Privacy Policy

Last updated: January 2024

Introduction

Crystal Fury Limited ("we", "us", "our") is committed to protecting your privacy and handling your personal data responsibly. This privacy policy explains what information we collect, how we use it, and your rights regarding that information.

We are the data controller for personal information collected through our website and in the course of providing our services. Our registered address is 47 Bartholomew Lane, London, EC2N 2AB, and we are registered with the Information Commissioner's Office under registration number ZA274891.

Information We Collect

We collect personal information in several ways:

Information you provide directly

When you contact us or use our services, you may provide:

• Your name, address, and contact details
• Date of birth and National Insurance number
• Financial information including pension details, income, assets, and debts
• Employment history and current employment status
• Health information relevant to retirement planning
• Family circumstances and details of dependants
• Correspondence between you and our team

Information we collect automatically

When you visit our website, we may automatically collect:

• Technical information including IP address, browser type, and operating system
• Information about your visit including pages viewed, time spent, and navigation paths
• Cookie-related data as described in our Cookies Policy

Information from third parties

With your consent, we may obtain information from:

• Pension providers regarding your pension arrangements
• Government agencies regarding state benefits
• Other financial advisors you've previously worked with

How We Use Your Information

We use your personal information for the following purposes:

Providing our services

• Conducting pension reviews and retirement planning analysis
• Preparing reports and recommendations
• Communicating with you about your case
• Liaising with pension providers and other third parties on your behalf

Legal and regulatory compliance

• Meeting our obligations under the Financial Conduct Authority rules
• Maintaining records as required by law
• Responding to requests from regulators
• Preventing fraud and financial crime

Business operations

• Improving our services based on client feedback and usage patterns
• Training our staff
• Managing our business relationship with you

Legal Basis for Processing

We process your personal information on the following legal bases:

• Contract: Processing necessary to provide our services to you
• Legal obligation: Processing required to comply with our regulatory obligations
• Legitimate interests: Processing necessary for our legitimate business interests, such as improving our services
• Consent: Where you have given explicit consent, particularly for special category data such as health information

Special Category Data

Some information we collect may be considered "special category" data under data protection law, including health information. We only collect such information where it is relevant to our services (for example, health conditions that might affect your retirement planning) and where we have your explicit consent to do so.

Data Sharing

We may share your personal information with:

• Pension providers: To obtain information about your pension arrangements or implement recommendations
• Professional advisors: Including accountants and lawyers where relevant to your case
• Regulatory bodies: Including the Financial Conduct Authority and the Information Commissioner's Office
• Service providers: Who help us operate our business, such as IT support providers, under strict confidentiality agreements

We do not sell your personal information to third parties or share it for marketing purposes without your consent.

Data Retention

We retain your personal information for as long as necessary to fulfil the purposes for which it was collected. For clients, this typically means:

• Client files and advice records: Indefinitely, as you may return to us for further advice
• Financial transaction records: Seven years from the end of the relationship
• Website analytics data: 26 months

Where you enquire about our services but do not become a client, we retain your contact details for two years unless you ask us to delete them sooner.

Data Security

We take appropriate technical and organisational measures to protect your personal information, including:

• Encryption of data in transit and at rest
• Access controls limiting who can view your information
• Regular security assessments and staff training
• Secure disposal of physical documents
• Professional indemnity insurance covering data breaches

Your Rights

Under data protection law, you have the right to:

• Access: Request a copy of the personal information we hold about you
• Rectification: Ask us to correct inaccurate information
• Erasure: Ask us to delete your information in certain circumstances
• Restriction: Ask us to limit how we use your information
• Portability: Receive your information in a structured, commonly used format
• Objection: Object to processing based on legitimate interests
• Withdraw consent: Where processing is based on consent, withdraw that consent at any time

To exercise any of these rights, please contact us using the details below. We will respond within one month of receiving your request.

International Transfers

We do not routinely transfer your personal information outside the United Kingdom. If circumstances require such a transfer, we will ensure appropriate safeguards are in place, such as standard contractual clauses approved by the UK government.

Changes to This Policy

We may update this privacy policy from time to time. We will notify you of significant changes by posting a notice on our website or by contacting you directly. The date at the top of this policy indicates when it was last updated.

Contact Us

If you have questions about this privacy policy or how we handle your personal information, please contact us:

• Email: [email protected]
• Post: Data Protection Officer, Crystal Fury Limited, 47 Bartholomew Lane, London, EC2N 2AB

Complaints

If you are unhappy with how we have handled your personal information, you have the right to lodge a complaint with the Information Commissioner's Office (ICO). You can contact the ICO through their website at ico.org.uk or by post at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

However, we would appreciate the opportunity to address your concerns before you contact the ICO, so please reach out to us first.