When providing our services, each party acts as an independent controller of the data and processes the data for its own independent purposes. In this sense, Cognism processes the data to provide its services, while our customers normally process the data for marketing/lead generation, outside of Cognism’s control and visibility. Thus, each party has to comply with its obligations under applicable data privacy and/or marketing regulations.
Please note that it is only when using certain specific functionalities (like Refresh or Enhance), that a minimal processing activity is conducted on our customers’ behalf, and Cognism acts as a processor and our customers as controllers of the data.