Privacy Notice

Cadogan Asset Management Limited (CAM) is an FCA Regulated Firm and this privacy notice explains how we use any personal information we collect about you.

CAM is registered in the UK and its registered address is 12 Endeavour Square, London, E20 1JN. It’s company registration number is 10065415.

About our Privacy Notice

For the purposes of data protection law, we are a data controller in respect of your personal data.

The Firm is responsible for ensuring that it uses your personal data in compliance with data protection laws.

We are registered with the Information Commissioners Office as a Data Controller with registration number ZA211904.

This privacy notice applies if you are a client, a prospective client, an intermediary or a client of an intermediary. The privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.

What information do we collect about you?

We collect information about you when you engage us for discretionary investment services and for certain client’s corporate finance activities. This information will relate to your personal and financial circumstances. It may also include special categories of personal data such as data about your health, if this is necessary for the provision of our services.

We may also collect information when you voluntarily complete any client surveys or provide feedback to us.

Information relating to usage of our website is collected using cookies. These are text files placed on your computer to collect standard internet log information and visitor behaviour information. We will use your information collected from the website to personalise your repeat visits to the site.

Personal information that could be collected by CAM on the Website:

  • via enquiry, registration, claim forms, feedback forms and forums;
  • when you engage with any of our products or services;
  • when you fill out a survey, or vote in a poll, on this website;
  • through feedback forms and web analytics tags; and
  • when you provide your details to us either online or offline.

In addition, we may also collect IP addresses via a web analytics package.

The Website or may contain links to other websites which are outside our control and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy policy, which may differ from ours.

Information we obtain from other sources

Intermediaries

We will potentially receive information from agents, financial advisers and introducers including your personal details (which may include information about your health), contact details and relevant assets or policy details for the purposes of entering into and administering your agreement with us.

Why do we need to collect and use your personal data?

The primary legal basis that we intend to use for the processing of your data is for the performance of our contract with you. The information that we collect about you is essential for us to be able to carry out the services that you require from us effectively. Without collecting your personal data we would also be unable to fulfil our legal and regulatory obligations.

Where special category data is required we will obtain your explicit consent in order to collect and process this information.

How will we use the information about you?

We collect information about you in order to provide you with the services for which you engage with us.

You have the right to object to the use of your data for processing based on legitimate interests or the performance of a task mentioned above. However, please be aware that should you object to the use of your data it is high likely that we will not be able to provide our agreed services for you.

Who might we share your information with?

If you agree, we may email you about other products or services that we think may be of interest to you.

We won’t share your information for marketing purposes with any other companies outside of the Firm.

In order to deliver our services to you effectively we may send your details to third parties such as those that we engage for professional compliance, accountancy, trading, custodian or legal services as well as product and platform providers, life offices and SIPP Providers.

Where third parties are involved in processing your data we will have a contract in place with them to ensure that the nature and purpose of the processing is clear, that they are subject to a duty of confidence in processing your data and that they will only act in accordance with our written instructions.

Where it is necessary for your personal data to be forwarded to a third party we will use appropriate security measures to protect your personal data in transit.

To fulfil our obligations in respect of prevention of money-laundering and other financial crime we may send your details to third party agencies for identity verification purposes.

CAM will also take all reasonable steps to ensure that any personal data that you provide via the Website is kept secure. Although we endeavour to protect your personal data, because of the nature of the Internet, we cannot guarantee the security of your data transmitted to the Website and any inward transmission of data is carried out at your own risk.

How long do we keep hold of your information?

In principle, your personal data should not be held for longer than is required under the terms of our contract for services with you. However, we are subject to regulatory requirements to retain data for specified minimum periods. We also reserve the right to retain data for longer than this due to the possibility that it may be required to defend a future claim against us. In any case, we will not retain your personal data for longer than 5 years from the end of our regulatory obligations to retain the data.

You have the right to request deletion of your personal data. We will comply with this request, subject to the restrictions of our regulatory obligations and legitimate interests as noted above.

How can I access the information you hold about me?

You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information please email or write to us using the contact details noted below.

When your personal data is processed by automated means you have the right to ask us to move your personal data to another organisation for their use.

We have an obligation to ensure that your personal information is accurate and up to date. Please ask us to correct or remove any information that you think is incorrect.

Therefore, if you believe that there may be an error in any of the information that you have submitted via the Website, or held by us, please email: feedback@cadoganam.com and we will review your records and amend them as soon as possible.

Marketing

We would like to send you information about our products and services which may be of interest to you. If you’ve agreed to receive marketing information, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please contact us by email or post.

Cookies

We use cookies to track visitor use of the website and to compile statistical reports on website activity.

For further information visit http://www.allaboutcookies.org/

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

What can you do if you are unhappy with how your personal data is processed?

If you have a complaint in relation to the Website, or how CAM handles your data, please contact us at:

Cadogan Asset Management Limited
12 Endeavour Square
London
E20 1JN

Email:
feedback@cadoganam.com

You also have a right to lodge a complaint with the supervisory authority for data protection. In the UK this is:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

0303 123 1113 (local rate)

Changes to our privacy policy

We keep our privacy policy under regular review and we’ll place any updates on this web page (and/or) inform you of any changes when they occur. This privacy policy was last updated on 24th May 2018.

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you. Please direct any such request to us by e-mailing us on feedback@cadoganam.com

Or write to us at: -

The Data Protection Officer
Cadogan Asset Management Limited
12 Endeavour Square
London
E20 1JN