High Star Energy Ltd
Heritage House
79-80 High Street
Gravesend
Kent
DA11 0BH
Privacy:
High Star Energy Ltd is committed to protecting the privacy of your personal information. Our company
is registered with the Information Commissioners Office (ICO), in order to make transparent our data
handling practices, and complies with the General Data Protection Regulations (GDPR) effective from
May 2018.
Good information handling makes good business sense. By doing this we believe we will enhance
our business’s reputation, increase customer and employee confidence, and by making sure
personal information is accurate, relevant and safe, save both time and money.
Our organisation act as a Data Controller as we keep or process information about living people
and must comply with certain important rules about how we collect and use personal information.
Lawful Basis for Processing
Our firm must have a valid lawful basis in order to process a person’s data and be able to demonstrate
the processing of data is “necessary” in order to provide our products and services. There are six
lawful bases.
Our organisation process on the basis of the following:
CONTRACT - We may have to process information to fulfil our contractual obligations to provide a
quotation, or act as credit intermediary in a finance agreement, or provide a warranty. In this
instance the processing is necessary for the performance of the contract.
LEGAL OBLIGATION - We may have to process information for health and safety reasons. In this instance
Health and Safety is legislation.
LEGITIMATE INTERESTS - In many instances the processing is necessary, for example to ultimately create
a finance plan through a lender when acting as a credit intermediary or carrying out a Customer Survey
Report.
CONSENT - We ask person’s to positively opt in if they want to receive further information on an
alternative product or service that we market separately.
We do not process special category data.
Collection of Information – Your consent
We may collect personal information from you if you provide it voluntarily. If you do provide
personal information to use, we will assume that you have read this Privacy Notice and have
consented to us using your personal information in the ways described in this Policy and at the
point where you give us your personal information. If, after providing us with personal
information, you later decide that you do not want us to use it for particular purposes, then
please write to us at the address shown.
Collection of your Information
We may collect and process the following data:
Information you provide when buying our products or services;
Information you provide to us by filling in our forms;
Information collected through correspondence with our Sales and/or Customer Relations teams;
Information you provide to us through the recruitment process;
Information you provide to us in order to register for alerts;
Social Media interaction;
Statistical data about your browsing actions and patterns for the administration of your application
for employment;
We may require you to submit personally identifiable information in order for you to make use of
our services. You confirm that any information you enter or provide will be true. We will only request
and collect information which is necessary or reasonable in order to provide you with your requested
services and to improve the services that we provide. It will not be a requirement to provide any
additional information which is not needed to provide the services.
Reasons for Collection of your Information
In the course of our dealing with you we may collect and process certain information about you,
including your name, date of birth, address, contact details (including your email address and
contact telephone number), payment details (where applicable), and other information about you
in respect of which services and products may be provided. Your personal information may be used
by us, our employees, contractors or agents to:
• identify you during any communication between you and us;
• assess eligibility for services and products (whether provided by us or on our behalf);
• carry out regulatory checks and meet our obligations to our regulators;
• communicate with you to arrange the provision of such services and products;
• administer and provide such services and products;
• detect and prevent loss, fraud and other criminal activity;
• carry out credit reference checks through associated third parties;
• carry out market research and to help us review, develop and improve the services and products
we offer; and
• contact you (in accordance with your preferences), by post, telephone, SMS, email and other electronic
means with information about products, services, promotions, and offers that may be of interest to
you.
• Keep legal certificates and work records relating to the services we have provided to you including
details relating to:
Warranty, maintenance and guarantee information;
Any information which we consider may be required by the Health and Safety notice, product recall
or modification;
Industry Body Documentation and records;
Records of Advice given;
In the event that we sell or buy any business or assets, we may disclose personal information
held by us to the prospective seller or buyer of such business or assets. If we or substantially
all of our assets are acquired by a third party, personal information held by us will be one of
the transferred assets.
Your personal information may also be used by us, our employees or agents if we are under a duty
to disclose or share your personal information in order to comply with any legal obligation, or
in order to enforce any agreement we have with or otherwise concerning you, or to protect our
rights, property or safety or those of our customers, employees or other third parties.
With whom do we share your personal information?
Third parties such as our Principal, the Financial Conduct Authority, a finance lender (where
applying for a finance option where we act as a credit intermediary), a finance credit broker,
credit reference agencies (who may check the information against other databases, public or
private to which they have access), or fraud prevention agencies. This information may come from
your interactions with us or them through applying for finance or other consumer finance
product; or ascertain from the way in which the loan is administered and managed.
In connection with the above purposes, your personal information may be transferred to, or
otherwise processed by third party service providers acting on our behalf, our agents and law
enforcement authorities (including the police).
Access to Information
The GDPR gives you the right to access information held about you. You have the right to ask for
a copy of the personal information held about you. You also have the right to ask for
inaccuracies in information to be corrected. Any access request is not subject to a fee unless
the requests are unreasonable in which case a fee may be charged and will be disclosed at the
time of request. A copy of the information held about you by us can be requested by writing to
us at the address shown.
Transfer of Information Abroad
We will not transfer your personal information outside the EU without first obtaining your
consent.
Change of Policy
We may occasionally change the Privacy Notice to reflect customer and company feedback. Any
changes will be shown on this page.
Breach Notification
Our business has the effective processes to identify, report, manage and resolve any personal
data breaches.
Dealing with Data Protection Complaints
We aim to comply fully with our obligations under the General Data Protection Regulations. If a
customer has any questions or concerns regarding our company’s management of personal data
including their right to access data about themselves, then they should contact Adam Crake the
director, who is responsible for ensuring our company is compliant with data protection and is
the nominated data protection lead or Data Protection Officer (DPO).
If our company holds inaccurate information, then the customer should write to our firm at the
address shown providing the director with any evidence to show what the information should say
keeping copies of the correspondence. If after a reasonable amount of time (28 days is
recommended) the information has not been corrected, then the customer can make a complaint.
There are two courses of action:
1. Contact the director to process the complaint.
2. If the customer is still dissatisfied, they can go directly to the Information Commissioner, the
independent body that oversees data protection and the GDPR. They can be contacted on 0303 123 1113
or their website is www.ico.org.uk.
Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access
or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard
and secure the information we collect online.
How we use cookies
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you
agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit
a particular site. Cookies allow web applications to respond to you as an individual. The web application
can tailor its operations to your needs, likes and dislikes by gathering and remembering information
about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about
web page traffic and improve our website in order to tailor it to customer needs. We only use this
information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages
you find useful and which you do not. A cookie in no way gives us access to your computer or any
information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but
you can usually modify your browser setting to decline cookies if you prefer. This may prevent you
from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links
to leave our site, you should note that we do not have any control over that other website. Therefore,
we cannot be responsible for the protection and privacy of any information which you provide whilst
visiting such sites and such sites are not governed by this privacy statement. You should exercise
caution and look at the privacy statement applicable to the website in question.