Privacy Notice Control.

This Privacy Notice is v1.5 and is valid from 0001hrs on 15 June 2020.  It replaces and supersedes all other Privacy Notices associated with Red Star Financial Management 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 & Contact Details.

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

Red Star Financial Management Ltd
St Georges House
Peter Street
Manchester
M2 3NQ

Our telephone number is 0161 834 5333.

Data Protection Officer Contact Details.

In observance of the General Data Protection Regulation and the Data Protection Act 2018, Red Star Financial Management 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@redstarfm.com, or writing to:

Data Protection Officer
Red Star Financial Management Ltd
St Georges House
Peter Street
Manchester
M2 3NQ

Personal data categories we collect

We may collect, use, store and transfer different kinds of personal data about you which we have categorised as follows:

• Identity Data: This includes first name, maiden name, last name, marital status, title, date of birth and gender.

• Contact Data: This includes email address and telephone numbers.

• Financial Data: This includes bank account information and payment details.

• Compliance Data: This includes recorded calls for quality checks and staff training. Such recordings may also be used to help us combat fraud.

• Technical Data: This includes internet protocol (IP) address, 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 this website.

• Usage Data: This includes information about how you use our website, products and services.

• Marketing and Communications Data: This includes your preferences in receiving marketing from us and your communication preferences.

• Aggregated Data: This includes statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

• Special Categories of Personal Data: This includes health and vulnerability related data that you may voluntarily share with us during the fulfilment of our services to you. We will always ask for your explicit consent to record and share Special Category Data.

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

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

For What Purposes Do We Process Personal Data?	What are the lawful basis’ by which we process data?
Supply, perform, manage and fulfil our products and services to you which enable you to claim for PPI, claim money that you are owed, will save you money or will strengthen your financial position and associated customer support and aftercare;	Contract
Make and manage customer payments	Contract
Manage fees and charges due on customer payments	Contract
Communicate with clients to fulfil, administer or enforce contractual obligations via email, telephone, SMS text, postal mail and push notifications;	Contract
Communicate with customers where we have your consent to do so via email, telephone, SMS text, postal mail and push notifications;	Consent
Communicate with clients on matters where we have a legal obligation to do so via email, telephone, SMS text, postal mail and push notifications;	Legal Obligation
Communicate with clients on matters where we have a legitimate interest to do so (see legitimate interest section below), via email, telephone, SMS text, postal mail and push notifications;	Legitimate Interest
Direct market similar or aligned new products and services to our existing customers;	Legitimate Interest, Consent
Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers;	Legitimate Interest, Consent
Verify the identity of individuals where necessary including for Subject Access Requests (SAR);	Contract
Update clients about changes to how we process their personal data and/or new processing activities via email, telephone, SMS text, postal mail;	Legal Obligation
Gather feedback for service and product improvement via email, telephone, SMS text, postal mail;	Legitimate Interest
Share testimonials, case studies and feedback on our website and future marketing;	Consent
Resolve complaints and/or disputes;	Legitimate Interest
Request continuation of Consent prior to consent expiry;	Consent
Collect payments or arrears should we have the need to do so;	Legitimate Interest
Protect our organisation, staff, associates, suppliers, partners and clients;	Legitimate Interest
Prevent, detect and investigate fraud;	Legal Obligation
Prevent, detect and investigate crime;	Legal Obligation
Comply with the law;	Legal obligation
Fulfil our statutory or regulatory obligations;	Legal obligation
Maintain our own accounts and records;	Legal obligation
For reporting, analytics and product/service improvement (including training);	Legitimate Interest
Improve and maintain data accuracy or completeness;	Legitimate Interest
Track your email engagement;	Legitimate Interest
Personalise your online experience;	Legitimate Interest
Conduct market research.	Legitimate Interest
To recruit and manage our staff;	Contract, Legitimate Interest and Legal Obligation
Sell your personal data	Legitimate Interest, Consent

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:

• Direct market products and services to you via post, emails, telephone, SMS text and push notifications where they are similar/aligned to our to our current products and services that enable you to claim money that you are owed, will save you money or will strengthen your financial position, and a soft opt-in exists;

• Request specific consent to share customer personal data with specific fulfilment partners so that they may direct market similar or aligned new products and services to our existing customers;

• For reporting, analytics and product/service improvement (including training);

• Improve and maintain data accuracy or completeness;

• Track your email engagement;

• Personalise your online experience. This could include customising the content and/or layout of our pages for individual users, for both visitors and contributors;

• 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.

• Sell your personal data;

• Resolve complaints and/or disputes;

• 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;

Sharing your personal data

Red Star Financial Management 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, this includes communicating with you to update you about our privacy notice and changes to how we process your personal data;

• 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 Management 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 organisation’s aim to help you claim money that you are owed, save you money and/or will strengthen your financial position that we do not currently provide ourselves.  Presently these include:

• • • PPI Register – Trading Style of Red Star Financial Management Ltd.
    • Evason Fildes Ltd (09551063).
    • Perligo Ltd (09178128).
    • JKZ 10 Ltd (08157178).
    • Sierra Kilo Ltd (08146402).
    • Rank Right Advertising Ltd (07317123).
    • Resolve Financial Advisors Ltd (07216917).
    • Red Star Financial Services Ltd (07129316).
    • Front Row Claims Ltd (07819181).
    • Mitchell Farrar Holdings Ltd

• • Where an external 3^rd 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 of PPI claims and/or helping you to:

• • • Claim money that you are owed;
    • 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:

Categories	Who we use	Privacy Notice
Web analytics service providers	Google Analytics	https://policies.google.com/privacy?hl=en
Social Media Provider	LinkedIn	https://www.linkedin.com/legal/privacy-policy
	Facebook	https://en-gb.facebook.com/privacy/explanation
	Twitter	https://twitter.com/en/privacy
	Instagram	https://help.instagram.com/519522125107875
	Google Ads	https://policies.google.com/technologies/ads
	Facebook Ads	https://en-gb.facebook.com/policy.php
	Microsoft – Bing	https://privacy.microsoft.com/en-gb/privacystatement
Cookie Provider	Cookiebot	https://www.cookiebot.com/en/privacy-policy/
Data Accuracy Support Provider	UK Search	https://www.uksearchlimited.com/ksupload/userfiles/Privacy-Policy-and-Fair-Processing-Notice-V6-UKSL-070918.pdf
Debt collection support providers;	UK Search	https://www.uksearchlimited.com/ksupload/userfiles/Privacy-Policy-and-Fair-Processing-Notice-V6-UKSL-070918.pdf
IT support providers;	Pareto IT LLP	TBC
Call & SMS Communication Provider	24X	http://24x.com/GDPR/PrivacyPolicy.pdf
Email Delivery	Mail Chimp	https://mailchimp.com/legal/privacy/
Mail scanning & support providers	Managed Inc	https://managedink.co.uk/wp-content/uploads/2018/07/Privacy-Policy.pdf
Feedback/review service providers;	Reviews.io	https://www.reviews.io/front/business-user-privacy-policy
Compliance Consultants	CSS Assure	https://www.cssassure.com/privacy-notice

Where we choose and/or have your permission to share/sell your personal data with 3^rd 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.

Selling your personal data

Red Star Financial Management Ltd may choose to sell your personal data.

You have the Right to Object to us selling your personal data at any time and can do so by informing us by telephone, post or email.

Where we choose to sell your information, we shall do so in the following circumstances:

• Where we have your “Consent” to do so;

• Where we have a “Legitimate Interest” to do so, including;

• • 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 organisation.

• • For the purposes of generating revenue for our business we may sell your data to the categories of industry listed below:

Financial Services
Banking	Breakdown and Recovery Services	Car Insurance	Claims Management Services	Financial Products	Funeral Plan
Home & Contents Insurance	Legal Services – Conveyancing, Wills, Trusts etc	Life Insurance	Mis-Sold Financial Products	Mortgages	Pre-paid Funeral Plans
Private Medical Insurance	Travel Insurance
Other
Charities	Cosmetic Surgery	Entertainment, Gaming, Leisure	Gambling and Lotteries	Health and Beauty	Mail Order
Marketing services	Public Sector	Publishing/Media	Retail & lifestyle	Trace, Asset Repatriation and Debt Collection	Travel

Home, Property & Related Industries
Bathroom Fitters	Blacksmith	Childcare, creche and playgroups	Cleaning companies	Do It Yourself businesses	Doctors
Dentists	Door, window and conservatory suppliers and services	Drainage & Damp Specialists	Driveway Specialists	Employment & Recruitment	Electrical Services
Fast Moving Consumer Goods	Floor fitter	Garden Decking, Improvement, Landscaping, Management, Maintenance & Equipment	Gas & Heating Services	General Building & Home Improvement Services
Gyms & Health Clubs	Health Providers	Handy man services	Home Entertainment Providers / Installation	Home Furnishings	Window Cleaners / Bin Cleaners / Drive & Patio Cleaners
Home / Purchase Survey Services	Home Removal Companies	Home Security Services – incl CCTV & Alarms	Joiner & Carpentry Services	Kitchen Designer and Fitter Services	Locksmiths
Loft conversion services	Log burner services – wood supplies and chimney sweep	Mobile Telecommunication	Optometrists	Painting & Decoration Services	Pest control services
Pets Services: kennelling, catteries, groomers & vet services	Plaster / renderer services	Plumbing Services	Renewable Energy Services	Roofer	Schools & Education facilities
Septic tank & waste removers	Sports, recreation and social clubs	Stonemason	Storage Providers	Swimming pool, swim spa and hot tub services – incl installation, maintenance	Tilers
Tree Surgery	Utilities Providers – Gas	Wine cellar services	White Goods & Appliance Providers	Waste Removal & Skip Hire

International Personal Data Transfer – Countries & Organisations.

Red Star Financial Management Ltd may transfer personal data to countries outside of the UK and/or EEA. Specifically, we use data processors based in South Africa.

If data is transferred outside of the EEA, Red Star Financial Management Ltd will put in place Standard Contractual Clauses with the Data Controller or Data Processor which contractually obliges them to protect your information to the same standard required by the General Data Protection Regulation and Data Protection Act 2018 post 31 December 2020.

Personal Data Retention Period

Red Star Financial Management 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;

• Where you have purchased, or enquired about purchasing, a Red Star Financial Management Ltd product or services, we shall retain any personal details applicable to the contract delivery for a period of 7 years (name, email, telephone, postal address) after completion of the contract. During this time, we may contact you using consent and/or legitimate interest to market additional products or services.

• Where you have downloaded free content from our site, we shall retain your contact details (name, email, mobile telephone number) for a period of 2 years, or until you exercise your Right to Object or opt out.  During this time, we may contact you using legitimate interest to market similar free content that may be of interest to you.

• Where you have signed up to receive information emails from Red Star Financial Management Ltd, we shall retain your contact details (name, email, mobile telephone number, company, job title) for 2 years, or until you withdraw your consent.

• 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 after the date of collection, or our last positive engagement, or until you withdraw your consent, whichever is latest, so that we may keep you informed if:

• • We expanded our portfolio of product or service offerings;

• • Where a new and/or additional PPI claim may be made that may come about due to current legal challenges, future legal challenges and/or fresh evidence of mis-selling or unfair commission.

• • New or emerging product or service offerings that may enable you to claim money that you are owed, will save you money or will strengthen your financial position are introduced.

• Client contact details.  Where you have completed part or all of our website webforms and/or we have provided you with a product or service that is designed for you to claim money that you are eligible to claim; and/or will enable you to save money; and/or will strengthen your financial position, we shall retain your contact details for direct marketing purposes for 7 years after any associated deadline (for example the PPI deadline) or full delivery of the product/service we have provided, so that we may keep you informed:

• • If we and/or any of our trading styles or group entities expand our portfolio of product or service offerings;

• • Where a new and/or additional PPI claim may be made that may come about due to current legal challenges, future legal challenges and/or fresh evidence of mis-selling or unfair commission.

• • New or emerging product or service offerings that may enable you to claim money that you are owed, will save you money or will strengthen your financial position are introduced.

• For our PPI claims service, we shall retain your contact details and relevant PPI claims data for 7 years after the PPI deadline, or the completion of your claim.  We retain your data for this period of time to enable us to contact you about any changes or challenges to the PPI deadline and/or the circumstance where a claim may be made that may come about due to current legal challenges, future legal challenges and/or fresh evidence of mis-selling and/or unfair commission.

• 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 Management will not charge for this service however we do have the right to charge an administrative cost should we feel the request is excessive (excessive means that you submit a subject access request multiple times for the same or similar information).  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.

• Automated decision-making, including profiling.  Red Star Financial Management Ltd does not use currently use automated decision-making tools or profiling in the processing of your Personal Data.

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@redstarfm.com, or writing to:

Your Right to Withdraw Consent

You have the right to withdraw your consent to Red Star Financial Management 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@redstarfm.com, or writing to:

Data Protection Officer
Red Star Financial Management Ltd
St Georges House, Peter Street, Manchester, M2 3NQ

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 Management 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@redstarfm.com, or writing to:

Data Protection Officer
Red Star Financial Management Ltd
St Georges House
Peter Street
Manchester
M2 3NQ

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.