Privacy Notice Control.

This Privacy Notice is v1.01 and is valid from 0001hrs on 01 October 2019. It replaces and supersedes all other Privacy Notices associated with Red Star Financial Services Ltd.

We take your privacy very seriously. This Privacy Notice details what Personal Data we collect and how we shall use it.

Please take time to read this Privacy Notice and ensure that you understand its contents.

Changes to this Policy

We continually review our Privacy Notice and update it where necessary. We advise that you regularly check our Privacy Notices for updates. We do not wish to bother you with lots of minor amendments, but where we make significant changes to our policy, we shall email you to inform you.

Our Name And Contact Details.

The Data Controller of your Personal Data is Red Star Financial Services Ltd. This means the organisation decides how your personal data is processed and for what purposes. Our contact details are:

Boardwalk
21 Little Peter Street
Manchester
M15 4PS

Our telephone number is 0161 823 1733.

Data Protection Officer Contact Details.

Red Star Financial Services Ltd takes its data protection obligations extremely seriously. In observance of the General Data Protection Regulation and the Data Protection Act 2018, Red Star Financial Services Ltd have chosen to establish a Data Protection Officer. Should you wish to contact our Data Protection Officer regarding a data protection matter you can do so by emailing dpo@redstarfs.com, or writing to:

Data Protection Officer,
Red Star Financial Services Ltd
Boardwalk
21 Little Peter Street
Manchester
M15 4PS

For what purposes do we process personal data, and what are the lawful basis’ by which we process data?

Red Star Financial Services Ltd processes your Personal Data for the following purposes:

What are our legitimate interests for processing your data?

Where we have used legitimate interest as the lawful basis for processing your Personal Data we may use your Personal Data to:

• Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our credit brokerage services or insurance brokerage services and other services that may save you money or may strengthen your financial position;
• To prevent, detect and investigate fraud;
• To prevent, detect and investigate crime;
• To fulfil our statutory or regulatory obligations;
• To maintain our own accounts and records, including recording any contact we have with you via post, emails, telephone, SMS text and push notifications;
• For reporting, analytics and product/service improvement, (including internal training)
• To resolve complaints and/or disputes;
• To improve data accuracy or completeness;
• To track your email engagement;
• To personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;
• To conduct market research. Including research on the demographics, interests and behaviour of our customers in order to help us gain a better understanding of different audiences and enable us to improve our service. This research may be carried out internally by our employees or we may ask another company to do this work for us. Data will be anonymised to protect your data rights for research purposes.
• To verify staff suitability and experience for employment.
• To verify eligibility to work in the UK.

Sharing your personal data

Red Star Financial Services Ltd may choose to share your personal data internally and/or share/sell your personal data externally to the business. Where we choose to share/sell your information, we shall do so for the following reasons:

• • Where we have your “Consent” to do so. Where we process your data under the Consent Lawful Basis you have the right to withdraw consent. Please refer to “Your Right to Withdraw Consent” section below;
  • Where necessary to fulfil the services and/or products we are “Contracted” to provide to you;
  • Where we have a “Legal Obligation” and are required by law and to law enforcement agencies, judicial bodies, government entities, tax authorities or regulating bodies around the world;
  • Where we have “Legitimate Interest” to do so, including;
    • For the purposes listed in the “What are our legitimate interests for processing your data?” section above.
    • For reporting, analytics and service improvement purposes across our trading styles and/or within any future group construct should Red Star Financial Services Ltd establish or become part of a group.
    • Where one of our registered trading styles and/or current associated businesses provides a product or service similar/aligned with our business of helping you save money and/or may strengthen your financial position that we do not currently provide ourselves. Presently these include:
      • Red Star Financial Management Ltd (07044178).
      • Evason Fildes Ltd (09551063).
      • Perligo Ltd (09178128).
      • Be Money Savvy Ltd (08484524).
      • JKZ 10 Ltd (08157178).
      • Korixon Ltd (09547116)
      • Sierra Kilo Ltd (08146402).
      • Rank Right Advertising Ltd (07317123).
      • Resolve Financial Advisors Ltd (07216917).
      • Front Row Claims Ltd (07819181).
    • Where an external 3rd Party, with whom we are yet to have a relationship, provides a product or service that we do not currently provide ourselves, and which we reasonably believe would be of benefit to you and you would reasonably expect to receive and is similar/aligned to our business helping you to:
      • Save money, or;
      • Strengthen your financial position
    • In this case we would contact you using Legitimate Interest to request specific Consent to share your Personal Data.
    • Where we believe it is necessary to protect or defend our rights, property or the personal safety of our people or visitors to our premises or websites;
    • Where required for a proposed sale; reorganisation; transfer; financial arrangement; asset disposal; or any other transaction relating to our business and/or assets held by our business.
    • We we outsource support functions of our business to trusted partners. The categories of these recipients include:
      • Payment service providers;
      • Order fulfilment service providers;
      • Mail support providers;
      • Email and chat support providers;
      • Call centre support providers;
      • Marketing service provider;
      • Web analytics service providers. Presently we use Google, Facebook, Twitter, Instagram.
      • IT support providers;
      • Feedback/review service providers;
      • Research agencies;
      • Auditing firms;
      • Legal support providers;
      • Debt collection support providers;
      • Credit reference agencies;
      • Fraud protection agencies;
      • Data protection support providers;
      • Human resources support providers (staff only);
      • Travel management support providers (staff only);
      • Training and learning providers (staff only);
      • Perk providers (staff only);
      • Medical and health providers (staff only);

Where we choose and/or have your permission to share/sell your personal data with 3rd Party’s we will ensure that they have signed a contract that requires them to:

• Abide by the requirements of all relevant data protection and privacy legislation;
• Treat your information as carefully as we would;
• Only use the information for the purposes it was supplied (and not for their own purposes or the purposes of any other organisation); and
• Allow us to carry out checks to ensure they are doing all these things.

International Personal Data Transfer – Countries & Organisations.

Red Star Financial Services Ltd does not presently transfer Personal Data to any countries outside of the EU or international organisation.

If in the future we choose to do so, and the country to which we transfer your personal data does not have a recognised EU or UK Adequacy Agreement, we shall ensure that the endorsed ICO Safeguard contract is in place with the Data Controller or Data Processor within the Country which contractually obliges them to protect your information to the same standard required by the General Data Protection Regulation.

Personal Data Retention Period

Red Star Financial Services Ltd has the following data retention policies:

• Where a Regulating Body directs a statutory retention period, we shall retain the relevant data for the statutory period. For example, your financial transactions data shall be retained for 7 years;
• Prospect contact details. Where you have enquired about one of our products or services that is designed to assist you to claim money that you are owed, enable you to save money; and/or will strengthen your financial position we shall retain your contact details for 7 years, or until you withdraw your consent, so that we may keep you informed if:
  • o We expanded our portfolio of product or service offerings;
  • o New or emerging product or service offerings that may enable you to save money or may strengthen your financial position are introduced.
  • o If we and/or any of our trading styles or group entities expand our portfolio of product or service offerings;

When we no longer need this information, we will anonymise your data and/or dispose of it securely.

The rights available to individuals in respect of the processing.

Unless subject to an exemption under legislation, you have the following rights with respect to your personal data:

• Your right of access. You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about your Right to Access here. In most cases Red Star Financial Services will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive. Fees will not exceed £50. Information will be provided within a month from the day you request it. We will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.
• Your right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about your Right to Rectification here.
• Your right to erasure. You have the right to ask us to erase your personal information in certain circumstances. You can read more about your Right to Erasure here.
• Your right to the restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about your Right to the Restriction of Processing here.
• Your right to object to processing. You have the right to object to processing if we are able to process your information because the process forms part of our public task, or is in our legitimate interests. You can read more about your Right to Object to Processing here.
• Your right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated. You can read more about your Right to Data Portability here.

If you wish to exercise any of your Individual Rights, you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing dpo@redstarfs.com, or writing to:

Data Protection Officer
Red Star Financial Services Ltd
Boardwalk
21 Little Peter Street
Manchester
M15 4PS

Your Right to Withdraw Consent

You have the right to withdraw your consent to Red Star Financial Services Ltd’s processing your data at any time. Please note that this only applies for personal data processed under the Consent Lawful Basis. To determine what of your personal data is processed under the Consent Lawful Basis, please refer to the “What are the lawful basis’ by which we process data?” section above.

If you decide you wish to withdraw your Consent from a processing activity that uses the lawful basis of Consent you can do so by informing a member of our team or by contacting our Data Protection Officer by emailing dpo@redstarfs.com, or writing to:

Data Protection Officer
Red Star Financial Services Ltd
Boardwalk
21 Little Peter Street
Manchester
M15 4PS

Automated decision-making, including profiling.

Red Star Financial Services Ltd does not use currently use automated decision-making tools or profiling in the processing of your Personal Data.

Your Right to Lodge a Complaint with the ICO

You have the right to lodge a complaint with the UK’s Supervising Authority: The Information Commissioners Office. Prior to lodging a compliant, Red Star Financial Services Ltd would like the opportunity to address any complaint you may have.

Should you have a complaint please in the first instance contact our Data Protection Officer by emailing dpo@redstarfs.com, or writing to:

Data Protection Officer
Red Star Financial Services Ltd
Boardwalk
21 Little Peter Street
Manchester
M15 4PS

If your complaint has not been resolved, you can lodge a complaint with the Information Commissioners Office via email https://ico.org.uk/global/contact-us/email/ or by writing to:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire. SK9 5AF.

Or by telephone on 0303 123 1113.

Red Star Financial Services Ltd Privacy Notice version 1.01, valid from 0001hrs on 01 October 2019