Privacy Policy

INTRODUCTION

This Privacy Policy explains how we use the personal information that Cordello Home Limited collects or generates both in relation to this website and our products and services.

Cordello Home Limited collects and uses certain Personal Data. Cordello is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.  

At Cordello Group, we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Cordello in the course of carrying on commercial activities.

We use the following definitions in this Privacy Policy:

“Cordello”, “we” or “us” means Cordello Home Limited.

“Personal Data” means any data which relates to a Cordello individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Cordello (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Cordello or any other person in respect of an individual. 

The products and services we provide

This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:

1. Information we receive through our website ("Cordello website");
2. Information we receive through our products ("Cordello products"); and/or  
3. Information we receive through our support (or cloud-based) services.

The types of personal data we collect

Many of the services offered by Cordello require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described above, we will collect and process the following Personal Data about you:

Information that you provide to Cordello Home. This includes information about you that you provide to us by completing forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

• basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country).
• any information that you choose to share with Cordello which may be considered Personal Data

Information that we collect or generate about you. This includes (by way of non-exhaustive list):

• information relating to your (or an applicant’s) investment in the applicable Cordello Product, emails (and related data), customer relationship management information, call recordings and website usage data.
• a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the applicable Cordello Products.   
• through our cloud security services, traffic and security reports that include information on the internet usage of the relevant users.     

 Information we obtain from other sources. 

• This might include information obtained for the purpose of our know-your-client procedures (which include anti-money laundering procedures, counter-terrorist financing procedures, politically-exposed-person checks, sanctions checks, among other things), information from public websites and other public sources and information received from your advisers or from intermediaries. 

How we use your information

Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• to communicate with you in order to provide you with services or information about Cordello and Cordello Products;
• for our business activities relating to the Cordello Products, such as investor relations, discussions with the applicable Cordello Product’s service providers and counterparties, decision-making in relation to the applicable Cordello Product, and business strategy, development and marketing;
• to set up users to use Cordello Websites;
• for assessing and processing applications for interests in the Cordello Products and other interest dealings, including performing know-your-client procedures, issuing and withdrawing interests, receiving payments from and making payments to the applicant, calculating net asset value, and overseeing these processes;
• for general business administration, including communicating with investors, communicating and liaising with service providers and counterparties, accountancy and audit services, risk monitoring, the administration of IT systems and monitoring and improving products;
• for compliance with legal and regulatory obligations and industry standards, including know-your-client procedures, the automatic exchange of tax information, legal judgments and internal policies and procedures;
• for ongoing review and improvement of the information provided on Cordello Websites to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
• to understand your needs and interests; and/or
• for the management and administration of our business.

However, we use Personal Data, we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

• we need to do so in order to perform contractual obligations with our customers;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• we have obtained your consent; and/or
• the use of your Personal Data as described is necessary for our legitimate business interests, such as:
• allowing us to effectively and efficiently manage and administer the operation of our business;
• maintaining compliance with internal policies and procedures;
• monitoring the use of our copyrighted materials;
• enabling quick and easy access to information on Cordello Products; and/or
• ensuring the security of information systems.

We will take steps to ensure that the Personal Data is accessed only by employees of Cordello that have a need to do so for the purposes described in this Privacy Policy. 

Disclosure of your information to third parties

We may share your Personal Data outside of Cordello Home for the following purposes (in pursuit of our contractual obligations to you as a client):

• with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased the Cordello Product(s). Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
• with third party agents and contractors for the purposes of providing services to us (for example, Cordello’s accountants). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation or regulation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
• if we sell any of our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
• if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer. 

International transfers of personal data

Cordello Home is a global business. Our customers and our operations are spread around the world. As a result, we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme;
• such transfer being otherwise permitted pursuant to appropriate safeguards envisaged by applicable law; or
• in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.

You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in the Questions and Concerns section below.

How we safeguard your information

We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

As a condition of employment, Cordello employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Cordello employee is prohibited and may result in disciplinary measures.

When you contact a Cordello employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

How long we keep your personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

• the purpose for which we are using it – Cordello will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data. 

Your rights

In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Cordello;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled or required to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled or required to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details listed below. 

Questions and concerns

Cordello’s registered office may be contacted using the following contact information: Cordello Home, Tea Building, Studio 2.10, 56 Shoreditch High Street, London E1 6JJ, United Kingdom

If you have any questions or concerns about Cordello’s handling of your Personal Data, or about this Policy, please contact our Privacy Officer using the following contact information:

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from us, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Cordello will provide you with the contact information for that regulator. 

Cookies

During the course of any visit to the Cordello website, cookies may be downloaded to your device. We use these cookies to understand if you have visited the web site before or are a new/unique visitor. Once this is determined, we then store information about your visit such as your current location (to the nearest major location, such as London UK or New York City USA), what pages you visit, and how long those pages take to load. If you log in to the members’ area of the website we may record additional information such as, time of login and what documents you download.

If you choose not to allow cookies, you will be unable to log in to the members’ area of the Cordello website.

Cookies used by the Cordello website:

The Cordello website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics sets two cookies in order to evaluate your use of the website and compile reports for us on activity on the website.

The information collected by these cookies is anonymised and limited to web site use and performance, device operating system, browser type, internet service provider name and non-specific geographic location.

Google stores the information collected by the cookie on servers in the United States. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using the Cordello website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

life@cordellohome.com. 

Last update: June 2018