Registration of an account on the Cogent Credit Website requires your name and a valid email address and password. Please be aware that any other information you enter may possibly be displayed on the Cogent Credit Website intentionally (depending on choices you make during the registration process, or depending on the way in which the Cogent Credit Website is configured) or unintentionally (subsequent to a successful act of intrusion by a third party). As on many websites, the Cogent Credit Website will also automatically receive general information that is contained in server log files, such as your IP address, and cookie information. The Cogent Credit Website also gathers usage data which may include information about how you use the Cogent Credit Website. Information about how advertising may be served on the Cogent Credit Website is set forth below.
We process different types of data for any customers we process on behalf of our clients:
Identity Data includes first name, last name.
Verification Data (see Verification section below) includes images of you and your ID documents.
Contact Data includes home address, business address, billing and delivery address(es), place of work, role, email address(es) and telephone number(s).
Financial Data includes customers' bank account details (bank name, account name, number, address and sort code) and credit references and checks.
Transaction Data includes details about order history, payment instructions, payment patterns.
Profile Data includes usernames and passwords, account preferences, and any feedback and survey responses given.
Usage Data includes information about how you use our website and/or software.
Marketing and Communications Data includes your preferences in receiving marketing and your communication preferences.
It is important that the personal data we hold about you is accurate and current. Please ensure to keep us informed if your personal data changes.
In providing its products and services, Cogent Credit collects and aggregates commercial data from a number of publicly available sources and combines this with data provided in application forms.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purpose of satisfying any legal, accounting or reporting requirements. By law, we are required to keep basis information about our customers for six (6) years after they cease being customers for tax and legal purposes.
Cogent Credit will only use your personal data for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org.
|How we may use your information||Legal basis|
Verify your identity and any other information you've provided
Prevent or detect fraud or money laundering
Prepare anonymised statistical reports from information about you and other customers to help us manage our business better, for example improving our risk models
Improve the relevance of marketing messages we may send you
Analyse, assess and improve our services to customers, and for training and monitoring purposes
Assess your credit worthiness, to trace you and take appropriate action against you should you fail to pay amounts owed
To establish, exercise or defend legal claims
Sending you servicing and marketing messages
Legitimate interest –
Developing and providing new products and services
Protecting our clients from unnecessary risks
Preventing fraud and money laundering
Protecting our clients against harm to their rights and interests
Verify your identity and any other information you've provided us
Prevent or detect fraud, money laundering
|To comply with anti-money laundering laws and regulations|
|Manage your account||To satisfy our clients agreements with you|
Send you marketing messages
Refer you to lenders if you do not receive the full trade credit you request
If we deem it necessary to share your personal data, we will require all third parties to respect the security of your personal data and to treat it in accordance with the law.
From time to time, we may share your personal data which involves transferring it to third parties who may be established outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: (a) the country is deemed to provide an adequate level of protection for personal data by the European Commission; (b) we will use of specific contracts approved by the European Commission; or (c) the third party is part of the Privacy Shield which requires a similar protection of personal data shared between Europe and the United States.
There are two main reasons we perform a verification on behalf of a wholesaler.
Firstly, most customers end up exceeding the threshold at which the law requires Anti-Money Laundering checks to be done. Our wholesale clients have a legal duty to try and prevent the acceptance of any monies from criminal sources.
2. Legal certainty
If we don’t do this we risk that someone who is not authorised to commit your business actually tries to do so. Fraud is more and more common and our clients rely on us to minimise any risk that it is someone posing as you attempting to obtain goods or services.
The process of verification involves:
Taking a photo of your passport or driving license and ensuring it is both a valid document belonging to you and that it matches the images we take of you. This work is done by machine. We outsource the processing work to Onfido. The data captured is not stored by the wholesaler or by Cogent Credit. It is only stored by Onfido and will only be retrieved in a situation where it is legally necessary.
You may refuse to go through the digital process outlined above (if, and when, we deem it appropriate) but we will still need proof you are the person you say you are. You can do this manually instead by emailing email@example.com and arranging a meeting where you come to 18 Hanway Street London W1T 1UF with a copy of your passport or driving license and we will process you manually.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and third parties who have a business need to know this information. All personal data is protected by the latest firewall and software technology. Document and image data captured during any verification process is stored by Onfido. Onfido is trusted by numerous large financial institutions to do this. Once your relationship with the respective wholesaler has come to an end, Onfido will be instructed to delete this information.
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
|__Request Verification Token||Cogent Credit||HTTP||Session||Helps prevent Cross-Site Request Forgery (CSRF) attacks.|
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
|_ga||Google Analytics||HTTP||Session||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
|_gat||Google Analytics||HTTP||Session||Used by Google Analytics to throttle request rates.|
|_gid||Google Analytics||HTTP||Session||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.|
|collect||Google Analytics||Pixel||Session||Used to send data to Google Analytics about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.|
Marketing cookies are used to track visitors across websites. The intention is to follow up with targeted marketing information and material for the individual.
|__ptq.gif||Hubspot||Pixel||Session||Sends data to the marketing platform Hubspot about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels.|
|__cfduid||Hubspot||HTTP||1 Year||Used by the content network, Cloudflare, to identify trusted web traffic.|
As Cogent Credit's products and services are aimed at business users, Cogent Credit does not allow persons who are aged seventeen or younger to become members of the Cogent Credit Website. For more information, please contact us at firstname.lastname@example.org.
Changes may be made to this Policy from time to time. You will be notified of substantial changes to this Policy either through the posting of a prominent announcement on the Cogent Credit Website, and/or by an email message sent to the email address you have provided, which is stored within your user settings.
In relation to your personal data, your rights under data protection laws, include: (a) right to access; (b) right to rectification; (c) right or erasure; (d) right to object to processing; (e) right to restrict processing; (f) right to data portability; and the (g) right to withdraw consent. If you wish to exercise any of your aforementioned rights, please contact Cogent Credit at email@example.com.
Cogent Credit offers no warranties or representations as regards to maintenance or non-disclosure of data.
If you have any questions about this Policy or about the Cogent Credit Website, please contact us at firstname.lastname@example.org.