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Introduction
This Privacy Notice sets out how personal data is collected, processed and disclosed in connection with Cordiant Digital Infrastructure Limited (the “Fund”).
We take privacy and security of your information seriously and will only use such personal information as set out in this Privacy Notice and in ways which are reasonably ancillary to what is set out below.
The Fund is a data controller for the purposes of the Data Protection (Bailiwick of Guernsey) Law, 2017 (as amended) (the “Guernsey DP Law“). This means that it determines how and why your personal data is processed.
This Privacy Notice is issued by the Fund and references to the “Fund”, “we”, “us” or “our” in this Privacy Notice refers solely to the Fund as controller. References to “you” include all individuals whose personal data we collect, hold and process in the course of operating the business of the Fund.
This Privacy Notice should be read in conjunction with any terms and conditions, policies or other relevant legal notices including the privacy notices of selected data processors which are available on their respective websites as applicable.
Contact Details
You can contact our data protection adviser in relation to data protection and your rights by emailing CORD@aztecgroup.co.uk.
The personal information we process
- We may collect various types of personal data about you, including:
- Your identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal data relating to claims, court cases and convictions, politically exposed person (“PEP”) status, personal data available in the public domain and such other information as may be necessary for us to provide our services to you and to complete our customer due diligence (“CDD“) process and discharge our obligations relating to anti-money laundering (“AML“) and combatting the financing of terrorism (“CFT“));
- Your tax status information (which may include your tax residency, tax identification numbers and/or tax status);
- Your contact information (which may include postal address and e-mail address and your home and mobile telephone numbers);
- Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);
- Your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold);
- Financial information, sources of wealth and your assets (which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history).
- We may also collect and process personal data regarding people connected to you, either by way of professional (or other) association or by way of family relationship.
- To the extent that such personal data contains “special category data”, for example: data relating to racial or ethical origin, political opinion, religious or philosophical belief, trade union membership or criminal data, then the processing of such data shall solely be for the purpose of complying with any duty imposed on us by an enactment or where it is necessary to prevent, detect or investigate any unlawful act or omission.
Where we obtain your personal information:
We collect your personal information from the following sources:
- personal information which you give to us, including but not limited to:
- information set out in any subscription agreement with the Fund;
- such other forms and documents as we may request that are completed in relation to the administration/management of any of our services;
- information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or
- any personal information provided by way of correspondence with us by phone, e-mail or otherwise;
- personal information we receive from third party sources, such as:
- entities in which you or someone connected to you has an interest;
- your legal and/or financial advisors;
- other financial institutions who hold and process your personal information; and
- credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements.
We may also collect and process personal information received in the course of dealing with advisors, regulators, official authorities and service providers by whom you are employed or engaged or for whom you act.
Why we collect your personal information:
Lawful grounds for processing:
- We may hold and process your personal information on the following lawful grounds:
- the processing is necessary for our legitimate interests, provided your interests and fundamental rights do not override those interests;
- the processing is necessary to comply with our contractual duties;
- the processing is necessary to comply with our legal and regulatory obligations;
- where we have obtained your consent to processing your personal information for a specific purpose; and
- on rare occasions, where it is needed in the public interest.
Purposes of processing
- Pursuant to paragraph 5.1 above, your personal information may be processed for the purposes set out below (“Purposes“). The Purposes based on our legitimate interests are set out in paragraphs 5.2.1 to 5.2.4 inclusive):
- facilitating the administration of our business and/or that of our service providers;
- communicating with you as necessary in connection with your affairs and generally in connection with your investment in the Fund;
- monitoring and recording telephone and electronic communications and transactions:
- for quality, business analysis, training and related purposes in order to improve service delivery; and
- for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);
- disclosing your personal information to any bank or financial institution or other third party lender providing any form of facility, loan, finance or other form of credit or guarantee to the Fund;
- to enforce or defend our legal and contractual rights or those of third party service providers;
- to comply with legal or regulatory obligations imposed on us (including but not limited to AML/CDD obligations);
- detecting and preventing crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanction on an ongoing basis (“Regulatory Assessments“);
- facilitating our internal administration and retaining your personal data as part of our Regulatory Assessments or future services entered into by you; and
- liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem it is appropriate to cooperate in relation to an investment and which has jurisdiction over the Fund or its investments.
We do not make decisions about you based on automated processing of your personal data.
Sharing personal information
We may share your personal data with our group companies and third parties (including the administrator, registrar, investment manager, the bookrunner, banks, financial institutions or other third party lenders, IT service providers, auditors and professional advisers) under the terms of any appropriate delegation or contractual arrangement. Those authorised third parties may, in turn, process your personal data abroad and may have to disclose it to foreign authorities to help them in their fight against crime and terrorism.
Data processing (as described above) may be undertaken by any entity in the Bailiwick of Guernsey. However, such data processing may also be undertaken by an entity which is located outside the Bailiwick of Guernsey, the United Kingdom or the European Economic Area (the “EEA“) in a third country without the same or similar data protection laws as the Bailiwick of Guernsey or any EU member state.
This means that the countries to which we transfer your data are not deemed to provide an adequate level of protection for your personal information. However, to ensure that your personal data receives an adequate level of protection we have put in place the following appropriate measure(s) to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the EU laws, the laws of the Bailiwick of Guernsey and the laws of the United Kingdom (as applicable) on data protection:
- utilisation of standard contractual clauses (also known as EU Model Clauses) for data protection which have been approved and adopted by the European Commission and/or the Office of the Data Protection Authority; and/or
- the use of another appropriate safeguard envisaged by Article 46 of (i) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data andon the free movement of such data, and repealing Directive 95/46/EC (the “GDPR“), or (ii) the UK version of the GDRP, which is part of UK law by virtue of the European Union (Withdrawal) Act 2018, as amended (the “UK GDPR“) (as applicable) being implemented.
In limited circumstances, applicable law may permit us to otherwise transfer your personal information outside the UK or the EEA.
If you would like further information about the safeguards we have in place to protect your personal information, please contact CORD@aztecgroup.co.uk.
Retention of personal information
- Your personal information will be retained for as long as required:
- for us to carry out the Purposes;
- in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or
- as required by data protection laws and any other applicable laws or regulatory requirements.
Access to and control of personal information
- You have the following rights (which may be exercisable depending on the circumstances) in respect of the personal information about you that we process:
- the right to access personal information;
- the right to rectify personal information;
- the right to restrict the use of personal information;
- the right to request that personal information is erased; and
- the right to object to processing of personal information.
- You also have the right to lodge a complaint about the processing of your personal information either with us, or with:
- The Office of the Data Protection Authority in Guernsey (www.odpa.gg);
- the Information Commissioner’s Office in the UK (www.ico.org.uk); or
- if you are an EU data subject, the supervisory authority in the EU member state of your residence.
Where we have relied on consent to process your personal information, you have the right to withdraw consent at any time. You also have the right to object to processing on the basis of legitimate interests (although this right is subject to certain exceptions).
If you wish to exercise any of the rights set out in this paragraph 8, please contact CORD@aztecgroup.co.uk.
Inaccurate or amended information
Please let us know as soon as possible if any of your personal information changes (including your correspondence details) by contacting us at CORD@aztecgroup.co.uk. Failure to provide accurate information or to update information when it changes may have a detrimental impact upon your investment, including the processing of any subscription instructions.
Communications and Media
People who email us
We use software to encrypt and protect email traffic. If your email service does not support this software, you should be aware that any emails we send or receive may not be protected in transit. Please contact us for further detail should you require it.
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.
Visitors to our website
We are committed to protecting and respecting your privacy on-line. We are aware of the concern which exists over the use of personal information provided over the internet and therefore, we do not collect personal data through our website.
We do not control and are not responsible for the privacy policy of any website or organisation to which our website provides links. By including references, hyperlinks or other connections to such third party websites, we do not imply any endorsement of them or any association with their owners or operators.
Google Analytics
The Fund’s website uses Google Analytics to help analyse how users use the site. The tool uses “cookies”, which are text files placed on your computer, to collect standard Internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the website (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the website and to compile statistical reports on website activity for the Fund.
We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personally Identifiable Information (“PII“) of visitors to our site. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a computer user. We will not associate any data gathered from this site with any PII from any source, unless you explicitly submit that information via a fill-in form on our website.
Questions
If you have any questions about this Privacy Notice or how we handle your personal information (e.g. our retention procedures or the security measures we have in place), or if you would like to make a complaint, please contact CORD@aztecgroup.co.uk.
This Privacy Notice was issued on 26 January 2021. We may update this Privacy Notice from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. We will endeavour to notify you of any substantive changes to our Privacy Notice, however, please review this web page frequently to see any updates or changes.
Use of Cookies
Supporting Site Information
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. We use cookies for the following general purposes:
Analytical cookies: These persistent cookies are used to recognize and count the number of visitors as well as providing other information about the visit such as duration, route through the site and what sites the visitor came from. This information helps us to improve the way our site works, for example by making sure users find what they need easily. These cookies are provided by Google.
Advertising and Third party cookies: We do not use persistent cookies or similar technologies (known as action tags, single pixel gifs and web beacons) to provide country-specific content or assess information about your visits to this site. These cookies may be used within third party advertisements on the site.
The table below gives more details about the specific cookies that may be used and why.
Strictly necessary cookies
These cookies are always active and are necessary for this website to function. They cannot be switched off. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences.
You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
| Function provider | Cookie name | Data stored | Purpose | Duration |
|---|---|---|---|---|
| Youtube.com | LOGIN_INFO, 1p_JAR, ANID, APSID, CONSENT, DSID, GPS, HSID, SID, SSID, IDE, NID, OGP, OGPC, PREF, SAPISID, SID, SIDCC, SSID, VISITOR_INFO1_LIVE, YSC, permutive-id, permutive-session, watched_video_id_list, demographics | Various unique identifiers, as well as login information that may relate to a Google account. | Video functionality | Some of the cookies expire up to 20 years after your last visit to a page containing a Youtube video, although some expire sooner. |
| cordiantdigitaltrust.com | PHPSESSID | Works by creating a unique id (UID) for each visitor and stores variables based on this UID. | Session cookie | When browsing session ends. |
| moove_gdpr_popup | Cookie set by the UK cookie consent plugin to record that you accept the fact that the site uses cookies. | 30 days | ||
| pum-* | These control the repeated display of popups in the browser. Cookies are assigned an identification (ID) number formatted as ‘pum-{integer}’. | 14 days | ||
| BrighterIR | AWSALB, AWSALBCORS | Cookie set by Amazon Web Services Load Balancer to preserve server session stickiness. | 1 week | |
| XSRF-TOKEN | Cookie set by Laravel framework to protect against cross-site exploits. | 2 hours | ||
| Laravel_session | Cookie set by Laravel framework to preserve session data on investor relations tools. | 2 hours | ||
| Cloudflare | __cf_bm | This cookie, set by Cloudflare, is used to support Cloudflare Bot Management. | 30 minutes |
Performance cookies
These cookies allow us to count visits and traffic so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular, and see how visitors move around the site.
All information that is collected by these cookies is aggregated, and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
These cookies are set by the Google Analytics service, but hosted by i3.energy.
| Host | Cookie name | Duration |
|---|---|---|
| cordiantdigitaltrust.com | _ga | 1 year |
| cordiantdigitaltrust.com | _gat | 1 minute |
| cordiantdigitaltrust.com | _gid | 24 hours |
Targeting cookies
We do not currently use targeting cookies.
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 https://tools.google.com/dlpage/gaoptout
How to Refuse the Use of Cookies
Most web browsers allow some control of most cookies through the browser settings. You may refuse the use of cookies by selecting the appropriate settings in your browser. However, if you do this you may lose some useful functionality such as personalisation and ‘keep me signed in’ and ‘remember me’ features.
How to Disable Cookies in Your Browser
Here’s how to prevent new cookies from being installed and how to delete existing cookies. The exact procedure depends on which browser you are using.
Internet Explorer
To prevent new cookies from being installed and delete existing cookies:
http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Firefox
To prevent new cookies from being installed:
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
To delete existing cookies:
https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
Google Chrome
To prevent new cookies from being installed and delete existing cookies:
https://support.google.com/chrome/answer/95647?hl=en
Safari
To prevent new cookies from being installed and delete existing cookies: