Privacy policy

Cahootz Group Ltd privacy policy, including cookie policy

Cahootz Group Limited (registered company number 14413674) ("we" or "us") trading as Cahootz is committed to protecting and respecting your privacy.

Summary

This policy outlines the personal information we collect from you, how it is obtained, its purpose and legal basis. This includes self-disclosed information, customer data, and marketing preferences. Our policy details how we use this information, your privacy rights, and legal protections. You have the right to access and request changes or deletion of your information. This policy is applicable to our products and services and goes into effect on 24 March 2023. Contact us using the information provided in this policy if you have any questions.

What kinds of information do we collect?

We may collect and process the following data about you:

Contact details and other information to confirm your identity

Your name, address, email address, phone number, date of birth, log-in information and password (your password as it is encrypted and we do not have access to see it)

Nationality and national identifier

Your nationality and an identifying number or code given to you by a government i.e. your National Insurance Number

Financial information

Details about financial transactions from your account to us, and your bank account and card details in order to process payments to you

Transactions

Details about the properties you have invested in via our platform

Communications

Your communications with us, including emails, phone calls and web chats

KYC ('Know Your Client) information

Details about you collected by us to identify and verify the identity of our customers, including a copy of your passport or identity card and a utility bill noting your home address

AML ('Anti-Money Laundering) information

As a result of money laundering regulations, we may need to verify the source of the funds which you are investing on our platform. We may therefore collect from you any of the following as evidence - a copy of your bank statement / savings account statement, payslip or completion statement from a house sale, for example

Technical information

The Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform

Behaviour on our site and platform

We collect information about your usage of our website and services, such as the complete Uniform Resource Locators (URL) clickstream of your visit (including date and time), the products you viewed or searched for, page response times, download errors, duration of visits to specific pages, page interaction details (such as scrolling, clicks, and mouse movements), and the means by which you navigate away from our website.

Consents

Any permissions, consents or preferences that you give us, including communications that you would like to receive from us and how you would like us to contact you.

Job Application

Throughout the recruitment process, we collect personal information such as your name, email address, and other relevant details.

How do we collect your information?

We may collect personal information:

  • Via our website;
  • Via live chat;
  • Via the internet;
  • Via customer surveys;
  • Via a job application
  • Via face to face meetings with members of the Cahootz team;
  • By email and letters; and
  • By phone.

We may also collect personal information from third parties we work with:

  • Our ‘KYC’ service provider;
  • Our payment service provider;
  • Credit reference agencies;
  • Financial advisers; and
  • Companies that introduce you to us.
How do we use your information and for what purposes?

We are only allowed to use your personal information if we have a lawful reason for doing so. We will use your information if we can satisfy that processing it is necessary:

  • to provide our product and/or services to you;
  • in order for use to comply with a legal or regulatory obligation;
  • when it is in our ‘legitimate interests’ (i.e. we have a business or commercial interest to use your information as long as it does not overly prejudice you); and/or
  • when you consent to it.

We use information held about you in the following ways:

What we use your information for

To manage our relationship with you:

  • To carry out marketing activities
  • To understand how our customers use our website and services
  • To provide guidance on our website and services
  • To engage with job applicants

To deliver our product and services to you:

  • To report transaction activity to you
  • To help you manage your portfolio
  • To manage and provide investments and services
  • To adhere to our obligations set out in agreements or contracts

To develop our products and services:

  • To test new products and/or services or iterations of existing products and/or services
  • To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
  • To manage how we work with third parties that provide services to us

To detect, investigate and report financial crime:

  • To comply with laws and regulations
  • To manage risk
  • To monitor and prevent fraud
  • To verify a customer’s identity
  • To respond to and resolve complaints

To run our business efficiently and in compliance with applicable regulatory standards:

  • Corporate governance
  • Financial and regulatory audits
  • Regulatory reporting and filings
  • Business, financial and strategic planning

Our basis for using your information

  • Provision of our product and services
  • Your consent
  • Compliance with legal and regulatory obligations
  • Our legitimate interests – developing products and services; keeping records and contact details up to date; determining which of our services may interest you. Assess and validate a candidate suitability and capability to carry out the duties assigned to a perspective role
  • Provision of our product and services
  • Compliance with legal and regulatory obligations
  • Our legitimate interests - being efficient with how we fulfil our legal and contractual obligations
  • Provision of our product and services
Who do we share your information with?

We may share your information with any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) and with other teams / departments within Cahootz, including Finance & Compliance, Customer Services, Analytics, Marketing and Technology for the purposes described in this policy. We may share your information with the following third parties:

  • The Financial Conduct Authority (FCA), and other regulators and authorities
  • Financial Services Compensation Scheme (FSCS)
  • HM Revenue & Customs (HMRC)
  • Credit reference agencies
  • Fraud prevention agencies
  • Third parties that we engage with to help us operate, improve, integrate, market and customise our product and/or services
  • Cahootz Group's payment service provider
  • Cahootz Group’s KYC service provider
  • IT providers / hosted IT solution providers
  • Cahootz Group’s auditors

If a service provider needs to access information about you to perform services on our behalf, they do so under instruction from us and with controls in place in order to protect your information. We do not sell your data to any third parties.

What marketing activities do we carry out?

We may use your personal information to provide you with details concerning products or services that could be of interest to you. We can only use your personal information to send you promotional content if we have your approval or a 'legitimate interest.' This means we have a business or commercial rationale to use your information as long as it does not unfairly disadvantage you. You have the option to request us to halt the delivery of promotional messages by contacting us at any time, selecting the 'unsubscribe' button present in all our emails, or updating your preferences in your 'Account Settings' section. Regardless of your communication preferences, you will still receive transactional statements and essential notifications, such as introductory communications following registration on our platform or any modifications to current products or services.

How long do we keep your personal information for?

We only keep personal information for as long as reasonably necessary to fulfil the relevant purposes described in this policy and in order to comply with our legal and regulatory obligations.

Where do we store your personal information?

We use data hosting service providers in Ireland, such as Amazon Web Services (AWS), to host the information we gather, and we enforce technical measures to secure your information. However, the internet's information transmission is not completely secure, and while we make every effort to protect your personal data, we cannot guarantee its security during transmission to our website, particularly if you are using an unsecured network. We will use rigorous processes and security features to prevent unauthorized access once we have obtained your information. If we have issued you with a password and PIN to access certain sections of our website, or if you have selected one, you are responsible for keeping them confidential and not sharing them with others.

Do we transfer personal data outside of the European Economic Area (EEA)?

We will only send your information outside of the EEA to:

  • Comply with our legal and regulatory obligations; or
  • Work with agents, contractors or advisers who we use to help run our product and/or services.

If we do transfer information to our agents, contractors or advisers outside of the EEA, we will put appropriate safeguards in place to ensure that such information is protected in the same way as if it was being used in the EEA.

What are your rights?

Under data protection laws, you possess certain rights regarding the personal information we possess about you. You can exercise these rights by contacting us using the details specified in this policy. However, in specific cases, we may be unable to fulfill your request due to obligations to comply with legal or regulatory requirements. If we cannot comply with your request, we will explain the reasons why and respond to you accordingly. Your rights include:

The right to access your personal information:

You are entitled to a copy of the personal information we hold about you and certain details of how we use it. Your information will be provided to you electronically, unless otherwise requested. We will respond to your request within a reasonable period of time, but at the latest within one month of the request (assuming we have any requisite information from you in order to be able to process your request).

The right to rectification:

You have the right to have your information rectified if it is inaccurate or incomplete. We aim to ensure that your personal information is accurate, however, please do contact us if you require your information to be updated or amended or, alternatively, you can amend your personal details in ‘Settings’.

The right to erasure:

You have the right to request the deletion or removal of your information. There are, however, specific circumstances where we may be unable to deal with your request, e.g. if we need to retain your information to comply with a legal or regulatory obligation.

The right to restrict processing:

You have the right to request that we limit the way we use your information if you have a particular reason for wanting that restriction e.g. in circumstances where you believe that we don’t have the appropriate rights to process your information.

The right to data portability:

You have the right to obtain some of your information in a format you can move from one service provider to another. Should you request it, we will provide you with an electronic file of your basic account information.

The right to object:

You have the right to object to us processing your information e.g. you can ask us to stop sending you marketing communications at any time.

Consent

You can withdraw your consent at any time. Please contact us if you want to do so.

You can also ask us to stop marketing to you by clicking on the ‘unsubscribe’ link that appears in all of our emails or by updating your preferences in ‘Settings’. Please note that it can take approximately 24 hours for any changes to your preferences to be actioned.

Cookie policy

To enhance your browsing experience, our website uses cookies, unique identifiers and similar technologies that help us distinguish you from other users of our website and collect data. Cookies allow us to recognise you and remember your preferences when you return to our website. By browsing our website, you consent to the use of cookies. Cookies are small files of letters and numbers that are saved to your computer when you visit websites. They contain information that is transferred to your computer's hard drive. We use different types of cookies to perform different functions:

  • Strictly necessary cookies: These cookies are essential for us to operate our website, including cookies that allow you to log into secure areas of our website.
  • Analytical/performance cookies: These cookies help us understand how visitors use our website, allowing us to improve its functionality and design.
  • Functionality cookies: These cookies enable us to recognise you when you return to our website, personalise our content for you and remember your preferences.
  • Targeting cookies: These cookies track your visit to our website and are used to make our website and advertising displayed on it more relevant to your interests. We may share this information with third parties.

Please note that third-party cookies may also be used on our website, which are likely to be analytical/performance cookies or targeting cookies. We have no control over these cookies. You can enable or disable cookies on your web browser. However, blocking all cookies (including essential cookies) may prevent you from accessing all or parts of our website, and some features may not be accessible to you. To learn more about cookies, please visit ico.org.uk/for-the-public/online/cookies.

How to contact us

You can request access to the personal information we hold about you by writing to us at:

Cahootz Group Ltd
7 Bell Yard
London WC2A 2JR

If you have any questions about how we collect, store or use your personal information please contact us via email at support@cahootz.com.

How to complain

If you want to make a complaint about how we have handled your personal information, please contact us at support@cahootz.com and we will investigate the matter and report back to you.  If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the UK’s data protection regulator -  the Information Commissioner’s Office.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

Last updated: 24 March 2023

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