Resolute respects your privacy and is committed to protecting your personal data, as well as in general keeping all information collected confidential.
We will not lend or sell your information to third parties.
Resolute Asset Management LLP
4th Floor, Alpha House
24A Lime Street
London EC3M 7HS
As Resolute has fewer than 250 employees, is not a public authority and does not have core activities consisting of large scale processing of special categories of data or requiring large scale, systematic monitoring of individuals we are not legally obligated to appoint a Data Protection Officer, however, we do have a Data Governance Officer, responsible for handling all data protection and privacy related issues. Her details are as follows:
+44(0) 20 77337 2230
All client information is confidential. It will remain so.
The General Data Protection Regulation (GDPR) and other laws relating to data protection and data privacy apply to personal information. This is primarily information about our employees and potential employees. There will also be some personal data in client information we will collect from time to time. Our policy is to treat all personal data to the same high standard as follows:
Personal data, or personal information, 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 will only use your personal data when the law allows us to.
We may collect, use, store and transfer different kinds of personal data about you on the basis that it is in our legitimate interests to do so in order to carry out our business (and your interests and fundamental rights do not override those interests), or to perform a contract with you, or to comply with legal or regulatory obligations, for example in order to comply with KYC/AML checks. We will collect personal information including identity data, contact data, financial data and technical data.
We may sometimes collect information relating to your health (this is known as a Special Category of Personal Data) where this is necessary to help us provide a service to you (for example if you need particular access assistance), or for insurance purposes, or in order to protect your vital interests, such as keeping on record emergency contact details. By submitting such data to us voluntarily, you will be consenting to us using that data for the purpose of responding to and complying with your request, or for the purpose of notifying your emergency contact in the case of an emergency.
We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, 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.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you), in which case we may use this information indefinitely without further notice to you.
If you are or were a Resolute employee or client, we will keep most of your information for the duration of your relationship with us and up to 7 years after such relationship ends, solely to comply with legal requirements such as tax records. Where required by a specific law or regulation, we may keep the specified information for the legally required period.
Our data is also managed by external providers such as internet companies and software companies. We share data only as far as legally permitted to do so and only as strictly necessary. Within Resolute your information is processed and accessed only by specific individuals who provide HR, IT and system administration services and also undertake leadership reporting, as well as the partners and other senior members of Resolute. External third parties may include:
We require all our employees and third parties to respect the security of all 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.
Your personal information may need to be shared with our service providers, which may involve transferring it to countries outside the European Economic Area (EEA). Where we do so, we will ensure that we do this in accordance with current data protection laws by only transferring it to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.
You have certain rights under data protection laws in respect of the personal data we hold relating to you. You are entitled to a copy of the information we hold about you in a portable format or otherwise, to request access to, correction, erasure, or restriction of processing to the personal information we hold about you, and to object to processing or automated decision making. You also have the right to withdraw your consent, where you have given this. Please note that the application of these rights vary according to the legal basis used to process your data. In certain circumstances we are required to retain copies of information we hold about you by other regulations. In this instance we will not be able to erase or modify your data.
Please see the Definitions below for more information on your rights; details can also be found on the ICO’s Website. If you wish to exercise any of the rights set out above, please contact our Data Governance Officer by calling us on +44 (0) 20 7337 2230 or emailing us at firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we reserve the right to charge a reasonable fee if your request is clearly repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
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.
You have the right to make a complaint about the way in which we handle your personal data 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 please contact us in the first instance.
We ensure all our third party providers of services or data processing have 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.
It is important that the personal data we hold about you is accurate and current. We would be grateful if you would 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.
You have the right to: