Privacy Policy

Introduction

Stellar Circuit is committed to protecting your privacy and handling your personal information with care and respect. This privacy policy explains what information we collect, why we collect it, how we use it, and your rights regarding your personal data.

We are registered as a data controller with the Information Commissioner's Office and comply fully with the UK General Data Protection Regulation and the Data Protection Act 2018.

Information We Collect

To provide financial planning services effectively, we collect various types of information:

Personal Identification Information

This includes your name, date of birth, address, email address, and other contact details necessary for establishing and maintaining our professional relationship.

Financial Information

We collect details about your income, employment, assets, liabilities, existing financial arrangements, pension details, investment holdings, insurance policies, and tax status. This information is essential for providing appropriate financial guidance.

Sensitive Personal Data

In certain circumstances, we may need to collect sensitive information such as health data when assessing protection needs or other personal circumstances relevant to your financial planning.

Website Usage Data

When you visit our website, we collect information about your device, browser, IP address, and how you interact with our site through cookies and similar technologies.

How We Collect Information

We gather information through several methods:

• Directly from you during meetings, phone calls, and email correspondence
• Through documentation you provide such as bank statements, pension statements, and tax returns
• From third parties with your consent, including pension providers, investment platforms, and insurers
• Automatically through our website using cookies and analytics tools

How We Use Your Information

We process your personal data for specific, lawful purposes:

Providing Financial Services

Your information enables us to analyse your financial position, develop appropriate strategies, provide recommendations, implement financial arrangements, and conduct ongoing reviews of your circumstances.

Legal and Regulatory Compliance

We are required by law and financial services regulations to collect, verify, and retain certain information. This includes anti-money laundering checks, regulatory reporting, and maintaining adequate records.

Communication

We use your contact information to respond to enquiries, schedule appointments, share relevant updates about your financial arrangements, and provide information about changes to regulations or products that may affect you.

Service Improvement

Anonymised and aggregated data helps us improve our services, understand client needs better, and develop new offerings that may benefit our clients.

Legal Basis for Processing

We process your personal data based on several legal grounds:

• Contract: Processing is necessary to fulfil our service agreement with you
• Legal Obligation: We must process certain data to comply with financial regulations and legal requirements
• Legitimate Interest: Processing is necessary for our legitimate business interests, such as preventing fraud and improving our services
• Consent: For certain activities like marketing communications, we rely on your explicit consent which you can withdraw at any time

Sharing Your Information

We only share your personal information when necessary and appropriate:

Financial Product Providers

When implementing recommendations, we share relevant information with pension providers, investment platforms, insurance companies, and other financial institutions to establish and manage your arrangements.

Professional Service Providers

We may share information with solicitors, accountants, or other professionals when coordinating comprehensive financial planning, always with your knowledge and typically with your explicit consent.

Regulatory Bodies

We may be required to disclose information to financial regulators, tax authorities, or law enforcement agencies when legally obligated to do so.

Service Providers

Trusted third parties who support our business operations, such as IT service providers, document storage facilities, and professional indemnity insurers, may process your data on our behalf under strict confidentiality agreements.

We never sell your personal information to third parties for marketing purposes.

Data Security

Protecting your information is paramount. We implement robust security measures including:

• Encrypted storage of digital files and secure destruction of physical documents when no longer needed
• Restricted access to personal data, limited only to staff members who require it for their duties
• Regular security audits and updates to our systems and procedures
• Secure communication channels for transmitting sensitive information
• Comprehensive data breach procedures to respond quickly to any security incidents

While we take extensive precautions, no data transmission over the internet or electronic storage system can be guaranteed as completely secure. We continually work to maintain the highest standards of data protection.

Data Retention

We retain your personal information for as long as necessary to fulfil our service obligations and comply with legal requirements. Financial services regulations require us to maintain client records for a minimum of six years after our professional relationship ends. Some information may be retained longer if required by law or necessary for legal claims.

Once information is no longer required, we securely destroy or permanently delete it according to our data retention schedule.

Your Rights

Under data protection law, you have several important rights:

Right to Access

You can request a copy of the personal information we hold about you, free of charge in most circumstances.

Right to Rectification

If information we hold is inaccurate or incomplete, you can request corrections.

Right to Erasure

In certain circumstances, you can request deletion of your personal data, though this may be limited by legal retention requirements.

Right to Restrict Processing

You can request that we limit how we use your information in certain situations.

Right to Data Portability

You can request your data in a structured, commonly used format to transfer to another service provider.

Right to Object

You can object to certain types of processing, including direct marketing.

To exercise any of these rights, contact us using the details provided on our contact page. We will respond within one month of receiving your request.

Cookies and Website Tracking

Our website uses cookies to enhance functionality and analyse usage. You can control cookie settings through our cookie preference centre and your browser settings. For detailed information about our use of cookies, please see our separate Cookies Policy.

Third-Party Links

Our website may contain links to other websites. We are not responsible for the privacy practices of external sites and encourage you to review their privacy policies before providing any personal information.

Changes to This Policy

We review and update this privacy policy periodically to reflect changes in our practices, technology, legal requirements, and other factors. When we make significant changes, we will notify existing clients directly and update the "last updated" date at the top of this page.

Contact and Complaints

If you have questions about this privacy policy, how we handle your personal information, or wish to exercise your data protection rights, please contact us using the details on our contact page.

You also have the right to lodge a complaint with the Information Commissioner's Office if you believe we have not handled your personal data appropriately. Details can be found at www.ico.org.uk.