Our privacy policy outlines how we manage and store your information, so please read it carefully, as by accessing and using the website you confirm that you have read, understood and agree to be bound by it.

If you do not wish to be bound by this privacy policy you should not continue to use or access the portal.

We care about your privacy

 

References to “we”, “us” and “our” mean CoInvestor. References to “Portal” means the CoInvestor website and the online services provided by us in relation to the website and any data managed by, displayed or transmitted from such services.

You may use the Portal as an “Authorised User” of an Investor. An Authorised User means:

  1. where the Investor is an individual, an adviser to that Investor acting under a discretionary mandate, rather than as an investor in your own right; and
  2. where the Investor is a trust, family office or other corporate investment entity, a trustee, beneficiary, employee or other authorised representative of such entity.

Where you are using the Portal as an Authorised User then you warrant and represent to, and agree with us, that:
  1. you are clearly and lawfully authorised to use the Portal on behalf of such investor, and to bind the investor to these terms and conditions as an Investor;
  2. you shall promptly provide reasonable evidence of such authorisation where requested by us;
  3. you shall ensure such authorisation remains valid throughout the period of your use of the Portal on behalf of the Investor;
  4. where you are advising an individual Investor, the Investment is suitable and appropriate for the Investor you are advising; and
  5. you shall indemnify us for all loss suffered, or likely to be suffered, by us a result of any breach of the above warranties and representations.


 

  • References in this privacy policy to “we”, “us” and “our” means CoInvestor. References to “Portal” means the CoInvestor website at www.coinvestor.co.uk (“Website”) and any other online services provided by us and any data managed by, displayed or transmitted from such services. References to “you” and “your” means a user of the Website and the services provided by us.

    This privacy policy sets out the principles governing our use of the information we obtain about you from you, and from enquiries we make and from other organisations such as credit reference and fraud prevention agencies (your “Personal Information”).

    Please read this privacy policy carefully as by accessing and using the Website you confirm that you have read, understood and agree to be bound this privacy policy. If you do not wish to be bound by this privacy policy you should not continue to use or access the Portal.

    If you are using the Portal in your capacity as an adviser to an investor, rather than as an investor in your own right, then you warrant and represent to us that:

    1. I. you are clearly and lawfully authorised to use the Portal on behalf of such investor, and to bind the investor to this privacy policy;
    2. II. you are authorised by such investor to provide all Personal Information about him/her which you submit via the Portal; and
    3. III. you shall indemnify us for all loss suffered, or likely to be suffered, by us a result of any breach of the above warranties and representations.

     



    1. Personal Information we collect from you

    1.1 We respect your right to privacy and will only process personal information you provide to us in accordance with the Data Protection Act 1998 and other applicable privacy laws. We are registered with the Information Commissioners Office under registration number ZAO93432.

    1.2 When you register with CoInvestor, and whilst you continue to use CoInvestor, we will collect information from you which will include the following:

    1. a. information you provide to us by completing the registration process and other forms on the Portal which might include (but is not limited to) your name, date of birth, postal address, phone number, email address and certain tax and regulatory information. We only request and collect information that is necessary for us to process in order to facilitate investment applications you choose to make via the portal.
    2. b. information you provide to us when you write to us by email or post;
    3. c. information you provide to us when we speak to you by telephone; and
    4. d. details of transactions you carry out via the Portal.

    1.3 We also obtain information about your investments through our Portal from the Manager whose deal or fund you have invested into or from your financial adviser where they have requested we list your historic investments. We use this information to update the ‘My Portfolio’ section of your CoInvestor account and also, where necessary, to comply with our obligations to you under the investor terms and conditions which apply to the use of the Portal by investors.

  • 2. Use of Personal Information

    2.1 We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information for the following purposes:

    1. a. to verify your identity in order to prevent and detect crime and money laundering;
    2. b. to manage your CoInvestor account and update the records we hold about you from time to time;
    3. c. to pass onto relevant Managers, Custodians, Investee Companies, third party identification checking services in connection with your decision to participate in Investment Opportunities through the Portal;
    4. d. to provide and administer the CoInvestor Portal and services;
    5. e. to identify fraud;
    6. f. to carry out anonymised statistical analysis and market research;
    7. g. to fulfil our regulatory duties;
    8. h. to develop and improve our services and products;
    9. i. to notify you about changes to our service;
    10. j. to provide you with information, services that you request from us or which we feel may interest you, when you have consented to be contacted for such purposes; and
    11. k. to disclose your personal information to carefully chosen third parties so that they may contact you with products and services which they think might interest you, where you have given us your consent to do so.

    2.2 We do not disclose information about identifiable individuals to our advertisers, but we may provide then with anonymised aggregate information about the use of the Portal from time to time.

    2.3 If you do not want us to use your Personal Information in one or more of the ways mentioned above, or to pass your details on to third parties, but you wish to continue accessing and using the Portal, please let us know by contacting us at connect@coinvestor.co.uk with the words “Data Protection” in the subject line. Please note that if we are unable to use certain Personal Information, this may limit your use of the Portal and specifically your ability to engage in investment activity through the Portal.

    2.4 Where you authorise an adviser to register on, and use, the Portal on your behalf, then you acknowledge and agree that we are entitled to use the Personal Information provided by such adviser as if it was provided directly by you, to the extent this information is required by us to provide the services requested by the adviser on your behalf.

    2.5 Where you use the Portal as an adviser or Manager or in any other authorised capacity which does not involve you investing in your own right, we only collect personal information from you which is necessary to identify you and the particular Investment Opportunity to which your use of the Portal relates.

    2.6 If you no longer wish an adviser to use the Portal on your behalf then please contact us at connect@coinvestor.co.uk so we can set up new log-in details for your account.

  • 3. Access to Personal Information

    3.1 You have the right to ask us to provide you with copies of personal information that we hold about you at any time. An administrative fee may be payable in exceptional cases, but we will not charge you until we have told you how much the fee is and what it is for, and you have told us you still want to proceed. You should direct any such request to connect@coinvestor.co.uk with the words “Data Protection” in the subject line.

    3.2 In accordance with legal and regulatory requirements, we will retain the records relevant to your CoInvestor account and any activity you conducted on the Portal for a minimum period of six years following the termination of your access to the Portal. This period may be extended by force of law, regulatory requirement of by mutual consent between you and us.

  • 4. Cookies

    4.1 The CoInvestor website uses cookies to collect information about you.

    4.2 Cookies are small files, typically made up of letters and numbers, that are stored on your browser when you access the CoInvestor website. We set and access these cookies on your computer in order to automatically log data regarding each visit you make to the website such as your IP address, browser type, referring/exit pages, and operating system. We may use this information to monitor server errors, server administration or to monitor visitor behaviour. These cookies don't collect information that identifies individual site users. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

    4.3 Cookies allow us to store information about your preferences and to provide you with a better service. You can however choose to disable the cookies we use by changing your website browser settings. You may also delete cookies that have already been placed on your browser. Please note that disabling or deleting cookies may prevent you from using the full range of services available on the Portal.

    4.4 We may use cookies to allow this website to remember choices you make (such as your username, or the region you are in) and provide enhanced and more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you may be able to customise from time to time. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

    4.5 Cookies may also be used to improve the user experience and to enable some of the functionality provided by this website. Please note that some cookies may be placed by third party service providers who perform some of these functions (or other services) for us. Cookies may be used on this website for the following third party services: Google Analytics, LinkedIn Follow button, Twitter Follow button, Google +1 button, other social marketing tools and third party video service providers. Some of these services may be used to track your behaviour on other websites and we have no control over this.

    4.6 By continuing to use the Website without adjusting your browser's cookie settings, you agree that we can place these cookies on your device.

  • 5. Safeguarding Personal Information

    5.1 Whilst we take appropriate technical and organisation measures to safeguard the personal information that you provide to us, we accept no liability if communications are intercepted by third parties or incorrectly delivered or not delivered.

    5.2 If we transfer your information to third parties we will take steps to ensure that such transfer and any on-going processing by such third parties is carried out securely and in accordance with applicable privacy law.

  • 6. Your Rights

    Under data protection legislation you have a number of rights in respect of information held about you. These rights are as follows, and can be exercised in accordance with the applicable legislation:

      1. a. Access to information: You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please email us at connect@coinvestor.co.uk.

      1. b. Ensuring accuracy of information: We want to make sure that your personal information is accurate and up-to-date. You may ask us to correct or complete information that is inaccurate or incomplete.

      1. c. Right to erasure: You may have a right to erasure, which is more commonly known as the ‘right to be forgotten’. This means that in certain circumstances you can require us to delete personal information held about you.

      1. d. Ability to restrict processing: You may also have the right to require us to restrict our use of your personal information in certain circumstances. This may apply, for example, where you have notified us that the information we hold about you is incorrect and you would like us to stop using such information until we have verified that it is accurate.

      1. e. Right to data portability: You may have the right to receive personal data we hold about you in a format that enables you to transfer such information to another data controller (e.g. such as another service provider).

      1. f. Review by an independent authority: You will always have the right to lodge a complaint with a supervisory body. The relevant authority in the UK is the Information Commissioner’s Office.

      1. g. Preventing direct marketing: We do not sell your data. From time to time, we may send emails containing information about new features and other news about CoInvestor. This is considered direct marketing. You have the right to stop us from contacting you for these purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at connect@coinvestor.co.uk.

      1. e. Objecting to other uses of your information: You may also have the right to object to our use of your information in other circumstances. In particular, where you have consented to our use of your personal data, you have the right to withdraw such consent at any time. You may do this by contacting us at connect@coinvestor.co.uk.
  • 7. Third party websites

    7.1 The Website may contains links to other websites operated by third parties. If you follow a link to any of these websites, please be aware that this privacy policy will not apply and that we accept no responsibility or liability for the content or operation of third party websites. You should read the privacy policy of each website you visit before you submit any personal data to these websites.



Definitions


  • Custodian: means the legal entity appointed by us or the Manager to provide custodian services (including receiving agent services) in relation to an Investment Opportunity.

  • Investment Opportunity: means an investment opportunity listed on the Portal by a Manager.

  • Manager: means the authorised manager of an Investment Opportunity.