Privacy Policy

Privacy Notice

Due to Data Protection laws and related regulations, you have the right to receive assurances from Cohort Invest regarding the collection, processing, and secure, confidential storage of personal data for specific purposes. As a Data Controller, Cohort Invest is obligated under Data Protection laws to inform you about the data we gather, the reasons behind its collection, our processing procedures, and any sharing arrangements. These details are outlined in our Privacy Notice.

Should you require any further details or wish to enquire on the details we hold on you or your employees please visit the Contact us section of the website.

What data we collect

We will only collect such data that is needed to complete our KYC and AML processes.This includes:

• Funder names(including Director/Shareholders for corporate funders)
• Funder email addresses and contact numbers (including Director/Shareholders for corporate funders)
• Funder details including dates of birth and addresses (includingDirector/Shareholders for corporate funders)
• Names of shareholders who hold greater than 25% voting or ownership rights in the funding company
• Source of wealth information and funder profile information (including Director/Shareholders for corporate funders)

Why we collect your data

Under Data Protection laws we must have a legal basis for the collection of your data. This means that there must be a specific reason for us to request your data. Cohort Invest collects data to meet Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations. These checks are to limit or mitigate the impact of money laundering, terrorism funding, corruption, and other forms of financial crime.

Sources of information

Data will be gathered from yourself directly and will also be collected from external sources to enable us to verify your identity.

Who we share your data with

Your data will be shared with other, external data processors to assist us in completing AML checks and other internal loan management processes. These include:

• Due diligence providers
• Our partner company, Cohort Capital Ltd
• Statutory Bodies on their lawful request, e.g. NCA, police forces

Due diligence providers

• We use Credas as our due diligence provider. The CredasID checking service verifies the person against an identity document using biometric facial recognition and the Credas technology confirms the identity document is genuine. Credas use a number of data sources to run additional checks such as Proof of Address, Politically Exposed Persons (PEP’s) and Sanctions List checks so we can meet our compliance commitments.
• Credas stores data securely in the cloud, available to you when and where you need it.Further details on how they use your information can be found directly from the Credas website: credas.com

Solicitors

• As part of the loan process, we will in certain circumstances pass your data to solicitors acting on behalf of the company. These details will only be shared to facilitate the completion of a loan.

Partner Firm

• Cohort Capital Ltd is our partner firm and is responsible for the loan underwriting process. Cohort Invest Ltd will share your data with Cohort Capital Ltd for internal statistical and loan management purposes only. Cohort Capital is also subject to the Data Protection Act and ICO regulations and oversight.

Statutory Bodies

• We are obligated to fulfil requests from statutory bodies, including but not limited to the National Crime Agency, police forces, the Serious Fraud Office, etc., for specific personal data as required by law. This process is conducted confidentially, and due to legal provisions, you will not be notified when such data transfers occur. Additionally, details regarding the data submitted to these entities are exempt from disclosure under a Subject Access Request.

Your Rights

Data Protection legislation provides you with express rights which include:

Your right to object or request erasure of the data we hold

• You may object to Cohort Invest holding or processing your personal data and/or request that we remove this data from our storage. Please be advised, however, that should you request that this takes place before a loan completes then we will be unable to provide you with funds. Where your loan does complete we have an obligation to retain your information in order to assure the repayment of your funds in line with the funding agreement so we will be unable to remove your data during the term of any loan funded with Cohort Invest. Please contact the firm’s Data Protection Representative for further details or to exercise your rights.

Your right to correct your data

• Where you or we become aware of an error in the data that Cohort Invest processes or holds, you have a right to have that data corrected. You can inform our Data Protection Representative of any errors that need to be corrected.

Your right to a copy of your data

• You also have the right to request either the details of the data we hold on you or to request a copy of this. We are obliged to provide this to you within 30 days of receipt of your request. Please contact the firm’s Data Protection Representative to request this.

Your right to data portability

• You have the right to request that data which we hold is passed to another Data Controller for their use on your behalf via a “machine readable” format. This can be requested from the Data Protection Representative of Cohort Invest.

Your right to complain

• You have a right to complain, via our Data Protection Representative, in regards to how and why we process, or any errors we have made in the processing of, your data.
• Your complaint can also be made to the Information Commissioners Office:
• Post: ICO, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
• Telephone: 0303 123 1113
• Website: www.ico.org.uk

Data retention

Cohort Invest will only retain your data for as long as is necessary. In all cases this will be for the term of the loan plus 7 years, where you fund a loan with us.We are obliged to retain your data for this period in order to meet our regulatory and legislative obligations. 

Data storage

All Data that Cohort Invest collects is controlled and stored within the UK. We do not transfer data to any entity outside of the UK or the EEA. Where this does occur, we will inform you of the situation and seek your consent prior to the initiation of the transfer.

Cookies

A 'cookie' constitutes a data fragment that a website sends to your computer's internet browser, residing on the hard disk, enabling the website to recall your identity. Typically, it comprises a unique, randomly generated number. Most commercial and business websites generally use cookies. However, they cannot singularly identify you, nor do we intend to use them for such purposes. You retain the option to manually delete cookies—please refer to your browser's help manual should you wish to do so. There are also websites that help you do this. "Session cookies" persist in your browser only until closure, while "persistent cookies" endure for a longer duration, determined by the cookie's specified "lifetime."

Use of ‘Cookies’

We use session cookies to facilitate information continuity across pages, eliminating the need for redundant data entry. Additionally, we may employ persistent cookies to recognise your assigned number upon revisiting our website, without further identification, potentially enabling us to gauge your interests and tailor content accordingly for your benefit. Third parties may deploy cookies through this website. They may be used to compile statistics to comprehend user behavior or monitoring the frequency and manner of specific content consumption.

Web beacons

Certain pages may incorporate electronic markers known as web beacons, enabling us to tally page visits. They gather limited data, including viewing timestamps and cookie numbers. Furthermore, we may host web beacons from third-party advertisers to assess campaign efficacy, while ensuring no personally identifiable information is collected.