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Privacy Policy – Cognition Shared Solutions Ltd.  

1. Introduction 2. Data Controller  3. What Data We Collect 4. Purpose and Legal Basis for Processing   5. Data Sharing and Transfers   6. Data Retention Policy   7. Your Rights Under UK GDPR   8. Security Measures   9.  Cookies and Tracking Technologies   10. Contact Information   11. Updates to This Privacy Policy

1. Introduction

 This Privacy Policy explains how Cognition Shared Solutions Ltd. ("we," "our," or "us") collects, processes, and protects the personal data of individuals who engage with our recruitment services. As a recruitment intermediary, we match IT contractors from Poland with UK-based businesses and facilitate invoicing between the parties. We are committed to complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Data Controller

 Cognition Shared Solutions Ltd. is the controller of your personal data. Our company details are:

  • Company Name: Cognition Shared Solutions Ltd.
  • Registered Address: 124 City Road, London, United Kingdom, EC1V 2NX
  • Contact Email: [email protected]
  • Contact Telephone: + 44 20 37695927

 3. What Data We Collect

We collect and process data from companies seeking contractors:

  • Identity and contact details of the business representative.
  • Company information, including industry, size, and specific project requirements.
  • Hiring requirements, including desired skills, experience level, and project scope for potential contractors.
  • Budget expectations for contractor compensation.

4. Purpose and Legal Basis for Processing

We process personal data for the following purposes and legal bases under the UK GDPR:

Purpose ​

Legal Basis

To facilitate contract negotiations and introductions between clients and contractors

Performance of a contract (Article 6(1)(b))

To process invoices between clients and our affiliated company in Poland

Legal obligation (Article 6(1)(c))

To maintain security and prevent fraud

Legitimate interest (Article 6(1)(f))

Providing your data is voluntary but necessary to participate in our contractor network and use our services.

  5. Data Sharing and Transfers

 5.1. We may share personal data with:

Our affiliated company in Poland (Cognition Shared Solutions sp. z o.o.) for the purpose of recruitment and talent management.

Service providers (e.g., cloud hosting, CRM) under strict Data Processing Agreements (DPAs).

UK tax authorities if required for compliance with financial regulations.

5.2. International Data Transfers

Since we collaborate with our affiliated company in Poland (an EU country), we ensure data transfers comply with the UK GDPR through Standard Contractual Clauses (SCCs) and equivalent safeguards.

  6. Data Retention Policy

We retain personal data as follows:

  • Recruitment Data: 6 months.
  • Client Data: Retained for the duration of our business relationship and for a maximum of 6 months while searching for suitable candidates.

Financial and invoicing data: 6 years in compliance with UK tax laws.

  7. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

  • Right to access – Obtain a copy of your data.
  • Right to rectification – Correct inaccurate or incomplete data.
  • Right to erasure – Request deletion of your data under certain conditions.
  • Right to restrict processing – Request limited processing under specific circumstances.
  • Right to data portability – Request your data in a structured format.
  • Right to object – Object to data processing based on legitimate interest.
  • Right to withdraw consent – Withdraw your consent at any time.
  • Right to lodge a complaint – File a complaint with the UK Information Commissioner's Office (ICO) if you believe your data is being processed unlawfully.

  8. Security Measures

We implement the following security measures to protect your data:

  • Data encryption during storage and transmission.
  • Multi-factor authentication (MFA) for system access.
  • Strict access controls limiting data access to authorized personnel only.
  • Regular security audits and compliance reviews.

  9.  Cookies and Tracking Technologies

Our website uses cookies to enhance user experience and improve functionality. We use:

  • Essential Cookies – Required for site functionality (e.g., session management).
  • Analytical Cookies (if enabled) – To track website traffic.

Users can manage cookie preferences via their browser settings or our Cookie Management Tool.

  10. Contact Information

For any inquiries regarding this Privacy Policy or your data rights, contact us:

Postal Address: 124 City Road, London, United Kingdom, EC1V 2NX

  11. Updates to This Privacy Policy


This Privacy Policy is reviewed and updated periodically. Any changes will be posted on this page with an updated revision date.

Last updated: 04 March 2025