Privacy Notice

About this notice

This Privacy Notice ("Notice") will apply to any personal information Cohen Brothers Management Limited (together with its respective subsidiaries and affiliates, "Cohen Brothers" or "us") collects or otherwise receives about its clients, investors and other third parties ("you"), including in connection with its business dealings, when you access our website 'www.cohenbrothers.eu’ ("Website") or otherwise engage with us.

Cohen Brothers is committed to ensuring that information which is provided to us, or otherwise obtained by us, from which you can be identified or that reasonably relates to you ("Personal Information") is kept safe and handled in compliance with this Notice and the "Data Protection Legislation" (meaning any law applicable from time to time relating to the processing of Personal Information, including without limitation, the Data Protection Act 2018, General Data Protection Regulation (EU) 2016/679, and the Privacy and Electronic Communications (EC Directive) Regulations 2003).

By using and/or contacting Cohen Brothers through the Website (or otherwise engaging with us), you acknowledge that Cohen Brothers may collect, use and transfer your Personal Information as set out in this Notice. Cohen Brothers reserves the right to change this Notice from time to time and you should therefore check this page frequently to ensure that you are happy with any changes.

Who we are

Please refer to our disclaimer.

For the purpose of the Data Protection Legislation, we are deemed to be a "data controller" in respect of any Personal Information that you provide to us or we otherwise obtain about you.

The Personal Information we collect and use

 

Cohen Brothers may, via the Website and in connection with its business dealings (including potential business opportunities), collect certain Personal Information about you. Examples of Personal Information collected may include your name, position, work e-mail address and a telephone number. We will not collect any Personal Information from you that we do not need.

How we use your Personal Information

Cohen Brothers will collect and hold Personal Information for use in connection with:

  • our legitimate business interests;

  • conducting our financial services business and performing internal business processes;

  • providing the services you (or another individual on your behalf) have requested and to provide you with information relating to the provision of such services;

  • continually improving our Website and the services that we provide; and

  • complying with our legal obligations.

We will not use or disclose your Personal Information for any purpose other than those described above without your consent, unless required or authorised by law.

 

Who we share your Personal Information with

We may share your Personal Information internally with any member of the Cohen Brothers group or our tied agents. We will not share your details with whoever else, unless we have your explicit consent or it is necessary for, (i) the performance or provision of the services you have requested; (ii) us to comply with our legal obligations; or (iii) our legitimate business interests.

This will include Cohen Brothers' IT providers, who have the capacity to access data held on our systems, and certain third party providers used by Cohen Brothers for offshore data storage services. Contractual safeguards are in place with third parties who may have access to your Personal Information to ensure that your information is kept confidential and is handled in accordance with this Notice.

We may also share the Personal Information of investors with our clients, including clients which are located outside of the EEA, in order to allow us to fulfil our obligations under certain client mandates. Investor Personal Information will only be shared in this way where, (i) there has been a clear dialogue between the relevant investor and the Cohen Brothers relationship manager regarding the nature of the Personal Information which Cohen Brothers intends to transfer and the identity of the client which is the intended recipient; and (ii) appropriate obligations have been imposed on the client with respect to maintaining the security and confidentiality of the Personal Information.

How long your Personal Information will be kept

 

The Personal Information that Cohen Brothers collects or you otherwise provide to us will be retained for only as long as is necessary for the purpose for which it was collected. When we no longer need it, we will securely delete or anonymise your Personal Information unless we are required to retain a copy under applicable law, including any regulations imposed from time to time by our regulators.

Recruitment

This section describes how Cohen Brothers collects and uses Personal Information about you during the application and recruitment process.

  • The Personal Information we hold about you

We may collect store and use the following categories of Personal Information about you:

Information relevant to our recruitment decision, including CVs, application forms, interview notes, results of pre-employment checks, references, criminal record checks;

Information relating to your right to work: including passport information, visa details, immigration permissions, travel information; and

Information relating to reasonable adjustments which may be required to accommodate a disability.

We collect this Personal Information either directly from you or from third parties including employment agencies, former employers, other referees, qualifications bodies, or background check agencies or publicly available sources e.g. LinkedIn.

 

  • How we use your Personal Information

We process your Personal Information for the following purposes:

recruiting employees who have the appropriate skills, qualification and experience for each role;

ensuring employees have the right to work in the relevant jurisdiction; and

complying with our duty to make reasonable adjustments.

We process your Personal Information because it is necessary for our legitimate interests of operating our business efficiently, maintaining standards of service to our clients, or because it is necessary for us to comply with our legal obligations.

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your personal information changes during the recruitment process.

 

  • Automated means

We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

 

  • Who we share your information with

We share your Personal Information with third party service providers who assist with our recruitment process. These providers include online recruitment services.

 

  • How long we keep personal information

We retain Personal Information from the recruitment process for a period of ten years post employment or entering in an agent agreement.

Storage and transfer of your Personal Information
 

The Personal Information you provide to us will be transferred to and stored on our servers and we take all steps reasonably necessary to protect your Personal Information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

In processing your Personal Information it may be transferred outside of the European Economic Area ("EEA") and made available on a group wide basis where it is relevant to the group’s business activities. Therefore, additional steps have been taken to ensure your Personal Information will be treated securely and in accordance with this Notice and the Data Protection Legislation when it is processed in, or otherwise accessed from, a location outside the EEA. This means that Cohen Brothers will only transfer your Personal Information to third parties outside the EEA if that third party, (a) is situated in a country that has been confirmed by the European Commission to provide adequate protection to Personal Information; (b) has agreed (by way of written contract incorporating the "model clauses" as approved by the European Commission or by some other form of data transfer mechanism approved by the European Commission) to provide all protections to your Personal Information as required by the Data Protection Legislation; or (c) we have your explicit consent to do so.

By submitting your Personal Information to Cohen Brothers, you acknowledge this transfer, storing or processing of your Personal Information.

 

What are your rights as a data subject?

 

You are entitled to know some details about the Personal Information Cohen Brothers holds about you and how that information is processed. If you would like to request this please contact us via the details set out at the end of this Notice.

You are also able to access and update the Personal Information we hold about you at any time and ask us to, (a) make changes to ensure that any Personal Information we hold about you is accurate, complete and up-to-date ; (b) erase or stop processing any Personal Information we hold about you where there is no longer a legal ground for us to hold it; or (c) in some cases, transfer any information

we hold about you to a third party. If you wish to exercise any of these rights, please contact us via the details set out at the end of this Notice.

 

Keeping your Personal Information secure

 

We have appropriate security measures in place to prevent your Personal Information from being accidentally lost, used, or accessed in an unauthorised way, and to ensure that your Personal Information is handled in accordance with this Notice.

Whilst we strive to protect your Personal Information as outlined above, we cannot ensure the security of any Personal Information that you transmit to us over the internet (including via our Website) and you do so at your own risk. However, once we receive your transmission, we take steps to ensure that your Personal Information is secure on our systems.

Cookies

We use cookies on our Website to distinguish you from other users. Cookies are small files which are stored on your device when you visit a website so that it can remember something about you at a later time. Cookies cannot be used to identify you personally and are not harmful to your device.

We are constantly improving our Website based on information recorded by cookies regarding how visitors interact with our Website. These cookies record anonymous information about visits and clicks on each web page and measure any errors that occur whilst you are using our Website.

The Website uses persistent cookies. Persistent cookies are stored on your device in between browser sessions and allow your preferences or actions across a website site to be remembered.

If you would like to restrict or block the cookies which are set by us, or any other website, you can do this through your browser settings. Please be aware that restricting cookies may impact on the functionality of the Website. You can find out more information about the specific cookies we use and the purposes for which we use them in the table at the end of this Notice. You can find more information about cookies generally here: http://www.allaboutcookies.org/.

Linked sites

Our Website may, from time to time, contain links to and from third party websites. Links are provided only as a convenience. The inclusion of any link is not and does not imply any affiliation, endorsement, approval, verification or monitoring by Cohen Brothers of any information on the third party website. Cohen Brothers is not responsible for the content of any site linked or linking to our Website. Your linking to any other websites is at your own risk, and you should review the privacy notices of these websites before you submit any Personal Information to them.

Questions and complaints

If you have a query or complaint regarding the way in which your Personal Information is being handled by us, please contact us in the first instance via email at client_complaint_officer@cohenbrothers.eu and we will investigate the matter. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner for Ireland regarding such issues.

Changes to this notice

We may change our Privacy Notice from time to time and any changes we make will be posted on our Website and, where appropriate, notified to you when you next access our Website. It is your responsibility to ensure that you are aware of the latest version of this Notice and by continuing to use our Website or otherwise engage with us, you will be deemed to have accepted any revised terms.

Contact us

Questions, comments and requests regarding this Notice are welcomed and should be addressed via email to contact@cohenbrothers.eu

GENERAL NOTICE

Acceptance of terms

By using this Website, you are accepting the practices and consenting to the terms herein and below. If you do not consent to all of the terms below, then you should immediately discontinue your use of and access to this website.

Ownership and Trademarks

“Cohen Brothers” is the trade name for Cohen Brothers Management Limited, its subsidiaries and affiliates. The trademarks, logos and service marks used on the Website are registered trademarks of Cohen Brothers. Nothing on the Website shall be interpreted as granting any licence or right to use any image, trademark, logo or service mark on the Website. Cohen Brothers reserves all rights with respect to copyright and trademark ownership of all material on the Website, and will enforce such rights to the full extent by permissible by law.