Privacy & Cookie Policy 2018-05-18T15:47:20+00:00

PRIVACY STATEMENT

Introduction

This is the privacy policy of Cresco Capital Management (UK) Limited (“CrescoCap”, the “Company”, “we”, “our” or “us”).

We take your privacy seriously and we are committed to protecting personal data that we receive from you. This privacy policy explains our policies and practices regarding the processing of your personal data, including how and why we process personal data and what measures we have implemented to comply with relevant data protection laws and regulations and to keep personal data secure for the duration required. This policy explains your rights under applicable data protection laws and regulations.

This privacy policy is effective as of 18th May 2018. We review our privacy practices on an ongoing basis, and as such we may change this policy from time to time. Please check this policy frequently to ensure that you are familiar with its current content.

About us

Cresco Capital Management (UK) Limited is a company registered in England and Wales (Company No. 09109717) with its registered address at 21 Arlington Street, London, SW1A 1RN.

Cresco Capital Management (UK) Limited is a financial services company authorised and regulated by the Financial Conduct Authority (FCA) (Ref. No. 775842).

The data controller (as defined under EU data protection law) is Cresco Capital Management (UK) Ltd.

Contacting us

If you would like additional information on anything in or related to this privacy policy, or you would like to exercise any rights that you may have in relation to your personal data, please contact us at info@crescocap.com.

Personal data we may process about you

The types of personal data relating to you that we may “process” (such as collect, use and store) depends on your interaction with us. The key types of personal data that we may process are set out below.

(*Note that the legal bases in the table below are required to be specified under EU data protection law, but are not required, or required to be specified, if you are not an EU citizen/do not reside in the EU.)

Personal data that you give us

Activity Types of personal data that we may process Our legal bases* for processing
Your contact with us, such as your interest in our services Name, title, gender

Contact details (personal or business email address, telephone numbers, address)

Company

Position

Information relating to any matter that you want to discuss with us that relates to you as an individual, such as a description of yourself and your requirements

Any other personal data that you may disclose to us in your contact with us, such as in calls or email correspondence

Legitimate interests:

Getting to know clients / colleagues / recruiters / employees / workers / consultants / industry contacts / service providers, whether actual or potential

Growing our business

Managing business communications with our clients and industry contacts

Responding to your communication(s) with us

Your use of our services / our use of your services Name, title, gender

Contact details (personal or business email address, telephone numbers, address)

Company

Position

Investment experience

Financial standing

Information relating to any matter that you want to discuss with us that relates to you as an individual

Information from identification documents

Financial information, such as bank account details and requests relating to invoices

Any other personal data that you may disclose to us during your relationship with us, such as in calls or email correspondence

Information required by us for processing in relation to our dealings with the Financial Conduct Authority (FCA) or other public and statutory authorities

Legitimate interests

Getting to know clients / colleagues / recruiters / employees / workers / consultants / industry contacts / service providers, whether actual or potential

Growing our business

Responding to your communication(s) with us

Contract

Fulfilling our obligations under our contract or other agreement with you

Your interest in employment with us or our clients or third- party consulting arrangement Name, title, gender, date of birth

Results of background checks including references, qualifications, and to the extent permitted by law, criminal background checks (unspent convictions)

Passport, work permit, visa, or other immigration documentation

Contact details (personal, business or educational institution email address, telephone numbers, address)

Curriculum Vitae, including relevant skills and experience

Application reasons

Language capabilities

Special requirements (such as, or relating to, a disability / health issue)

Any other personal data that you may provide to us through the application process, such as views and preferences that you disclose to us in interviews, your responses to questions, and demonstrations of your skills

Legitimate interests

Getting to know employees or potential employees / workers / consultants

Fulfilling our staffing requirements

Ensuring potential recruits of any kind are appropriately qualified for positions at the firm

Consent

On the basis of the consent that you have provided to us to process your personal data in the context of your application which would include in relation to our conducting criminal background and other checks

Legal obligation

We have a legal obligation to verify your right to work lawfully in the UK

Personal data that we may collect through cookies

This website does not use cookies to collect any personal data.

Cookies are small text files stored on your computer or mobile device by your browser which can be used to store certain preferences on a website, track if you have visited that site before and provide data about the way you use a website.

You can limit or block the use of cookies in your browser settings. These settings differ between browsers. If you choose not to allow cookies, the quality of your browsing experience may be reduced.

This website uses the following types of cookie:

Session cookie – stored temporarily in the browser’s memory and used to perform essential site functions and to ensure pages are sent to the browser as quickly and efficiently as possible

If you have any questions about our use of cookies, please email info@crescocap.com.

Other information that we may collect automatically

We may collect the following information relating to our website visitors automatically: domain name, IP address, and type of browser and type of operating system used. We may use this information for internal statistical analysis, such as to see where our website is being used geographically. However, we do not link this information with any personal data.

Personal data from minors

Our services, including our website, are directed solely at adults. We do not collect information from minors. Minors should not provide personal information to us via the website or in any other way.

Why we process your personal data

We collect, store and otherwise process your personal data in order to perform services, rights and obligations according to our contract with you, to comply with our legal obligations, to exercise our legitimate interests, or upon your consent. The following are purposes for which we may process your personal data:

  • To determine your appropriateness for our products and services
  • To process and manage your use of our products and services.
  • To respond to your questions, comments, complaints, or requests.
  • To follow up with you on a job application.
  • To operate and expand our business activities.
  • To further our internal business purposes, such as to perform data analysis, audits, fraud and unlawful activity monitoring, and prevention.
  • To comply with the requirements of the Financial Conduct Authority (FCA), and other regulators, public bodies, statutory authorities, or applicable law.
  • To settle enquiries or complaints, defend legal claims, and support regulatory requests

How we process your personal data

We may process your personal data in the following ways (depending upon your interaction with us):

  1. Collecting your personal data that you provide to us in conversations, emails, or meetings with us.
  2. Recording your personal data, such as through electronic or handwritten notes that we make.
  3. Organising and storing your personal data on our servers, in our case management system, in our electronic HR filing system, in our employees’ email inbox folders, or in hard copy files.
  4. Using your personal data to provide our services to you, and address any preferences, complaints, or comments that you have.
  5. Disclosing your personal data to third parties, where necessary, appropriate and/or as required by law (see section 6 providing more information on this below).

When we collect personal data about you via third parties, we ensure that these parties have asked for your consent before they share your data with us. Subsequently, we always identify ourselves in our first communication to you and the state the purpose for which we require the data.

Also, for regulatory purposes, we reserve the right to obtain information on you from other sources such as credit reference agencies or fraud prevention agencies.

How we protect your personal data

We have implemented security policies and technical measures to protect the personal data that we collect, consistent with applicable privacy and security laws. These security measures are designed to prevent unauthorised access, improper use or disclosure, unauthorised modification, and unlawful destruction or accidental loss of your personal data.

We update and test our personal data privacy and security measures on an ongoing basis. We also provide training to our employees on privacy laws and how to comply with them, and have disciplinary procedures in place that may be imposed on employees if they do not comply with our standards. We ensure that only employees who need to know your personal data to fulfil the purposes of processing that personal data (as described in this privacy policy) have access to it.

With whom we share your personal data

We take your privacy seriously and will not share your personal data with others, except in the following circumstances:

  1. Service providers – we may disclose your personal data to third-party service providers to provide us with services such as website hosting and professional services, including information technology services, payroll services, auditing services, consultancy services, regulatory services, and legal services.
  2. Affiliated entities – we may disclose your personal data to affiliated entities under the same ownership to provide us with information technology, administration and other services, and to protect the operations of those affiliated entities.
  3. Corporate transactions or events – we may disclose your personal data to a third party in connection with a corporate reorganisation, merger, joint venture, sale, transfer, or other disposition of all or any portion of our business or shares.
  4. Legal reasons – we may use or disclose your personal data as we deem necessary or appropriate under applicable laws; to respond to requests from public, governmental and regulatory authorities; to comply with court orders, litigation procedures, and other legal processes; to obtain legal remedies or limit our damages; to protect the operations of our affiliated entities; and to protect the rights, safety, or property of our employees, you, or others.

International transfers of personal data

Some of our service providers are located outside the European Economic Area (EEA). Accordingly, if you are an EU citizen/resident in the EEA, please note that any transfer of your personal data to a non-EEA country will be done in accordance with EU data protection law requirements by using standard contractual clauses that have been approved by the European Commission. Such a transfer may also be necessary in order to perform a contract with you/fulfil your request and/or through obtaining your explicit consent.

Your rights with respect to your personal data

If you are an EU citizen and reside in the EU, or are non-EU national residing in the EU, you may have the following rights with respect to the personal data you provide to us, to the extent permitted by applicable data protection laws:

  1. To withdraw any consent that you have provided to us to process your personal data.
  2. To access or review your personal data held by us.
  3. To have your personal data erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn your consent to, or object to, its processing and there are no other legitimate grounds for processing it or you consider it has been unlawfully processed.
  4. To have the processing of your personal data restricted if you contest its accuracy, its processing is unlawful, we no longer need it but you need it for a legal claim, or you have objected to its processing and await verification of our legitimate grounds for processing it.
  5. To have your personal data transferred to another company under certain circumstances.
  6. To complain to your national data protection regulator if you feel that your personal data has been unlawfully processed.

How long we retain your personal data

We retain your personal data only for as long as is necessary to facilitate our relationship with you, in accordance with our retention policies, and in accordance with applicable laws. We do not collect more personal data than we need to fulfil our purposes stated in this privacy policy, and we will not retain it for longer than is necessary.