Privacy Policy

BACKGROUND:

Cedus Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits and uses this website and the application, cedus-invest.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

2. Information About Us

Our Site is owned and operated by Cedus Limited, a limited company registered in England and Wales under company number 08236742 (‘we/us/our’).

Main Trading Address: 50 Liverpool Street, London EC2M 7PR

Registered Office: Innovation House, Wincombe Lane, Shaftesbury, Dorset SP7 8FG

Telephone Number: +44 (0)207 112 5122

Website: www.cedus.co.uk

Contact: dpo@cedus.co.uk

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Where you are using Our Site through one of Our Customers who provides you with access to Our Site, your use of Our Site is subject to their policies and our processing of your personal information is governed by the contract we have with them. We only use personal information as allowed by Our Customers and act as a data processor. Our Customers are responsible for the obligations of a data controller. If you have any queries about Our processing of your personal information, compliance with applicable laws or requests to exercise your data protection rights please contact them. We are not responsible for the privacy policies of Our Customers or any technical or organisational methods they have in place to protect the security of your personal information.

This Privacy Policy does not apply to any content that is inputted/uploaded, processed, stored or hosted by Our Customers through your use of your Account with us and such personal information is governed by Our Customer’s policies.

4. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

1. The right to be informed about Our collection and use of your personal data.
2. The right to access the personal data we hold about you.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

As mentioned above, if you are using Our Site through one of Our Customers you should contact them with any privacy related issues, questions or requests.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

6. What Data Do You Collect and How?

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 which we have grouped together as follows:

1. Identity Data includes first name and last name.
2. Contact Data includes email address, location and telephone numbers.
3. Account Data includes security-related information (including user names and passwords, authentication methods and roles).
4. User Content includes any documentation or information that you upload to Our Site which contains personal information.
5. Technical and Usage Data includes anonymous technical and usage data

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

We use different methods to collect data from and about you including through:

Direct interactions. You provide personal information to Us when you use Our Site, create or maintain your Account, create, post or submit User Content.

Our Customers: your organisation/employer that arranges access to Our Site for you may provide personal information related to you or others within your organisation may provide personal information related to you when they submit User Content.

Third Party Service Providers: From analytics providers such as Google based outside the UK and from third party providers of authentication process services.

7. How Do You Use My Personal Data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. Where we need to perform a contract with Our Customers.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal obligation.

8. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

* No personal data is collected using data analytics, only anonymous technical and usage data.

As mentioned above we will only use your Personal Data in accordance with the instructions from Our Customers.

9. How Long Will You Keep My Personal Data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of performing a contract with Our Customers and satisfying any legal, regulatory, tax, accounting or reporting requirements.

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, regulatory, tax, accounting or other requirements.

Where Our Customers require us to retain your personal data under the terms of our contract with them you should contact them for details of relevant retention periods.

10. How and Where Do You Store or Transfer My Personal Data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In accordance with the instructions from Our Customer your personal information may be held on Our Cloud software.

We will only store your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.

Alternatively we may be instructed that your personal data will not be held on any Cloud software and will therefore be held solely by Our Customer on premise and the security of your personal data will be the responsibility of and governed by policies and practices of Our Customer.

11. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

Where you access Our Site through one of Our Customers, we may share your personal information with them in order to perform our contract with them.

We may share your personal information with third party service providers who provide us with technical support such as authentication processes.

If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights,

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all.

You may restrict Our use of Cookies. For more information, see Part 14.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, please contact the organisation that arranges your access to Our Site. We will assist them with any such request in accordance with our obligations as a data processor.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for load balancing and analytics purposes. For more details, please refer to the table below.

Before Cookies are placed on your computer or device, you will be shown a prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

and the following third-party Cookies may be placed on your computer or device:

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) the following Cookies:

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. we recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 1^st June 2021.