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Privacy Policy

Cornelian is committed to protecting your personal information. This Privacy Policy has information about the personal details we collect; what we do with that information; who we might share it with and why; and your rights.

This version of our Privacy Policy was last updated May 2018.

Who we are

Cornelian Asset Managers Limited are a UK financial services company registered in Scotland (registration number SC113646) that is authorised and regulated by the Financial Conduct Authority (reference 143452) and as a Data Controller with the Information Commissioners Office (reference Z4632666).  Cornelian Asset Managers Group Limited comprises several companies of which Cornelian Asset Managers Limited, Cornelian Asset Managers General Partners Limited and Cornelian Asset Managers Nominees Limited are Data Controllers.

How to contact us

As a company of less than 250 employees, Cornelian is not required to appoint a Data Protection Officer but our Manager, Compliance & Risk  is responsible for overseeing data protection so if you have any questions about our Privacy Policy or the information we collect or use about you, please contact:

Manager, Compliance & Risk
Cornelian Asset Managers Limited

30 Charlotte Square
Edinburgh
EH2 4ET
Tel:  0131 243 4130

The information we collect and use

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you. This includes:

  • Information about who you are e.g. your name, date of birth and contact details
  • Information connected to your product or service with us e.g. your bank account details
  • Information about your contact with us e.g. meetings, phone calls, emails / letters
  • Information that is automatically collected e.g. via cookies when you visit our websites
  • Information you may provide us about other people e.g. joint applicants or beneficiaries for products you have with us
  • Information of health, marital status may be collected only when it is needed to provide the service you have requested or we require it to comply with legal obligations. This is sensitive data.
  • Information on children e.g. where a child is named as a beneficiary. In these cases, we will collect and use only the information required to identify the child (such as their name, age, gender)

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Cookies

A cookie is a small file and it is saved onto your computer or other device when you visit our website. Cookies store small pieces of information, for example, they will remember you have visited our website or performed a certain action so they help us customise our web service.

Your browser will allow you to disable cookies. However, if you do disable cookies you may find that your use of the site is impaired.

How we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

  • phone conversations with us
  • forms that are completed when you apply for one of our services or products
  • emails or letters you send to us
  • meetings with one of our investment managers
  • registering for one of our events
  • our online services such as websites or social media

We may also collect personal information on you from places such as business directories and other commercially or publicly available sources which we usually do to check or improve the information we hold (like your address).

What we use your information for

We only ever collect and use information which is personal to you if we really need to and where it is necessary, fair and lawful to do so. To make sure of this we will only collect and use your information when:

  • you have given us your consent to send you information about products and services offered by Cornelian or asked us to share information with another professional adviser e.g. your accountant
  • it’s necessary to provide the product or service you have requested
  • it’s necessary for us to meet our legal or regulatory obligations e.g. to send you reports on a portfolio
  • it’s in the legitimate interests of Cornelian e.g. to deliver appropriate information and guidance together with providing information on our investment proposition to clients.

If we are not able to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Risk & Compliance Manager.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who we may share your information with

We sometimes have to share your information with third parties and these third parties include:

  • Companies we have chosen to support us in the delivery of the products and services we offer to you and other clients e.g. technology companies; or companies who can help us in our contact with you, for example, an internet service provider
  • Our regulator, the FCA, and the Information Commissioner’s Office
  • Our auditors and other professional advisers including lawyers, bankers and insurers
  • Law enforcement, credit and identity check agencies for the prevention and detection of crime
  • HM Revenue & Customs (HMRC) e.g. processing of Individual Savings Accounts (ISA) returns, prevention of tax avoidance or tax regulation

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations as the Data Controller to keep your information safe and secure.

Where your information is processed

Your information is currently processed in the UK however this may change in future and we will amend this policy if that occurs.

Protecting your information

Any personal information, however it is collected or used, will have appropriate safeguards applied in line with our data protection obligations. We ensure our employees are appropriately trained and that our IT security controls are of a high standard.

Keeping your information

We will keep your personal information only where it is necessary to provide you with our products or services while you are a customer but we might be required to keep it after that time for instance, to meet our legal and regulatory regulation. This means the length of time we need to keep your information can vary in line with these obligations. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements

Your rights

You have a number of rights and these are:

To be kept informed
We will provide you within this policy, information on what personal data we have, why we have it, who we share it with and why.  

To have access
You can access the data we hold on you by making a request to our Manager, Compliance & Risk.

To correct your data
We will try to ensure your personal information is accurate but if you are aware it is inaccurate, you can request that it is corrected.

Right to request erasure
You can ask for your information to be deleted or removed from our records but there may sometimes be reasons we cannot fully comply this, for instance our regulator demands it is kept, but we will explain that to you if that’s the case.

Right to restrict processing
You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information but only so we don’t use it in the future for those reasons you have restricted.

Data portability
You can ask for a copy of your personal information for your own purposes to use across different services for instance, if you were transferring to another financial services provider.

Right to object
You can object to Cornelian processing your personal information where: it’s based on our legitimate interests. We will not use legitimate interests as a reason to send you marketing and would always ask for your consent.

How to make a complaint

If you do not believe we have dealt with your information as described in this policy, please contact our Manager, Compliance & Risk. We will investigate and do our best to address any issues. If you are still unhappy, you can complain to the Information Commissioner’s Office. Their website is www.ico.org.uk or you can telephone their helpline on 0303-123-1113. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

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