About us

We are committed to safeguarding the privacy of the personal information provided to us or collected by us during the course of our business as well as the personal information we receive from visitors to our website.

This policy explains how we may collect and use any personal information that we obtain about you and your rights in relation to that information.  It also sets out how to contact us if you have any questions or want to make a complaint to us about how we handle your personal information.

What information do we collect about you and how?

1. Business Development and Business Acceptance

We collect personal information about prospective clients and their beneficial owners or controllers as part of business development initiatives and our business acceptance process. The type of personal information we may collect includes name, address, nationality, business interests and employment history. We obtain this information from publicly available open sources.

2. Professional Services and Relevant Marketing

The type of personal information that we may collect includes current and historical information including your name and contact details (such as your address, email address and telephone numbers) and identifiers such as your organisation, employment history and positions held. We obtain personal information from your IP address and the operating system and web browser with which you access our website.  

We may email you about our services, regulatory developments and invite you to events (including those we may jointly host with other organisations).

You can control the information you receive through our direct marketing function by using the “Managing your preferences” option at the bottom of the emails.  If you no longer wish to receive marketing emails relating to our services by email or post, you can unsubscribe at any time by using the “Unsubscribe” option on the email footer or by contacting info@cosecadmin.com.

How we use your information?

We will only use your personal information within the boundaries of the law.  We will therefore only process your personal information if:

1. it is necessary in connection with a legal obligation;
2. it is necessary for the performance of a contract with you or the organisation you work for;
3. you have given your consent (where necessary) to such use or the organisation you work for has obtained your consent (where necessary) to share your information with us; or
4. if we (or a third party) have a legitimate interest which is not overridden by your interests or your rights and freedoms. Such legitimate interests include the provision of professional services, running the firm’s business and marketing relevant services directly to you.

We may use your personal information to:

1. consider whether we can pursue certain business development initiatives;
2. comply with our legal obligations to identify and verify the identity of our clients and their beneficial owners;
3. deliver services to you and/or the organisation you work for, if you are a client;
4. maintain and develop our business relationship with you;
5. improve our services and products to you, if you or the organisation you work for are a client or prospective client;
6. identify services you may be interested in;
7. send you marketing materials and invite you to events;
8. monitor and analyse our business; or
9. process and respond to requests, enquiries or complaints received from you.

We will only retain your personal information for as long as is necessary for the purpose for which it was collected, including for the purposes of complying with any legal, regulatory, accounting or reporting requirements. Personal information processed in connection with our business acceptance processes and/or providing services will be retained in accordance with the firm’s retention and destruction policy unless we agree otherwise with you, in writing. 

How and why do we share your personal information?

We use third parties who provide services on our behalf and will share your information with them, for example a technology supplier may have access to your personal information when providing software support, or a company we use for a communications campaign may process the personal information of our contacts for us.  We may also have to share your personal information with regulators, government agencies, courts and other third parties.

We may only share your personal information with third parties where you have consented to us doing so (where necessary) or the organisation that you work for has obtained your consent for us to do so (where necessary) and we are under a legal, regulatory or professional obligation to do so (for example, to comply with anti-money laundering or sanctions requirements).

Third Party sites

Our Websites contain links to other sites which are controlled by third parties.  You should review these other sites’ privacy policies.  We do not accept any responsibility for their use of your personal information.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

How long we retain your data

If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

Your rights

You have certain rights that you can exercise under certain circumstances in relation to the personal information that we hold.  These rights are to:

1. request access to your personal information and request certain information in relation to its processing;
2. request rectification of your personal information;
3. request the erasure of your personal information;
4. request that we restrict the processing of your personal information; and
5. object to the processing of your personal information.

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.  Once the firm has received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you would like to exercise any of these rights, please contact us by emailing info@cosecadmin.com.