Privacy and Cookie
Policy
General
This Privacy Notice sets out how we obtain and use personal data
about you before and after any relationship with me, in accordance with the
Data Protection (Bailiwick of Guernsey) Law, 2017 (“GDP Law”) and in accordance
with the European Union General Data Protection Regulation (2016/679) (“GDPR”).
CoEfficient Limited (“CoEfficient", "We",
"Our", "Us", or the "Company") is a “data
controller”. This means that CoEfficient is responsible for deciding how we hold
and use your personal data. CoEfficient is required, under the data protection
legislation detailed above, to notify you of the information contained in this
privacy policy.
This notice applies to our clients (including their clients and
their underlying principals, directors, officers and employees) service
providers, intermediaries and other contacts of ours (whether current,
prospective, declined, exited or former) and all users of our website,
including those that sign up to our blog and other news items. CoEfficient may
update this Policy at any time, however when we do, and the change is
substantive, we will notify you.
Any questions in relation to this Privacy Policy or requests in
respect of personal data should be directed to hello@coefficient-solutions.com
in the first instance.
The Data We Hold
The personal data we hold varies depending on the services
provided by us, ensuring we only process personal data that is adequate,
relevant and necessary for the purpose. The types of data we collect and
process include:
•
Contact details
•
Information required
to meet legal and regulatory requirements.
•
I
nformation
provided during the provision of our services.
•
F
inancial
information, such as payment-related information.
•
Any other information
you may provide to us.
Purposes of processing
CoEfficient uses your personal data for the
following purposes:
Purpose and Lawful
Basis for Processing
•
To enter into or exit client relationships
and provide analytics, insights and other advisory services.
•
To manage our client,
intermediary and other business relationships.
•
To seek to ensure our business is conducted
efficiently and with a view to enhancing client services.
•
To administer any contract we have entered
into with you or where you are a party related to an entity for which we are
contracted to provide services.
•
To fulfil the
contract we have entered into.
•
To provide our
contacts with marketing material.
All marketing material is provided on the basis of consent.
Consent may be withdrawn at any time by unsubscribing from our newsletter or
emailing: hello@coefficient-solutions.com.
•
To ensure the
security of any systems we use and prevent fraud.
•
To obtain legal
advice and/or representation.
•
To meet all legal and
ethical obligations including in respect of managing conflicts of interest.
•
To ensure we meet all
legal and ethical obligations incumbent on us.
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 we need to use your personal data for
an unrelated purpose, we will notify you and explain the legal basis which
allows us to do so.
Please note: We may process your personal data without your
knowledge or consent where this is required or permitted by law.
Failure to provide personal data
If you fail to provide certain personal information and data
when requested, we may not be able to fulfil the contract we have entered into
with you, or on your behalf, or provide the services requested or we may be
prevented from complying with our legal obligations.
Sources of personal data
Our sources of data may include clients, data subjects directly,
introducers, intermediaries, advisers, third parties connected to the data
subject (for example: family member, employer or another service provider who
provides services to the data subject) or open-source material.
We collect personal data via the completion of forms [electronic
and paper] provided to you and completed by you, from documents provided
including due diligence documents, from correspondence including email, from
meetings, text messages and telephone conversations.
We will collect personal data throughout the course of our
business relationship or while we provide services to clients connected to you.
We rarely share information with third parties, however
sometimes we may have to, including third party service providers, where
required by law, where it is necessary to administer our business relationship,
where it is necessary for us to provide the services to you or where we have
another legitimate interest in doing so.
The following are
potential recipients of personal data (in each case including respective
employees, directors and officers):
•
Sub-contractors, agents, consultants or service providers such
as insurance brokers, IT firms or other professional advisers of us or our
clients, and their clients, and associated parties
,
bankers, auditors, accountants, investment
brokers, managers or advisers, legal and other professional advisers
•
Guernsey and overseas regulators, or other government, or
supervisory body and tax authorities when required by law
•
Law enforcement agencies where considered necessary for me to
fulfil our legal obligations
When we engage a third party to process your personal data, we
will require them to process your personal data in accordance with this
instruction and protect the data against unauthorised or accidental use,
access, disclosure, loss or destruction.
They cannot use your personal data for their own purposes. They
will only be permitted to process your personal data for a specified purpose
and in accordance with instructions. Where they no longer need to your personal
data to fulfil the contract, they will need to transfer the data back to us
and/or destroy or delete any data held by them.
Transferring data outside of
Guernsey and the EU
In the event any of the third parties detailed above are outside
of Guernsey and the EU and where we are transferring personal data, which would
be protected under the GDP Law or GDPR, we will ensure that we meet the
relevant requirements prior to carrying out such a transfer. This may include
only transferring the data where we are satisfied that:
The non-European Union country has Data Protection laws similar
to the Laws in Guernsey and the European Union. The recipient has agreed,
through contract, to protect the information to the same Data Protection
standards as Guernsey and the European Union
.
We have obtained consent from the relevant data subjects to the
transfer, or if transferred to the United States of America, the transfer will
be to organisations that are part of the Privacy Shield or any subsequent reciprocal
arrangement.
Data Security
We have put in place appropriate security measures to prevent
your personal data from being accidentally lost, altered, disclosed, used or
accessed without authorisation. In addition, we restrict access to your personal
data to those employees, agents, contractors, consultants and other third
parties who have a business need to access your data. They will only process
your personal data on our instruction and they are subject to a duty of
confidentiality.
We have in place procedures to deal with any suspected data
security breach and will notify you and any applicable regulator of a suspected
breach where we are legally obliged to do so.
Data Retention
We only keep data for as long as is necessary to fulfil the purposes
(as set out above) for which we collected it. To determine the appropriate
retention period for personal data, we consider the amount, nature and
sensitivity of the personal data, the potential for harm from unauthorised use
or disclosure of the data, the purposes for which we process the personal data
and whether we can achieve those purposes through other means, and the
applicable legal requirements.
Once our business relationship ends, we will retain and securely
destroy your personal data in accordance with our record retention and
destruction policy, applicable legislation and/or regulatory requirements.
Your Rights
As a data subject you have the following
rights in respect of your personal data:
Right of access
You have the right to request a copy of the personal data that
we hold about you and to check that we are lawfully processing that data. You
will not have to pay a fee to access your personal data (or exercise any of the
other rights) unless your request is clearly unfounded or excessive, in which
case we may charge a reasonable fee or refuse to comply with the request.
Right of rectification
You have the right to correct data that we hold about you, which
is inaccurate or incomplete.
Right of erasure
This enables you to ask us to delete or remove personal data
where there is no good reason for us to continue to process it.
Right to restrict processing
This enables you to ask us to suspend the processing of your
personal data for example: if you want us to establish its accuracy or the
reasons for processing it.
Right of portability
You have the right to
have the data we hold about you transferred.
Right to object
You have the right to object to certain types of processing
including direct marketing. You also have the right to ask us to delete or
remove personal data where you have exercised your right to object.
Right to object to automated processing including profiling -
you have the right not to be subject to decisions based on automated processing
or profiling. We do not currently undertake any automated processing or
profiling.
If you wish to exercise these rights, you should send the
request in the first instance to hello@coefficient-solutions.com.
Status
This Privacy Policy sets out our current policy as regards the
maintenance and processing of personal data. It does not form, and should in no
way be construed as, a contract and no contractual rights or causes of action
shall arise in relation to or consequence of the content of this Policy.
Changes to this Privacy Policy
This Privacy Policy is kept under review and any updates will
appear on our website at www.coefficient-solutions.com
This Privacy Policy was last updated on 30
June 2022.
The changes were related to the incorporation of CoEfficient
Limited and the changes were not substantive.
Complaints
In the event you wish to make a complaint about how your
personal data is being processed or how your complaint has been handled you
have the right to lodge a complaint directly with the Office of the Data
Protection Authority (“ODPA”) either via email
enquiries@odpa.gg
or by post at:
The Office of the Data Protection Authority
St Martin’s House
Le Bordage
St. Peter Port
Guernsey
GY1 1BR
You may also appeal
to certain courts against (i) any failure of the ODPA to give written notice of
whether the complaint is either being investigated or not being investigated
and where applicable, the process and outcome of the investigation and (ii) a
determination of the ODPA not to investigate the complaint or a determination
that a controller or processor has not breached or is not likely to breach an
operative provision in connection with the complaint.
Cookie Policy
Cookies are small text files which are transferred to your
computer or mobile when you visit a website or app.
We use them to:
•
Remember information about you, so you don’t have to give it to
us again.
•
Keep you signed in [if required], even on different devices.
•
Help us understand how people are using our
services, so we can make improvements.
•
To deliver advertising to websites outside of the UK.
•
To find out if our emails have been read and if you find them
useful.
First Party Cookies
These cookies are set by the website you’re visiting. And only
that website can read them.
Third Party Cookies
These cookies are set by someone other than the owner of the
website you’re visiting. Some of our web pages may also contain content from
other sites, which may set their own cookies. Also, if you share a link to a
page on our website, the service you share it on (for example, Facebook) may
set a cookie on your browser. We have no control over third-party cookies - you
can turn them off, but not through us.
Session Cookies
These cookies only last as long as your online session, and
disappear from your computer or device when you close your browser (like Chrome
or Safari).
Persistent Cookies
These cookies stay on your computer or device after your browser
has been closed and last for a time specified in the cookie. We might use
persistent cookies when we need to know who you are for more than one browsing
session. For example, we use them to remember your preferences for the next
time you visit, if you use the members area.
Strictly Necessary
Cookies
These cookies let you use all the different parts of our
website. Without them, services that you’ve asked for can’t be provided. Also,
we may collect data from you to help us understand how you are using the
website, so we can make it better.
Other Tracking
Technologies
Some sites use things like web beacons, clear GIFs, page tags
and web bugs to understand how people are using them and to target advertising
to them.
They usually take the form of a small, transparent image that is
embedded in a web page or email. They work with cookies and capture data like
your IP address, when you viewed the page or email, what device you were using
and where you were.
Contact details
If you have any questions about this Privacy and Cookie Policy
or any data which we hold about you, please contact us:
Email: hello@coefficient-solutions.com