undertake research and compile statistical aggregated reports based on data held in Cognism’s Platform (which may include inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable),	Our legitimate interest to conduct studies, research and statistical analyses, including for the purpose of understanding patterns and trends.
Direct marketing communications and advertising	to run our own marketing campaigns and promote our Services.	Our legitimate interest to develop our business activities with professionals If required by applicable law, we will request consent for electronic marketing communications. For more information on opt-out rights, please refer to section 9 of this Privacy Policy. For more information on how we work with the third-party advertising networks and social media platforms, please refer to our Cookie Policy. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.

Our Cognism Platform is provided to our Customers, that are acting as separate and independent data controllers (see Section 1 of this Privacy Policy), with their own purposes and reasons of processing. The intention of our platform (and generally our Services) is to provide our Customers with information for:

Conducting their B2B sales by contacting individuals on their business telephone, at their business email address or other electronic mail or otherwise promoting their market products and/or services;
Enriching their existing B2B customer relationship management records and receiving timely updates of business relationships market changes; and
Furthering their B2B knowledge by receiving studies, research and statistical analyses.

Since Customers will act as independent data controllers, they have their own privacy policies and opt-out options. We therefore recommend you review the policies of any organisation that has contacted you. Where Cognism has made personal data available to a Customer, the Customer’s privacy policy should identify Cognism as a data source.

Data regarding all types of data subjects

Purposes	Examples of use of your personal data	Legal basis
Improving the Services	to analyse, evaluate, maintain and improve the Website and the Services; to facilitate the use on our Website and Services.	Our legitimate interest to improve the Website, the Services, and the user experience
Ensuring the security of our Services	to monitor our Website and Services in order to prevent and detect security risks; to send security updates and alerts, and security maintenance messages; preventing, investigating and detecting crime, fraud and prosecuting offenders, including working with law enforcement agencies.	Our legitimate interest to ensure the security of our Website and Services and to prevent and detect fraud.
Pre-litigation or litigation management	to take action against any identified breach, including informing relevant third-parties such as law enforcement agencies; to manage any dispute or litigation.	Our legitimate interest to defend our rights and interests
Compliance with legal and regulatory obligations	to comply with applicable legal and regulatory obligations to manage your requests when you exercise your rights.	Our legal and regulatory obligations

5. WHO DO WE SHARE YOUR DATA WITH?

We will share your information, on a limited and need-to-know basis, with the following recipients:

Recipients	Purposes
Other Cognism affiliates	For the global management of the Website and Services operated by Cognism, where Cognism UK and Cognism d.o.o (Croatia) act as joint controllers, and where Cognism DOOEL Skopje (Macedonia), Mailtastic Limited (UK), and Kaspr SAS (France) can be recipients of data based on a data sharing agreement between affiliates.
Cognism Customers	Business contacts data on our Platform is specifically intended to be provided to Customers through our Services, on a limited basis, with the scope of access depending on the service package and license purchased. This access serves to assist Customers in their ability to conduct business-to-business sales, marketing, and recruiting activities. As noted above, Customers process this shared data as independent data controllers for their own purposes.
Data Suppliers and other service providers	For operational and technical purposes related to operating the Website and our Services, insofar as is necessary for suppliers, subcontractors and service providers to assist us in carrying out business activities. This category includes external third-party service providers, such as providers in the area of IT systems, such as support and hosting service providers, providers of technical engineering services, data storage and cloud providers and similar third-party vendors and outsourced service providers. Cognism Platform is hosted by Amazon Web Services (in Ireland). Data is also shared with data vendors offering validation services to confirm accuracy of data maintained on our platform, as well as sales engagement service providers such as Salesforce, HubSpot, Outreach, Microsoft Dynamics, Pipedrive, Bullhorn, Salesloft, and Zapier.
Professional advisers and all interested parties	Exclusively in the case of the management of possible disputes and other legal matters where appropriate. For example, to seek legal, tax or regulatory advise.
Administrative or judiciary authorities	Exclusively in case of an express and justified request from them or in case of an alleged violation of legal or regulatory provisions, and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
Other third parties such as potential acquirers or investors	If we are involved in a restructuring operation, merger, acquisition, sale of all or a portion of our assets or a similar transaction, as well as in case of insolvency, bankruptcy or receivership, where personal data are transferred to one or more third parties as assets of Cognism.

6. WILL YOUR PERSONAL DATA BE TRANSFERRED INTERNATIONALLY?

Cognism stores personal data inside the European Union.

Due to the nature of our global business and the technologies required, personal data may be transferred or onward transferred to third party service providers, Customers or affiliates outside of the UK and EU, including to the United States (“US”). Where we transfer personal data to the US or any other third country that is not the subject of an adequacy decision, we ensure appropriate safeguards are in place. In such case Standard Contractual Clauses (“SCCs”) are entered into with the recipient, after carrying out an assessment of the level of data protection laws and individual privacy rights in the third country.

You can request further details of the safeguards that apply to a specific international transfer by contacting privacy@cognism.com.

7. FOR HOW LONG DOES COGNISM STORE PERSONAL DATA?

As a general rule, your personal data will only be retained for the period necessary for the accomplishment of the purposes for which said data was collected, or as necessary to fulfil legal or regulatory obligations. For business contact data within our platform, we aim to remove data after 5 years from the date of collection. As our goal is to provide the most accurate data, earlier deletion occurs if we become aware data is inaccurate; individual’s exercise their rights to deletion; or the purpose no longer applies.

8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?

If you are based in the EU/ EEA/UK, you have the following rights over the way we process personal data relating to you. To make a request, please use the Cognism Privacy Centre or contact us at privacy@cognism.com addressed to the Privacy team. We recommend using these channels, but you can also contact us by post, using the above contact details.

Your rights	Scope of your rights
Right to access	You have the right to request: the confirmation on whether Cognism processes your personal data or not; a copy of such personal data; and information on the use of your personal data by Cognism in a clear, transparent and understandable way.
Right to rectification	You have the right to request the rectification of your personal data, to obtain the modification of your personal data if your personal data is obsolete, inaccurate or incomplete.
Right to delete	You have the right to request the deletion of your personal data (or right to be forgotten), when one of the following conditions applies: you object to the processing of your personal data and there are no overriding legitimate reasons justifying that Cognism must continue processing your personal data (e.g., legal obligation); you object to the processing pursuant to your right to object and there are no overriding legitimate grounds for continuing the processing, or you object to processing for direct marketing activities; you decide to withdraw your consent on which the processing is based (where the consent is the applicable legal basis); your personal data are no longer necessary for the original purposes for which the personal data were collected or otherwise processed; your personal data has been unlawfully processed; your personal data must be erased to comply with a legal obligation under EU or Member State law to which Cognism is subject.
Right to restriction of processing	You have the right to request the restriction of the processing during a limited period of time, where one of the following conditions applies: you contest the accuracy of your personal data, the processing of which is thus restricted for the period necessary for Cognism to verify the accuracy of such personal data; the processing is unlawful and, you oppose the erasure and request the restriction of the use of data; Cognism no longer needs your personal data for the purposes of the processing, but you need the personal data for the establishment, exercise or defense of legal claims; you have objected to the processing, which is thus restricted pending the verification of whether the compelling legitimate grounds of Cognism may override your interests, rights and freedoms.
Right to data portability	You have the right to request a copy of your personal data in a structured, commonly used and machine-readable format and also can request their transmission to another data controller where technically feasible. This right is not exercised in all circumstances, it applies only if it fulfils all the following conditions: your request is only related to your personal data (excluding anonymous or third party data); your request does not adversely affect the rights or freedoms of others, in particular those of Cognism (e.g., trade secrets) those of third-parties (e.g., intellectual property right); the processing is carried out by automated means (paper files are therefore not included); the processing is based on consent or the performance of a contract (to check if it is the case, you can see the Section 3 of this policy). In case of applicability of this right, we will help you to move, copy or transfer your personal data to other IT systems. If you request, Cognism will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.
Right to object	You have the right to object to our processing of your personal data at any time if the processing is based on our legitimate interest. Cognism will no longer process your personal data, unless they demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, such as the respect of a legal obligation or for the establishment, exercise or defense of legal claims. You also have the right to object to processing of personal data where personal data is processed for direct marketing purposes.
Right to withdraw your consent	You have the right to withdraw your consent when it has been obtained (i.e. where the processing of personal data is based on your consent), without this withdrawal affecting the lawfulness of the personal data processing operations previously carried out.
Right to lodge a complaint with your national data protection authority	If needed, you may also lodge a complaint with your national data protection authority. The main supervisory authority for Cognism Limited is the Information Commissioner’s Office. Further information, including contact details, are available at https://ico.org.uk. The main supervisory authority in the EU is the Croatian Personal Data Protection Agency (AZOP): Agencija za zaštitu osobnih podataka, Ulica Metela Ožegovića 16, 10000 Zagreb, email: azop@azop.hr. Further information is available at https://azop.hr. This right may be exercised at any time and free of charge, at the exclusion of potential postal fees or expenses related to legal representation or assistance should you choose to engage third-party assistance for the procedure.
Other rights	Depending on your country of residence, you may have additional local rights with respect to our processing of your personal data. For example, if you are based in France you can define either general or specific guidelines regarding your personal data in the event of your death (e.g., their deletion or transmission to any person of your choice). You may revoke your instructions at any time.

The exercise of these rights and potential limitations depend on the legal basis of the processing as indicated in Section 4 of this Privacy Policy, as follows:

	Access	Rectification	Erasure	Restriction	Data portability	Objection
Consent	Yes	Yes	Yes	Yes	Yes	Withdrawal of consent
Steps prior to entering into a contract			Yes		Yes	No
Contract			Yes		Yes	No
Legitimate interest			Yes		No	Yes
Legal obligation			No		No	No

Under certain circumstances, Cognism may ask you for specific information in order to confirm your identity and ensure the exercise of your rights. This is another appropriate security measure to ensure that personal data is not disclosed to an individual who does not have the right to receive it.

9. HOW TO OPT-OUT FROM THE COGNISM PLATFORM?

If you want to permanently erase your data from the Cognism Platform, please:

complete the form at the Cognism Privacy Centre (recommended); or
contact us at privacy@cognism.com.

Please note that we will need to collect some personal information to be able to validate you and action your request. The information provided will only be used to process and action your request. Your request will be processed in the shortest time possible and within the timeframes set forth under applicable Data Protection law.

10. HOW TO OPT-OUT FROM MARKETING COMMUNICATION FROM COGNISM

Where you receive a marketing email from us, and you would like to be removed from that mailing list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.

11. DOES COGNISM COLLECT DATA FROM CHILDREN?

We do not knowingly solicit data from or market to children under the age of 18. Our services are directed at business professionals and are not intended for children. If you suspect that your child’s data was inadvertently collected by us, please contact us at privacy@cognism.com.

12. HOW DOES COGNISM PROTECT YOUR PERSONAL DATA?

Cognism is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data.

Cognism ensures that all members of its personnel and any other person processing your personal data will respect the internal rules and procedures related to the processing of your personal data. In this context, Cognism reviews and updates its practices regularly to enhance your privacy.

Our security measures include:

hashing and encryption of our services and data (at rest with AES-256 and in-transit with TLS 1.2+);
annual penetration testing;
access controls such as multi-factor authentication;
restricted access of data to employees, contractors and agents; and
internal policies setting out our data security.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. If you have found a vulnerability or would like to report a security incident, you may send an email to security@cognism.com.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy, from time to time to reflect changes to our data processing activities, legal requirements or governance practices. We will also provide each “Version” with a last updated date. Material changes will be notified in accordance with applicable law. It is recommended to re-review often for the most up-to-date information.