Privacy Policy

Effective December 2nd 2021

This privacy policy provides you with details of how we collect and process your personal data through your use of our site

Who Are we?

Coghlan Capital is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details:
Full name of legal entity: Coghlan Capital LLC
PO Box 224
WV, 25430

If you wish to update your personal information you can do so by emailing us at

Purpose of this Privacy Policy

By using our website and services you consent to the collection, use and transfer of your personal data for processing as described in this privacy policy.

This privacy notice is issued on behalf of Coghlan Capital, which is responsible for protecting your personal data. This notice aims to give you information on how Coghlan Capital collects and processes your personal data through your use of this website ( or our online services.

We will not share nonpublic information about you with third parties outside of Coghlan Capital without your consent, except for the specific purposes described below. This privacy notice describes the information we may gather and the circumstance under which we may share it. Coghlan Capital respects your privacy and is committed to protecting your personal data. This privacy notice will inform you of how we use your personal data and tell you about your privacy rights and how the law protects you.

Our services are not intended for children and we do not knowingly collect data relating to children.

Changes to the Privacy Notice and your duty to inform us of changes

This version of the privacy notice was last updated on December 10th 2021.

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.

The Data we collect

For the purposes of this Privacy Notice, 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 (anonymized data).

We may collect, use, store and transfer different kinds of Personal Data, which we have grouped together as follows:
Identity Data
- Includes title, first name, surname, username

Contact Data
- Includes physical address, mailing address, email address and telephone number

Transaction Data
- Includes details of payments from and to you and details of service purchased by you

Technical Data
- Includes internet protocol (IP) address, login data, browser type and version, timezone and location, browser plug-in type and version, operating system and platform and other technology on the computer or other device you use to access our services.

Profile Data
- Your username, password ,and account settings

Geo-location Data
- Includes information about your geographic location derived from your IP address

We do not collect aggregated data for statistical purposes.

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 hen requested, we may not be able to perform the contract we are trying to enter with you. In this case we may have to cancel the service you have with us but we will notify you if this is the case at the time.

How is your Personal Data collected?

We obtain most personal data directly from you, when you apply for Coghlan Capital’s services, where by mail, email, phone or in person.

In addition to this we automatically collect Technical Data about your equipment, browsing actions, and monitor traffic patterns. We collect this Personal Data by using cookies, server logs and similar technologies. These analytical tools are used by us for internal purposes only and not used to collect or disseminate Personal Data to any third party.

How we use your Personal Data

We will only collect/and/or use your Personal Data as allowed by law. Most commonly we will use your Personal Data under the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or where we require to deliver and improved the service being delivered to you.

- Where we need to comply with a legal or regulatory obligation

- Where you have given your consent (including by your agreement to this Privacy Notice).

We use your Personal Data for the purpose on onboarding you as a new customer, to process and deliver orders, to notify you of changes to our services or notices. The legal basis for these activities is the performance of a contract we have or are entering with you.

Additionally, we use your technical data as they are necessary for our legitimate interests (to study how customers use our services and to help develop them and grow our business).

Automatic Decision Making

We do not employ automatic decision making.

Promotional/Marketing offers

Upon consent to the Privacy Notice, you will receive, or continue to receive, marketing communications from us. We may use your contact data, usage profile and profile data to determine which offers you may receive.

Opting out after giving consent

You can ask us to stop sending you marketing materials at any time by contacting us ( or by clicking the unsubscribe link in any of the emails you are sent.

Where you opt out of receiving marketing communications, this will not apply to other types of communications necessary to provide services, required for business purposes, and/or pursuant to regulatory requirements.


Cookies are small text files which are transferred from our website and stored on your device. We use cookies to help us provide you with a personalised service, and to help make our website and services better for you.

Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services which are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications or services to “remember” who you are and to remember your preferences within our websites, applications or services and which will stay on your computer or device after you close your browser or leave your session in the application or service).

You may optionally refuse or delete cookies. Most web browsers and mobile devices offer settings that permit the user to manage cookies. Please note that if you should elect to refuse of delete cookies you may experience inconvenience in the use of the website. For example, you may need to log in each time you visit the website.

Disclosure of your Personal Data

We do not disclose any Personal Data about customers or former customers to anyone, except as required by law.

International Transfers

If you are located outside of the United States please be aware that Personal Data we collect will be processed and stored in the United States. By using our website and/or services and submitting your Personal Data, you agree to the transfer, storage and/or processing of your Personal Data in the United States. In addition we may use third party service providers (credit card processing, cloud storage etc) based outside the EU.


If you are based within the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:
• the right to be told how we use your information and obtain access to your information;
• the right to have your information rectified or erased or place restrictions on processing your information;
• where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
• the right to object to any decisions based on the automated processing of your personal data, including profiling; and
• the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g. in the UK, the Information Commissioner’s Office).

If you request a copy of your information you may be required to pay a statutory fee.

We will retain your personal information for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with internal policies or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).


Summary - The California Consumer Privacy Act (“CCPA) provides certain rights for California consumers. If you are a consumer residing in California, there are additional terms that apply to you which you can read by clicking here.