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PRIVACY POLICY 

PLEASE SELECT YOUR LANGUAGE BELOW:

Norsk | Nederlands | Svenska | Dansk | Español | Deutsch | Italiano | Suomen
kieli

1. INTRODUCTION AND GENERAL TERMS

This Privacy Policy covers the processing of personal data by Cognism Limited
(“Cognism”, “we”, “us” or “our” in this policy) when providing its services to
its clients.

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

Telephone: +44 20 3858 0822

Email: privacy@cognism.com

Cognism is committed to protecting and respecting your privacy. This Privacy
Policy explains the basis on which personal data we collect from you or from
public sources will be processed by us. Where we decide the purpose or means for
which this personal data is processed, we are the “data controller.” We will
comply with all applicable data protection laws, including the General Data
Protection Regulation 2016/679. You have the right to object to us processing
your personal data for direct marketing purposes. Please see paragraph 7 below
for more details on how to do this.

This Privacy Policy explains the following:

 * What personal data we may collect about you;
 * Why our processing is lawful;
 * Who we may share your information with;
 * How we will use that information;
 * Who we may disclose that information to; and
 * Your rights regarding the information.

2. WHAT INFORMATION WILL COGNISM COLLECT ABOUT ME?

We collect and process the following data, which may include your personal data.

Cognism’s Website: If you contact us about our services or request a demo on our
website, the forms you complete or the emails you send may include information
about you, such as your full name, your email address, the organisation on
behalf of whom you are contacting us and your enquiry.

Cognism’s Online Client Platform: In order to provide a Cognism Client with
access to our platform and enable them to access our services, we collect the
full name, email address and password of each individual authorised by such
client to access the platform.

Analytics on the Website and the Platform: Our website and online client
platform uses cookies and other mechanisms to collect and log analytical
information, to help analyse use, to compile statistical reports on use of our
website and to improve our website and marketing. To find out more about the use
of cookies and adjust your cookie preferences, please see our cookie policy
here.

The following data may be collected:

 * number of visitors to our website;
 * pages visited while at the website and time spent per page;
 * page interaction information, such as scrolling, clicks and browsing methods;
 * websites where visitors have come from and where they go afterwards;
 * page response times and any download errors; and
 * other technical information relating to end user device, such as IP address
   or browser plug-in.

Cognism Database: Cognism gathers current and historic business contact data.
The data collected about individuals on the Cognism Database comprises:

 * Name;
 * Employer Company & Company Details;
 * Office Location (Country & City);
 * Business Telephone Number;
 * Business Email Address;
 * Job Title.

We also hold data in respect of your employer company such as its name, alias,
size, industry, website and industry. In some case we estimate individuals’ net
worth based on publically available data (for example, the individual’s
employment history or if such individual previously sold shares in a company).
Where you have moved jobs, we may hold your previous employers and previous
titles.

In order to provide certain aspects of its services, Cognism requires a business
email address to be recorded against profiles in its database. Where Cognism
does not have the business email address of a profile, it may generate a
business email address based on the email address structure understood to be
implemented by the employer company.

We also hold hashed personal email addresses. Hashing is a method of encryption,
whereby the email address itself is confuscated, and replaced with a unique
reference instead, called a hash. A hash is one of the means used to locate the
same individual on social networking. We do not reverse the hash or use the
personal email address to contact you.

The majority of the personal data we collect about you comes from publicly
available sources such as from business and employment-oriented social networks,
recruitment websites and company websites.

Information is also gathered from correspondence with you (by email or phone),
from our clients, recruiters and other premium data providers. Cognism does not
seek to collect any non-business-related data such as date of birth, home
address, personal email or telephone number and Cognism does not collect
sensitive personal data.

3. GROUNDS OF PROCESSING

3.1 CONSENT

On some occasions, Cognism processes your data with your consent. Your consent
may be obtained by third parties on Cognism’s behalf. You have the right to
withdraw such consent at any time and we will cease to process data after
consent is withdrawn.

3.2 LEGITIMATE INTEREST

Cognism processes your personal data when it is in our or our clients’
legitimate interest to do so and when these interests are not overridden by your
rights. Our and our clients’ legitimate interests include: having information
about potential business customers organised in one searchable database, having
access to up-to-date and complete information, being able to identify the
individual that occupies a certain role within a B2B lead; being able to
identify individuals with a certain estimated net worth, enabling clients to
only reach out to relevant contacts, being able to generate and contact
potential B2B leads in order to undertake forms of B2B marketing, having access
to aggregated statistical insights for the purpose of understanding patterns and
trends.

3.3 NECESSARY BECAUSE OF A LEGAL OBLIGATION

Cognism may process your data to comply with our legal and regulatory
obligations e.g. preventing, investigating and detecting crime, fraud or
anti-social behaviour and prosecuting offenders, including working with law
enforcement agencies.

3.4 NECESSARY TO FULFIL AN OBLIGATION UNDER A CONTRACT

Cognism may process your data where we have a contract with the individual and
we need to process their personal data to comply with our obligations under the
contract.

4. DATA SHARING

We will share your information with the following:

4.1 OUR COMPANIES

Access to personal data within Cognism and our group of companies is restricted
to those individuals who have a need to access the information for our business
purposes.

4.2 COGNISM CLIENTS

We may share personal data with our clients or their customers as part of the
offering of our services. Cognism provides limited access of its database.
Cognism clients or their customers may use the data to contact individuals on
their business telephone, at their business email address, through other
electronic mail or through targeted display ads on social networks in order to
market products and/or services.

Please note that in making available the data to its clients, Cognism is
processing such data as a processor on behalf of the client, who is acting as
the controller. Clients will likely have their own privacy policies and opt-out
options, and we recommend you review them. Where Cognism has made personal data
available to it clients, the client privacy policy should list Cognism as a data
source.

4.3 SUPPLIERS, SUBCONTRACTORS, SERVICE PROVIDERS

We keep your information confidential, but may disclose it to suppliers or
subcontractors insofar as it is reasonably necessary for the purposes set out in
this privacy policy. However, this is on the basis that they have agreed to
safeguard this information.

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.

4.4 DATA MANAGEMENT PLATFORM

A Data management platform (DMP) is a technology platform used for collecting
and managing data, mainly for digital marketing purposes. Cognism supplies DMPs
with data so that the DMP can generate audience segments, which are used by
advertisers to target specific types of users in online advertising campaigns.

4.5 GOVERNMENT AUTHORITIES

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).

4.6 POTENTIAL ACQUIRERS OR INVESTORS

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

Cognism Website and Cognism Client Platform: We may process your personal data
for the following purposes for Cognism’s own:

 * to administer platform log-ins (where applicable) and to deliver our services
   to our clients or their customers under the agreed terms of service;
 * to process your enquiries to reply and provide support, including providing
   you and/or your organisation with information about the services Cognism
   offers;
 * to keep you updated via our mailing list with information on news, offers,
   and updates about Cognism (see below for how to unsubscribe);
 * to compile reports on how visitors use the Cognism website and improve the
   website;
 * 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.

We work with the third party advertising networks and social media platforms as
set out in our cookie policy here. 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.

Cognism Database: We may use your personal data on the Cognism Database for the
following purposes:

 * to build our sales intelligence database to enable our clients or their
   customers to generate and manage sales leads in respect of businesses and
   high net worth individuals;
 * to enable our clients or their customers to serve relevant display ads on
   social networks (such as Facebook, LinkedIn and Instagram) and other
   services;
 * to enable our clients or their customers to enrich their existing customer
   relationship management records and receive timely updates of changes;
 * to undertake research and compile statistical aggregated reports based on
   data held in Cognism’s sales intelligence database;
 * to supply data management platforms;
 * to run our own marketing campaigns and promote our services.

We also 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.

All content: If you send us objectionable content or otherwise behave in a
disruptive manner when using our website, we may process personal data included
in your messages to respond to and stop such behaviour. Where we reasonably
believe you are or may be in breach of the law (for instance, because content
you send amounts to harassment or is defamatory), we may use your personal data
to inform relevant third parties such as your email/internet provider or law
enforcement agencies about the content.

6. MARKETING OPT-OUT OPTIONS

If you do not wish for your personal data to be used in the Cognism Database for
the purposes set out above, please fill in your details here or contact us using
the above contact details.

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.

7. THE APP

Additional Limits on Use of Your Google User Data: 

Notwithstanding anything else in this Privacy Policy, if you provide the App
access to the following types of your Google data, the App’s use of that data
will be subject to these additional restrictions: 

7.1 App’s use and transfer to any other app of information received from Google
Accounts will adhere to Google API Services User Data Policy, including the
Limited Use requirements, which is available at the following link:
https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes. Please
note that these are Google policies, and as such, Cognism does not have any
control or interference on the same. We recommend you to visit Google´s policies
directly for further details on their procedures and future updates. 

7.2 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. 

7.3  The App will not use this Gmail data for serving advertisements. 

 7.4 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. 

8. HOTJAR

Notwithstanding anything else in this Privacy Policy, please note that we use
Hotjar in order to better understand our users’ needs and to optimize this
service and experience. Hotjar is a technology service that helps us better
understand our users' experience and this enables us to build and maintain our
service with user feedback. Hotjar stores the information on our behalf in a
pseudonymized user profile and is contractually forbidden to sell any of the
data collected on our behalf. For further details, please see the 'about Hotjar'
section of Hotjar's support site .

9. 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.

9.1 YOU HAVE THE RIGHT TO REQUEST A COPY OF THE PERSONAL DATA 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 data held about you on our files (and with any third parties
to whom it has been disclosed to).

9.2 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

9.3 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.

9.4 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, or if you do not think we are handling your personal data
   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

10. DATA RETENTION

We will hold your personal data for as long as is necessary for the relevant
purpose.

To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm
from unauthorised use or disclosure of your personal data, the purposes for
which we process your personal data and whether we can achieve those purposes
through other means, and the applicable legal requirements.

11. CHILDREN

We do not 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
privacy@cognism.com. We will delete such information from our files within a
reasonable time.

12. SECURITY

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.

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.

13. CHANGES

We will notify you of any changes to this Privacy Policy by email and/or notice
on the website, as appropriate.

14. INTERNATIONAL DATA TRANSFERS

Your personal data which you supply to us is generally stored and kept inside
the European Economic Area (EEA). However, due to the nature of our global
business and the technologies required, your personal data may be transferred to
third party service providers outside the EEA, in countries where there may be a
lower legal level of data protection.

Where we transfer your data outside of the EEA, we transfer the minimum amount
of data necessary, anonymise it where possible and we have agreements in place
with those parties which include standard data protection clauses to ensure that
appropriate safeguards are in place to protect your personal data in accordance
with this Privacy Policy and the European levels of data protection. If you
would like to find out more about these safeguards, please contact us.

15. CALIFORNIA RESIDENTS & CCPA

If you are a California resident, as defined in Section 17014 of Title 18 of the
California Code of Regulations, you have certain rights in respect of the
personal information we hold about you.

If you have questions or concerns about our privacy policies and practices,
please contact us at the details set out at the top of this Policy.

Please see above for:

 * the date on which this Policy was last updated (see paragraph 1)
 * categories of personal information collected about you (see paragraph 2)
 * categories of sources from which the personal information was collected (see
   paragraph 2)
 * purposes for collecting and selling personal information (see paragraph 5)
 * categories of third parties with whom we share personal information (see
   paragraph 4)
 * where you have a profile on our database, a list of categories of personal
   information sold about you in the last 12 months (see paragraph 2)
 * where you have a profile on our database, a list of categories of personal
   information sold about you in the last 12 months (see paragraph 2)

We have disclosed and sold personal information to third parties within the last
12 months.

We do not sell the personal information of minors under 16 years of age without
affirmative authorization.

You can designate an authorised agent to make a request under the CCPA on your
behalf. The authorized agent must submit proof that they have been authorized by
you to act on your behalf and proof of their own identity.

You have the right to:

 * request access to your personal information and request that Cognism disclose
   what personal information it collects, uses, discloses, and sells;
 * request deletion of your personal information collected or maintained by us;
 * opt-out of the sale of your personal information (fill in your details here:
   Do Not Sell My Info);
 * not be discriminated against for exercising any of your rights under the
   California Consumer Privacy Act of 2018 (CCPA).

To make a verifiable request, please contact us using the above contact details,
addressed to the Data Protection Officer or call us on 001 8338291090 We may
verify your request by asking for proof of identity.

Last updated – 3rd of November, 2021

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