Privacy Notice – Introducing Finance Intermediaries

Professional introducers of client business

For the purposes of this Privacy Notice, Brightstar Financial, Bright Star or Brightstar are all trading styles of Bright Star Financial Limited and is a data controller as defined in the General Data Protection Regulation (GDPR). This is because Bright Star Financial Ltd may in some cases determine how your personal information will be used. By personal information, we mean information which, either by itself or combined with other information that is available to us, can be used to identify you, your principals, directors, shareholders or anyone employed by you or engaged by you who may access our online systems. For the purpose of this Privacy Notice, where we refer to “you” or “your” this will also include your principals, directors, shareholders, employees, contractors and workers.

If you are referring or passing personal client data to us, please do so under the terms of your original Introducer Agreement.

For avoidance of doubt this Privacy Policy is intended for those who undertake professional business services only, and is not a direct consumer Privacy Policy.

Introducers

We will process your information in support of any applications made through Brightstar in line with the Introducer or Network Agreement. Such personal data is given directly by you and by people or companies authorised by you to act on your behalf, and it may also include information obtained from those third parties authorised by you to share such information with us, including:

Identity Information

Forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier.

Contact Information

• Home address, Business address, email address and telephone and fax numbers
• Financial Information
• Banking details (to enable payment of fees payable to you)
• Technical Information
• Internet protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices used to access brightstarhub.co.uk or easysource+ or its associated sub systems or applications
• Profile and Usage Information
• Feedback and survey responses, and how you use our website, products and services
• Marketing and Communications Information including your preferences in receiving future news and services from Brightstar.

Why we need your data?

We will only collect and use your personal information in accordance with data protection laws for the purpose of facilitating your registration onto our Intermediary panel and onward processing of any applications you make on behalf of your clients through Brightstar or easysource+.  Our grounds for processing your personal information are as follows:

• For the purposes of performing our Contract (Introducer Agreement) with you. This includes the administering and management of our relationship in relation to the role that you undertake under the Agreement with Brightstar. For more information, please refer to the Introducer Agreement.

For the purposes of our own Legitimate Interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so.  Our grounds for processing your personal information are as follows:

• For the Management of our own accounting and other business operations
• To monitor emails, calls and other communications in line with our Agreement with you as an Intermediary to Bright Star Financial Ltd
• To respond to case enquires or grievances / complaints
• To notify you about changes to our terms or privacy policy
• Records of any surveys that you may be asked to complete for research purposes (although you do not have to respond to them)
• Developing statistics for market research and ongoing analysis to improve our website, product / services, marketing, customer relationships and experiences
• To deal with our good governance requirements

For the purposes of future marketing under Consent – You will be asked for your Consent to receive communications from Brightstar in relation to our services and products. We will never sell or pass your details onto third parties.

Where we store your personal data

We currently only store data within the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. In the event that data could be processed outside of the EEA, we will endeavour to inform you of this and ensure that it remains complaint with EEA standards.

Once we have received your personal data, we will use (and require our suppliers and partners to use) procedures and security features to try to prevent unauthorised access, unlawful processing, accidental loss or destruction of, or damage to it. However, the transmission of information via the Internet is not completely secure and, while we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our service and any transmission is at your own risk.

How long we keep your data

Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted.

Businesses or individuals conducting business related activities with Brightstar will be initially opted in for marketing purposes upon registration with our systems. You will be given the option to unsubscribe from marketing e-mails utilising an “unsubscribe” option contained within every marketing e-mail. The information we use for marketing purposes will be kept with us until you notify us that you no longer wish us to retain this information.

If you have any concerns or would like to be removed from future marketing, please contact us on marketing@brightstarhub.co.uk

Disclosure of your information

We will keep your personal data confidential and only disclose it to others for the purposes of facilitating your loan application(s) on behalf of your client(s), as well as in the following specific circumstances:

• To investigate, prevent or detect fraud or carry out checks against money laundering
• For audit purposes and to meet obligations to any relevant regulatory authority or taxing authority
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements to which you are a party; or to protect our rights, property, or safety, or that of our customers or others (which includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction)
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets, or
• If substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets
• You have provided us with expressed prior consent to share your information in connection with a specific project or proposition not listed above

The Use of Your Data with Regards to Trustpilot

We have teamed up with the independent review company Trustpilot to collect independent customer reviews. Trustpilot may contact you via the email address provided, to ask you to share your experience of Bright Star Financial Ltd. The only information we share with Trustpilot is your name and email address to enable them to contact you with a feedback request. You are under no obligation to provide feedback via this method.

• Businesses or individuals conducting business related activities with Brightstar will be opted in to receive Trustpilot review requests upon registration with our systems.
• Trustpilot will only use basic name and e-mail address details to send one review request and one reminder.
• Any customer details will not be used for any other purpose and cannot be given to any 3rd party organisations or businesses.

Your rights

You have the right to request a copy of the personal information that we hold about you, its origin and any recipients of it as well as the purpose of any data processing carried out.

• Right to access: the right to request copies of your personal information from us
• Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete
• Right to erase: the right to request that we delete or remove your personal information from our systems
• Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it
• Right to object: the right to object to our use of your personal information
• Right to data portability: the right to request that we move, copy or transfer your personal information

If you have any questions or would like to exercise your right under this Privacy Policy, in the first instance, please contact Steve Burch – Group Head of Compliance via the following methods:

Email – customerservice@brightstarhub.co.uk

Phone – 01277 500900

Address –Brightstar Financial, Unit 7, Lake Meadows Business Park, Woodbrook Crescent, Billericay, Essex, CM12 0EQ

We will aim to respond to all requests within 30 days except in instances where the request may be complex. We shall let you know within the 30-day period if we will need more time but no longer than 90 days.

Complaints

If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated.

Email – customerservice@brightstarhub.co.uk

Phone – 01277 500900

Address – Brightstar Financial, Unit 7, Lake Meadows Business Park, Woodbrook Crescent, Billericay, Essex, CM12 0EQ

If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office http://ico.org.uk/

This Policy was made available when first registering for easysource+, it is your responsibility to have read and understood this policy prior to accepting the Terms and Conditions.

We keep our privacy notice under regular review. This privacy notice was last updated on 25^th April 2022.