Cognism Limited and our affiliated companies (together, “Cognism”, “we”, “us” or “our”) may collect and process personal data relating to you as part of our Cognism Email Signature Platform.
At Cognism we are committed to respecting your privacy and protecting the personal data that we obtain and hold about you and others.
Cognism provides a platform, available at: https://signatures.cognism.com/#/freesignup (“Cognism Signature Platform”) to help businesses (“Cognism Signature Client(s)”) conduct email signature marketing so they and their staff (“Platform Users”) can make a great impression with a professional signature and increase brand awareness with personalised campaign banners.
Where we decide the purpose or means for the processing of the personal data that you provide when using our Cognism Signature Platform we are the “data controller” for the purposes of the EU General Data Protection Regulation, UK General Data Protection Regulation and the Data Protection Act 2018.
A brief Explanation of our Data Sharing
The Cognism Signature Platform is offered free of charge. In return for the provision of the Cognism Signature Platform by Cognism, the Cognism Signature Client permits us and members of our group to:
- use Platform Users' business contact information (of those staff who make use of personalised email signatures) for marketing purposes, including B2B direct marketing; and
- access the Platform Users’ email inbox content, specifically the information in email signatures of received emails and IP addresses.
Third party marketers may also access this contact information for use in their marketing campaigns.
If your organisation has provided your business contact information to us as per the above, your personal data will be processed and shared as set out in this Policy. This does not affect your privacy rights, including your right to object and opt out, which are set out in paragraph 4. More information on this data sharing is set out in paragraph 3.
The Cognism Signature Platform may contain hyperlinks to third party websites. These websites operate fully independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our website is not an endorsement. Should you use any of these websites, such use is at your own risk and we would recommend that you review their respective privacy policies and Terms and Conditions.
1. WHAT INFORMATION WILL WE COLLECT ABOUT YOU?
Information provided to us by you or the Cognism Signature Client when using the Cognism Signature Platform
In order to provide a Cognism Signature Client with access to the Cognism Signature Platform and enable us to administer the client accounts, we collect the full name, email address and password of each individual authorised by such Cognism Signature Client (being the Platform Users) to access the Cognism Signature Platform.
In order to create a personalised email signature for Platform Users, we ask the Cognism Signature Client to provide us with the business contact information of each Platform User. At a minimum the Cognism Signature Client will provide the full name and business email address. Further information can be entered on a voluntary basis by the Client. The Cognism Signature Client also permits us access to data in the Platform Users’ email accounts including email signatures of all received emails and IP addresses.
We share this information with our group companies for marketing purposes and inclusion in commercial services. See paragraph 3 below for more information on this and how to object to and opt-out of such data sharing.
Cognism Signature Platform Analytics Information
When you use , the following data may be collected by our services providers, which will be aggregated before reporting back to us:
- User ID;
- device operating system & version;
- IP address;
- device make and model;
- session time start, end and duration;
- page response times and any download errors;
- page interaction information, such as scrolling, clicks and browsing methods;
- use frequency; and identification of crashes and defects.
Information provided by you when contacting us regarding the Cognism Signature Platform
If you contact us, 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 (if applicable) and your enquiry.
2. HOW WE USE PERSONAL DATA
Providing our services to Cognism Signature Clients and prospective clients
In line with the legitimate interest we have in promoting and operating our business we may process:
- information about you to administer Cognism Signature Platform log-ins (where applicable) and to deliver our Services to Cognism Clients under the agreed terms of service.
- your enquiries to reply and provide support, including providing you and/or your organisation with information about the Services we offer.
We may process information about you so that we can understand usage of our Cognism Signature Platform, analyse and improve our Cognism Signature Platform and develop new services or new parts thereof.
This processing is necessary for us to pursue our legitimate interests, being our interests in: (i) operating our business; (ii) ensuring that our Cognism Signature Platform functions properly so that you and other users have the best experience; (iii) identifying and correcting any bugs or problems with the Cognism Signature Platform or any part thereof; and (iv) developing and creating new services in the future.
All content you submit to us
If you send us objectionable content or otherwise behave in a disruptive manner when using our Cognism Signature Platform, we may process personal data included in your messages to respond to and stop such behavior.
We only process personal data in this way for the legitimate interests of ensuring that use of the Cognism Signature Platform is lawful, does not disrupt our systems, does not harass our staff or other individuals, and to enforce our legal rights and to comply with our legal obligations.
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.
Where we process personal data in this way, we will hold that personal data on our systems for as long as is reasonably necessary to achieve these objectives.
3. DO WE SHARE YOUR INFORMATION?
Sharing Data with our Group Companies for their Services
We are part of the Cognism Group and may share your personal data with other companies in our Group.
Where a Cognism Signature Client has provided us with a Platform User's:
- business contact data in order for the Cognism Signature Platform to create a personalised email signature banner for them; and/or
- access to their email inbox in order for us to use natural language processing software to recognise email signatures and extract the contact data contained within,
Cognism or Cognism’s clients may use the information to contact professionals on their business telephone, through electronic mail or conduct online advertising campaigns, in order to market products and/or services.
Other Data Sharing
We may disclose your personal data to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. We only permit them to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data. Activities which are carried out by or in collaboration with third party service providers include hosting.
In addition, we may disclose your personal data 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 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 business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the website of any changes in ownership or use of your information, as well as any choices you may have regarding that information.
4. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA WHICH WE PROCESS.
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, in response to any requests submitted by you to us:
- for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
- to restrict, stop processing, or to delete your personal data;
- for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
- to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/
To make a request in relation to any of the aforementioned rights, please send your requests to email@example.com
We do not use the Email Signature Platform to knowingly solicit information 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 firstname.lastname@example.org. We will delete such information within a reasonable time.
We will take appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Email Signature Platform taking into account the likelihood and severity those risks might pose to the rights and freedoms of individuals.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorized disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
The Platform uses SSL encryption for data security reasons and to protect the transmission of confidential content, such as requests you send to us as a site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line. If SSL encryption is activated, the data you transmit to us cannot be read by third parties.
Please be aware that, while we make the security of our website and your personal data a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal data with us, you accept the aforesaid and provide your information at your own risk.
7. INTERNATIONAL DATA TRANSFERS
We are a European service provider but are part of a global group of companies.
There are agreements in place to ensure that where personal data is transferred out of the EEA it is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission, such as the European Commission’s standard contractual clauses.
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know by emailing us at email@example.com.
To find out more about the standard contractual clauses, please visit: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX:32021D0914&locale=en
8. RETENTION PERIODS OR CRITERIA
We will hold your personal data for as long as is necessary for the relevant purpose for which that personal data was obtained, or as otherwise described in this Policy.
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 unauthorized 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.
If you would like us to stop using or holding your personal data and/or would like to request its deletion, please email us at firstname.lastname@example.org
This Policy may be updated from time to time. We will notify you of any changes by posting the new Policy here, and, where feasible, by letting you know by email or your account.
10. CONTACT US
Questions, comments and requests in relation to this Policy are welcome and should be addressed to email@example.com.
Last updated – 30th of August, 2021