Privacy Policy
Introduction
Privacy statement of Emford Global DMCC trading as Cobus (“Emford” or “We”).
To perform our contractual obligations, Emford collects, processes, and stores personal data relating to you, including but not limited to, sensitive personal data. Emford treats any personal data we collect according to our client on-boarding processes in line with current Regulatory Obligations as a Licensed and Supervised Management Company and Corporate Trustee and as part of the provision of our services as private and confidential and we abide by all data protection laws as may be applicable. We have implemented organizational, physical, and technical safeguards which are designed to protect your personal information from unauthorized access, use, or disclosure. We are also committed to being transparent about how your personal data is collected and used. We ask that you read this privacy statement carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information, your rights in relation to your personal information, and on how to contact us and the supervisory authorities if you have a complaint on the way your personal data is being collected or processed.
Collection of Personal Data
We collect personal data directly from you, and where lawful and reasonable, we may collect personal information about you from third parties and publicly available sources, such as Business Introducers, internet websites, Anti-Money Laundering screening software for the purposes set out below. Personal data we may collect includes but is not limited to:
- Name
- Contact information including email address and phone number
- Demographic information such as postcode, preferences, and interests
- Other information relevant to customer surveys and/or offers
Use of Personal Data
We use your personal data to:
- Meet our responsibilities towards you
- Follow your instructions
- Process your personal data for ordinary business purposes (e.g., to open and maintain your bank account, give effect to transactions, administer claims where applicable, manage our risks, and maintain our overall relationship with you)
- Carry out statistical and other analyses to identify potential markets and trends, evaluate and improve our business (this includes improving existing and developing new products and services)
- Tell you about services and products available within the Group
- Make sure our business suits your needs
- Comply with applicable laws
Without your personal data, we may not be able to provide or continue to provide you with the products or services that you need.
Your Consent
You are entirely free to decide whether or not to provide us with your personal data and there are no consequences should you refuse to do so unless for when the supply of specific personal data is mandatory by law. We shall process your personal data if you give us your express consent willingly or in accordance with the law. You give your consent to us through our client acceptance mandate and services agreements.
Third-Party Disclosure
We may only disclose your personal data if:
- The law requires it or such personal data is exempted from data protection laws
- Such disclosure is for the administration of justice or in the public interest or relates to the use of a unique identification number to facilitate sharing information and avoid multiple registrations among public sector agencies
- Such disclosure is necessary for the performance of a contract to which you are a party or to enable you to enter into a contract
- Such disclosure is required to protect your vital interests
- You agreed that we may disclose your data for the purposes for which such data has been collected and of which you have been informed
Third Parties
We routinely share your personal data internally if access to the data is necessary for the performance of our contract. We may share your personal data with the regulatory authorities, if required. We will not share your personal information with any other third party except with your prior written consent.
We may ask third-party service providers to agree to our privacy policies if they need access to any personal data to carry out their services. We will not disclose your personal data to external organizations that are not our service providers, unless you give us your consent, or unless required by law, or if it is necessary for the conclusion or performance of our agreement with you.
Transfer Across Borders
Sometimes we may process your personal data in other countries, either to carry out your instructions or for ordinary business purposes. These countries may not have the same level of protection. If necessary, we will ask the party to whom we transfer your personal data to agree to our privacy principles, associated policies, and practices.
Security of Personal Data
We have implemented organizational, physical, and technical safeguards designed to protect your personal information from unauthorized access, use, or disclosure. Our security systems are designed to prevent loss (including accidental loss), alteration, unauthorized destruction, damage, and/or unlawful access to your personal data.
Storing of Personal Data
We store personal data as required by law.
Retention of Personal Data
We retain personal data as per statutory and regulatory requirements. Where there is no legal requirement, your personal data will be destroyed after one year following the lawful purpose for which the data was obtained.
Access to Your Personal Data and Your Other Rights
As our customer, you may:
- Ask us to give you a description of your personal information that we hold
- Ask us to correct or update your personal information through our customer service channels
- Ask us to restrict the processing of or erase your personal data
- Object to the processing of your personal data for a specific purpose
We will take note of your rights under applicable privacy and data protection laws. You have the right to query a decision that we make about our services that you have requested for. During your contractual relationship with us, if you would like further information on the way in which Emford collects, processes, and protects personal information or would like to access and correct your personal information, please contact the Data Protection Officer at the address set out below.
Monitoring of Electronic Communications
We communicate with you through different methods and channels. If allowed by law, we may record and monitor electronic communications to make sure that they comply with our legal and regulatory responsibilities and internal policies.
Usage of Cookies
Given our website is continually evolving as we aim to ensure it best serves the interest of our users.
The website of Emford uses Google Analytics, a web analytics service provided by Google, Inc (“Google”). Google Analytics uses cookies (text files of data sent to your computer) to help website operators analyze how users use the website. These cookies do not collect or store any personally identifiable information, except for Internet Protocol (IP) addresses. Information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google will use this information to compile reports on website activity and internet usage. We, in turn, use this information to improve our user experience and content. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You may turn cookies off in your web browser by selecting the appropriate settings in your browser.
Right to Change This Privacy Statement
We may change this privacy statement. We will communicate all changes on our websites. The latest version of our privacy statement will replace all earlier versions unless it says differently.
Queries, Complaints, and Breach
In the event that you have an inquiry, please email us at [email protected] addressed to “The Data Protection Officer” and we shall deal with your issue promptly.
GDPR Policy
Introduction
This GDPR Policy outlines how Emford Global DMCC trading as Cobus (“Emford” or “We”) complies with the General Data Protection Regulation (GDPR). We are committed to safeguarding the privacy of our website visitors and service users.
Data Collection and Processing
Under GDPR, personal data must be processed lawfully, fairly, and transparently. We collect and process personal data only for specific, explicit, and legitimate purposes. The data we collect is adequate, relevant, and limited to what is necessary.
Legal Basis for Processing
We process personal data under the following legal bases:
- Consent: You have given clear consent for us to process your personal data for a specific purpose.
- Contract: The processing is necessary for a contract we have with you.
- Legal Obligation: The processing is necessary for us to comply with the law.
- Legitimate Interests: The processing is necessary for our legitimate interests unless overridden by your data protection rights.
Data Subject Rights
Under GDPR, you have the following rights:
- Right to Access: You have the right to request copies of your personal data.
- Right to Rectification: You have the right to request correction of any inaccurate personal data.
- Right to Erasure: You have the right to request the deletion of your personal data under certain conditions.
- Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data.
- Right to Data Portability: You have the right to request that we transfer your data to another organization, or directly to you.
- Right to Object: You have the right to object to our processing of your personal data.
Data Security
We have implemented technical and organizational measures to ensure the security of personal data. This includes measures to prevent unauthorized access, data breaches, and other security incidents.
International Data Transfers
Personal data may be transferred to countries outside the European Economic Area (EEA) only if appropriate safeguards are in place, such as standard data protection clauses approved by the European Commission.
Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, accounting, or reporting requirements.
Contact Information
For any GDPR-related queries or complaints, please contact our Data Protection Officer at:
ADDRESS EMFORD GLOBAL DMCC Office 1204 Tiffany Tower Cluster W JLT Dubai, UAE
CONTACT US Tel: +44 (0) 8371 2200 Email: [email protected]
CCPA Policy
Introduction
This CCPA Policy outlines how Emford Global DMCC trading as Cobus (“Emford” or “We”) complies with the California Consumer Privacy Act (CCPA). We are committed to protecting the privacy of California residents.
Personal Information We Collect
We collect the following categories of personal information:
- Identifiers such as name, address, email address, and phone number
- Commercial information such as records of products or services purchased
- Internet or other electronic network activity information such as browsing history and interactions with our website
Use of Personal Information
We use personal information to:
- Provide and improve our services
- Process transactions
- Respond to inquiries and customer service requests
- Comply with legal obligations
Consumer Rights Under CCPA
California residents have the following rights under CCPA:
- Right to Know: You have the right to request information about the categories and specific pieces of personal information we have collected about you.
- Right to Delete: You have the right to request the deletion of your personal information.
- Right to Opt-Out: You have the right to opt-out of the sale of your personal information. However, we do not sell personal information.
- Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights.
Exercising Your Rights
To exercise your CCPA rights, please contact us at:
ADDRESS EMFORD GLOBAL DMCC Office 1204 Tiffany Tower Cluster W JLT Dubai, UAE
CONTACT US Tel: +44 (0) 8371 2200 Email: [email protected]
We may request additional information to verify your identity before processing your request.
Data Security
We implement appropriate security measures to protect personal information from unauthorized access, disclosure, and loss.
Contact Information
For any CCPA-related queries or complaints, please contact our Data Protection Officer at:
ADDRESS EMFORD GLOBAL DMCC Office 1204 Tiffany Tower Cluster W JLT Dubai, UAE
CONTACT US Tel: +44 (0) 8371 2200 Email: [email protected]