1. Introduction and General Terms
This policy covers services are provided by Cognism Limited (“Cognism”, “we”, “us” or “our” in this policy).
Telephone: +44 20 3858 0822
Email: [email protected]
Cognism is committed to protecting and respecting your privacy. This policy explains the basis on which personal information we collect from you will be processed by us. Where we decide the purpose or means for which personal data supplied by you is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.
This policy explains the following:
What personal information we may collect about you;
Ground for processing;
Who we share your information with;
How we will use that information;
Who we may disclose that information to; and
Your rights regarding the information.
Our online services contain hyperlinks to websites owned and operated by third parties. These third-party websites may have their own privacy policies and we recommend you review them. They will govern the use of personal information you submit or which are collected by cookies whilst visiting those websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of them is at your own risk.
2. What information will COGNISM collect about me?
We collect and process the following information which may include your personal data.
The majority of the personal information we collect about you comes from publicly available data. We also gather information from recruiters and other premium data providers where their collection processes have consented in to allow redistribution. This may include your name, username, age, gender, address, telephone number, e-mail address, job title and CV/Resume.
3. Grounds of Processing
On some occasions, Cognism processes your data with your consent. Your consent is often obtained from third parties. You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Cognism processes your personal information when it is our legitimate interest to do so and when these interests are not overridden by your data protection rights. As applicable, we will use information about you for delivering, selling and supplying our good and services to our customers, understanding our customers' behaviour, activities, preferences, and needs, promoting, marketing and advertising our products and services, improving existing products and services and developing new products and services, responding to enquiries and contacting you about matters requiring your attention. We may use third parties to assist us with this.
Necessary to fulfil a contract
Cognism may process your data when we need to do this to fulfil a contract with you, such as to send your CV to an employer or recruiter for a specific job application.
Necessary because of a legal obligation
Cognism may process your data to comply with our legal and regulatory obligations eg preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
4. Data Sharing
We will share your information with the following:
Access to personal information within Cognism and our group of companies is restricted to those individuals who have a need to access the information for our business purposes.
Our service providers
This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.
Other third parties
We may share personal information with other third parties. We will always do this under contract and in accordance with your instructions.
If you would like to find out more about how the third parties listed in this policy use your information, this should be set out in their respective privacy policies.
Third party types include:
Account Management and Customer Support
Business Supplies and Equipment
Database Management and Analysis
Information Technology and Services
International Trade and Development
Leisure, Travel & Tourism
Public Relations and Communications
Strategy and Promotion
Search Engine Optimisation
Security and Investigations
Staffing and Recruiting
Translation and Localization
In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
5. How we will use information we collect about you and who will we share it with
We will use information about you for delivering, selling and supplying our good and services to our customers, understanding our customers' behaviour, activities, preferences, and needs, promoting, marketing and advertising our products and services, improving existing products and services and developing new products and services, responding to enquiries and contacting you about matters requiring your attention. We may use third parties to assist us with this.
We process personal data to comply with our necessary legal and regulatory obligations. These include preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
We use various forms of marketing to provide you with promotional materials about our services, as well as the services of other companies in our group of companies. We may use third-party providers to assist us with this.
We will not process your information for the purposes of marketing unless you give your consent or you have given it already.
We process information to understand how visitors use our website and to compile statistical reports regarding that activity.
This processing is necessary for us to pursue our legitimate interests of improving our services, and providing a better and more personalised experience to our users. We may use third party analytics providers.
6. Consumer Control & Opt-Out Options
If you do not wish to receive promotional or other marketing material from us please contact us using the above contact details.
7. Your rights in relation to personal data which we process relating to you
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.
To make a request, please contact us using the above contact details, addressed to the Data Protection Officer.
Ask for a copy of data we are processing about you and have inaccuracies corrected
You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.
We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).
Object to us processing data about you
You can ask us to restrict, stop processing, or to delete your personal data if:
you consented to Cognism processing the personal data, and have withdrawn that consent;
Cognism no longer needs to process that personal data for the reason it was collected;
Cognism is processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of Cognism, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
the personal data was unlawfully processed; or
you need the personal data to be deleted in order to comply with a legal obligation
Obtain a machine-readable copy of your personal data, which you can use with another service provider
If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, 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.
Make a complaint to a Supervisory Authority
If you are unhappy with the way Cognism is processing your personal data, please let us know.
If you do not agree with the way we have processed your data or responded to your concerns, If you do not think we are handling your personal information adequately, you have the right to lodge a complaint with the Information Commissioner's Office. Further information, including contact details, are available at https://ico.org.uk
8. Data Retention
We will cease use of your data for marketing purposes no more than 5 years after your last transaction with us. We typically retain your data for 5 years from your last transaction with us to satisfy our regulatory obligations.
Please note that Cognism reserves the right to remove from our database, and data which include any content that we consider to be illegal or offensive.
We do not use the Application to knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. We will delete such information from our files within a reasonable time.
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 information.
Our security measures include:
Hashing and encryption of our services and data;
Regular review of information collection;
Encryption of our services and data;
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.
We will notify you of any changes to this policy by email, notice on the website or account message.
12. International Data Transfers
Your Personal Information which you supply to us is generally stored and kept inside the European Economic Area, however due to the nature of our global business and the technologies required, your Personal Information may be transferred to third party service providers outside the EEA, in countries where there may be a lower legal level of data protection.
13. Additional Google Details for Cognism Apps
Additional Limits on Use of Your Google User Data:
The App will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.
- The App will not use this Gmail data for serving advertisements.
- The App will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the App's internal operations and even then only when the data have been aggregated and anonymized.
Last updated: May 2019