At Cohesion Investments, we take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our: Cohesion Investments Limited and Cohesion Investments (Cayman) Limited

Personal data: Any information relating to an identified or identifiable individual

Personal data we collect about you

The table below sets out the personal data we will or may collect in the course of advising and/or acting for you.

• Your name, address and telephone number
• Information to enable us to check and verify your identity, e.g. your date of birth or passport details

Personal data we may collect

• Electronic contact details e.g. your email address and mobile phone number
• Information relating to the matter in which you are seeking our services
• Information to enable us to undertake a credit or other financial checks on you
• Your financial details so far as relevant to your instructions, e.g. the source of your funds relating to an investment
• Information about your use of our IT, communication and other systems, and other monitoring information, (e.g. if using our website or a secure online client portal)
• Your National Insurance and tax details
• Your bank and/or building society details
• Details of your professional online presence, e.g. LinkedIn profile
• Details of your spouse/partner and dependants or other family members, e.g. if relevant to an investment or KYC checks
• Your employment status and details including salary and benefits
• Your nationality and immigration status and information from related documents, such as your passport or other identification, and immigration information
• Details of your pension arrangements
• Your employment records including, e.g. if relevant to an investment or KYC checks
• Other information relevant to the conduct of due diligence or KYC checks
• Information about your use of our information and communications systems
• This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.

How your personal data is collected

We collect most of this information from you direct. However, we may also collect information:

• from publicly accessible sources, e.g. Companies House, HM Land Registry, LinkedIn or a your employer’s corporate website;
• directly from a third party, e.g:
  – sanctions screening providers;
  – credit reference agencies;
  – client due diligence providers;

• from a third party with your consent, e.g:
  – your bank or building society, another financial institution or advisor;
  – consultants and other professionals we may engage in relation to our service;

• via our website; and
• via our information technology (IT) systems

How and why we use your personal data

Under data protection legislation, we can only use your personal data if we have a proper reason for doing so, e.g:

• to comply with our legal and regulatory obligations;
• to take steps at your request prior to entering into a contract;
• for the performance of our contract with you; or
• for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests

The list below explains what we use (process) your personal data for and our reasons for doing so:

• To provide professional services to you
  – For the performance of our contract with you or to take steps at your request before entering into a contract
• Conducting checks to identify our clients and verify their identity
  – To comply with our legal and regulatory obligations
• Screening for financial and other sanctions or embargoes
  – To comply with our legal and regulatory obligations
• Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business
  – To comply with our legal and regulatory obligations
• Gathering and providing information required by or relating to audits, enquiries or regulatory bodies
  – To comply with our legal and regulatory obligations
• Ensuring business policies are adhered to
  – For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
• Operational reasons, such as improving efficiency, training and quality control
  – For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can delivery the best service for you
• Ensuring the confidentiality of commercially sensitive information
  – For our legitimate interests or those of a third party, i.e. to protect our intellectual property and other commercially valuable information
  – To comply with our legal and regulatory obligations
• Statistical analysis to help us manage our practice, e.g. in relation to our financial performance, client base, work type or other efficiency measures
  – For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can delivery the best service for you at the best price
• Preventing unauthorised access and modifications to systems
  – For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
  – To comply with our legal and regulatory obligations
• Updating and enhancing client records – For the performance of our contract with you or to take steps at your request before entering into a contract
  – To comply with our legal and regulatory obligations
  – For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our clients about existing and new services
• Statutory returns
  – To comply with our legal and regulatory obligations
• Ensuring safe working practices, staff administration and assessments
  – To comply with our legal and regulatory obligations
  – For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
• Marketing our services to existing and former clients, third parties who have previously expressed an interest in our services, third parties with whom we have had no previous dealings
  – For our legitimate interests or those of a third party, i.e. to promote our business
• Credit reference checks via external credit reference agencies
  – To comply with our legal and regulatory obligations
  – For our legitimate interests or those of a third party, e.g. as part of background checks prior to an investment
  – For the performance of our contract with you or to take steps at your request before entering into a contract
• Preventing fraud
  – To comply with our legal and regulatory obligations
  – For our legitimate interests or those of a third party, e.g. as part of background checks prior to an investment
  – For the performance of our contract with you or to take steps at your request before entering into a contract
• Processing invoices and payments
  – To comply with our legal and regulatory obligations
  – For the performance of our contract with you or to take steps at your request before entering into a contract

Marketing communications

We may use your personal data to send you updates (by email, text message, telephone or post) about market developments, updates or information about our services that might be of interest to you and information about including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

• contacting us by email on clientservices@cohesioninvestments.com
• using the ‘unsubscribe’ link in emails
• communicating your preference to us clearly in any other way

Who we share your personal data with

So far as is necessary, we may share personal data with:

• professional advisers where this is relevant to our services, such as accountants, tax advisors or other experts;
• representatives of investment funds;
• other third parties where necessary to carry out your instructions;
• compliance advisers;
• our professional advisers (e.g. accountants, lawyers);
• credit reference agencies;
• our insurers and brokers;
• external auditors, e.g. in relation the audit of our accounts;
• our bank; and
• external service suppliers, representatives and agents that we use to make our business more efficient

We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Where your personal data is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.

How long your personal data will be kept

We will keep your personal data after completion of our services. We will do so for one of these reasons:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law

We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data.

When it is no longer necessary to retain your personal data, we will delete or anonymise it.

Transferring your personal data out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), e.g:

• with our investment partners and service providers located outside the EEA;
• if you are based outside the EEA;
• where there is an international dimension to the services we are providing

These transfers are subject to special rules under European and UK data protection law.

We will ensure that any transfer complies with data protection laws and that relevant contracts contain appropriate clauses to confirm this. We will ensure that all personal data will be secure.

Your rights

You have the following rights, which you can exercise free of charge:

• Access
  – The right to be provided with a copy of your personal data
• Rectification
  – The right to require us to correct any mistakes in your personal data
• To be forgotten
  – The right to require us to delete your personal data in certain situations
• Restriction of processing
  – The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
• Data portability
  – The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
• To object
  – The right to object:
  - at any time to your personal data being processed for direct marketing (including profiling);
  - in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
• Not to be subject to automated individual decision-making
  – The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you would like to exercise any of those rights, please:

• email, call or write to our Data Protection Officer—see below: ‘How to contact us’; and
• let us have enough information to identify you (e.g. your full name, address and email or telephone number);
• let us have proof of your identity and address (e.g. a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy policy

We may change this privacy policy from time to time. The latest version will be available on our website.

How to contact us

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Our Contact Details

Cohesion Investments

60 Grosvenor Street

Mayfair, London

W1K 3HZ

clientservices@cohesioninvestments.com