This Policy is issued by Accresco Investment Management Ltd. References in this Policy to “Accresco” are references to Accresco Investment Management Ltd, any affiliated entities and its subsidiaries. It concerns individuals outside our organisation, including visitors to our websites, customers and suppliers with whom Accresco interacts in one way or the other.
Reference in this Policy to “Personal Data” means any information that identifies, or could reasonably be used to identify, a living individual, either on its own or together with other information.
Collection of Personal Data: Accresco may collect your Personal Data from different sources, namely:
Relevant Personal and Sensitive Personal Data: Accresco may process the following categories of personal data, such as:
Processing your Sensitive Personal Data: Accresco does not seek to collect or otherwise process your personal data except when:
Purposes for which we may process your Personal Data, and legal bases for Processing: Whether we receive your Personal Data directly from you or from a third-party source, Accresco will only process your personal data for the purposes listed below, subject to applicable law:
Accresco may also need to transfer and disclose your personal data to other related companies affiliated to Accresco and/or third parties (including Sub-Processors) involved in your matters, for legitimate business purposes, in accordance with applicable laws. Where Accresco transfer or disclose your personal data, Accresco will do this in accordance with applicable data protection laws and will take appropriate safeguards to ensure its integrity and protection. Accresco shall procure that each Sub-Processor enters into a written agreement subjecting such Sub-Processor to equivalent obligations with respect to Personal Data that are imposed on Accresco under this Policy and under the Act.
Accresco has international customers and business ventures and Accresco may need to transfer your personal data and to other related companies within the group in connection with the purposes set out in this policy. All our data resides on private cloud in Microsoft data centres in the northern Europe.
Accresco has implemented the appropriate physical, technical and organisational security measures which ensures a level of internal security designed to protect your personal data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing of your Personal Data, in accordance with the applicable law. You are responsible for ensuring secure sending of your personal data to Accresco.
Accresco takes reasonable steps designed to ensure that:
Accresco may request you to confirm the accuracy of your personal data from time to time.
Accresco takes reasonable steps designed to limit the collection of personal data to what is directly relevant and necessary to accomplish specific purposes set out in this policy.
Accresco takes reasonable steps to ensure your personal data, subject to any applicable law, are retained for only as long as it is necessary to fulfill the purposes set out in this policy.
Subject to applicable law, you may have a number of rights regarding the processing of your personal data, including:
Accresco may process your personal data to contact you, primarily by email and also by telephone, so that we can provide you with information concerning services that may be of interest, provided that we have first obtained your consent, to the extent required by, in accordance with applicable law. If you do not wish to receive marketing communications from Accresco, you can opt-out at any time by contacting your regular Accresco’s contact or by electronically unsubscribing from emails Accresco have sent you. After you have unsubscribed, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.
If you have any comments, questions or concerns about any of the information in this policy, or any issues relating to the processing of personal data by Accresco, please contact your regular Accresco’s client service contact:
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