Privacy Policy

This Privacy Policy explains how Cognitio Wealth ("we", "us" or "our") collects, uses, stores and protects your personal information.

Cognitio Wealth is committed to protecting your privacy and processing personal information fairly, lawfully and transparently in accordance with the Personal Information Protection Act 2016 (PIPA) of Bermuda, together with any other applicable laws and regulatory requirements.

For the purposes of PIPA, Cognitio Wealth acts as the organisation responsible for determining the purposes and means by which your personal information is processed.

This Privacy Policy applies to our clients, prospective clients, introducers, professional advisers, service providers, website visitors and any individual who provides us with personal information.

We may collect personal information including, but not limited to:

• Name, date of birth and identification details.
• Residential and correspondence addresses.
• Email address and telephone numbers.
• Passport and identification documents.
• Financial information, investment objectives and source of wealth.
• Banking details.
• Tax residency information.
• Employment and business information.
• Information required for anti-money laundering (AML), sanctions screening and Know Your Customer (KYC) obligations.
• Communications between you and us.
• Information voluntarily provided through our website, email correspondence, telephone calls or meetings.

Where necessary to provide our services or comply with legal obligations, we may also collect sensitive personal information, such as information relating to your health, tax status or other information permitted under Bermuda law.

We may collect personal information:

• Directly from you.
• Through our website enquiry or contact forms.
• During client onboarding.
• From financial advisers, intermediaries or introducers acting on your behalf.
• From banks, custodians, fund administrators and investment platforms.
• From publicly available sources.
• From regulatory bodies and identity verification providers.

Our website may also automatically collect limited technical information such as your IP address, browser type and website usage information for security and analytical purposes.

We use your personal information to:

• Provide wealth management, investment advisory and related professional services.
• Carry out identity verification and due diligence.
• Meet our legal and regulatory obligations.
• Prevent fraud, money laundering and financial crime.
• Communicate with you regarding your account.
• Improve our products and services.
• Respond to enquiries.
• Manage our contractual relationship with you.
• Send marketing communications where permitted by law or where you have consented.

Under Bermuda's Personal Information Protection Act 2016 (PIPA), we process personal information where it is necessary:

• To perform a contract with you.
• To comply with legal or regulatory obligations.
• For our legitimate business interests, provided these are not overridden by your rights.
• Where you have provided your consent.
• Where otherwise permitted under Bermuda law.

We do not sell your personal information.

Your information may be shared with:

• Banks and custodians.
• Investment managers.
• Fund administrators.
• Auditors.
• Compliance consultants.
• Legal advisers.
• Accountants.
• Technology providers.
• Regulatory authorities.
• Government agencies where required by law.

All third-party service providers are required to maintain appropriate confidentiality and security standards.

Where personal information is transferred outside Bermuda, we take reasonable steps to ensure appropriate safeguards are in place.

We maintain appropriate technical, organisational and administrative safeguards designed to protect your personal information against unauthorised access, disclosure, alteration or destruction.

Whilst we use commercially reasonable security measures, no transmission over the internet can be guaranteed to be completely secure.

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting and reporting obligations.

Where required under Bermuda regulatory requirements, anti-money laundering legislation or other applicable laws, records may be retained for a minimum of five years or longer where required.

Subject to applicable law, you may have the right to:

• Request access to your personal information.
• Request correction of inaccurate information.
• Request deletion where appropriate.
• Withdraw consent where processing is based upon consent.
• Object to certain processing activities.
• Request that we cease or restrict certain processing where permitted by law.

Requests should be submitted using the contact details below.

We may occasionally send information regarding our products or services which may be of interest to you.

You may opt out of marketing communications at any time by contacting us or by using the unsubscribe facility included in our communications.

Our website may use cookies and similar technologies to improve user experience, enhance website functionality and collect anonymous analytical information.

You may control cookies through your browser settings.

Our website may contain links to third-party websites.

We are not responsible for the privacy practices or content of those websites.

If you have concerns regarding how we process your personal information, please contact us in the first instance.

If your complaint cannot be resolved, you may be entitled to raise the matter with the appropriate Bermuda regulatory authority or any other competent authority having jurisdiction.

We may update this Privacy Policy from time to time to reflect changes in legislation, regulation or our business practices.

The latest version will always be available on our website.

If you have any questions regarding this Privacy Policy or wish to exercise your privacy rights, please contact: