Data Privacy Notice

 
 

COACH HOUSE INVESTMENT MANAGERS LIMITED

Coach House Investment Managers Limited (“Coach House”) will collect investors’ personal data. This privacy notice intends to show investors how their personal data is processed, for what purposes this will be done and what rights each investor has in relation to the personal data that will be collected and used. Personal data is at all times processed in order for Coach House to fulfil its obligations, however in certain circumstances Coach House may be required to obtain the investor’s consent before the processing is done.

Coach House will at all times ensure that in such circumstances where consent is required in order for them to process personal data, that they request the investor’s consent in a clear and easily accessible manner.  The investor will retain the right to either refuse to consent to the processing of their personal data, or consent to the processing in a clear and identifiable manner.

The investor retains the right to withdraw their previously given consent at any time they see fit.

Personal data

Coach House complies with its GDPR obligations and ensures that personal data shall be processed lawfully and in a transparent manner in relation to its investors; that the personal data shall be collected and processed for the purposes stated; that the personal data shall be accurate and at all times kept up to date; that the personal data shall be kept for no longer than is necessary for the purposes for which it is collected; that the personal data shall be adequately securitised and be protected against loss, unauthorised access or processing, and destruction or damage.

Investors’ personal data will be treated as strictly confidential.  Investors’ personal data will only be shared with third parties in order to fulfil contractual obligations or if consent to do so has been given.

Coach House will keep the personal data for no longer than is necessary in order to fulfil its regulatory requirements and facilitate its administrative and reporting obligations.

Data retention

For audit trail purposes, Coach House shall hold personal data for a period of at least five years in order for them to comply with their record keeping obligations under the Money Laundering Regulations 2017.

At the end of that period, Coach House will be required to delete all personal data relating to you, unless a legal requirement requires them to keep the data for a prolonged period of time, or you have expressly consented to their data being held for an extended period of time.

Data Storage

Personal data is stored as hard copy in the Coach House office in a locked, secure location.

Personal data is stored electronically on company computers, and at third party hosting providers.  Company computers are secured by password and have virus software installed as standard.  Squarespace (www.squarespace.com) and Dropbox (www.dropbox.com) provide third party hosting.  Both providers have their own published privacy policy, which can be found on their respective websites.

Investors’s personal data rights

Investors will have the following rights with respect to their personal data:

  • The right to access personal data

  • The right to request that personal data regarding them is corrected if it is found to be inaccurate

  • The right to request that their personal data is erased where it is no longer necessary

  • The right to withdraw consent to processing at any time

  • The right to restrict processing where there is a dispute in relation to the accuracy or processing of the personal data

  • The right to request that Coach House provide the investor with their personal data

  • The right to object to the processing of personal data

You also have a right to complain to the Information Commissioner's Office which regulates the processing of personal data.

Data Coach House collects and receives

Coach House collects the following data from investors that are private individuals; directors & individuals that own 20% or more of corporate investors; and trustees & beneficiaries for any Trust investor:

  • Name

  • Address

  • Email address

  • Telephone numbers

  • Date of birth

  • Nationality

  • National insurance number

  • Unique tax payer reference

  • Copy of identification documents, such as passport or driving licence

  • Copy of documents with proof of address, such as utility bill or bank statement

  • Bank account d etails

Source of personal data

The Personal and Confidential Information you have provided, we have collected from you, or we have received from third parties. Where information is obtained from third parties, we shall ensure that at all times the source from which the information originates from is made known.

Failure to provide personal data

Where a statutory or contractual obligation with you requires us to obtain personal data from you and you fail to provide the data requested, we may not be able to perform the contract we have with you. In this case we may have to cancel a product or service you have with us if we deem this to be the appropriate approach.

How Coach House uses the data

The personal data will be used for the following purposes:

  • Email addresses and telephone numbers are used to communicate with investors.  Communication includes reporting performance and administration of funds in which the investor has invested, as well as information on new fund launches.

  • Names, addresses and unique tax payer references of investors that have invested in specific funds are reported to government entities as part of tax and partnership reporting requirements.

  • Bank account details are used to make payments to investors, representing distributions from funds in which the investor has invested.

  • All other data is held exclusively to satisfy Coach House’s compliance obligations to know the identity of its clients.

Lawful basis for processing

The following state the lawful bases for processing.

  • Consent of the data subject is required solely for the marketing of new investment opportunities.

  • Processing is necessary for the legitimate interests of the data controller, that is the administration of the funds and its compliance obligations, except where such interests are overridden by the interests, rights or freedoms of the data subject.

  • Processing is necessary for compliance with a legal obligation to report to UK government organisations, Companies House and HMRC.

Who else may have access to your Personal data?

Coach House may need to share personal data with third parties as may be required by law, or in order to fulfil contractual obligations. Where your personal data is shared with third parties, we will ensure that equivalent safeguards are offered in order to protect your personal data.

International transfers of Personal data

Coach House does not transfer personal data to countries outside of the EEA. Coach House understands that transfers of personal data to countries outside of the EEA will be deemed unlawful unless the recipients of personal data in non-EEA countries offer an equivalent level of data protection to that of EEA countries, or unless Coach House offer safeguards in accordance with Article 46 GDPR.

Contact Details

In order to exercise all rights, queries and complaints please contact the Data Protection Officer, Tim Lander at info@coachhousegroup.co.uk