1. About this policy

The Cam Crowd (“CAM”) is a trading style of Cadogan Asset Management Limited (“Cadogan”) which is authorised and regulated by the Financial Conduct Authority under Firm reference number 749342. References in these Terms and Conditions to “Cadogan”, “The CAM Crowd”, “CAM” "we", "us" and "our" are to be construed as meaning to Cadogan Asset Management Limited trading as The CAM Crowd. 

Cadogan Asset Management Limited has its registered address at 15 Half Moon Street London W1J 7DZ and is incorporated in England & Wales under company registration number 10065415. 

The purpose of this notice is to let you know how we look after your personal information, including what we learn through third parties, by having you as a customer (or potential customer) and information you provide to us directly or through our websites. This notice also informs you of your rights regarding personal information and how the law protects you. 

‘Personal information’ is any information that can be used to identify an individual. 

The privacy of your personal information is very important to us. Other than as expressly set out below (see Personal data we share with third parties) or advised as part of product specific terms and conditions, we confirm that your personal information will not be disclosed or sold to third parties without your authorisation. 

This privacy notice covers the website: thecamcrowd.co.uk only. 

Your Acceptance of this Policy 

This Policy governs your use of the website and investment platform, including any dispute concerning privacy. By using the website and investment platform, you accept this Policy in full. You should read the Policy carefully and ensure that you understand its effect before proceeding to use the website and investment platform. We reserve the right to modify this Policy at any time due to a change in the law or otherwise without notice by posting the changes on this page. Your continued use of any portion of the website and investment platform following the posting of the updated Statement will constitute your acceptance of the changes. If we make any material changes, we will notify you by email. 


  1. Personal information we collect

Personal information that you provide to us directly 

You may provide us with personal information through a variety of mechanism including over the phone (including recorded messages), face to face, hardcopy or electronic forms or surveys, email correspondence and/or our websites. Examples of the information you may provide us includes information on your financial position, socio-demographics and contact information. 

Information about you from outside organisations 

Financial advisers 

Organisations that introduced you to us 

Public information sources (e.g. companies house) 

Fraud prevention agencies 

Credit reference agencies 

Market researchers 

Other sources which you may directly authorise us to source information from 

Information about you when you use our products and services 

This includes information when you use our services, for example profile and usage data as well as transactional and payments data for your accounts and products. Our websites collect information via your account when you’re logged in as well as through cookies other internet tracking software. Please see our cookies policy below for more information on cookies. 


  1. How we process your personal information and our legal basis

In addition to our own policies, the privacy of your personal information is protected by law. This section outlines the legal reasons we rely on to collect and process your personal information. We are legally required to meet one or more of the following reasons to hold and process your personal information: 

  • Legal obligation – where we need to use some of your information to comply with relevant legislation 
  • Legitimate interest – where we may process your data where we have a legitimate interest to do so. Legitimate interest may include commercial interests; before we do this we will also consider your rights and interests 
  • Contractual requirement – where we may process your personal information to fulfil a contraction obligation 
  • Consent from you – where we ask you for permission to use your personal data in a certain way 

Our legal reasons for processing your personal information vary depending on the information and the means for which we are using it. These uses include:

  • Development and provision of services 
  • Maintain and deliver products and services 
  • Management of customer relationships and resolving complaints 
  • Manage and conduct marketing of products and communicate with you 
  • Research, develop, test and deploy new products 
  • Effectively present content to you on our websites 
  • Legal basis for using your personal information: Contractual requirements, legal obligation, consent, legitimate interest. 
  • Managing and improving our operations 
  • Manage fees and charges on client accounts 
  • Conduct business efficiently and manage our financial position 
  • Plan, develop and maintain business capability 

Legal basis for using your personal information: Contractual requirements, legal obligation, legitimate interest. 

 Managing risk and preventing crime 

 Managing risk both to us and you 

 Complying with legal requirements and regulations 

 Managing & preventing financial crime 

 Maintaining and improving corporate governance 

Legal basis for using your personal information: Contractual requirements, legal obligation, legitimate interest. 

  • We have legitimate interests in processing personal data we collect from you to: 
  • Develop and price products and services
  • Comply with regulatory guidance and recommendations 
  • Reduce and manage risks to you and us 
  • Evaluate if we have products which may interest you, and to communicate these to you 
  • Maintain and develop efficiencies in the way we meet our legal and contractual obligations 

 

  1. How long we keep personal information

We will keep your information stored on our systems for as long as it takes to provide the services to you, meet our recording keeping obligations under law or for as long as we maintain a legal legitimate interest in your personal information. 

For example, if you make an investment in a product with us then we will hold your personal information for a period of at least 7 years from the date of your last investment so that we can comply with our legal obligations. 


  1. Personal data we share with third parties

We will not sell the personal information that we collect from you. Some data processing in relation to personal information we collect from you may be carried out for us by a third party so that we can provide you with products and services, run our business, and obey rules that apply to us. We may share your information with: 

Official bodies 

Regulators (e.g. the Financial Conduct Authority, Information Commissioner Etc.) 

HMRC and other tax authorities 

Law enforcement and other enteral and local government 

Service providers 

Agents, suppliers and other contractors and services providers which help us run our business 

Reference checking agencies 

Other companies which help us meet our legal obligations 

 General 

Organisations or advisors which introduce you to us 

Member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries 

Market researchers or advisers which help us develop new ways of doing business 

We may also share your information with companies you ask us to share your information with or other third parties you explicitly authorise us. 


  1. Collecting Your Financial Data

As a The CAM Crowd Investor, when you wish to deposit investment funds in your Account, you do so in one of two (2) ways i.e. by bank transfer or payment card. For this, you will be required to provide your bank details in order for payment to be processed, for example, you will be required to provide MangoPay S.A. with Financial Data in order to authorise payment. When you wish to transfer monies via the website, your consent is given to provide your Data necessary to process the payment with MangoPay S.A. directly. To make and complete the transaction via a third party such as MangoPay S.A. their policies shall be applicable to you. We will not share Financial Data with any other third parties without your prior consent. 


  1. How we store and transfer your personal information

European Economic Area 

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. 

Safeguards 

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy notice. All information you provide to us or our third-party suppliers is stored on secure servers. For our online platforms, any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of this site, you are responsible for keeping this password confidential. Please do not share this password with anyone. 

Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website(s); any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access (although, as is the norm, no guarantees can be given). 


  1. Your rights

Where you have given us your consent to collect and process information for a specific purpose you retain the right to rescind the consent at any time. In addition, there are other rights you are entitled to as the owner of personal information we collect and process, these rights are: 

  • Right to object – you may object to us keeping or using your personal information 
  • Right to be forgotten - you may ask us to delete remove or stop using your personal data if there is no legal reason for us to have it and it impinges on your privacy 
  • Right to rectification - if your personal information is inaccurate or incomplete you may request this information is rectified 
  • Right of access - this is the right to obtain a copy your personal data, if you wish we will provide this in an electronic format 

We will try to keep personal information which we hold about you up to date, but if you think that we are holding information which is inaccurate, or you are otherwise unhappy about our use of your personal information then please send us an email us at compliance@cadoganam.co.uk. You also have the right to complain and lodge appeals to the regulator if you our happy with the outcome of a complaint. 


  1. How we use cookies

This site uses cookies to distinguish you from other users of this site. This helps us to provide you with a good experience when you browse this site and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. 

What is a cookie? A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. 

What cookies do we use? We use several different cookies to help us run and improve our website, including: 

Strictly necessary or functionality cookies 

These are cookies that are required for the operation of this site. They include, for example, cookies that enable you to log into secure areas of this site, use a shopping cart or make use of e-billing services. 

Functionality cookies 

These are used to recognise you when you return to this site. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region). 

Analytical / performance cookies 

They allow us to recognise and count the number of visitors and to see how visitors move around this site when they are using it. This helps us to improve the way this site works, for example, by ensuring that users are finding what they are looking for easily. 

Targeting and third party cookies 

These cookies record your visit to this site, the pages you have visited and the links you have followed. We use this information to make this site more relevant to your interests. We may also share this information with third parties for this purpose in accordance with the statements set out above. 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. 

How to turn cookies off 

You can block cookies by adjusting the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of this site. For more information on how to do this please refer to: https://www.aboutcookies.org/. 

I.P. address 

This site logs your Internet Protocol (I.P.) address. All computers that are linked to the internet have an I.P. address. An I.P. address does not provide identifiable personal information. 

Links 

This site provides links to other websites. Our privacy notice and cookie policy apply only to this the stated websites and we are not responsible for the privacy and/or data capture and use practices of third party sites. 


  1.  Complaints or Queries

We try to meet the highest standards when collecting and using Data. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of Data is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This Policy does not provide an exhaustive detail of all aspects of our collection and use of Data. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below or to our Data Protection Officer by email at compliance@cadoganam.com. If you are not happy with the way in which your Data is being handled by us, you can complain to the Information Commissioner whose details can be found at: http://www.ico.org.uk/ 


  1. Contact information

Questions, comments and requests regarding this privacy notice and cookie policy are welcomed and should be addressed to compliance@cadoganam.com, or mailed to: 


The Data Protection Officer 

Cadogan Asset Management Limited 

15 Half Moon Street 

London 

W1J 7DZ