Privacy Policy

Cox Capital Ltd (“Company”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This policy explains how we collect and process your personal data when you visit our website, create an account, subscribe to our services, take our courses, or take part in our member community — together, the “Platform” at mcoxcapital.com. The Platform is not intended for children and we do not knowingly collect data relating to children.

1. WHO WE ARE AND HOW TO CONTACT US

Cox Capital Ltd is the controller and responsible for your personal data. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this policy, including any request to exercise your legal rights, please contact the DPO using the details below.

Contact details

• Full name of legal entity: Cox Capital Ltd (company number 12772817);
• Name and title of DPO: Matthew Cox, CEO;
• Email address: info@mcoxcapital.com;
• Registered office: 7 Church Plain, Great Yarmouth, Norfolk, NR30 1PL; and
• Trading address: 24/25 The Shard, 32 London Bridge Street, London, SE1 9SG.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 please contact us in the first instance.

Changes to this policy and your duty to inform us of changes

We keep this privacy policy under regular review; this version was last updated on the date shown above. It is important that the personal data we hold about you is accurate and current, so please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Platform 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. We encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you, which we have grouped as follows:

• Identity Data includes first name, last name, and username or similar identifier;
• Contact Data includes email address and postal address;
• Account Data includes your login credentials (stored securely), your subscription, and your access permissions;
• Financial and Transaction Data includes details of your subscriptions and the payments to and from you. Card payments are handled by our payment provider (Stripe) — we do not store your full card details;
• Community Data includes the profile, posts and contributions you make in our member community;
• Usage Data includes information about how you use the Platform, its courses and features, including questions you ask our knowledge tools;
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform; and
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law, as it will not directly or indirectly reveal your identity. If we combine Aggregated Data with your personal data so that it can identify you, we treat the combined data as personal data used in accordance with this policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have 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 give you access to the Platform or your subscription. In that case we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect data from and about you, including through:

• Direct interactions — you give us your Identity, Contact and Account Data when you create an account, subscribe to our services, buy a course, request marketing, enter a survey, or contact us or give us feedback;
• Automated technologies — as you interact with the Platform, we automatically collect Technical and Usage Data about your equipment and browsing actions using cookies and similar technologies (please see our Cookie Policy); and
• Third parties — we may receive data about you from our payment provider (transaction confirmations) and our member-community platform.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
• Where we need to comply with a legal obligation.

Purposes for which we will use your personal data

• To register you as a new user and manage your account;
• To provide the Platform to you, including access to your courses and the member community;
• To take and manage your subscription and other payments;
• To send you service messages, such as account verification, receipts, and renewal and account notices;
• To provide support and respond to your enquiries;
• To improve the Platform, our courses, services and customer relationships; and
• To send you marketing where you have requested it or purchased from us and have not opted out.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on.

Marketing and opting out

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what may be of interest to you and to decide which services and offers may be relevant. You can ask us to stop sending you marketing at any time by following the opt-out link in any marketing message or by contacting us. This will not apply to service messages that relate to your account or subscription. We will get your express opt-in consent before we share your personal data with any third party for their own marketing.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with the parties set out below for the purposes above:

• Service providers who help us deliver the Platform to you — including our payment provider (Stripe), our member-community platform (Circle), and our hosting and email providers — who process your data only on our instructions;
• Professional advisers, regulators and law-enforcement bodies where we are required to share it by law; and
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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

Some of our external third parties are based outside the UK, so their processing of your personal data may involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
• Where we use certain service providers, we use specific contracts approved for use in the UK (such as the UK International Data Transfer Agreement or Addendum) which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used 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 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.

8. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data — see Your Legal Rights below. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:

• Request access to your personal data (a “data subject access request”), enabling you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you, enabling you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide.
• Request erasure of your personal data where there is no good reason for us continuing to process it. We may not always be able to comply for specific legal reasons, which will be notified to you where applicable.
• Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object. You also have the right to object where we process your personal data for direct marketing purposes.
• Request restriction of processing of your personal data, enabling you to ask us to suspend the processing of your personal data — for example, to establish its accuracy, or where our use is unlawful but you do not want us to erase it.
• Request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format. This right only applies to automated information which you initially consented to us using, or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at info@mcoxcapital.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we could refuse to comply with your request in these circumstances.

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests, in which case we will notify you and keep you updated.