At Glass Lake Finance Limited, your privacy is of the utmost importance to us and we are committed to safeguarding our users privacy whilst providing a personalised and valuable service. When we use the terms “we,” “us” or “our,” we are referring to Glass Lake Finance Limited.
Glass Lake Finance Limited is an appointed representative of The On-Line Partnership Limited which is authorised and regulated by the Financial Conduct Authority. Registered Office: Glass Lake Finance Limited, Gloucester House, Church Walk, Burgess Hill, West Sussex, RH15 9AS. Registered in England and Wales no. 12941810
This privacy statement covers the services provided by our website (www.glasslake.co.uk). We will treat your personal information as confidential and in accordance with applicable data protection legislation. The purpose of this statement is to inform users of this website, what information is collected about you when you visit our site, how the information is used, if it is disclosed and the ways we protect your privacy. By visiting and submitting information via our site, you are accepting and consenting to the practices described in this statement.
TOPICS
○ What information do we collect about you and how do we use it?
○ Confidentiality and security
○ Access to your information and correction
○ Cookies
○ Other websites
○ Changes to our privacy policy
○ How to contact us
WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE USE IT?
In order to provide you with the best possible service, we sometimes need to collect information about you. We only ask for information that we have a reason for and will only use this information for the reason it was intended.
We collect information about you when you speak to us about your requirements.
CONTACT US FORM
We will collect the following:
○ Name: So we know what to call you
○ Email address: So we can contact you or provide you with further information
NEWSLETTERS
We may send you information about products and services of ours that are of a legitimate interest to you. You may opt out at any time. You have the right to stop us from contacting you for marketing purposes, and if you no longer wish to be contacted for marketing purposes, please email info@glasslake.co.uk.
THIRD PARTIES
We will not pass ANY of your details on to Third Parties unless this has been discussed and agreed by yourself.
CONFIDENTIALITY AND SECURITY
Here at Glass Lake Finance Limited, the confidentiality of your information is of paramount concern to us. Any information you provide us with will be held securely and in accordance with the Data Protection laws.
Your personal information will not be disclosed for marketing purposes with other companies.
We may also disclose your personal data if we reasonably believe we are required to do so by law, regulation or other government authority or to protect the rights and property of Glass Lake Finance Limited, its affiliates or the public.
ACCESS TO YOUR INFORMATION AND CORRECTION
You have the right to request a copy of the information that we hold about you. If you would like a copy of your personal data, please email info@glasslake.co.uk.
We want to make sure that your personal data is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
You also have the right to be forgotten. If you would like us to start the process of removing your data, please let us know using the above details.
COOKIES
What are cookies? A cookie is a small file, often including a unique identifier, that is sent to your device’s browser from a web server and is stored on your device’s hard drive.
They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.
No personal information is stored in our cookies.
This website uses Google Analytics, a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us compile reports to analyse how users use the site – meaning that we use them to see how many users come to our website, the pages that generate interest and the links that users most often click on (amongst other things) so that we may then improve the site. Google Analytics uses cookies which do not enable any website user to be individually identified and these cookies will only be used for website analytics purposes. For an overview of privacy at Google please visit www.google.co.uk/intl/en/analytics/privacyoverview.html. By using this website, you consent to the use of the Google Analytics cookie in the manner and for the purposes set out above.
Although no personal information is stored in our cookies once you are registered user of our investment services, a unique user identification number will be generated for your account. These unique user identification numbers will be submitted to Google Analytics but only for the purposes of tracking the use of the website so we can understand where we can make website improvements and future modifications and no personal information will be associated or accessible by reference to the unique user identification numbers.
Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing the internet software browsing settings. It may also be possible to change the settings to enable acceptance of specific cookies. Please refer to the help section on your browser. If cookies are disabled it may mean that not all services of a site, or indeed any, might be available.
For more information about cookies and how to disable them please visit www.allaboutcookies.org (please note that this link will take you to an external website).
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
GOOGLE ANALYTICS
We may also collect the following non-personal data via Google Analytics when you use our site. This information helps us continuously make improvements to our site that will improve your experience with our site and services. We use a Google Analytics code on our site to gather the following information. Please note, this information cannot be traced back to you.
○ Device type
○ Location
○ Browsing activity
This non-personal data is automatically deleted off our system after 38 months.
More information can be found online on how Google Analytics process this information, or the Google Analytics privacy policy.
OTHER WEBSITES
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
CHANGES TO OUR PRIVACY POLICY
We may change this privacy policy statement at any time, and such changes take immediate effect. Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified by email or via a notification on our site.
CONTACT
Please don’t hesitate to get in contact with us about our privacy policy, information we hold about you or if you have a complaint.
You can email us at: info@glasslake.co.uk Or you can write to us at: Glass Lake Finance Limited, Gloucester House, Church Walk, Burgess Hill, West Sussex, RH15 9AS.
This privacy policy was last updated in January 2021.
At Glass Lake Finance Limited, your privacy is of the utmost importance to us and we are committed to safeguarding our users privacy whilst providing a personalised and valuable service. When we use the terms “we,” “us” or “our,” we are referring to Glass Lake Finance Limited.
Glass Lake Finance Limited is an appointed representative of The On-Line Partnership Limited which is authorised and regulated by the Financial Conduct Authority. Registered Office: Glass Lake Finance Limited, Gloucester House, Church Walk, Burgess Hill, West Sussex, RH15 9AS. Registered in England and Wales no. 12941810
This privacy statement covers the services provided by our website (www.glasslake.co.uk). We will treat your personal information as confidential and in accordance with applicable data protection legislation. The purpose of this statement is to inform users of this website, what information is collected about you when you visit our site, how the information is used, if it is disclosed and the ways we protect your privacy. By visiting and submitting information via our site, you are accepting and consenting to the practices described in this statement.
TOPICS
○ What information do we collect about you and how do we use it?
○ Confidentiality and security
○ Access to your information and correction
○ Cookies
○ Other websites
○ Changes to our privacy policy
○ How to contact us
WHAT INFORMATION DO WE COLLECT ABOUT YOU AND HOW DO WE USE IT?
In order to provide you with the best possible service, we sometimes need to collect information about you. We only ask for information that we have a reason for and will only use this information for the reason it was intended.
We collect information about you when you speak to us about your requirements.
CONTACT US FORM
We will collect the following:
○ Name: So we know what to call you
○ Email address: So we can contact you or provide you with further information
NEWSLETTERS
We may send you information about products and services of ours that are of a legitimate interest to you. You may opt out at any time. You have the right to stop us from contacting you for marketing purposes, and if you no longer wish to be contacted for marketing purposes, please email info@glasslake.co.uk.
THIRD PARTIES
We will not pass ANY of your details on to Third Parties unless this has been discussed and agreed by yourself.
CONFIDENTIALITY AND SECURITY
Here at Glass Lake Finance Limited, the confidentiality of your information is of paramount concern to us. Any information you provide us with will be held securely and in accordance with the Data Protection laws.
Your personal information will not be disclosed for marketing purposes with other companies.
We may also disclose your personal data if we reasonably believe we are required to do so by law, regulation or other government authority or to protect the rights and property of Glass Lake Finance Limited, its affiliates or the public.
ACCESS TO YOUR INFORMATION AND CORRECTION
You have the right to request a copy of the information that we hold about you. If you would like a copy of your personal data, please email info@glasslake.co.uk.
We want to make sure that your personal data is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
You also have the right to be forgotten. If you would like us to start the process of removing your data, please let us know using the above details.
COOKIES
What are cookies? A cookie is a small file, often including a unique identifier, that is sent to your device’s browser from a web server and is stored on your device’s hard drive.
They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website in order to track online traffic flows.
No personal information is stored in our cookies.
This website uses Google Analytics, a popular web analytics service provided by Google, Inc. Google Analytics uses cookies to help us compile reports to analyse how users use the site – meaning that we use them to see how many users come to our website, the pages that generate interest and the links that users most often click on (amongst other things) so that we may then improve the site. Google Analytics uses cookies which do not enable any website user to be individually identified and these cookies will only be used for website analytics purposes. For an overview of privacy at Google please visit www.google.co.uk/intl/en/analytics/privacyoverview.html. By using this website, you consent to the use of the Google Analytics cookie in the manner and for the purposes set out above.
Although no personal information is stored in our cookies once you are registered user of our investment services, a unique user identification number will be generated for your account. These unique user identification numbers will be submitted to Google Analytics but only for the purposes of tracking the use of the website so we can understand where we can make website improvements and future modifications and no personal information will be associated or accessible by reference to the unique user identification numbers.
Most browsers are initially set to accept cookies. However, you have the ability to disable cookies if you wish, generally through changing the internet software browsing settings. It may also be possible to change the settings to enable acceptance of specific cookies. Please refer to the help section on your browser. If cookies are disabled it may mean that not all services of a site, or indeed any, might be available.
For more information about cookies and how to disable them please visit www.allaboutcookies.org (please note that this link will take you to an external website).
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
GOOGLE ANALYTICS
We may also collect the following non-personal data via Google Analytics when you use our site. This information helps us continuously make improvements to our site that will improve your experience with our site and services. We use a Google Analytics code on our site to gather the following information. Please note, this information cannot be traced back to you.
○ Device type
○ Location
○ Browsing activity
This non-personal data is automatically deleted off our system after 38 months.
More information can be found online on how Google Analytics process this information, or the Google Analytics privacy policy.
OTHER WEBSITES
Our website contains links to other websites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.
CHANGES TO OUR PRIVACY POLICY
We may change this privacy policy statement at any time, and such changes take immediate effect. Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified by email or via a notification on our site.
CONTACT
Please don’t hesitate to get in contact with us about our privacy policy, information we hold about you or if you have a complaint.
You can email us at: info@glasslake.co.uk Or you can write to us at: Glass Lake Finance Limited, Gloucester House, Church Walk, Burgess Hill, West Sussex, RH15 9AS.
This privacy policy was last updated in January 2021.
PRIVACY NOTICE
Glass Lake Finance Ltd (GLF) understands its obligations in regards to your fundamental right to a private life and has implemented systems and controls to ensure your rights and freedoms are protected.
GLF undertakes to meet its obligations under the Data Protection Act, the Privacy and Electronic Communications Regulations and the EU General Data Protection Regulation (GDPR).
| WHAT PERSONAL DATA DO WE COLLECT? | GLF will collect the following data, dependent upon the financial service required: Name, address, contact telephone numbers, email address, bank statements, passport, council tax and utility bills, driving licence, benefit statements, shotgun licence, payslips, criminal record information, existing pension information, life cover information, investment information, details of assets and liabilities, health information – life policies and long term care information – annual expenditure and any other existing relevant policy. Different variations of data are required for each product so we may not be required to collect all of the data listed above for all products. |
| HOW WE COLLECT YOUR PERSONAL DATA | You directly provide GLF with the personal data we collect by the following methods: Original physical copy, scanned certified email copy, scanned certified postal copy. |
| WHO WILL PROCESS YOUR PERSONAL DATA? | Access to your personal data is permitted only for those employees who require it to fulfil their responsibilities on your behalf. Your personal data will be initially processed by GLF. Your personal data will be further processed by On-Line Partnership Group Limited on behalf of its subsidiary company The On-Line Partnership Limited who acts as our Principal for regulatory purposes. In the event of incapacity of your adviser, your data will be shared with an authorised On-Line Partnership Group Limited locum adviser in order to carry out the responsibilities within your service agreement. All parties will process your personal data in accordance with this Privacy Notice. All parties are subject to information security training to enforce and communicate best practice when handling information. |
| WHAT HAPPENS IF WE WANT TO PROCESS YOUR PERSONAL DATA FOR OTHER REASONS? | Though there are some legal exceptions, if we wish to process your personal data for any other unrelated purpose than those we have informed you about we will notify you. |
| WHAT ARE THE CONSEQUENCES IF YOU DO NOT PROVIDE YOUR PERSONAL DATA? | Your personal data is essential to enable us to take steps at your request prior to entering into a contract or to perform a contract to which you are a party. Without this information we will not be able to proceed to provide any financial service. Processing will only occur whereby it is necessary to protect the vital interests of our client. |
| WHAT MAKES THE PROCESSING LAWFUL? | The lawful basis for the processing of your personal data as per Article 6(1) of the GDPR is:
|
| KEEPING YOUR PERSONAL DATA UP TO DATE | We will record your information exactly as you provide it. You may ask us to update it at any time and we will action your request promptly and notify relevant third parties of any changes. |
| WHAT ABOUT SENSITIVE PERSONAL DATA? | Unless we are processing because it is necessary for reasons of substantial public interest, we will only process sensitive personal data, such as data concerning health, with your explicit and informed consent for specific processing activities. In such cases you will be asked to sign a separate consent form to evidence this and that you understand the purpose(s) of the processing of such data. Your consent may be withdrawn at any time. |
| HOW WILL WE FURTHER USE YOUR PERSONAL DATA (OUR LEGITIMATE INTERESTS)? |
You have the right to object to processing for these purposes and we shall cease unless we can show we have compelling legitimate grounds to continue. |
| PROCESSING WHEN PERFORMING A TASK CARRIED OUT IN THE PUBLIC INTEREST | We will use your personal data to protect members of the public against dishonesty, money laundering or fraudulent activities. This must necessarily be carried out without your explicit consent to ensure this function is not prejudiced. Part of this processing involves verifying your identity using third parties such as GB Group Plc or Creditsafe Business Solutions Ltd. |
| WHAT PERSONAL DATA IS REQUIRED? | We only collect data that is necessary to carry out the purposes listed above. This includes data you supply and data we receive from reference agencies. Where practical and lawful we will inform you about any of your personal data we receive from third parties that you may be unaware of. |
| HOW SECURE WILL YOUR PERSONAL DATA BE? | We will ensure that your data is only accessible to authorised people in our firm and will remain confidential at all times. Appropriate security measures are in place to prevent unauthorised access, alteration, disclosure, loss, damage or destruction of your information. If we have a contract with another organisation to provide us with services or a service on our behalf to process your personal information, we’ll make sure they give reassurances regarding appropriate security measures in place and only process your data in the way we’ve authorised them to. These organisations won’t be entitled to use your personal data for their own purposes. If necessary, our security teams will check them to make sure they meet the security requirements we’ve set. Please contact our Data Protection Officer below if you would like further information. |
| WILL WE SHARE YOUR PERSONAL DATA WITH ANYONE ELSE? | We may share your data with:
|
| TRANSFERRING YOUR PERSONAL DATA OUTSIDE THE UK / EUROPEAN UNION | We do not usually transfer any of your personal data outside of the UK or EU except when we need to perform pre-contractual measures (credit and identity checks) or because the checks we request are necessary for important reasons of public interest. Some companies, like Creditsafe Business Solutions Ltd, may transfer data outside of the EU to countries which do not, in the view of the EU Commission, offer an adequate level of protection. In such cases Creditsafe encrypts any data it sends to other agencies and only transfers information necessary to carry out checks.
(A list of countries used to perform checks include Germany, Netherland, Belgium, France, Sweden, Norway, Finland, Luxembourg, Switzerland, Liechtenstein, Spain, USA, Estonia, Latvia, Lithuania, Poland, Slovakia, Czech Republic, Hungary, Slovenia, Bosnia, Serbia, Montenegro, Croatia, Macedonia, Kosovo, Albania, Bulgaria, Romania, Ukraine, Austria, Denmark, Moldova, Portugal, Italy, Canada, Brazil, Greenland, China, India, Australia, Russia, South Korea, Taiwan, Mexico, South Africa, New Zealand, Hong Kong, UK.) Furthermore, we will occasionally use third parties for the processing of personal data in third countries. However, we shall put in place appropriate safeguards to ensure your data is safe before such transfers. |
| WHAT ABOUT DIRECT MARKETING? | We will use your personal data now and in the future to carry out direct marketing activities as these are legitimate interests pursued by us. Sometimes this includes, with your consent, sharing data with product providers for their marketing activities. You can choose which method you’d prefer us to use to contact you (by email, telephone, SMS or post) and you have the right to object at any time to the use of your personal data for this purpose and we will cease marketing activity. Just let the person who gave you this form know about your preferences. |
| AUTOMATED DECISION-MAKING PROCESSES | We sometimes use automated processes when making decisions but you will not be subject to a decision based solely on automated processing, including profiling. |
| TELEPHONE CALL RECORDING | In line with The Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 we may record incoming or outgoing telephone conversations for the following purposes:
|
| HOW LONG WILL WE KEEP YOUR PERSONAL DATA FOR? | The Financial Conduct Authority lays down rules relating to how long your personal data should be held for and we will keep your data to meet these requirements. We will not keep your personal data for longer than is necessary. |
| REQUESTING A COPY OF YOUR PERSONAL DATA WE HOLD | You may at any time ask for a copy of the personal data we hold about you – it is your legal right. We will provide you with a copy of any non-exempt personal data within one month unless we ask you for an extension of time. To protect your personal data, we will ask you to verify your identity before we release any data. We may refuse your request if we are unable to confirm your identity. |
| IMPORTANT RIGHTS | You have the right, on grounds relating to your situation, at any time to object to processing which is carried out as part of our legitimate interests or in the performance of a task carried out in the public interest. We will no longer process your personal data unless we can demonstrate there are compelling legitimate grounds which override your rights and freedoms or unless processing is necessary for the establishment, exercise or defence of legal claims. You have the right to object at any time to processing your personal data for marketing activities. In such a case we must stop processing for this purpose. |
| WHAT ARE YOUR OTHER LEGAL RIGHTS? | In addition to the rights above the additional following rights:
To exercise any of these rights please contact our Data Protection representative. |
| HOW TO CONTACT OUR DATA PROTECTION OFFICER / DATA PRIVACY OFFICER* | Your trust is important to us. That is why you can contact our data protection officer about any data protection or marketing issues by:
Writing to: Telephoning: 01273 033900 |
| HOW DO YOU MAKE A COMPLAINT TO THE REGULATOR? | • By writing to:
Information Commissioner’s Office, • By telephoning: 0303 123 1113 https://ico.org.uk/for-organisations/report-a-breach/ |