Website Privacy Policy

Website Privacy Policy

BlueCove Limited (“BlueCove”) is a new firm and at present does not have any products or clients. BlueCove is targeting the first half of 2019 for FCA authorisation and intends to launch its initial suite of investment products during the third quarter of 2019.

We respect the privacy of every person whose personal information we may process as a result of applying to work at BlueCove or who engages with us to use the products and services that BlueCove may in future provide (our “Products and Services”). This applies to applications and Products and Services that occur through “www.bluecove.com” (the “Site”).

This Policy will be updated when we launch Products and Services.

Purpose of this Policy

This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and any Services and/or to understand how your personal information may be processed by us as a result of providing said Services or when you apply to work at BlueCove. Please take a moment to read and understand it.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

Who are we and what do we do?

The Site is operated by BlueCove (“we”, “us” or “our”). The data controller for your personal information processed via the Site is BlueCove.

BlueCove is registered in England and Wales with company number 11269446 and has its registered office at 10 New Burlington Street, Mayfair, London, W1S 3BE.

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:

  • sending an e-mail to legal@bluecove.com; or
  • calling us on: 0203 146 1500

What personal information do we collect and how do we use it?

Our primary goal in collecting personal information from you may be to: (i) verify your identity; (ii) develop, and once we are FCA-authorised, to market Products and Services; (iii) carry out requests made by you on the Site or in relation to our Products and Services; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us and/or third parties, including our clients and users of the Site or of any Products and Services; (viii) provide support for the provision of said Products and Services; (ix) for recruitment purposes; and (x) use as otherwise required or permitted by law.

To undertake these goals we may process the following personal information:

  1. A. If you are a visitor to the Site:
    • Name and job title
    • Contact information including email address
    • Demographic information such as postcode, preferences and interests
    • Other information relevant to provision of any Products and Services
  2. B. If you are an individual whose personal information may be processed by us in the future as a result of providing Products and Services to others (including individual investors and clients and institutional and corporate investors and clients) we will process a variety of different personal information depending on the Products and Services provided in question.

    For instance, if we are providing Products and Services to an institutional client, we may be provided with and then process, personal information about the client’s representatives including but not limited to any representative’s name and contact details. 

    We might also need to process personal information in relation to institutional clients’ workers who may be involved with BlueCove’s Products and Services.

  3. C. If you are a potential recruit to BlueCove:
    • Name and job title
    • Contact information including email address
    • Curriculum vitae, your education, employment history and similar information that you may provide to us
    • Other information relevant to potential recruitment to BlueCove

In particular, we may use your personal information for the following purposes:

  • Recruitment strategy
  • Business Administration
  • Compiling metrics
  • Providing feedback
  • Legal and regulatory purposes

We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Products and Services.

Who do we share your personal information with for this purpose?

We may share personal information with a variety of the following categories of third parties, as necessary:

  • Recruitment agents
  • Insurers 
  • Software as a Service and other technology providers and platforms
  • Regulators/tax authorities/corporate registries/government organisations
  • Third party vendors/service providers

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide Products and Services as effectively as we can and to recruit and retain talent.

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you, or where it is in our legitimate interest (for example business administration) or a third party’s legitimate interest to use personal information in such a way to ensure that we provide any Products and Services in the best way that we can.

Recruitment

We use your personal information for the following recruitment purposes:

  • To assess your suitability for any position for which you may apply at BlueCove – whether such application has been received by us online, via email or by hard copy or in person application.
  • To review BlueCove’s equal opportunity profile in accordance with applicable legislation. Note that BlueCove does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation.
  • All employment related decisions are made entirely on merit.

Who do we share your personal information with for these purposes?

We may share your personal information with third parties who assist us in carrying out our recruitment activity. We additionally utilise the services of the online technology tool Greenhouse, to assist us in recruitment and in upholding GDPR standards.

What is our legal basis?

Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you, or where it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for BlueCove.  We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent.

Insight and analysis

We may analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with any Products or Services.

Where you have given your consent (where lawfully required), we may use cookies, log files and other technologies to collect personal information from the computer hardware and software (including your mobile device) you use to access the Site. This includes the following:

  • an IP address to monitor Site traffic and volume;
  • a session ID to track usage statistics on our Site;
  • information regarding your professional interests and any experiences with our Products and Services and contact preferences.

Our web pages and e-mails contain “cookies” “web beacons” or “pixel tags.” (“Tags”). Tags allow us to track your receipt of an e-mail, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our e-mail messages, we use a “click-through URL” linked to a certain website administered by us or on our behalf.

By using this information, we are able to measure the effectiveness of our content and how visitors use our Site and our Products and Services. This allows us to learn which parts of our Site are the most interesting to visitors.

Who do we share your personal information with for these purposes?

In the future we may share your personal information with a variety of third party service providers to assist us with insight analytics.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way that enables us to provide the very best Products and Services to you and any future clients.

How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

Third Party contractors and other controllers

As mentioned above, we may appoint sub-contractor data processors as required to help us to deliver any Products and Services, for example outsourced providers and other third party vendors. Where we do so, they will process personal information on our behalf and at our direction. We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

Further, in the future, we may appoint external data controllers in common with us where necessary to deliver any Products and Services. Where we do so, we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation (where necessary) putting appropriate safeguards in place to ensure any personal information is processed according to our legal and regulatory obligations.

Extra-EEA Transfers

If you are based within the EEA, please note that in relation to any Products or Services, we may transfer personal information to countries outside the EEA. Not all countries provide the same level of protection in relation to personal information as within the EEA. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information. This will include having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

How long do we keep your personal information for?

Regarding visitors to the Site, we will retain relevant personal information for at least 12 months from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world), or for longer (for example seven years) where we are required to do so according to our regulatory obligations or insurance obligations.

Regarding personal information we may process as part of providing Products and Services to any future client, we will retain relevant personal information for at least seven years from the date of our last interaction and in compliance with our future regulatory obligations under the EU General Data Protection Regulation (or similar legislation around the world) or for longer where we are required to do so according to our regulatory obligations or professional indemnity obligations.

If personal information is only useful for a short period e.g. for future specific marketing, once BlueCove is FCA approved, we may delete it.

Confidentiality and security of your personal information

We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

All of our members, employees, workers and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the Site.

How to access your information and your other rights?

You have the following rights in relation to the personal information we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make.

Your right of access

If you ask us, we’ll confirm whether we’re processing your personal information and, subject to any applicable exemptions, provide you with a copy of that personal information (along with certain other details) within the timescales, or extended timescales provided for by the GDPR for complex requests. If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your personal information). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability

You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

Your right to object

You can ask us to stop processing your personal information and we will do so if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • in the future processing your personal information for direct marketing.

Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Information Commissioner’s Office (ICO) in the UK where your concern relates to BlueCove. You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their office on 0303 123 1113.

If you want to exercise any of these rights you can do so by contacting us.

Collection of information by third-party sites and sponsors

The Site contains links to other sites whose information practices may be different from ours. Visitors should consult the other sites’ privacy notices as BlueCove has no control over information that is submitted to, or collected by, these third parties.

Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time, in particular when we have become FCA-authorised and launch Products and/or Services.

To ensure that you are always aware of how we use your personal information, we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes, as required, to comply with changes in applicable law or regulatory requirements. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.