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PRIVACY POLICY



(Last Revised: May, 2020)
 
Client Privacy Policy Summary


This privacy statement applies to Absolute Strategy Research Ltd (ASR) with
registered office address at Salisbury House, Station Road, Cambridge, CB1 2LA
and the entities we own or control (“ASR”, “we”, “us” or “our”).



ASR is committed to protecting your information by handling it responsibly and
safeguarding it using appropriate technical, administrative, and physical
security measures.



The privacy notice below explains what information we gather about you, what we
use it for and who we share it with. It also sets out your rights and who you
can contact for more information or queries.



Information About You That We Process


We may process information about you that: (i) you provide to us, (ii) that we
obtain from third parties or (iii) that is publicly available. This information
may include your name, gender and contact details. It may also include
‘sensitive’ or ‘special categories’ of personal data, such as dietary
requirements or mobility information.



How We Use Information About You


We collect and process information about you and/or your business to enable us

 * provide our services to you

 * to enable us to provide you with information that we think may be of interest
   to you

 * to meet our legal or regulatory obligations



When we send you information we think you might be interested in, you have the
right to unsubscribe at any time by contacting us as set out here, or by
following the unsubscribe instructions in our communications.



Sharing and Transferring Your Information


We may share information about you across the ASR Network, and with some third
parties. For more information see Section 5.

We may transfer some information about you to countries outside the European
Economic Area that have less stringent data protection laws. When we do this, we
will make sure your information remains adequately protected.



Your Rights


Your rights under data protection laws include the right to: 1) request copies
of your data; 2) request correction of your data; 3) request erasure of your
data; 4) object to us processing your data; and 5) ask us to restrict the
processing. For more information about your privacy rights click here.



Contact Points


If you have any questions or comments about privacy issues or wish to exercise
any of the rights set out above, please write to Data Protection Officer, ASR,
1-2 Royal Exchange Buildings, London, EC3V 3LF, or email
 DPO@absolute-strategy.com.



 

ASR Privacy Policy


Contents
1. Who this privacy statement applies to and what it covers 
2. What personal data we collect 
3. How we use your personal data 
4. The legal grounds we use for processing personal data 
5. Sharing your personal data 
6. Transferring your personal data outside the UK 
7. Protecting your personal data 
8. How long we keep your personal data for 
9. Your rights 
10. Sending you marketing information 
11. Right to complain 
12. Changes to this privacy statement

 

In this Statement:
“Data Protection Legislation” means the EU General Data Protection Regulation
2016/679; together with all other applicable legislation relating to privacy or
data protection (including the UK Data Protection Act 2018).



“Process” means any operation performed on information about you, including to
collect, record, organise, structure, store, alter, use, transfer, destroy or
otherwise make available.

 
1. Who this privacy statement applies to and what it covers
This privacy statement applies to ASR with registered office address at
Salisbury House, Station Road, Cambridge, CB1 2LA and the entities we own or
control (“ASR”, “we”, “us” or “our”)



We are committed to protecting your privacy and handling your information openly
and transparently.



This privacy statement explains how we will collect, handle, store and protect
information about you when:

 * providing services to you;

 * you use our Website; or

 * performing any other activities that form part of the operation of our
   business.



When we refer to “our Website” or “this Website”, we mean webpages with a URL
starting www.absolute-strategy.com

In this privacy statement, your information is sometimes called “personal data”.
We may also refer to “processing” your data, which includes handling,
collecting, protecting and storing it.

 
2. What personal data we collect
We may collect, record and use your personal data in physical and electronic
form, and will hold, use and otherwise process that data in line with the Data
Protection Legislation and as set out in this statement.



When we provide services to you and perform due diligence checks in connection
with our services (or discuss possible services we might provide), we will
process personal data about you. We may also collect personal data from you when
you use this Website.



We may process your data because:

 * you give it to us (for example, in a form on our Website or through access to
   our Research Library);

 * we obtain it through a third- party service providers that we use to help
   operate our business); or

 * it is publicly available.

 

We may process personal data from you because we observe or infer that data
about you from the way you interact with us or others. For example, to improve
your experience of this Website and to make sure that it is working effectively.
For example, we (or our service providers) may use cookies (small text files
stored in a user’s browser) or Web beacons to collect personal data.



The personal data we process may include your:

 * name, gender;

 * contact information, such as address, email, and mobile phone number;

 * country of residence;

 * employment and education details (for example, the organisation you work for,
   your job title and your education details);

 * applications and services that we provide (including with third parties);

 * IP address, browser type and language, your access times;

 * information in any complaints you may make;

 * details of how you use our products and services; and

 * details of how you like to interact with us, and other similar information
   relevant to our relationship.

 

The personal data we collect may also include so called ‘sensitive’ or ‘special
categories’ of personal data, such as details about your:

 * dietary requirements (for example, when ASR would like to provide you with
   lunch during a meeting); and

 * health (for example, so that we can make it easy for you to access our
   buildings, products and services);



We will typically seek separate permission from you in writing to process these
special categories of personal data.



If you choose not to provide, or object to us processing, the information we
collect (see Section 9 ), we may not be able to process your instructions or
continue to provide some or all of our services to you or our client.

 
3. How we use your personal data
We process information about you and/or your business to enable us and other
members of ASR to provide our services to you, and to meet our legal or
regulatory obligations.



Use of personal data for other activities that form part of the operation of our
business.



We may also use your personal data in connection with:

 * legal or regulatory requirements;

 * requests and communications from competent authorities;

 * client account opening and other administrative tasks;

 * relationship management, which may involve:
   
   * sending you thought leadership or details of our products and services;
   
   * contacting you for feedback on services;
   
   * sending you event invitations; and
   
   *  other marketing or research purposes;

 * business development, which may involve:
   
   * the use of third-party data sources to help us verify and improve the
     information we hold about key business relationships with individuals;
   
   * the use of data through our Client Relationship Management platform by
     Consultants engaged by ASR industry surveys:
   
   * access to personal data related to survey responses will be restricted to
     the ASR individual(s) responsible for the survey.
   
   * Any personal data will be redacted from reports or analysis prepared by the
     Survey Team.
   
   * Individual personal response will expressly not be accessible by the ASR
     sales team

 * services we receive from our professional advisors, such as lawyers,
   accountants and consultants; or

 * protecting our rights and those of our clients.



Use of personal data collected via our Website

In addition to the above, we may also use your personal data collected via our
Website:

 * to manage and improve our Website;

 * to tailor the content of our Website to give you a more personalised
   experience;

 * to draw your attention to information about our products and services that
   may be of interest to you; or

 * to manage and respond to any request you submit through our Website.

 
4. The legal grounds we use for processing personal data
We are required by law to set out in this privacy statement the legal grounds on
which we rely in order to process your personal data. We rely on one or more of
the following lawful grounds:



 * you have explicitly agreed to us processing your information for a specific
   reason;

 * the processing is necessary to perform the agreement we have with you or to
   take steps to enter into an agreement with you;

 * the processing is necessary for compliance with a legal obligation we have
   such as keeping records for tax purposes or providing information to a public
   body or law enforcement agency; or

 * the processing is necessary for the purposes of a legitimate interest pursued
   by us or a third party, which might be:



 * to provide our services to you and other third parties and ensure that our
   client engagements are well-managed;

 * to protect our business interests; o to ensure that complaints are
   investigated;

 * to evaluate, develop or improve our services or products; or  

 * to keep you informed about relevant products and services and provide you
   with information, unless you have indicated at any time that you do not wish
   us to do so.

 

To the extent that we process any special categories of data relating to you for
any of the purposes outlined above, we will do so because:

 * you have given us your explicit consent to process that data;

 * we are required by law to process that data in order to ensure we meet our
   ‘know your client’ and ‘anti-money laundering’ obligations (or other legal
   obligations imposed on us);

 * the processing is necessary to carry out our obligations under employment,
   social security or social protection law;

 * the processing is necessary for the establishment, exercise or defence of
   legal claims; or

 * you have made the data manifestly public.

 * Please note that in certain circumstances it may be still lawful for us to
   continue processing your information even where you have withdrawn your
   consent, if one of the other legal bases described above is applicable.

 
5. Sharing Your Personal Data


In connection with any of the purposes outlined in the “How we use your personal
data?” section 3 above, we may disclose details about you to:

 * other members of ASR or third parties that provide services or online
   platforms to us;

 * competent authorities (including courts and authorities regulating us and
   other members of the ASR Network);

 * your employer and/or its advisers, or your advisers;

 * anyone to whom we may transfer our rights and/or obligations under the Terms;

 * any other person or organisation after a restructure, sale or acquisition of
   any member of the ASR, as long as they use your information for the same
   purposes we did;

 
6. Transferring Your Personal Data Outside the UK


Information we hold about you may be transferred to other countries (which may
include countries outside the European Economic Area (“EEA”)):

 * where we do business;

 * which are linked to your engagement with us;

 * from which you regularly receive or transmit information; or • where our
   third parties conduct their activities.



These countries may have less stringent privacy laws than we do, so any
information they hold can become subject to their laws and disclosure
requirements, including disclosure to governmental bodies, regulatory agencies
and private persons. In addition, a number of countries have agreements under
which information is exchanged with other countries for law enforcement, tax and
other purposes.



When we, or our permitted third parties, transfer your personal data outside the
EEA, we will impose contractual obligations on the recipients of that data to
protect your personal data to the standard required in the EEA. We or they may
also require the recipient to subscribe to international frameworks intended to
enable secure data sharing.



We may also transfer your personal data when:

 * the transfer is to a country deemed to provide adequate protection of your
   personal data by the European Commission; or

 * where you have consented to the transfer.



If we transfer your personal data outside the EEA in other circumstances (for
example, because we have to by law), we will make sure it remains adequately
protected.



We may share non-personal, anonymised and aggregated information with third
parties for several purposes, including data analytics, research, submissions,
thought leadership and promotional activity.

 
7. Protecting Your Personal Data


We use a range of measures to ensure we keep your personal data secure, accurate
and up to date. These include:

 * education and training to relevant staff to ensure they are aware of our
   privacy obligations when handling personal data;

 * administrative and technical controls to restrict access to personal data to
   a ‘need to know’ basis;

 * technological security measures, including fire walls, encryption and anti-
   virus software; and

 * physical security measures, such as security passes to access our premises.



The transmission of data over the internet (including by e-mail) is never
completely secure. Whilst we use appropriate measures to try to protect personal
data, we cannot guarantee the security of data transmitted to us or by us.

 
8. How long we keep your personal data for
We seek to ensure that we only keep your personal data for the longest of:

 * the period necessary for the relevant activity or services;

 * any retention period that is required by law; or

 * the period in which litigation or investigations might arise in respect of
   the services.

 
9. Your rights
You have various rights in relation to your personal data. In particular, you
have a right to:



 * obtain confirmation that we are processing your personal data and request a
   copy of the personal data we hold about you;

 * be informed about the processing of your personal data (i.e. for what
   purposes, what types, to what recipients it is disclosed, storage periods,
   any third party sources from where it was obtained, confirmation of whether
   we undertake automated decision-making, including profiling, and the logic,
   significance and envisaged consequences);

 * ask that we update the personal data we hold about you, or correct such
   personal data that you think is incorrect or incomplete;

 * ask that we delete personal data that we hold about you, or restrict the way
   in which we use such personal data; withdraw consent to our processing of
   your personal data (to the extent such processing is based on previously
   obtained consent);

 * receive a copy of the personal data concerning you, which you have provided
   to us, in a structured, commonly used and machine-readable format and to
   transmit such personal data to another party (to the extent the processing is
   based on consent or a contract);

 * ask us to stop or start sending you marketing messages at any time by using
   the contact details in section 11 below; and

 * object to our processing of your personal data.



If you would like to access or see a copy of your personal data, you must ask us
in writing. We will endeavour to respond within a reasonable period, and in any
event within one month in line with Data Protection Legislation. We will comply
with our legal obligations as regards your rights as a data subject.



To help us ensure that your information is up to date, let us know if any of
your personal details change using the contact details set out in section 11.



You may also use the contact details in section 11 if you wish to make a
complaint relating to your privacy.

 
10. Sending you marketing information
We and other members of ASR may use your information from time to time to inform
you by letter, telephone, email and other electronic methods about products and
services (including those of third parties) that may be of interest to you.



You may, at any time, ask us and/or other members of ASR not to send marketing
information to you by following the unsubscribe instructions in communications
from us, or contacting us in the way described in section 11 below.

 
11. Right to Complain


If you wish to raise a complaint about how we are using your information,
exercise any of the rights set out above, or if you have any questions or
comments about privacy issues, you can contact us by:



 * writing to Data Protection Officer, Absolute Strategy Research at 1-2 Royal
   Exchange Buildings, London EC3V 3LF; or

 * sending an email to DPO@absolute-strategy.com



You can also complain to the Information Commissioner’s Office, which regulates
and supervises the use of personal data in the UK, on 0303 123 1113. If you are
not based in the UK, you have a right to complain to the EU Data Protection
Authority (“DPA”) in your jurisdiction.

 
12. Changes to this Privacy Statement


We may modify or amend this privacy statement from time to time. When we make
changes to this privacy statement, we will amend the revision date at the top of
this page. The modified or amended privacy statement will apply from that date.
We encourage you to review this statement periodically to remain informed about
how we are protecting your information.



Absolute Strategy Research is a limited liability company registered in England
and Wales with registered number 05727405 and its regisered office at Salisbury
House, Station Road, Cambridge, CB1 2LA, United Kingdom.




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