The Resolution Life Group recognises the importance of protecting your personal information and is committed to protecting and respecting your privacy.
This privacy notice will inform you about how we look after your personal data. It also describes our practices around cookies and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
1. Important information and who we are
Who are we?
Resolution Life Group Holdings Ltd. (a Bermuda limited company with registration number 52575) and its respective subsidiaries (the “Resolution Life Group”, “we” or “us”) collect and use certain personal data. For the purposes of data protection law, we are a controller in respect of your personal data. We are responsible for ensuring that we use your personal data in compliance with data protection laws, including but not limited to:
- the EU General Data Protection Regulation 2016/679 (“EU GDPR”); and
- the EU GDPR as incorporated into the laws of the UK (“UK GDPR”) as applicable (together, “GDPR”).
Purpose of this privacy notice
We are committed to keeping all your personal data secure. This privacy notice governs the handling of personal data by the Resolution Life Group in the course of carrying on commercial activities. It:
- sets out information on how the Resolution Life Group collects and processes your personal data, including any data you may provide through filling in forms on the Resolution Life Group Website or by corresponding with us by phone, email or otherwise; and
- describes our general privacy practices that apply to personal information we collect, use and share about clients, business partners and other individuals, within our business.
Our site is not intended for children and we do not knowingly collect data relating to children.
Please take the time to read and understand this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Key terms used in this privacy notice
We use the following definitions in this privacy notice:
| Cookie | means a small text file that includes a small quantity of information sent to the browser of Users, by a web server, and stored on the hard disk drive of a computer for purposes of archiving and collecting navigation data for statistical analysis purposes, and offering Users services related to their interests or location |
| Data concerning health | means personal data related to the physical or mental health of a natural person, including the provision of health care services, which reveal information about his or her health status |
| Personal health | means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, the Resolution Life Group (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of the Resolution Life Group or any other person in respect of an individual. It does not include data where the identity has been removed (anonymous data) |
| Privacy notice | means this privacy notice |
| Resolution Life Group Website | means the platform consisting of the Resolution Life Group website https://www.resolutionlife.com/ with restricted access |
| Resolution Life Group, We or us | means Resolution Life Group Services Limited and other companies of the Resolution Life group |
| User(s) or You | means the users of the Resolution Life Group Website. |
Contact details
Our full details are:
Resolution Life Group Services Limited
The Caxton
1 Brewer’s Green
London SW1H 0RH
United Kingdom
dataprivacy@resolutionlife.com
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 25 January 2024.
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 by contacting: dataprivacy@resolutionlife.com.
Third party links
The Resolution Life Group 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. When you leave the Resolution Life Group Website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
We may collect, use, store and transfer different kinds of personal data about you:
This includes information about you that you provide to us, for example, by visiting the Resolution Life Group Website, filling in forms or by corresponding with us by post, phone, email or otherwise. The nature of the services you are requesting will determine the kind of personal data we might ask for, though such information may include (by way of a non-exhaustive list):
- basic personal data, such as:
- first name, maiden name, last name, marital status, title, date of birth and gender (“Identity Data”); and
- postal address, email address and telephone numbers (“Contact Data”); and
- any information that you choose to share on the Resolution Life Group Website which may be considered personal data;
Information that we collect or generate about you (for example, as you interact with the Resolution Life Group Website). This includes (by way of non-exhaustive list):
- any information regarding the services purchased and/or used on the Resolution Life Group Website and our interactions with you (including camera recorded images);
- a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
- through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each User, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.);
- internet protocol (“IP”) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Resolution Life Group Website (“Technical Data”); and
- activity data relating to the publication of content, the creation of targets or the use of protected documents on the Resolution Life Group Website, such as altering a document’s permissions and information regarding the individual that performed the activity.
This includes the Personal Data provided to us by third-party service providers, agencies or other publicly available sources where applicable. For example, we may obtain your personal data from insurance companies and pension scheme providers.
- When you visit Resolution Life Group Website, cookies are used to collect technical information about the services that you use, and how you use them.
- For more information on the cookies used by Resolution Life Group please see our cookie policy
We may collect information relating to your health and/or genetics from cedants in connection with your insurance, where we are entitled to do so in compliance with applicable laws. We otherwise do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. Additionally, Users may be unable to access the Resolution Life Group Website if such Personal Data are not provided.
3. How we use your personal data
Your personal data may be stored and processed by us in the following ways and for the following purposes:
- we may register individuals visiting our sites, collecting Identity and Contact Data for reasons of security and safety of persons and belongings;
- for the purpose of providing our services and fulfilling our contractual obligations to clients and other third parties;
- for the purpose of underwriting our business with clients;
- for conducting data analysis, which helps us assess risks, price our products appropriately and improve our services;
- for reviewing, managing and processing claims;
- for assessing, improving and developing our services;
- for enhancing our knowledge of risk and insurance markets in general;
- for ongoing risk management activities to measure and limit our exposure to concentration of particular risks;
- for marketing purposes (e.g. newsletters, surveys, client events, etc.);
- for the purpose of designing, underwriting and pricing of new reinsurance contracts;
- for ensuring that we meet our obligations pursuant to existing reinsurance contracts, including assessment and payment of claims and associated administration/regulatory requirements;
- for ongoing review and improvement of the information provided on Resolution Life Group Website to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
- to allow you to use and access the functionality provided by the Resolution Life Group products;
- to assess your application for Resolution Life Group products, where applicable;
- to set up customers to use Resolution Life Group products;
- to conduct analysis required to detect malicious data and understand how this may affect your IT system;
- for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
- to understand feedback on Resolution Life Group products and to help provide more information on the use of those products and services quickly and easily;
- to communicate with you in order to provide you with services or information about Resolution Life Group products
- for in-depth threat analysis;to understand your needs and interests;
- for the management and administration of our business;
- in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures and fulfilling legal or regulatory obligations and protecting ourselves and our clients against fraud, money laundering, terrorism and other crimes; and
- for the administration and maintenance of databases storing personal data.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- we may rely on your consent where such consent can be validly obtained (including by meeting the requirement that such consent it is freely given by you);
- where it is needed to perform a contract pursuant to a business relationship we are about to enter into or have entered into with you;
- we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
- where we need to comply with a legal or regulatory obligation that we believe we are subject to; and/or
- where it is necessary for our Legitimate Interests (or those of a third party) and your interests and fundamental rights do not override those interests, including for the business purposes listed above.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to provide the best service. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
4. Disclosures of your personal data
We may share your personal data within the Resolution Life Group for the purposes described above. We will take steps to ensure that access to personal data is restricted to Resolution Life Group employees on a need-to-know basis. We may have to share your personal data with the parties set out below:
- Service providers who provide client management, IT and system administration services.
- Professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- To the extent required by law, for example, to HM Revenue & Customs in the United Kingdom, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
- As required by law, or if in good faith we believe disclosure is required by law.
We never sell personal information or pass it to third parties for marketing purposes. We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
5. International transfers
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") and United Kingdom (“UK”). It may also be processed by staff operating outside the EEA/UK who work for us or for one of our suppliers. Whenever we transfer your personal data out of the EEA/UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- the country that we send the data to might be approved by the European Commission / UK Government (as applicable) as offering an adequate level of protection for personal data;
- the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission / UK Government (as applicable), obliging them to protect your personal data; or
- the recipient may have adhered to binding corporate rules (only for intragroup transfers).
In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA/UK. Please contact dataprivacy@resolutionlife.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA/UK.
6. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, 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) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
For more details on the specific retention periods which we apply, please contact us using the details set out in the “Contact details” section above.
7. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
You have the right to access the data that we hold on you. To do so, you should make a subject access request.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at dataprivacy@resolutionlife.com.
If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the EU/UK data protection authority (as applicable) which, in the UK, is the Information Commissioner’s Office (“ICO”).