From 25 May 2018, this policy applies to any person –including existing investors, potential investors, developers, service providers and introducers – registering, using or interacting with Cogress’ website www.cogressltd.co.uk (“website”), applications, offline activities, products and services, from any device, and any other instances where Cogress collects your personal data.
In this policy, we aim is to provide you information which is concise, transparent, intelligible, easily accessible and uses clear and plain language. We take your privacy seriously and will only use your personal information to provide the products and services you have requested from us.
Please read this policy in conjunction with our Terms and Conditions and Cookies Policy.
“Personal data” is information that can be used to identify you, directly or indirectly, alone or together with other information (e.g. full name, contact details, precise location, device IDs, certain cookie).
For complete information on GDPR and related topics, visit the Information Commissioner’s Office (“ICO”) website at www.ico.org.uk.The ICO is the UK’s independent regulatory office (national data protection authority) dealing with the Data Protection.
As applicable, we are the data controller of your personal data. “Data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.
Cogress is registered with the Information Commissioner’s Office (“ICO”).
Contact Details & Data Protection Officer
We have voluntarily appointed the role of Cogress’ Data Protection Officer (“DPO”) to Ilanit Orly, Director and Chief Operating Officer. For any queries or questions on this policy, or to contact the DPO, contact details are as follows:
- Address: Cogress Limited, 50 Eastcastle Street, 2nd Floor, London, W1W 8EA, UK
- E-mail: [email protected]
- (+44) 020 7100 9744
Information that you provide to us
Cogress may obtain personal information about you because you or other third parties (e.g. a service provider in respect of the products and services) provide it to us, or because the information is publicly available (e.g. on your LinkedIn profile).
The personal data that we may collect and process may include your full name, age, date of birth, gender, contact details, proof of identity and address, nationality, employment and investments history, financial information, bank account details, complaint details and how you interact with our website.
We will process personal information that you give to us as follows:
- Signing up to receive information on Cogress’ products and services– when you register on our website (i.e. as a high net worth investor or a self-certified sophisticated investor) to become an investor or a potential investor of Cogress; or when, in any capacity (e.g. existing or potential service provider), you contact us with queries (i.e. via phone or e-mail); or respond to our communications.
- In connection with the provision of our products and services to you– you will provide us with personal information, when you, or the company you represent, or we will obtain information about you, when you wish to become or become an investor of Cogress (e.g. information you provide by completing our Appropriateness Questionnaire and when we conduct anti-money laundering (“AML”) and Know Your Customer (“KYC”) checks on you). If you are not an investor, we may also collect or receive your personal information because you are involved in one of our investor’s matters (i.e. you referred an investor to us, or are an introducer). This process may include processing special category of data (e.g. biometrics where used for ID purposes).
- Developers– when, as a Developer or related party, you contact us to explore the possibility of doing business with Cogress. Subsequently, Cogress may process extensive information about a developer to undertake the due diligence process, and during the business relationship.
Cogress does not intentionally request or collect or store information about children.
If you change your mind about being contacted in the future by Cogress, please let us know.
Other information that we otherwise collect from you
What do we use your personal data for?
Your information will enable us to keep you informed of and to supply our products and services. By registering on the website, you also agree that we may contact you as necessary. We may use the information we obtain about you as follows:
- To comply with our legal and regulatory obligations (e.g. record-keeping requirements, conducting AML and KYC checks, at application and periodically thereafter, and to determine your appropriateness to investment).
- To provide products and services to investors.
- To provide information on investment opportunities to potential investors and repeated investors (including about important changes, or developments to, as applicable, the website, our products and services and business).
- To operate and improve our products, services and business.
- To provide personalised content to you (e.g. tailoring our products and services and our digital customer experience to you).
- To update and enhance our investors’ and potential investors’ records.
- For advertising, marketing and business development purposes (e.g. to provide you with innovative products and services, including sending you newsletters, updates, marketing communications and other information that may be of interest to you, including via social media and digital channels (e.g. LinkedIn)); to make automated decisions on whether to offer you a product or service.
- To establish, exercise or defend our legal rights, or for the purpose of any legal proceedings, and for crime prevention (e.g. manage any actual or potential fraud or illegal activity).
- For our legitimate business interests (e.g. undertaking business research, analysis, due diligence on developers, managing the operation of our websites and our business and general analysis for management purposes).
- To investigate any complaint or expression of dissatisfaction we may receive from you, and to contact you for your views on our services (e.g. survey).
- To monitor and to keep records of our communications between you and our staff.