Effective date: 2023-08-24
Updated on: 2023-08-24

This Privacy Policy explains the policies of Coleman Capital on the collection and use of the information we collect when you access https://www.coleman.capital (the “Service”). This Privacy Policy describes your privacy rights and how you are protected under privacy laws.

By using our Service, you are consenting to the collection and use of your information in accordance with this Privacy Policy. Please do not access or use our Service if you do not consent to the collection and use of your information as outlined in this Privacy Policy. This Privacy Policy has been created with the help of CookieScript Privacy Policy Generator.

Coleman Capital is authorised to modify this Privacy Policy at any time. This may occur without prior notice.

Coleman Capital will post the revised Privacy Policy on the https://www.coleman.capital website

Collection and Use of Your Personal Information
Information We Collect

When using our Service, you will be prompted to provide us with personal information used to contact or identify you. https://www.coleman.capital collects the following information:

• Usage Data
• Name
• Email
• Mobile Number

Usage Data includes the following:

• Internet Protocol (IP) address of computers accessing the site
• Web page requests
• Referring web pages
• Browser used to access site
• Time and date of access

How We Collect Information
https://www.coleman.capital collects and receives information from you in the following manner:

• When you fill a registration form or otherwise submit your personal information.

Your information will be stored for up to 90 days after it is no longer required to provide you the services. Your information may be retained for longer periods for reporting or record- keeping in accordance with applicable laws. Information which does not identify you personally may be stored indefinitely.

How We Use Your Information
https://www.coleman.capital may use your information for the following purposes:

• Providing and maintaining our Service, as well as monitoring the usage of our Service.
• For other purposes. Coleman Capital will use your information for data analysis to identify usage trends or determine the effective of our marketing campaigns when reasonable. We will use your information to evaluate and improve our Service, products, services, and marketing efforts.

How We Share Your Information
Coleman Capital will share your information, when applicable, in the following situations:

• With your consent. Coleman Capital will share your information for any purpose with your explicit consent.

Third-party Sharing
Any third party we share your information with must disclose the purpose for which they intend to use your information. They must retain your information only for the duration disclosed when requesting or receiving said information. The third-party service provider must not further collect, sell, or use your personal information except as necessary to perform the specified purpose.

Your information may be shared to a third-party for reasons including:

• Analytics information. Your information might be shared with online analytics tools in order to track and analyse website traffic.

If you choose to provide such information during registration or otherwise, you are giving Coleman Capital permission to use, share, and store that information in a manner consistent with this Privacy Policy.

Your information may be disclosed for additional reasons, including:

• Complying with applicable laws, regulations, or court orders.
• Responding to claims that your use of our Service violates third-party rights.
• Enforcing agreements you make with us, including this Privacy Policy.

Cookies
Cookies are small text files that are placed on your computer by websites that you visit. Websites use cookies to help users navigate efficiently and perform certain functions. Cookies that are required for the website to operate properly are allowed to be set without your permission. All other cookies need to be approved before they can be set in the browser.

• Strictly necessary cookies. Strictly necessary cookies allow core website functionality such as user login and account management. The website cannot be used properly without strictly necessary cookies.
• Performance cookies. Performance cookies are used to see how visitors use the website, eg. analytics cookies. Those cookies cannot be used to directly identify a certain visitor.

You can change your consent to cookie usage below.

Strictly necessary

Security
Your information’s security is important to us. https://www.coleman.capital utilizes a range of security measures to prevent the misuse, loss, or alteration of the information you have given us. However, because we cannot guarantee the security of the information you provide us, you must access our service at your own risk.

Coleman Capital is not responsible for the performance of websites operated by third parties or your interactions with them. When you leave this website, we recommend you review the privacy practices of other websites you interact with and determine the adequacy of those practices.

Contact Us
For any questions, please contact us through the following methods:
Name: Coleman Capital
Address: 3rd Floor Cardinal House 39-40 Albemarle Street, London, W1S 4TE
Email: enquiries@coleman.capital
Website: https://www.coleman.capital
Phone: + 44 (0) 203 651 3042

Due to the nature of the Firms business, personal client data needs to be collected and maintained for regulatory reasons but also in accordance with GDPR.
“Personal data can be anything that allows a living person to be directly or indirectly identified”
Data must only be held for a valid reason, be available to the client for a Subject Access Request (SAR) to be returned within a month and only held for as long as necessary. Data must also be encrypted and accessed only by persons with a need to access and maintain it.

1. Data relating to contact details, banking details and correspondence may only be collected, managed and categorised by authorised personnel.
2. Clients must be aware of what data the Firm is collecting, why and for how long the Firm intends to keep it.
3. Pseudonymised / anonymized data can be kept only if the client could not be inferred from it.
4. Stored data is always encrypted and stored on a separate machine to the keys.
5. Once a client ceases to conduct business with the Firm only data required for regulatory reasons is to be kept.
6. Client Data is to be kept up to date and accurate.
7. Client Data is only to be stored by the Firm and not by 3rd party vendors.
8. Client Data is not to be shared with other entities unless the client confirms (either in writing of via email) that they consent and that the respective entity has a GDPR policy.
9. Record of any client data processing is to be amended to the “central data log”.

1. Internal search of Firm data to find all files containing the clients name is performed with results collated.
2. Email correspondence searched for and collated using Microsoft Compliance for Office 365.
3. Data provided in reasonable media for the client in electronic form within 30 days of the request.