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Privacy Policy

Privacy Policy

Introduction

Cognis Capital LLP (“Cognis”) respects the privacy and security of your personal data and is committed to protecting that information. This Privacy Statement provides information about the personal data we process, why we process it, how we process it and your legal rights in connection with it, in accordance with the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679 the “GDPR”). The legislation is intended to ensure that all personal information held by organisations (including, for example, a work email address) which might allow you, as an individual, to be identified, is accurate and secure and there is no misuse of personal information by that organisation.

This document sets out how Cognis collects, uses and safeguards the personal information that you, as an individual, provide to us. By providing your information to Cognis you consent to the collection and use of your personal information in the manner set out below.

This statement covers all communication with Cognis, including access to and use of Cognis’ website (the “Site”). This privacy statement may be updated from time to time and we will post updates to this page, which will be effective immediately upon posting.

Who are we?

Cognis is an FCA authorised and regulated alternative investment manager and advisor based in London. We manage funds on behalf of European and non-European non-retail investors.

Cognis is a data controller. As a data controller we are responsible for determining the purposes for which and manner in which any personal data is processed.

If you have any questions about this privacy policy or want to exercise any rights set out in this privacy policy please contact us on 020 3709 7246 or email operations@cogniscapital.com.

What personal information do we collect?

When you visit the Site or contact Cognis, and when providing any services to you, Cognis may collect personally identifiable information about you from information provided by you.

This can include the following information relating to you: name, address (residential or corporate), geographical location, email address, contact details, corporate contact information, correspondence records.

We may also obtain personal information on you from other public sources.

If you are an investor in a fund managed by Cognis, you will be asked for certain personal information to process the subscription and information required for regulatory purposes. These requirements and your rights in relation to the processing of this information will be separately explained in the fund prospectus and application form.

How do we use the information we collect?

Typically, Cognis will use the personal information provided by you to:

fulfil our contractual obligations with you;
carry out functions that we have are obliged to carry out (e.g. tax reporting);
to provide you with services, or provide you updates in relation to investment opportunities, which you have requested;
to provide you with updates in relation to our business and our investments;
for client due diligence, internal business administration and record keeping purposes;
to respond to your email enquiries;
to invite you to events;
for legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement agency requests;
where required or considered appropriate, carrying out 'know-your-client' (KYC) checks and other procedures that we undertake prior to you becoming a client of ours and in the course of our ongoing business relationship;
to provide services to investment vehicles in which you have invested and which have appointed us to act as manager or adviser; and
for recruitment.

Our lawful basis for processing personal data

The lawful basis for processing your personal data in the ways set out in this Privacy Notice is one or more of:

the use of personal data in this way is necessary for the performance of a contract with you for provision of our products and/or services or to take steps at your request prior to entering into such a contract;
we have legal or obligations that we have to discharge;
the use of your personal data is necessary for our legitimate interests in:

- ensuring the quality of the products and services we provide to you;

- collecting information for marketing purposes;

- communicating with you;

you have consented to such use; and/or
to establish, exercise or defend our legal rights for the purposes of legal proceedings.

Accordingly, you understand that we may use your personal information for the purposes as described above, provided that we are acting in a fair, transparent and accountable manner and that we have taken appropriate steps to prevent the activity having any unwarranted impact on you and also noting your right to object to such use.

Should we wish to use your personal information for other purposes (including, if applicable, any purpose that requires your additional consent), we will contact you.

Recipients of data

Cognis may disclose personal information to:

Service providers of the funds it manages (including Administrators and Custodians), other service providers and their respective affiliates engaged by Cognis to process data for the above-mentioned purposes;
Regulatory authorities, courts and bodies as required by law or to service providers for internal investigations and reporting.

The disclosure of personal information to the third parties set out above may involve the transfer of data other jurisdictions outside the European Economic Area (“EEA”) which may include the United States. Any transmission of personal information by Cognis or its service providers outside the EEA shall be in accordance with the conditions of the GDPR. These countries may not have the same data protection laws that apply in the EEA, but Cognis will authorise its group entities or other service providers to transfer personal information to other countries only where standard contractual clauses or other safeguards permitted under the GDPR have been put in place with parties to whom personal information will be transferred.

We will never share your personal information with others for marketing purposes, unless you have given us your explicit permission to do so. Where you have done so, we will only share your information with those service providers that help us manage our marketing activities.

Third party sites

Our communications may contain links to third party websites. As we do not control the information on these websites, you should review their privacy policies and cookie policies to learn about how that website may collect and use your personal information.

When accessing any third-party sites that may be linked you will leave this website. Cognis is not responsible for the contents, operation or security of such sites.

Retention period

Cognis will retain personal information only for as long as required for the purposes set out above. Once the personal information is no longer required, we will take appropriate steps to dispose of any records containing your personal information, to the extent this is operationally feasible and proportionate.

Data subject rights

You have the following rights in relation to the personal information we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make:

Right to access any personal data held
Right to have any inaccurate personal data rectified
Right to restrict the use of personal data
Right to request that personal data is erased
Right to object to the processing of personal data
Right to obtain a copy of any personal data held in electronic form (data portability)

Cognis will notify you of any personal data breach affecting you that is likely to result in a high risk to your rights and freedoms.

You also have the right to lodge a complaint with the Office of the Data Protection Commissioner, or your local supervisory authority, if you consider that the processing of your personal information by us infringes the Data Protection Legislation.

Opting out of receiving communications

Cognis and its service providers from time to time send communications, such as fund performance information, manager factsheet, general updates and event information. All such communications from us include an “unsubscribe” link which can be clicked should you no longer wish to receive these types of communication from us. Alternatively, you can send an email to operations@cogniscapital.com requesting to be removed from some of or all our mailing lists.