Introduction and Purpose

Ensuring the protection and security of your personal data is of the upmost importance to CORDET. This Privacy Notice explains how CORDET as a controller, will use and looks after the personal data it holds about you.

Please read this Privacy Notice carefully. By visiting our website or using any of our services, you indicate your agreement to our use of your personal data as set out in this Privacy Notice.

Identity and Contact Details Of The Data Controller

In this Privacy Notice when we say “we”, “us” or “CORDET”, we mean CORDET Capital Partners LLP (company number OC385212, ICO registration ZA648335) whose registered office is at 2 St. James’s Market, London, England, SW1Y 4AH.

Questions or complaints regarding this notice or any other personal data related concerns can be sent to data@cordetcapital.com.

Sources Of Personal Data

We obtain your personal data form the following sources:

When you contact us in person, via our website, by telephone, email, or any other interaction.
When you visit our website, more information about this can be found in our Cookie Notice (https://www.cordet.com/privacy-notice/).
When you apply to or do use any of our services.
When third parties who provide you or us services such as brokers, legal advisors, accountants provide us with your personal data.
When third party providers that provide us with services including fraud prevention, identification verification, due diligence checks and other related services provide us with your personal data.
From publicly available sources including Companies House, internet searches, online registers.

Types Of Personal Data We Collect

We may hold and process the following personal data:

Contact details: your preferred name, address, telephone number email address and social media identifiers.
Identity details: your full name, data of birth, nationality, country of birth, country of residence, tax identification number and/or National Insurance Number.
Verification details: details of your passport, driving licence, utility bills or other documentation necessary to verify your identity or address.
Account information: details of the services you discuss with, or request from us, and correspondence with us in relation to such services.
Records of communication: details or recordings of any meeting, call, or correspondence you have with us.
Financial details: your employment status, income, source of wealth, financial experience and background with investing, existing investments, bank account details, and tax returns.
Technical data: your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website, our website makes use of cookies further details on this are available in our Cookies Notice (https://www.cordet.com/privacy-notice/).
Third party records: any records held by third parties such as financial crime prevention agencies, the Electoral Register, companies house, credit reference services or any personal data provided to us by third party providers performing fraud prevention, identification verification and due diligence checks and other related services.

How And Why We Use Your Personal Data

The main purposes for which we use your personal data are as follows:

Administration or management of our business: enabling the creation of credentials to access our services and in order to comply with our obligations arising from any contracts entered into with you, n, corresponding with you and handling any queries, complaints or issues raised.
Research: researching current and historical trends in the investment market and tracking our transaction sourcing and pipeline, generating analytics relating our website and our services to help improve our offerings.
Legal and regulatory compliance: where required or recommended by law or to the extent necessary for the proper operation of our systems undertaking fraud prevention, identification verification and due diligence checks to enable us to comply with our regulatory obligations,, or for the enforcement of any agreement we are party to,.
Marketing: providing you with information about services we offer that are similar to those that you have already engaged us to provide or enquired about. You may opt out of receiving this information when we collect details or at any time by contacting us using the contact details below (https://www.cordet.com/contact/).
Managing operations: this includes business practices related to our day-to-day business activities, ensuring compliance with our internal policies planning and budgeting, financial reporting, marketing materials, resource management, potential mergers and acquisitions, including due diligence and audits, internal auditing, accounting, and supplier management.
Fraud prevention: this to protect us/our customers includes preventing, detecting, and investigating fraud and other potential crimes including sharing your personal data with law enforcement agencies, regulators (for example, the Financial Conduct Authority), courts, or other public authorities.

Lawful Basis For Our Processing Of Personal Data

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:

Compliance with a legal obligation: Where we need to comply with a legal obligation.
Consent: Where you have provided your consent to the processing for one or more specific purposes.
Legitimate interests: Where it is necessary for legitimate interests pursued by us or a third party and your interests and fundamental rights do not override those interests.
Performance of a contract: Where we need to perform the contract we have entered with you.

Automated Processing

CORDET does not make use of automated processing or decision making.

How we protect your personal data

The security and confidentiality of your personal data is extremely important to us. We have technical, administrative, and physical security measures in place to:

Protect your personal data from unauthorised access and improper use;
Secure our IT systems and safeguard the personal data; and
Ensure we can restore your personal data in situations where the personal data is corrupted or lost in a disaster recovery situation.

Where appropriate, we use encryption or other security measures that we deem appropriate to protect your personal data. We also review our security procedures periodically to consider appropriate new technology and updated methods.

Who we share your personal data with

We may disclose your information to:

Businesses that are part of the same group of companies within CORDET, or that become part of that group.
Our brokers, dealers, IT providers, services providers and agents in order to provide and maintain the provision of the services.
Our appointed auditors, accountants, lawyers, and other professional advisers, to the extent that they require access to your personal data in order to advise us.
Fraud prevention, identification verification, due diligence checks and other related organisations to allow us to undertake the checks set out above. We will supply details of such agencies on request.
Providers of investments or services we recommend. We may also be required to share personal data with auditors appointed by the providers of such products or services.
The Financial Conduct Authority, or any relevant regulatory authority including relevant tax or customs authorities or courts when they are entitled to request disclosure.

Some entities within the CORDET Group, and our services providers are based overseas and potentially outside of the EEA. In such instances, we take appropriate measures to ensure that your personal data is processed in accordance with data protection legislative requirements.

How long we keep your personal data

We keep personal data for as long as is reasonably required for the purposes explained in this Privacy Notice. We also keep records – which may include personal data – to meet legal, regulatory, tax or accounting needs. We will also retain files if we reasonably believe there is a prospect of a dispute or claim. The specific retention period for your personal data will depend on your relationship with us and the reasons we hold your personal data.

When determining the period for retaining your personal data, we take into account factors including:

Whether there are any existing obligations we may owe you or you may owe us;
Whether you require any follow-up communications;
The likelihood for potential or actual disputes;
Legal obligations under applicable law to retain data for a certain period of time; and
Guidelines issued by the Information Commissioner’s Office “ICO”.

We are committed to only keeping your personal data for as long as we need to in order to fulfil the relevant purpose(s) it was collected for, as set out above in this notice, and for as long as we are required or permitted to keep it by law.

If you choose not to give us your personal data

Should you fail to provide us with certain information when requested, we may be unable to provide you with the information or services you have requested from. Before we can begin providing you with our services, we need to obtain certain information about you, so that we can verify your identity in order for us to meet our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 and any other applicable legislation and for the purposes of crime prevention and fraud prevention. You are obliged to provide this information and if you do not provide it, we will be unable to provide you with our services.

Your rights

You have the following rights in relation to the personal data that CORDET holds about you.

Right to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the details in this Privacy Notice.
Right to access: You have to obtain access to the personal data held about you and certain other information (also set out in the Privacy Notice).
Right to rectify: You are entitled to have your personal data corrected if you believe it is inaccurate or incomplete.
Right to erasure: You have the right to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it.
Right to restrict processing: You have the right to restrict or suppress further processing of information – for example whilst its accuracy is verified.
Right to data portability: You have the right to get certain personal data from us as a digital file, so you can keep and use it yourself, or give it to other organisations if you choose to.
Right to object to processing: You have the right to object to the processing of your personal data where we rely on our legitimate interest for that processing.
Right to withdraw consent: Where we rely on your consent to use your personal data, you have the right to withdraw that consent at any time.

Exercising your rights

If you wish to excise any of these rights or make a complaint you may contact us at data@cordetcapital.com or the Data Protection Team, 2 St James’s Market, London SW1Y 4AH.

Please note in some instances to fulfil your request we may need to verify your identity or request some additional information.

If you are not satisfied with our response to your rights request or complaint or believe our processing does not comply with data protection law you can complain directly to the ICO through:

Writing to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF;
Calling: 0303 123 1113; or
Submitting a message through the ICO’s website at: www.ico.org.uk

Cookie Notice

This is the Cookie Notice for CORDET, accessible from www.cordet.com

What Are Cookies

As is common practice with almost all websites this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it and why we sometimes need to use these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the site’s functionality.

For more general information on cookies see the https://ico.org.uk/for-organisations/guide-to- pecr/cookies-and-similar-technologies/

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.

The Cookies We Set

Essential Cookies: These cookies are essential for the core functionality of our website. They enable you to navigate the site and use its features, such as accessing secure areas. Without these cookies, the website functionality is compromised and therefore accepting these cookies is a pre-condition of your usage of our website.

Cookie Title / Name / Provider / Lifespan / Purpose

cf_bm / http://vimeo.com/ / 30 minutes / This is a Cloudflare cookie, used to enable Cloudflare bot products to function.
_cfuvid / http://vimeo.com/ / Session / This is a Cloudflare cookie, used to aid in rate limiting.

Analytics cookies: to optimise user experience. These cookies allow us to see how visitors interact with the website by collecting and analysing various data. Such data might include how long a user spends on the website, which links are most popular and at what point visitors leave the site. These cookies allow us to ensure our operational features and services work through viewing session recordings. This category may also include cookies that allow us to customise what you see on our website and where, based on what we know about you. Our website will still work without them.

Cookie Title / Name / Provider / Lifespan / Purpose

_ga / https://www.cordet.com / 400 days / This cookie stores a unique user ID for use by Google Analytics to identify users across multiple sessions.
_ga_8YRPVVDHRS / https://www.cordet.com / 400 days / This cookie is used by Google Analytics to persist session state.
_ga_HWJEEXZL4M / https://www.cordet.com / 400 days / This cookie is used by Google Analytics to persist session state.
vuid / http://vimeo.com/ / 400 days / This is a Vimeo cookie, which generates and stores a user ID for Analytics purposes.

If you are still looking for more information you can contact us through one of our preferred contact methods:

Email: info@cordetcapital.com