In this Policy when we refer to Coremont or “we”/”us”/”our”, we mean Coremont LLP (the “Firm”). Coremont’s contact address is 55 Baker Street, London, W1U 8EW and we are authorised and regulated in the UK by the Financial Conduct Authority.
We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
The information that we collect and where we get it from
“Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
We will collect and process the following personal information about you:
- Information that you provide to us
We will process personal information that you give to us including when you email us or contact us through various channels as follows:
- Accessing our site: In accessing our site, especially through the password protected client login portal, the information that you provide may include your full name, title, telephone number, geographical location, email address and information about your employer or your business.
How we use the information we collect
We may do the following with your personal information:
- use it to engage in marketing and business development activity in relation to our services to comply with legal and regulatory obligations that we have to discharge
- record and monitor your use of our site or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
- use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our site and our business
- use it to look into any complaints or queries you may have, and
- use it to prevent and respond to actual or potential fraud or illegal activities.
Also, we may collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Consent – we may (but usually do not) need your consent to use your personal information. You can withdraw your consent by contacting us (see below).
- Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest – we may use your personal information for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation – we may use your personal information as necessary to comply with applicable law/regulation.
How we share information with third parties
We share personal information with our international offices. As a result, your personal information may be transferred to locations outside of the United Kingdom and the European Union as well as within it for the purposes described above.
We may also share your personal information outside the Firm. This may include:
- Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
- Third parties relevant to the regulated services that we provide. This may include, but is not limited to, counterparties to transactions or litigation, regulators, authorities, governmental institutions and stock exchanges.
- To the extent required by law, regulation or court order, for example, if we are under a duty to disclose your personal information in order to comply with any legal obligation.
Where we transfer your personal information outside of the United Kingdom and the European Union, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
- the country to which we send the personal information may be approved by the United Kingdom
- the recipient may have signed a contract based on standard contractual clauses such as “model contractual clauses” approved by the European Commission, obliging them to protect your personal information, or
- where the recipient is located in the United States, it may be a certified member of the EU-US Privacy Shield scheme with the commitment to include the Uinted Kingdom post Brexit.
In other circumstances, the law may permit us to otherwise transfer your personal information outside Europe. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.
You can obtain more details of the protection given to your personal information when it is transferred outside Europe (including a sample copy of the model contractual clauses) by contacting us using the details set out below.
Keeping your information and information security
How long we hold your personal information for will vary and will depend principally on:
- the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
Your choices and rights
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
- Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are obliged under regulation to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally or regulatory entitled to refuse that request.
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
- We can, on request, tell you which data protection authority is relevant to the processing of your personal information
If you would like further information on the collection, use, disclosure or processing of your personal information or the exercise of any of the rights listed above, please contact us at firstname.lastname@example.org
What are cookies?
Cookies are small text files which are placed on our site and/or a service user’s computer to provide us with information about use of our site and/or services.
Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor or user.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org. Alternatively, you can search the internet for other independent information on cookies.
- Analytical purposes: Analytical cookies allow us to recognise, measure and track users of our site and/or services in anonymous form. The information collected includes the number of visitors to our site and/or users of our services, where visitors have come to our site from and the pages that they have visited. This helps us to improve the way our site and/or services work, for example, by determining whether site visitors and/or users of services can find information easily, or by identifying the aspects of the site and/or services that are of the most interest to them (as further explained below).
- Usage preferences: Some of the cookies on our site and/or services are activated when visitors to our site and/or users of our services make a choice about their usage of our site and/or services. Our site and/or services then ‘remember’ the settings preferences of the user concerned. This allows us to tailor aspects of our site and/or services to the individual user.
- Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.
Your cookie preferences
To make full use of our site and/or services, your computer or mobile device will need to accept cookies, as our site and/or services will not function properly without them. In addition, cookies are required in order to provide you with personalised features on our site and/or services.
Third party cookies
Analytic cookies are used to gather statistics about the use of our site and/or services in order to improve their performance and design. For these purposes, analytic cookies collect information about your device type, operating system type, browser type, domain, other system settings, IP address, referring URLs, information on actions taken on our site and/or services and the dates and times of your visits, as well as the country and time zone in which your device is located.
These cookies may be provided by our third-party analytics tool providers, HubSpot (a web analytics service, hosted on servers in the United States and in the EU), and Google Analytics (a web analytics service provided by Google, Inc., whose servers may be in the UK, EU or in the United States of America). The information obtained through these cookies may be disclosed to, or collected directly by, these third-party service providers. For more information about HubSpot and Google Analytics’ cookie and information practices (including the types of cookies used and their expiration date), please visit the links below:
How to control and amend cookies
You can control which cookies you want to be stored on your computer through the settings in your web browser. You can configure your browser to accept or reject certain or all cookies, as well as see what cookies have been set.
If you wish to remove cookies set by our site from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use.
The “Help” menu in the toolbar of most web browsers will tell you how to change your browser’s cookie settings, including how to have the browser notify you when you receive a new cookie and how to disable cookies altogether.