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Privacy Policy

Your privacy is important to us. It is Keystone Financial's policy to respect your privacy regarding any information we may collect from you across our website, keystoneltd.co.uk.

Keystone Financial may revise this policy at any time by updating this page.

Last Updated: July, 2020

 

Information we collect

Log data: When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

Device data: We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

1. Personal information

We may ask for personal information, such as your:

  • Name

  • Email

  • Phone/mobile number

  • Mailing address

  • Work address

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so. These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);

  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;

  • you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or

  • we need to process your data to comply with a legal obligation.

  • Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

  • We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

3. Collection and use of information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to enable you to customise or personalise your experience of our website;

  • to enable you to access and use our website, associated applications and associated social media platforms;

  • to contact and communicate with you;

  • for internal record keeping and administrative purposes;

  • for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms;

  • to run competitions and/or offer additional benefits to you;

  • for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;

  • to comply with our legal obligations and resolve any disputes that we may have; and to consider your employment application.

4. Disclosure of personal information to third parties

We may disclose personal information to: third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators; our employees, contractors and/or related entities;

sponsors or promoters of any competition we run; credit reporting agencies, courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you; and third parties to collect and process data.

5. International transfers of personal information

The personal information we collect is stored and processed in United Kingdom, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

6. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

7. Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

9. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

10. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

Keystone Financial Data Controller
Harriet MacKenzie-Williams
keystoneltd.co.uk

This policy is effective as of 1 June 2020.

 

Cookies Policy

We use cookies to help improve your experience of keystoneltd.co.uk. This cookie policy is part of Keystone Financial Ltd’s privacy policy and covers the use of cookies between your device and our site. We also provide basic information on third-party services we may use, who may also use cookies as part of their service, though they are not covered by our policy.

If you don’t wish to accept cookies from us, you should instruct your browser to refuse cookies from http://keystoneltd.co.uk, with the understanding that we may be unable to provide you with some of your desired content and services.

Keystone Financial may revise this policy at any time by updating this page.

Last Updated: July, 2020

 

What is a cookie?

A cookie is a small piece of data that a website stores on your device when you visit, typically containing information about the website itself, a unique identifier that allows the site to recognise your web browser when you return, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.

Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences), and to personalise your content (eg. advertising, language).

Cookies set by the website you are visiting are normally referred to as “first-party cookies”, and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called “third-party cookies”, and can be used to track you on other websites that use the same third-party service.

Types of cookies and how we use them

Essential cookies: Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts and payment processing. We use essential cookies to enable certain functions on our website.

Performance cookie: Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or by third-party services. We use performance cookies on our site.

Functionality cookies: Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and time zone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you’re visiting (first-party) or by third-party service. We use functionality cookies for selected features on our site.

Targeting/advertising cookies: Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you’re visiting (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third-party service. We use targeting/advertising cookies on our site.

Third-party cookies on our site: We may employ third-party companies and individuals on our websites—for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by Keystone Financial Ltd’s cookie policy.

Our third-party privacy promise

We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.

How you can control or opt out of cookies

If you do not wish to accept cookies from us, you can instruct your browser to refuse cookies from our website. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie.

If you browse websites from multiple devices, you may need to update your settings on each individual device.

Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit. 

 

Terms of Use

The following Terms of Use apply to users, viewers and all people who access the site: keystoneltd.co.uk. Please read these terms carefully before using the site. 

Keystone Financial may revise these terms at any time by updating this page.

Last Updated: July, 2020

 

1. Terms

By accessing the website at https://keystoneltd.co.uk, you are agreeing to be bound by these terms of service, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this website are protected by applicable copyright and trademark law.

2. Use License

Permission is granted to temporarily download one copy of the materials (information or software) on Keystone Financial Ltd's website for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:

  • modify or copy the materials;

  • use the materials for any commercial purpose, or for any public display (commercial or non-commercial);

  • attempt to decompile or reverse engineer any software contained on Keystone Financial Ltd's website;

  • remove any copyright or other proprietary notations from the materials; or

  • transfer the materials to another person or "mirror" the materials on any other server.

This license shall automatically terminate if you violate any of these restrictions and may be terminated by Keystone Financial at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer

The materials on Keystone Financial Ltd's website are provided on an 'as is' basis. Keystone Financial Ltd makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties including, without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights.

Further, Keystone Financial Ltd does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its website or otherwise relating to such materials or on any sites linked to this site.

4. Limitations

In no event shall Keystone Financial Ltd or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption) arising out of the use or inability to use the materials on Keystone Financial' website, even if Keystone Financial Ltd or a Keystone Financial Ltd authorised representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

5. Accuracy of materials

The materials appearing on Keystone Financial Ltd's website could include technical, typographical, or photographic errors. Keystone Financial Ltd does not warrant that any of the materials on its website are accurate, complete or current. Keystone Financial Ltd may make changes to the materials contained on its website at any time without notice. However, Keystone Financial Ltd does not make any commitment to update the materials.

6. Links

Keystone Financial Ltd has not reviewed all of the sites linked to its website and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by Keystone Financial of the site. Use of any such linked website is at the user's own risk.

7. Modifications

Keystone Financial Ltd may revise these terms of service for its website at any time without notice. By using this website, you are agreeing to be bound by the then current version of these terms of service.

8. Governing Law

These terms and conditions are governed by and construed in accordance with the laws of the United Kingdom and you irrevocably submit to the exclusive jurisdiction of the courts in that State or location. 

 

Complaints Procedure

We aim to provide our clients and their advisers with excellent client service but at times things can go wrong. If you are unhappy with our service, or think there is a problem, please let us know immediately. 

We will resolve complaints as quickly as we can. Some complaints require detailed investigation and/or a dialogue with third parties and take some time to resolve. 

We will provide fair redress where we believe it is appropriate. For this purpose, fair means proportionate to the circumstance, consistent with Financial Conduct Authority Rules and Financial Ombudsman Guidelines. 

 

How to make a complaint

If you wish to register a complaint, please contact us:

In writing:
The Compliance Officer
Keystone Financial Ltd
21 Hazel Street
SUTTON IN ASHFIELD
NG17 3FD

By telephone:
01743 829097

How will we handle your complaint?

We regard any expression of dissatisfaction from or on behalf of any client to be a complaint irrespective of whether it is made orally or in writing or whether it is justified or not.

We will provide a copy of this procedure to any client who makes a complaint or to any client who requests it.

On receipt of a complaint we will pass the details to Harriet MacKenzie-Williams, Compliance Officer.

We regard a complaint as: -

a) An expression of dissatisfaction from an eligible complainant.
b) Relating to a regulated activity.
c) A client who has or may suffer financial loss material distress or significant inconvenience.

We have two levels of complaint:

1. A complaint where we can resolve it informally within three days of your confirming its nature. Where we resolve such a complaint informally, we will write to you summarising the complaint, the resolution we agreed with you at the time and remind you of your right to refer the complaint to FOS. 

2. Where a complaint cannot be resolved informally, we will enter the formal written dispute service, which we aim to resolve as soon as possible and in any event within eight weeks of notification.

Where we cannot resolve your problem within three working days

We will acknowledge your complaint in writing within 3 business days.  If we receive an oral complaint, we will refer in our letter of acknowledgement to the matter complained of and detail our understanding of this for you to confirm the accuracy of this.  This letter may contain our offer to settle where appropriate. 

If your complaint relates to a product or service that we arranged for you, but the matter is the responsibility of the product or service provider rather than our firm, we will refer the matter to the provider within 3 business days and write to you to confirm this, together with contact details for the provider concerned. 

The acknowledgement letter will confirm that -

1. We will investigate the complaint and respond fairly and promptly; 

2. Our Compliance Director will review the details surrounding the matter complained about and will examine the file and any other relevant information.   If the complaint is in respect of business conducted by our Compliance Director, then another senior employee will investigate.

3. Once the investigation is completed then our Compliance Director will write a “Final Response” letter to you with his appraisal of the matter, our final decision and the nature and terms of any settlement, if applicable. If we decide an offer of redress is appropriate, any compensation we offer will be a fair offer taking all the facts into account. 

If you are advised that we have concluded the matter and you are not satisfied with our final response, you may then take the complaint to the Financial Ombudsman Service (FOS).

If we write to you and you do not respond within eight weeks to our “settlement letter” we will treat the matter as closed.

a) If the investigation is not completed fairly and promptly within eight weeks following the initial receipt of the complaint, you will be informed of the reasons for the delay -

1. Setting out why the matter is still unresolved.
2. Giving you a full summary of our investigation to date, explaining why we have not been able to conclude the matter and when we expect to do so.
3. Advising you that you may now take the matter to the Ombudsman (see below) and
4. Enclosing a leaflet explaining how to take the complaint to the Ombudsman.

The Financial Ombudsman Service 

If we have not issued our final response letter within 8 weeks of receipt of the complaint or, if you are dissatisfied with our final response, you have the right to refer your complaint to the Financial Ombudsman Service, free of charge but you must do so within six months of the date of our final response letter.
If you do not refer your complaint in time, the Ombudsman will not have our permission to consider your complaint and so will only be able to do so in very limited circumstances. For example, if the Ombudsman believes that the delay was as a result of exceptional circumstances. The Ombudsman can be contacted at:

Financial Ombudsman Service
The Financial Ombudsman Service
Exchange Tower
London E14 9SR

Tel: 0800 023 4567 or 0300 123 9 123
www.financial-ombudsman.org.uk

Be assured that we treat all complaints very seriously and we will conduct a full review and conclude all matters to the mutual satisfaction of the parties as quickly as possible maintaining appropriate records at all times.