Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controllers’ possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation 2016/679 (the ‘GDPR’) which comes into effect on 25th May 2018.
How do we process your personal data?
Brighter IR complies with its obligations under the GDPR by keeping personal data up to date, by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
Brighter IR will collect personal data directly from you as the data subject and may on occasion also collect relevant data from 3rd parties. We may monitor, record, store and use any telephone, email or other communication with you. Any new information you provide may be used to update an existing record we hold for you.
We may use your personal data for a number of different purposes including the following:
- To generate, manage and administer any contract you may have with us
- To keep you informed (by mail, email, telephone or otherwise) of relevant offers and products and services we consider may be of interest to you, unless you have opted out of receiving these;
- To comply with our legal obligations, co-operate with the court service, our regulators and law enforcement agencies and to prevent and detect crime;
- To transfer information to the Official Receiver or appointed insolvency practitioner if we receive notification of any bankruptcy or insolvency proceedings:
- To check instructions, you have provided or resolve disputes and complaints;
- To improve the quality of the service we provide and train our staff;
- Aggregating data for analysis and research and to provide management information internally or to the Group.
What is the legal basis for processing your personal data?
Under Article 6 of the GDPR, the legal basis that Brighter IR employs for processing your personal data may include one of the following:
- Where contractually it is needed to provide you with our products or services;
- Where it is in our legitimate interests to do so;
- To comply with our legal obligations;
- With your consent.
Usually, the legal basis will be contractual in that the processing of your personal data is necessary for the performance of a contract to which you, the ‘data subject’ is party, or in order to take preparatory steps at your request prior to entering into such a contract.
Sharing your personal data
Your personal data will be treated as being strictly confidential and will never be shared without your consent.
All the personal data that we hold about you will be processed by our staff, and no third parties (other than Proactive Investors Group Holdings Inc ‘the Group’) will have access to your personal data without your consent, or unless there is a legal obligation for us to provide them with this information. Please be aware however, that your personal data may be stored on cloud-based systems whose servers may or may not be located within the European Union.
Processing personal data outside of the EU
Where possible, we only process your information within the European Union (EU), which includes the UK, as we share similar standards of legal protection. We may send your data outside of the EU; however, we will always ensure it is processed and handled in line with the UK Data Protection Act 1998. Instances where we will transfer your data outside of the EU include:
- processing international payments; or
- disclosures to foreign authorities to reduce financial crime and terrorism.
How long do we keep your personal data for?
We will keep your personal information for as long as you are a customer or user of the services of Brighter IR and/or the Group. After you stop being a customer, we may keep your data for one of these reasons:
- To respond to any questions or complaints;
- To maintain records according to rules that apply to us.
We may keep your data if we cannot delete it for legal or regulatory reasons. We may also keep it for statistical purposes. If we do, we will make sure that privacy is protected, and the data only used for those purposes.
We will keep your personal data securely, and it will be destroyed securely if it is no longer needed for the lawful purposes for which it was obtained.
If you consent to receiving marketing from us, any information we use for this purpose will be held by us until such time as you notify us that you no longer wish to receive marketing information from us.
Your rights and your personal data
Unless subject to an exemption under the GDPR relating to a particular lawful basis used, you may have the following rights with respect to your personal data:
- to request a copy of your personal data which Brighter IR holds about you;
- to request that Brighter IR corrects any of your personal data if it is found to be inaccurate or out of date;
- to request your personal data to be erased where it is no longer necessary for Brighter IR to retain such data;
- to withdraw your consent to the processing of your personal data at any time;
- to request that Brighter IR provides you with your personal data, and where possible, to transmit the data directly to another data controller (known as the right to data portability);
- where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- to object to the processing of your personal data with regards to Direct Marketing;
- to lodge a complaint with the Information Commissioner’s Office (ICO).
Access to your information and correction
You have the right to request a copy of the information that we hold about you. This is called a Subject Access Request. If you would like a copy of all or some of your personal information, please email or write to us at the addresses provided in the “Contact Details” section of this Data Privacy Notice. In some exceptional cases, we may make a small charge for this service (for example multiple claims for the same information) but usually this data will be provided free of charge.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
We would like to send you information about products and services of ours and other companies within our group which may be of interest to you. If you have consented to receive marketing, you may opt out at a later date.
You have a right at any time to stop us from contacting you for marketing purposes or giving your information to other entities within our group. If you no longer wish to be contacted for marketing purposes, please email or write to us at the addresses provided in the ‘Contact Details’ section of this Data Privacy Notice.
If we wish to use your personal data for a new purpose, not defined by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to the commencement of the new processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
To exercise all relevant rights, or to raise queries or complaints, please in the first instance contact
1st Floor, Tudor House
Le Bordage, St Peter Port
Guernsey, GY1 1DB
You can contact the Information Commissioner’s Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or by post at The Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
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