We take your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal data, your rights in relation to your personal data and on how to contact us and supervisory authorities in the event you have a complaint.
Italicised words in this privacy notice have the meaning set out in the Glossary of Terms at the end of this document.
Who we are
Crystal Financial Solutions Ltd collects, uses and is responsible for certain personal data about you. When we do so we are required to comply with data protection regulation and we are responsible as a data controller of that personal data for the purposes of those laws.
When we mention “we”, “us” or “our” we are referring to Crystal Financial Solutions Ltd.
Crystal Financial Solutions Ltd is a company registered in England and Wales (reg number 04961014) whose registered office is at Congress House, Lyon Road, Harrow, Middlesex, HA1 2EJ. We are authorised and regulated by the Financial Conduct Authority. FCA ref number 622200.
We provide you with an advice service in relation to your Insurance, Mortgage, Pension and Investment requirements.
The personal data we collect and use
In the course of providing our service to you we may collect the following personal data when you provide it to us:
- contact information
- identity information
- financial information
- employment status
- company / corporate information
- lifestyle information
- health information
- data about criminal convictions or offences
- details of any vulnerability
- details of your dependents, beneficiaries and trustees (If you are providing information about another person we expect you to ensure that they know you are doing so and are content with their information being provided to us. You might find it helpful to show them this privacy notice and if they have any concerns please contact us.)
- product details
- Other data relevant to the intermediary services
Information collected from other sources
We also obtain personal data from other sources in the course of providing our intermediary services. Where we obtain this information from another party it is their responsibility to make sure they explain that they will be sharing personal data with us and, where necessary, ask permission before sharing information with us.
The personal data we obtain from other sources may include the following:
- From lenders / product providers, your product details
- Your accountants, solicitors, lawyers, other parties who could be involved with the transaction
- Your introducer (if you have been referred to us via an introducer)
How we use your personal data
We are required under GDPR to ensure that your data is only processed lawfully, fairly and transparently. We will process your data if it meets at least one of the following lawful basis for processing and how we will do this:
Entering into or Performance of a contract by:
- establishing your financial goals / objectives
- assessing your risks
- giving advice, recommendations and reporting to you
- updating, consolidating and improving the accuracy of our records
- verifying your identity and the information provided
- responding to your enquiries and complaints
- enabling you to access our online services and website
- helping you understand all your options and from time to time keep you updated about products, services and offers that may be of interest to you.
Legitimate Interest by:
- processing personal information to help us analyse the service we are providing and identify ways to improve.
- maintaining accurate records at all times
- contacting you when a product is due to expire or at renewal so that we can help you explore the options available to you
- helping to prevent and detect crime such as fraud and money laundering
- training staff to be able to offer you the best possible level of service
- analysing activity on our online services, emails and website to identify ways to improve our services.
- resolving complaints and disputes – If you have a reason to make a complaint, we will use your information to look into things for you
- carrying out market research to make help us improve the services we offer you
Compliance with a legal & regulatory obligation and public interest by
- adhering to legal obligations relating to accounting and complying with legislation on markets in financial instruments
- preventing fraud, bribery, corruption and the provision of financial and other services to persons subject to economic or trade sanctions on an on-going basis in accordance with our AML procedures
To protect vital interests of the data subject:
- to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving consent.
Below outlines the main third-party recipients linked to the processing of your data:
- Lenders / product providers
- External suppliers or data storage and data hosting services to retain records on our behalf.
- Compliance service providers
Special category data
Certain types of personal data are considered more sensitive and so are subject to additional levels of protection under data protection legislation. These are known as ‘special categories of data’ and include data concerning your health, racial or ethnic origin, genetic data and sexual orientation. Data relating to criminal convictions or offences is also subject to additional levels of protection.
We may process:
- health information and lifestyle information when providing intermediary services; and/or
- criminal conviction or offence information when providing intermediary services
In addition to the lawful basis for processing this information set out above, we will be processing it either (i) for the purpose of advising on, arranging or administering intermediary services or (ii) for the establishment, exercise or defence of any claims.
We may use personal data we hold about you to help us identify, tailor and provide you with details of products and services from us that may be of interest to you. We will do so in accordance with any marketing preferences you have provided to us.
In addition, where you provided your consent, we may provide you with details of products and services of third parties where they may be of interest to you.
You can opt out of receiving marketing at any time. If you wish to amend your marketing preferences, please contact us:
By phone: 020 8901 3737
By email: firstname.lastname@example.org
By Post: Crystal Financial Solutions Ltd, Congress House, Lyon Road, Harrow, Middlesex, HA1 2EJ
Whether information has to be provided by you, and if so why
We will tell you if providing some personal data is optional, including if we ask for your consent to process it. In all other cases you must provide your personal data in order for us to provide you with intermediary services.
How long your personal data will be kept
We will securely retain and maintain your personal data for as long as we reasonably require it for the purpose explained in this document. Your data may be held even after our relationship may have ended to ensure we can meet our regulatory or legal obligations and also to help us resolve any issues that may arise.
Transfer of your information out of the EEA
We may transfer your personal data to areas which are located outside the European Economic Area (EEA). Such countries do not have the same data protection laws as the UK and EEA. The European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in the UK and EEA, any transfer of your personal data outside of the EEA may not be subject to a high level of safeguards that are designed to help safeguard your privacy rights.
You have a right to ask us for more information about the safeguards as mentioned above. To learn more, please see ‘Your rights’ below.
You have legal rights under data protection regulation in relation to your personal data. These are set out under the below headings:
- To access personal data
- To correct / erase personal data
- To restrict how we use personal data
- To object to how we use personal data
- To ask us to transfer personal data to another organisation
- To object to automated decisions
- To find out more about how we use personal data
To access personal data
You can ask us to confirm whether or not we have and are using your personal data. You can also ask to get a copy of your personal data from us and for information on how we process it.
To rectify / erase personal data
You can ask that we rectify any information about you which is incorrect. We will be happy to rectify such information but would need to verify the accuracy of the information first.
You can ask that we erase your personal data if you think we no longer need to use it for the purpose we collected it from you.
You can also ask that we erase your personal data if you have either withdrawn your consent to us using your information (if we originally asked for your consent to use your information), or exercised your right to object to further legitimate use of your information, or where we have used it unlawfully or where we are subject to a legal obligation to erase your personal data.
We may not always be able to comply with your request, for example where we need to keep using your personal data in order to comply with our legal obligation or where we need to use your personal data to establish, exercise or defend legal claims.
To restrict our use of personal data
You can ask that we restrict our use of your personal data in certain circumstances, for example
- where you think the information is inaccurate and we need to verify it;
- where our use of your personal data is not lawful but you do not want us to erase it;
- where the information is no longer required for the purposes for which it was collected but we need it to establish, exercise or defend legal claims; or
- where you have objected to our use of your personal data but we still need to verify if we have overriding grounds to use it.
We can continue to use your personal data following a request for restriction where we have your consent to use it; or we need to use it to establish, exercise or defend legal claims, or we need to use it to protect the rights of another individual or a company.
To object to use of personal data
You can object to any use of your personal data which we have justified on the basis of our legitimate interest, if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information. If you raise an objection, we may continue to use the personal data if we can demonstrate that we have compelling legitimate interests to use the information.
To request a transfer of personal data
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller (e.g. another company).
You may only exercise this right where we use your personal data in order to perform a contract with you, or where we asked for your consent to use your personal data. This right does not apply to any personal data which we hold or process outside automated means.
To contest decisions based on automatic decision making
If we made a decision about you based solely by automated means (i.e. with no human intervention), and the decision made by us produces a legal effect concerning you, or significantly affects you, you may have the right to contest that decision, express your point of view and ask for a human review. These rights do not apply where we are authorised by law to make such decisions and have adopted suitable safeguards in our decision making processes to protect your rights and freedoms.
You can contact us for more information
If you are not satisfied with the level of information provided in this privacy notice, you can ask us about what personal data we have about you, what we use your information for, who we disclose your information to, whether we transfer it abroad, how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any automated decision making using your personal data.
We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information or change your details where we know we are dealing with the right individual.
We will not ask for a fee, unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before proceeding with your request.
We aim to respond to all valid requests within one month. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.
We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.
If you would like to exercise any of the above rights, please:
- email to our Data Protection Officer at email@example.com
- or write to Crystal Financial Solutions Ltd, Congress House, Lyon Road, Harrow, Middlesex, HA1 2EJ;
- let us have enough information to identify you, e.g. name, address, date of birth;
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures in place to prevent personal data from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Our supervisory authority
If you are not happy with the way we are handling your information, you have a right to lodge a complaint with the Information Commissioners Office. It has enforcement powers and can investigate compliance with data protection regulation (www.ico.org.uk).
We ask that you please attempt to resolve any issues with us before the ICO.
How to contact us
Please contact our Data Protection Officer if you have any questions about this privacy notice or the information we hold about you. If you wish to contact our Data Protection Officer, please contact us:
By email – firstname.lastname@example.org
By post – Crystal Financial Solutions Ltd, Congress House, Lyon Road, Harrow, Middlesex, HA1 2EJ.
Glossary of Terms
“We”, “us” or “our” – we are referring to Crystal Financial Solutions Ltd
contact information – these are details that can be used to contact a person, including title, first name, surname, personal telephone number, fax, email address, home address, country, postcode. This may also include work contact information such as telephone number, fax, email and address
company / corporate information – details about structure, staff, organisation and financial information.
data controller – means a natural or legal person (such as a company) which determines the means and purposes of processing of personal data. For example, we are your data controller as we determine how we will collect personal data from you, the scope of data which will be collected, and the purposes for which it will be used in the course of us providing you with intermediary services
data protection regulation – applicable data privacy and protection laws
employment status – this is information about your work, if you are employed, self-employed, unemployed, a student or on job seeker allowance
FCA – Financial Conduct Authority, being the independent watchdog that regulates financial services
financial information – this is information relating to your financial status, including salary/income, outgoings/expenditure, tax rate and P60
health information – this is information relating to your medical history, including symptoms, diagnoses, procedures and outcomes, as well as information about your height and weight. This could include previous and current or persistent medical conditions and family medical history
identity information – any information that can be used to verify their identity, such as name, date of birth, place of birth, gender, marital status, passport, drivers licence & national insurance number
intermediary services – these are the services we provide to you in relation to the product, which may include but are not limited to providing you with research, advice, application, referral, reporting and reviewing services
lenders – a mortgage lender (for a list of current lenders which we work with, please contact us)
lifestyle information – this includes both work and leisure behaviour patterns. Most relevant to your products may be your smoker status, alcohol consumption, health, retirement age and exercise habits
product – this is an investment, pension, mortgage, protection and/or general insurance product in respect of which we provide intermediary services to you
product provider – a company which provides investment, pension, protection and/or general insurance products (for a list of product providers which we work with, please contact us)
sanction check information – this is information relating to your politically exposed persons (PEPs) status and Her Majesty’s Treasury financial sanctions status, which is recorded to prevent fraud and money laundering
vulnerability – a vulnerable consumer is someone who, due to their personal circumstances, is especially susceptible to detriment, particularly when an advisory firm is not acting with appropriate levels of care. These customers are more likely to suffer severe detriment if something goes wrong. Details of vulnerability fall in to the following categories: health; resilience (financial); life events; and capability (financial knowledge/ confidence.