Privacy Notice
Last updated: 26th June 2019
Introduction
This Privacy Notice is designed to help you understand what personal information we collect, why we collect it, what we do with it, how we keep it secure and your choices when it comes to accessing, updating and deleting your information.
This notice covers personal information processed by Cadogan Financial Ltd.
Information that we collect
Generally, we collect your information when you choose to interact with us either through our website or by contacting us directly. We only collect information that is necessary to carry out our business, provide any service that you request and to keep you informed of similar services.
The most common situations in which we might collect your personal information are:
• if you are a current or past client or have expressed interest in becoming a client
• if you attend one of our training courses or express an interesting in attending one of our training courses
• if you share your CV with us, or a third party shares it with us on your behalf
• if you contact us seeking information about any aspect of our business or services
• if you are a current or past Associate of our company, or have expressed an interest in becoming an Associate
• if you give us your business card and/or other contact information
The type of information that we collect depends on the reason for which it is gathered. We may collect information such as:
• prefix, name, job-title
• email address
• contact information such as mailing address and telephone number
• in relation to potentially or actually working with us as an Associate your CV, which, in addition to the information listed above, might include your date of birth, educational history, professional background and experience, certifications and memberships, and marital status
• your payment details, if we have needed to pay you for services or products
• your history of interaction with our firm
• passport and visa information, if you provided this as part of delivering a project with us
• if you attend one of our courses, your dietary restrictions or allergies
Why we collect this information
When you provide personal information to us, we may use it for any of the purposes described in this Privacy Notice or as stated when we collected the information (or as obvious from the context of collection), including:
• if you are a client, delivering our services to you effectively and efficiently
• if you are an Associate or potential Associate, identifying possible consulting or training opportunities in which we might cooperate
• if you are an Associate, creating and storing of contracts, managing payments and identifying opportunities for you
• developing our business and services
• if you attend our training courses, making appropriate catering provision
• fulfilling our contractual obligations
The lawful basis for processing personal information
By law, we are only able to process your personal information if one or more of the following conditions applies:
• we can demonstrate a legitimate interest in the effective delivery of information and services to you and/or our clients, and in the effective and lawful operation of our businesses (provided these do not interfere with your rights)
• the processing relates to a contract that we have with you, or because you have asked us to take specific steps before entering into such a contract
• you have agreed to us processing your personal information for the relevant purpose. You also have the right to withdraw your consent at any time
Your rights
With regard to your personal data and how we process it, you have the following rights:
• the right to be informed
• the right of access
• the right to rectification
• the right to erasure
• the right to restrict processing
• the right to data portability
• the right to object
• rights in relation to automated decision-making and profiling
• sharing your information with other organisations
We may share your personal information with our service providers such as banks, payment processors, printers, database service providers, secure cloud storage providers, website hosting providers and email delivery service providers. Before sharing your personal information, we make sure that all such service providers meet relevant UK data protection regulations and legislation and that they will not use your personal information for anything other than the clearly defined purpose relating to the service that they are providing.
We may share your personal information with third parties – for example, to find consulting or training opportunities for Associates. We will only do this once we have your consent; you have the right to withdraw your consent at any time by contacting us at info@cadoganfinancial.co.uk.
We will never share your personal information with any third parties for marketing purposes without your prior consent.
International Transfers
As Cadogan Financial Ltd operates internationally, there may be instances if you are an Associate in which your personal information is transferred to and stored outside of the EU.
We only do this if:
• There is an EU model contract in place that ensures the recipient complies with the General Data Protection Regulation; or
• We have your prior consent, where we clearly explain how and to whom your information is being transferred outside of the EU; or
• The transfer is necessary for the performance of a contract between you and us, or the implementation of pre-contractual measures taken at your request or with your knowledge; or
• The transfer is necessary for the performance of a contract concluded between Cadogan Financial Ltd and another natural or legal person and in which you are an interested party.
Information security
Cadogan Financial Ltd is committed to protecting your personal information. We use appropriate technologies and policies so that your personal information is protected from unauthorised access and improper use.
How long we keep your information
We will retain your personal information only for as long as necessary, given the purposes for which it was collected, or as required to do so by law.
Your choices
If you wish to view, update and/or delete the personal information that we hold on you, or you want us to stop using your information or to stop contacting you, then please let us know by emailing info@cadoganfinancial.co.uk.
Updates and further information
This Privacy Notice was last updated on 26 June 2019.
If you have any questions or complaints about this Privacy Notice or the way your personal information is processed by us, or would like to exercise your rights as described above, please contact us at one of the following addresses:
Postal: Cadogan Financial Ltd, Higher House, High Street, West Lydford, Somerton TA11 8DG, United Kingdom
Email: info@cadoganfinancial.co.uk
You also have the right to lodge a complaint with your local data protection regulator. In the UK, that is the Information Commissioner’s Office (www.ico.org.uk)