PRIVACY POLICY
Last updated September 2024.
Here at COSMESURE® we are strongly committed to respecting and protecting your privacy, confidentiality and information in accordance with the UK Data Protection Act 2018 (“DPA 2018”), the UK General Data Protection Regulation (“UK GDPR”), and the Privacy in Electronic Communication Regulations (“PECR 2003”) to handle your personal data in certain ways.
This website is operated by COSMESURE LTD (“COSMESURE®”, “we” or “us”), a UK limited company.
How do we collect personal data?
Directly: We obtain personal data directly from individuals in a variety of ways, including obtaining personal data from individuals who provide us with their business card(s), complete our online forms, attend meetings, visit our offices or for recruitment purposes. We may also obtain personal data directly when, for example, we are establishing a business relationship, performing professional services through a contract.
Indirectly: We obtain personal data indirectly about individuals from a variety of sources, including recruitment services and our clients:
· Public sources - Personal data may be obtained from public registers (such as Companies House), news articles, social media, sanctions lists, government intelligence and crime prevention agencies and internet searches.
· Business clients - Our business clients may engage us to perform professional services which involves sharing personal data they control as part of that engagement. Our services may also include processing personal data under our clients’ control on our hosted software applications, which may be governed by different privacy terms, policies and notices.
· Recruitment - We may obtain personal data about candidates from an employment agency, and other parties including former employers, and credit reference agencies.
What categories of personal data do we collect?
We may obtain the following categories of personal data about individuals through direct interactions with us, or from information provided through client engagements, from applicants, our suppliers and through other situations including those described in this Privacy Notice.
o Personal data. Here is a list of personal data we commonly collect to conduct our business activities.
· Contact details (e.g., name, company name, job title, work and mobile telephone numbers, work and personal email and postal address).
· Professional details (e.g., job and career history, educational background and professional memberships, published articles).
· Family and beneficiary details for insurance and pension planning services (e.g., names and dates of birth).
· Financial information (e.g., taxes, payroll, investment interests, pensions, assets, bank details, insolvency records).
o Child data. Our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.
o Location-based data. We may process geographical locations.
What lawful reasons do we have for processing personal data?
We may rely on the following lawful reasons when we collect and use personal data to operate our business and provide our products and services:
o Contract – We may process personal data in order to perform our contractual obligations owed to (or to enter into a contract with) the relevant individuals.
o Consent - We may rely on your freely given consent at the time you provided your personal data to us.
o Legitimate interests – We may rely on legitimate interests based on our evaluation that the processing is fair, reasonable and balanced. These may include:
· Delivering services to our clients – To deliver the professional services our clients have engaged us to provide including information on new products and services.
· Direct marketing – To conduct and analyse our marketing activities. To deliver timely market insights and speciality knowledge including tailor-made online experience we believe is welcomed by our business clients, subscribers and individuals who have interacted with us.
· Corporate responsibility - Comply with our corporate and corporate social responsibility commitments.
o Legal obligations – We may process personal data in order to meet our legal and regulatory obligations or mandates.
o Public Interest – We may process personal data in order to perform a specific task in the public interest or in the exercise of official authority vested in us.
Why do we need personal data?
We aspire to be transparent when we collect and use personal data and tell you why we need it, which typically includes:
o Providing professional advice and delivering reports related to our tax, advisory, audit and assurance, pension scheme administration, mergers and acquisitions and other professional services. Our services may include reviewing client files for quality assurance purposes, which may involve processing personal data for the relevant client.
o Promoting our professional services, products and capabilities to existing and prospective business clients.
o Administering, maintaining and ensuring the security of our information systems, applications and websites.
o Seeking qualified candidates, and forwarding candidate career inquiries to our People team, which may be governed by different privacy terms and policies.
o Processing online requests, including responding to communications from individuals or requests for proposals and quotations.
o Complying with legal and regulatory obligations relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime.
o Compiling health and safety data (directly or indirectly) following an incident or accident. Indirect data can take many forms including an incident report, first aider report, witness statements and CCTV footage.
Do we share personal data with third parties?
We may occasionally share personal data with trusted third parties to help us deliver efficient and quality services. These recipients are contractually bound to safeguard the data we entrust to them. We may engage with several or all of the following categories of recipients:
o Parties that support us as we provide our services (e.g., providers of telecommunication systems, mailroom support, IT system support, archiving services, document production services and cloud-based software services).
o Professional advisers, including lawyers, auditors and insurers.
o A potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of our business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it.
o Parties that support as with anti-money laundering, client conflicts and independence checks.
o Law enforcement or other government and regulatory agencies (e.g., HMRC) or to other third parties as required by, and in accordance with, applicable law or regulation.
o Payment, marketing and recruitment services providers.
COSMESURE® will not transfer the personal information you provide to any third parties for their own direct marketing use.
Do we transfer your personal data outside the UK or European Economic Area (EEA)?
We store personal data on servers located in the UK and EEA.
Do we use cookies?
Our website may use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. The cookie statement is provided by Squarespace.
What are your data protection rights?
o Access – You can ask us to verify whether we are processing personal data about you, and if so, to provide more specific information.
o Correction – You can ask us to correct our records if you believe they contain incorrect or incomplete information about you.
o Erasure – You can ask us to erase (delete) your personal data after you withdraw your consent to processing or when we no longer need it for the purpose it was originally collected.
o Processing restrictions – You can ask us to temporarily restrict our processing of your personal data if you contest the accuracy of your personal data, prefer to restrict its use rather than having us erase it, or need us to preserve it for you to establish, exercise, or defend a legal claim. A temporary restriction may apply while verifying whether we have overriding legitimate grounds to process it. You can ask us to inform you before we lift that temporary processing restriction.
o Data portability – In some circumstances, where you have provided personal data to us, you can ask us to transmit that personal data (in a structured, commonly used, and machine-readable format) directly to another company if is technically feasible.
o Right to Object to Direct Marketing including Profiling – You can object to our use of your personal data for direct marketing purposes, including profiling. We may need to keep some minimal information to comply with your request to cease marketing to you.
o Right to Withdraw Consent – You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case.
If you would like to exercise your Data Subject Rights, you can email info@cosmesure.uk. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.
What about personal data security?
We have put appropriate technical and organisational security policies and procedures in place to protect personal data (including sensitive personal data) from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited only to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information. We may apply pseudonymisation, de-identification and anonymisation techniques in efforts to further protect personal data.
How long do we retain personal data?
We retain personal data to provide our services, stay in contact with you and to comply with applicable laws, regulations and professional obligations that we are subject to. Unless a different time frame applies as a result of business need or specific legal, regulatory or contractual requirements, where we retain personal data in accordance with these purposes, we retain such personal data for seven years.
Who can you contact for privacy questions or concerns?
If you have questions or comments about this Privacy Notice or how we handle personal data, please direct your correspondence to info@cosmesure.uk. We aim to respond within 30 days from the date we receive privacy-related communication.
Do we change this Privacy Notice?
We regularly review this Privacy Notice and will post any updates to it on this webpage. This Privacy Notice was last updated on September 2023.