Privacy and Cookies

At Cohort plc, we take your privacy seriously and this privacy statement explains what personal data or information we collect from you and from people who visit our website and how we use it.  We would encourage you to read the list below and click on ‘learn more’ if you would like more information on a specific topic.

We may change this information from time to time, so please check this page occasionally to ensure you’re happy with any changes.  This privacy statement was last updated on 16 May 2018.

If you have any questions regarding this statement and our privacy practices, please contact us by email dpl@Cohortplc.com or by post at Cohort plc, One Waterside Drive, Arlington Business Park, Theale, Reading, RG7 4SW.  Alternatively, you can telephone us on +44 1189 909 0390.

CONTENTS

Who are we?

Cohort plc is a registered company (05684823) our registered office address is 2 Waterside Drive, Arlington Business Park, Theale, Reading, RG7 4SW.  The Cohort Group includes our Trading Subsidiaries, Chess Technologies (Chess), MASS Consultants Limited, Systems Engineering & Assessment Ltd (SEA), Marlborough Communications Limited (MCL) and Empresa de Investigação e Desenvolvimento de Electrónica, S.A. (EID), Systems Consultants Services Limited (SCS).  In this document, ‘We’, ‘Us’, ‘Our’ or the ‘Group’ includes Cohort plc and its trading subsidiaries as listed above.

Cohort plc is a registered data controller (ZA298119).

What personal data or information do we collect?

The personal information we collect may include:

Identity Data

first name, last name, title, job title

Contact Data

billing/contact address, delivery address, email address, telephone numbers

Financial Data

bank account, billing and payment details

Contract Data

details about contract agreements or proposed agreements between us

Transaction Data

details about payments to and from you.  Details of products and services you have purchased from us or supplied to us

Profile Data

purchases or orders made by you, feedback and survey responses

Technical Data

internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website

Usage Data

information about how you use our website, products and services

Marketing and Communications Data

your preferences in receiving marketing communications from us and/or our third parties, and your communication preferences

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How is your personal data or information collected?

We may collect data or information about you when you:

  • make an enquiry about our products, services or business activities of Cohort plc or our trading subsidiaries
  • become a shareholder of Cohort plc
  • become a supplier to Cohort plc
  •  enquire about a job opportunity at Cohort plc or our trading subsidiaries
  • use the Cohort plc website
  • register to be sent an email news update or RNS alert from the Cohort plc website
  • provide a business card or contact details in another form to one of our Cohort plc or trading subsidiary employees in person eg. at a meeting or event

How is your information used?

We collect your personal data or information to operate our business effectively and provide you with the best information on the products and services from across the Group.

We may use your information:

  • To carry out our obligations arising from any contract or contract negotiations entered into by you or us as client or prospective client of Cohort plc or our Trading Subsidiaries
  • To process an enquiry that you have made to us or our Trading Subsidiaries
  • To contact you to discuss business opportunities or products and services from our Trading Subsidiaries that we believe may be of interest to you
  • To send you communications that you have requested, for example our email news alert
  • To process a job application
  • To conduct the due diligence and negotiations required as part of a potential or actual business merger or acquisition
  • To process our obligations associated with AIM Regulations and our shareholders
  • To invite you to events run by Cohort plc and our Trading Subsidiaries

We believe that all these purposes are justified on the basis of our legitimate interests in running and promoting our business, the contractual obligations of our Trading Subsidiaries to deliver products and services to you, and our legal obligations as appropriate.  We may also use your personal data to send you information, such as an email news update which you have signed up to receive and can opt-out from at any time.

Purpose / Activity

Type of data held

Length of time data held

How data held

As a client or agent of our Trading Subsidiaries  (including SCS)

  • Identity data
  • Contact data
  • Contract information
  • Financial information
  • Transaction data
  • Information and documents relating to the products / services we are providing, including communications with you
  • Your communications & marketing preferences

6 years after expiry of contract

Business administration and communications systems held on secure UK servers

 

Prospective clients of our Trading Subsidiaries (for example during a bid or tender process)

  • Identity data
  •  Contact data
  • Contract information
  • Financial information
  • Information and documents relating to the products / services we are discussing. including communications with you

The lesser of 6 years or when the warranty expires

Business administration and communications systems held on secure UK servers

 

Suppliers of products & services to Cohort plc (including Business Advisors)

  • Identity data
  • Contact data
  • Contract information
  • Transaction data
  • Information and documents relating to the products / services you are providing, including communications with you

6 years after expiry of contract

Business administration and communications systems held on secure UK servers

 

Current or prospective trade/commercial partners (eg. Business Advisors and Companies as part of an acquisition or merger)

  • Identity data
  •  Contact data
  • Names of Shareholders
  • Company Director details, including CVs & contracts
  • Commercial information, including supplier & customer contract details
  • Information and documents relating to negotiations including communications with Advisors

As specified by the relevant Non-Disclosure Agreement

Business administration and communications systems held on secure UK servers

Fund managers or individuals holding shares in Cohort plc

  • Name
  • Contact information (Fund Managers only)
  • Shareholding details

Permanently

Business administration and communications systems held on secure UK servers

Interested financial investors (eg. to be sent our financial reports or RNS updates)

  • Name
  • Contact information
  • Your communications preferences

Minimum of 1 year or until consent is withdrawn

Business administration and communications systems held on secure UK servers

Charitable organisations supported by Cohort plc or our Trading Subsidiaries

  • Name
  • Contact information
  • Financial information
  • Information and documents relating to the support we are providing, including communications with you

6 years

Business administration and communications systems held on secure UK servers

Website visitor

  • Technical data
  • Usage data

30 days

Google Analytics

 

Job Applicants

Please refer to our CANDIDATE PRIVACY POLICY

Our Current and Former Staff

Please refer to our Staff Privacy Policy in the Cohort plc Staff Handbook or contact dpl@cohortplc.com

 

 

 

Who has access to your information?

We do not sell or rent your personal data or information to any third party or share your information with third parties for their marketing purposes. 

We will disclose your data or information if required by law, for example by a court order or for the prevention of fraud or other crime.

We may pass your information to our Trading Subsidiaries for the purposes of providing you with relevant information about their products and services, or to enable discussions about co-operative working for mutual benefit.

We may pass your information on to our third party service providers, professional advisors, agents or subcontractors for the purposes of completing a task or providing services to you on our behalf.  Additionally to HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances.

We disclose only the personal information necessary to deliver that service and have a contract in place that requires them to keep your information secure and not to use it for their own marketing purposes.  When you are giving your personal data or information to the relevant third party this will be made very clear.  They may then be acting as the data processor of your information for this purpose and therefore we advise you to read their Privacy Policy which will be clearly displayed at the point of data collection.

Third party service providers who act as data processor on our behalf

DotMailer

Media Alert email fulfilment

Name / Email Address

LINK to Privacy Policy

Q4 Inc.

RNS Service provider

Name / Email Address

LINK to Privacy Policy

Google ReCaptcha

Robot checking tool on sign up form

IP Address

LINK to Privacy Policy

Google Analytics

Web Analytics

IP Address

LINK to Privacy Policy

Link Asset Services

Shareholder services

Identity, Contact, Financial & Transactional data

LINK to Privacy Policy

Investec

Nominated Advisor – Shareholder services

Identity, Contact & Transactional data

LINK to Privacy Policy

 

Transfers outside of the European Economic Area

Your personal data or information in the European Economic Area (EEA) is protected by data protection laws, but other countries do not necessarily protect your personal information in the same way.  The EEA covers all countries in the EU plus Norway, Liechtenstein and Iceland.  Some of the third party providers we use to help us manage our business and services may involve data transferring to the United States or other countries outside of the EEA.

We use the following third party online tools which may involve your data being processed outside of the EEA:

Google Analytics

Web Analytics

IP Address

LINK to Privacy Policy

 

Your choices & rights

You have a choice about whether or not you receive marketing communications about the innovative products and services available from across our Group.  We will not contact you for direct marketing purposes by post, email, phone or text message if you indicate to us that you wish to opt out of receiving such communications.

As an individual whose personal data is processed by Cohort plc you have these rights

  • The right to be informed, which is what this privacy policy is for
  • The right to access the data we hold about you
  • The right to object to direct marketing – either use the unsubscribe option or contact us directly
  • The right to object to processing carried out on the basis of legitimate interests
  • The right to erasure (in some circumstances)
  • The right to data portability
  • The right to have your data rectified if it is inaccurate
  • The right to have your data restricted or blocked from processing

How you can update your information

The accuracy of your information is important to us.  You can change your marketing preferences, unsubscribe or opt-out from receiving communications from us by contacting us at any time.

If you change your email address or if you want to update any of the information we hold on you, please email us  dpl@Cohortplc.com or by post at Cohort plc, One Waterside Drive, Arlington Business Park, Theale, Reading, RG7 4SW.  Alternatively, you can telephone us on +44 1189 909 0390.

How you can access your personal information

You have the right to ask for a copy of the personal information Cohort plc hold relating to you.  To do this please contact dpl@Cohortplc.com or by post at Cohort plc, One Waterside Drive, Arlington Business Park, Theale, Reading, RG7 4SW.  Alternatively, you can telephone us on +44 1189 909 0390.

You also have the right to lodge a complaint about our processing of your personal data with the UK’s Information Commissioner’s Office https://ico.org.uk/.  

Keeping your data secure

When you give us personal information we take steps to ensure that it’s treated securely and strive to protect it on our internal systems and our secure server systems encrypt your information. 

Contacting us via social media

We do not currently use Social Media as a communication platform.  

Contacting us via email

We use Transport Layer Security (TLS) to encrypt and protect email traffic in line with government. If your email service does not support TLS, you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Links to other websites

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

COOKIE POLICY

Use of cookies by this website

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site about aspects of your visit. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.  If you disable or refuse cookies, please note that some parts of the website may become inaccessible or not function properly.

Third-party cookies

On some pages of our website, other organisations may also set their own anonymous cookies. They do this to track the success of their application, or to customise the application for you. Because of how cookies work, our website cannot access these cookies, nor can the other organisations access the data in cookies we use on our website.  For example, when you submit data through a website form.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.

To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

The table below details every cookie used by this website.

Cookie

Name

Purpose

More information

Google Analytics

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These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Click here for an overview of privacy at Google