LAST UPDATED: 9 May 2022
Cocoa is committed to protecting your personal data. We want you to be familiar with how we collect, process, use and disclose your personal data. This notice (the “Privacy Policy”) describes our practices in connection with any personal data we collect from you, or that you provide to us.
By visiting www.cocoa.vc or making use of any of the services listed in the “Our Services” section below, you are accepting and consenting to this Privacy Policy.
1 – Important information
References to the terms “we”, “us” and “our” in this Privacy Policy are to COCOA I ADVISOR LIMITED (“Cocoa”), a private limited company incorporated in England and Wales with registered number 13635080. Cocoa Investment Advisor Limited is an Appointed Representative of The Fund Incubator Limited which is authorised and regulated by the Financial Conduct Authority – FRN 208716.
It is important that you read this Privacy Policy together with any other privacy policy update or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you.
This Privacy Policy may be updated from time to time. The “Last Updated” section at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes that we make to this Privacy Policy will be published on the website and is effective from the date specified at the top of the revised privacy policy. If we make any significant changes, we will take additional steps to inform you of these. Your use of our services following any such changes indicates that you have accepted them.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
2 – Our services
Cocoa is an early stage investment firm. In order to provide our services, we may collect personal data through a number of sources. Please see the ‘How is your personal data collected’ section for more information.
Where we need to collect personal data by law, or under the terms of a contract we have (or are negotiating) with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of the services you have with us, but we will notify you if this is the case at the time.
Our website and services are intended for adults only. We do not knowingly collect, use, process, or disclose personal data relating to children.
3 – How we process and use your data
“Personal data” is information that identifies you as an individual or relates to an identifiable individual.
We will only use your personal data when the law allows us to and we will not sell, trade or otherwise deal with your personal data in any way that contravenes this Privacy Policy (as may be updated from time to time).
We have set out below a description of the ways we plan to use your personal data, and on which legal basis we do so. Where we rely on our legitimate interests as a legal basis for processing, we have identified the nature of those legitimate interests.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Such may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Unless we request it, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., national insurance numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise.
4 – How is your personal data collected?
We use different methods to collect data from and about you including through:
Change of purpose
We will only use your personal data for the purposes for which we collected 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 using the contact details provided in the “Contact Details” section.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5 – Disclosures of your personal data
Cocoa will only disclose personal data in accordance with this Privacy Policy (as may be updated from time to time).
We may disclose personal data to third party service providers (including IT system administrators, professional advisers, providers of finance, HM Revenue & Customs, regulators and other authorities) to facilitate services they provide to us. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. In such circumstances, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6 – International transfers
Cocoa is based in the UK and is subject to UK GDPR and the Data Protection Act 2018. If we transfer personal data to our group or affiliate entities or to third parties outside of the UK, we will ensure your personal data is protected, for example by ensuring one or more of the following safeguards is implemented:
Please contact us using the contact details provided in the “Contact Details” section if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7 – Data security
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 other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We cannot guarantee the security of any personal data that you disclose online, for example when it is sent by email. You accept the inherent security risks of providing information online over the internet and will not hold Cocoa responsible for any breach of security unless this is due to Cocoa ’s negligence or willful default.
8 – Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You can request details of retention periods for specific categories of your personal data by contacting us using the details provided in the “Contact Details” section.
9 – Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Such rights include your right to:
If you wish to exercise any of the rights set out above, please contact us using the details provided in the “Contact Details” section.
We give you choices regarding our use and disclosure of your personal data for marketing purposes. You may opt-out from receiving electronic communications from us by following the ‘Unsubscribe’ link provided at the footer of any marketing materials that you may have received from Cocoa by email or by contacting us using the details provided in the “Contact Details” section.
Complaints
You have the right to lodge a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so we would encourage you to contact us in the first instance.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10 – Contact Details
If you have any questions about this Privacy Policy, please contact our data privacy representative using the details set out below.
There may be instances where will request additional information in order to identify you and assess your request. If you do not provide the requested information and, as a result we are not in a position to identify you, we may refuse to action your request.
We will not charge you for such communications or actions we take, unless:
We may be contacted at: Cocoa I Advisor Limited, Connect House 133-137 Alexandra Road, Wimbledon, London, United Kingdom, SW19 7JY
Email: hello@cocoa.vc