This policy explains what personal data Clementson Capital Group collects when you use this website or contact us, what we do with it, and the rights you have over it. We collect only what we need to respond to you and to run our advisory service.
Who we are
Clementson Capital Group is a trading name of CoachFlo LTD, a company registered in England and Wales, UK Company No. 17052803. CoachFlo LTD is the controller of your personal data for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. In this policy, “we”, “us” and “our” mean CoachFlo LTD trading as Clementson Capital Group.
You can reach us about anything in this policy at contact@clementsoncapital.com.
Data we collect
Information you give us. When you complete the Advisory Intake form or email us, we collect:
- your full name, email address and, if you provide them, your company or entity name and telephone or WhatsApp number;
- your chosen investment capital tier and target region;
- anything you write in the commercial objective field or in correspondence with us;
- a record that you ticked the consent box, and when.
Technical data. Like any website, our hosting provider receives your IP address, browser type, device information and the pages requested, and keeps this in standard server logs for security and reliability. We do not use this to identify you personally.
Information from other sources. Once an engagement proceeds, we collect the identity, ownership and source of funds information described in the client due diligence section, from you and from screening providers.
Please do not send us sensitive information, such as passport images or bank statements, through the enquiry form. We will tell you how to send those securely if and when they are needed.
How and why we use it
We must have a lawful basis for each use of your data. These are ours:
- Responding to your enquiry and assessing whether our mandate fits. Lawful basis: taking steps at your request before entering into a contract, and our legitimate interest in answering the people who contact us.
- Contacting you about your enquiry. Lawful basis: your consent, given when you tick the box on the form. You can withdraw it at any time.
- Delivering our services to clients. Lawful basis: performing our contract with you.
- Client due diligence, sanctions and fraud checks. Lawful basis: our legal obligations where they apply, and our legitimate interest in not being used for unlawful activity.
- Keeping the website secure and working. Lawful basis: our legitimate interest in protecting our systems.
- Establishing, exercising or defending legal claims. Lawful basis: our legitimate interest, or legal obligation where a court or regulator requires it.
We do not sell your personal data. We do not use it for automated decision-making or profiling that has legal or similarly significant effects on you. We will only send you marketing that you have asked for, and you can opt out of it at any time.
Client due diligence
We complete full client due diligence before any engagement commences. That means we may ask for, and will process, identity documents, proof of address, details of corporate ownership and control, and evidence of the source of your funds and wealth. We may also screen you and connected parties against sanctions lists, politically exposed person (PEP) records and adverse media. This screening can reveal information about criminal allegations or convictions, which we treat with additional care and process only where the law allows.
If we reach that stage we will give you a short, specific notice that sets out exactly what we are collecting and why. You are not asked for this information by completing the website form.
Who we share it with
We share personal data only where there is a reason to, and only the data needed:
- Service providers that host our website, provide email and IT services, or carry out identity verification and screening on our behalf. They act on our instructions. Our website is hosted by Vercel Inc. Enquiries sent through the Advisory Intake form are received by Formspree, a form-processing service, which passes them to us by email.
- Professional advisers we appoint or introduce for your matter, such as solicitors, accountants and regulated immigration advisers. We share your details with an introduced adviser only with your agreement.
- Banks and lenders where you instruct us to prepare and submit an application or make an introduction.
- Regulators, law enforcement and courts where we are required to by law or to protect our legal rights.
- Any buyer or successor if our business is ever sold or reorganised, subject to the same protections for your data.
International transfers
Many of the people we work with are based outside the United Kingdom, and some of our providers, including our website host, process data outside the UK. Where your data is transferred to a country without a UK adequacy decision, we rely on appropriate safeguards, such as the ICO’s International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses. You can ask us for details of the safeguards that apply.
How long we keep it
- Enquiries that do not proceed: up to 12 months from our last contact with you, then deleted.
- Clients: for the duration of the engagement and for six years afterwards, so that we can meet our legal obligations and deal with any claim.
- Server logs: for a short rolling period set by our hosting provider.
We may keep data for longer where the law requires it or where it is needed for a live legal claim.
Your rights
Under UK data protection law you have the right to:
- be told how your data is used, which is the purpose of this policy;
- access a copy of the personal data we hold about you;
- have inaccurate data corrected;
- have your data erased, in certain circumstances;
- restrict our use of your data, in certain circumstances;
- receive data you gave us in a portable format, where we process it by consent or contract;
- object to processing based on our legitimate interests, and to direct marketing at any time;
- withdraw consent at any time, without affecting anything we did before you withdrew it.
To exercise any of these rights, email contact@clementsoncapital.com. We will normally respond within one month. We may need to verify your identity first. There is no fee unless a request is clearly unfounded or excessive.
Complaints. If you are unhappy with how we have handled your data, please tell us first so that we can put it right. You also have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113.
Security
We use appropriate technical and organisational measures to protect personal data against loss, misuse and unauthorised access. This site is served over HTTPS with HTTP Strict Transport Security. Access to client information is limited to the people who need it. No method of transmission over the internet is completely secure, so please take care over what you send us and how.
Cookies and tracking
At the date above, this website does not set cookies and does not use analytics or advertising trackers. The site loads the Playfair Display and Inter typefaces from Google Fonts, which means your browser makes a request to Google’s servers and your IP address is visible to Google when that happens. If we add analytics or any non-essential cookies in future, we will ask for your consent first and update this policy.
Changes to this policy
We may update this policy from time to time. The date at the top of the page shows when it last changed. If a change materially affects how we use your data, we will tell you directly where we can.
Contact
CoachFlo LTD, trading as Clementson Capital Group
UK Company No. 17052803, registered in England and Wales
contact@clementsoncapital.com
Our registered office address is shown on our Companies House record. See also our Terms of Service.