Privacy Notice
Introduction
Cadogan Tate Group Limited and it’s subsidiaries and affiliates, including it’s parent companies (“We” or “Cadogan Tate”) value your privacy. This Privacy Notice explains how Cadogan Tate collects, uses, and shares Personal Data from its customers, prospect customers, vendors, business partners and website visitors when We act as a data controller. “Personal Data” is defined as any information that directly or indirectly identifies an individual (“Personal Data”). A Data Controller is an entity that decides why and how Personal Data is used or processed. This Privacy Notice sets forth our privacy standards when collecting and processing your Personal Data.
Cadogan Tate is committed to protecting your Personal Data in accordance with the applicable data protection laws where we operate. This includes the use of our website. Before using any website owned or controlled by Cadogan Tate, including www.cadogantate.com (collectively, the “Website”), please read this Privacy Notice carefully. If you do not accept and agree to be bound by its terms, then please discontinue the use of the Website.
Why we collect your Personal Data?
When We collect Personal Data, we ensure that their processing has a legitimate basis and is compliant with the applicable data protection laws. In most cases We collect and process your Personal Data based on the following legal grounds:
- Contract performance: when processing is necessary to conclude and perform our contract with you or in order to take steps at your request prior to entering into a contract (eg. sending you a quote or information about our services);
- Consent: when We have obtained your consent for processing your Personal Data (eg for receiving marketing or commercial information about our products and services or tracking your activities through our website using cookies);
- Legitimate interest: when process your Personal Data to fulfil our legitimate business purposes (e.g., displaying website content relevant to your geographical location or sending you information about our services and new services, our newsletters and other information related to your previous business relationship with us). When relying on legitimate interest, we will make sure it is proportionate and ensure that there is a good balance between your rights and our own business interests;
- Compliance with applicable laws: when processing is necessary to comply with the relevant legal or regulatory obligations that We have (eg when we have an obligation to report to public or tax authorities or to perform compliance checks).
What information we may collect and for what purpose?
Depending on your relationship with Cadogan Tate and the circumstances, and subject to the applicable laws and regulations in your country, We may collect and use your Personal Data through various situations or sources:
- Through our Website
- By telephone
- As a consequence of an email contact or an enquiry
- Through publicly available sources
- As a result of a job application
- During fairs and events
- In person
- etc
The Personal Data we collect include among others the following (non-limitative list): personal and/or professional contact information (e.g. name, address, telephone number); technical information (e.g., IP address, Client Portal’s user IDs and passwords, access logs), professional credentials (eg title/function), personal identification information (eg Tax ID, ID or Passport number/copy, Date of birth), bank account information, credit card details, CCTV footage, etc. These Personal Data will be processed for the following main purposes: contract negotiation and execution, regulatory compliance, business developments, marketing and communication, claim management, administration and accounting, tax, due diligence screening, audit investigations, service improvement, Health & Safety, security, etc.
Cadogan Tate does not knowingly collect, use, or process Personal Data of users who are under 16 years of age. In fact, the Website is intended solely for users who are 16 years of age or older. If you believe that We collected, used, or processed Personal Data of any person who is under 16 years of age, please contact Cadogan Tate at data@cadogantate.com.
We may also collect Personal Data via the Website through Cookies and similar technologies. A cookie is a small text file placed onto your device, by a website that you visit. These files allow us to operate the Website, improve the Website’s user experience by delivering content tailored to users’ interests, collect user data and enable other features. Where required, We use cookies only upon your consent. The Website also allows you to control some cookies through the cookies banner or through your browser’s settings. To know more about cookies and update your cookie settings, please click on the cookie link at the bottom corner of this page.
Plug-ins: The Website uses several Plug-ins. When you visit a page on the Website that uses a Plug-in, your browser establishes a direct connection to the server of the applicable third-party software platform (e.g., Facebook, Twitter, LinkedIn, YouTube) (the “Platform”). The Platform then directly transfers the Plug-in content to your browser, which embeds such content in the Website. This process enables the Platform to receive information about your use of the Website. If you are a member of a Platform and logged into your Platform account, then your use of the Website may also be assigned to your Platform account. If you want to prevent such assignment, then please log off of your Platform account before using the Website. For further information regarding the privacy, protection, and processing of your Personal Data by Platforms, please consult their respective privacy policies.
CCTV: we employ CCTV on all our physical locations for the purposes of security and health and safety. We usually hold this footage for approximately 30 days after which time the footage is overwritten. The images may be kept for a longer period of time for operational purposes or in case of actual or threatened complaint, claim or litigation. CCTV footage may also be provided to law enforcement or other regulatory bodies in the event of a security or safety incident, as required by applicable laws.
CCTV: we employ CCTV on all our physical locations for the purposes of security and health and safety. We hold this footage for approximately 30 days after which time the footage is overwritten. The images may be kept for a longer period of time and/or provided to law enforcement or other regulatory bodies in the event of a security incident.
How do we share your Personal Data?
Your Personal Data may be transferred to or accessed by other Cadogan Tate companies and/or third parties (eg our subcontractors) globally. If the recipients is located in a country that do not provide an adequate level of protection to your Personal Data from the perspective of the origin country, we shall ensure that the Personal Data subject to the transfer are adequately protected as required by the applicable data protection laws of the origin country.
When transferring Personal Data, We will rely on one or more of the following:
- Intercompany agreement on the transfer and processing of Personal Data within Cadogan Tate to enable internal transfer of Personal Data between our group companies located in different countries (as applicable).
- Standard Contractual Clauses (“SCCs”) for international transfers of Personal Data (eg. EU Commission standard contracts), as may be applicable and relevant.
- Where required by applicable law, We will request your consent for transfer of your Personal Data.
How long shall we keep your Personal Data?
We will retain your Personal Data for as long as is reasonably necessary for the purposes for which it was collected. In some circumstances We may retain your Personal Data for longer periods of time (eg when We are required to do so in accordance with legal, regulatory, tax or accounting requirements or if we need to keep accurate record of your dealings with us in the event of any actual or threatened complaint, claim or litigation).
Where We have obtained your consent to process your Personal Data in order to provide you with marketing information for our products and services, your Personal Data will be stored by us as long as you do not tell us you do not want to receive such information anymore, subject to more stringent requirements under applicable laws.
Where your Personal Data is no longer required We either delete it by erasing electronic files, shredding physical records or anonymise them in a way that We are no longer able to identify you. Cadogan Tate has dedicated internal policies that keep us compliant with the above retention rules.
Your Rights with respect to your Personal Data.
We acknowledge and respect your rights with regards to your Personal Data. Depending on the data protection laws applicable to you, these rights may include:
- access and obtain a copy of your Personal Data;
- rectify or erase your Personal Data;
- restrict the processing of your Personal Data;
- delete or anonymise your Personal Data, unless there are legal exceptions, e.g., when the law allows us such continuous processing or forbids us such deletion;
- request a copy of your personal data in a machine-readable format (“Data Portability”)
- object to the processing of your Personal Data or withdraw your consent for the processing of your Personal Data;
- obtain a copy of the Personal Data safeguards applied for transfers outside your jurisdiction where applicable;
- lodge a complaint with your local Data Protection Authority;
Subject to legal and other permissible considerations, We will make every reasonable effort to respond to your request as soon as possible (in any case within the timeframe required by law) or inform you if We require further information to fulfil your request. In some cases, your ability to access or control your Personal Data will be limited, as required, or permitted by applicable law. We may also ask you for additional information to verify your identity and for security purposes, before disclosing the requested Personal Data to you. Where permitted by law, We also reserve the right to charge a fee, if your request is manifestly unfounded or excessive.
How do we protect your Personal Data from unauthorised use or access?
Cadogan Tate recognises the importance of protecting your Personal Data and applies appropriate administrative, technical, and physical security controls to protect your Personal Data. These controls are designed to maintain the confidentiality of Personal Data and protect it from unauthorized access, improper use, and accidental loss.
Links to other websites
This privacy notice does not cover the links within the Website linking to other external websites. We encourage you to read the privacy statements on the external websites you visit.
Changes to this Privacy Notice
We may from time to time make changes to this privacy policy. Any changes will be published on our website and will be effective as of the date of publication (which will also be noted on our website). Your continued use of the Website following the posting of any revised Privacy Notice means that you accept and agree to be bound by such Notice. You are expected to review this Privacy Notice periodically and inform yourself of any revisions.
How to contact us
If you have any questions or want to request information about our privacy policy you can email us at data@cadogantate.com or write to:
Compliance Department
Cadogan Tate Group Limited
Cadogan House
239 Acton Lane
London
NW10 7NP
UK
We will ensure that we respond to your questions or queries in a timely and appropriate manner and in accordance with the applicable laws.