GDPR Privacy Policy

Last Updated: 1 August 2023

1. INTRODUCTION

Welcome to the Coterie Holdings UK Limited's ('Coterie') privacy policy. We understand that your privacy is very important and recognise the need to protect your personal data.

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Coterie collects and processes your personal data through your use of this website, including any data you may provide through this website.

We appreciate your trust and we are committed to protect not only your personal data. This privacy policy outlines the types of information Coterie may collect through your use of our services, how the information is being collected and processed, used, and how you can modify, delete or export your information.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our Compliance Officer in the following ways:
Full name of legal entity: Coterie Holdings UK Limited
Email address: compliance@coterieholdings.com
Postal address: Ground Floor, Egerton House, 68 Baker Street, Weybridge, Surrey KT13 8AL

You have the right to make a complaint at any time to the Information Commissioner's Office ('ICO'), the United Kingdom ('UK') regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated on 1 August 2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. WHAT INFORMATION DO WE COLLECT?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data includes first name, middle name, last name and suffix.
Contact data includes address, email address and telephone numbers.
Technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile data includes your username (your first name you will be referred to on the site) password.
Usage data includes information about how you use our website, products and services.
Marketing and Communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

INFORMATION THAT WE DO NOT COLLECT

We will not knowingly collect personal information about a person under the age of 18 or a person that has no legal capacity.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

apply for our services;
create an account on our website;
subscribe to our service or publications; or
give us feedback or contact us.

Information automatically collected. As you interact with our website, we will automatically collect and store data from your computer about your equipment, your browsing history and patterns, and other activities performed on our website. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

Like many other websites, we use standard cookies technology to collect information about how you use our website. Cookies are small amounts of data sent to your browser from a web server and stored on your computer's hard drive. Cookies can help a website recognise repeat users and allow a website to track web usage behaviour. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. If a cookie is placed, when you visit a website thereafter, a message is sent back to the web server by the browser accessing the website. We also use some cookies to improve our service to you and personalise your web-browsing experience. You can set your browser to notify you when you are sent a cookie and you may also elect not to accept cookies by changing the designated settings on your web browser. To navigate through many parts of our website, you do not need to turn on cookies. However, not utilizing cookies may prevent you from using certain functions and features.

Information from third parties or publicly available sources. We may also obtain personal information from organisations which you are employed or affiliated with, as well as other third parties, such as social media platforms. We will receive personal data about you from various third parties. This could include from:

analytics providers;
advertising networks; and
search information providers.

4. HOW WILL WE USE THE INFORMATION COLLECTED?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the services within the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	Identity Contact	Performance of a contract with you
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy; and Asking you to leave a review or take a survey	Identity Contact Profile Marketing and Communications	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity Contact Profile Usage Marketing and Communications Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Technical Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Promotional communication and advertisement - We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing). You will always have the option to opt-in to receiving specific marketing communications from us. You will receive marketing communications from us if you have opted in to receiving that marketing.

Legal compliance - In certain cases, we may retain your information necessary to comply with certain laws. For example, we are required by relevant laws to maintain certain information in compliance with accounting practices which is why we will collect certain banking information and identification from you.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. INTERNATIONAL TRANSFERS

Coterie offers customers a global service. We host our platform on Amazon Web Services ('AWS'). We currently maintain our server within the UK. Coterie employees based outside of the UK may access your data which is hosted in the UK. This means that we may share your data outside the UK. The download and storing of your data is restricted in those cases.

Whenever in the course of sharing information, we will ensure that the information is transferred in accordance with this privacy policy and as permitted by the applicable laws on data protection.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

6. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

7. HOW CAN I CONTROL MY PERSONAL INFORMATION?

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Not providing your information. You have the right not to provide your personally identifiable information to us. In such a case, you may be unable to access certain functions and services because certain information may be necessary for these functions or services to function properly. We will maintain and use the personally identifiable information collected from you (may be within and outside of the country that you are in), until such time that you request us to remove or stop using such information.

Your security. It is also important for you to keep your personal information, account and password safe and do not share such information with others.

QUESTIONS OR SUGGESTIONS?
If you have questions or concerns about this privacy policy, our collection, use, or disclosure of your personal information, please contact us.