Privacy Policy
Who Are We?
This Privacy Policy sets out the data processing practices of Crystal Data Ltd. All data captured will be used and held in accordance with the requirements of the Data Protection Act 2018.
Crystal Data Ltd
Devonshire House
Aviary Court
Wade Road
Basingstoke
RG24 8PE
Email: accounts@crystaldata.uk
Crystal Data provides telemarketing and lead generation services to its clients.
Crystal Data is the data controller. If you have any requests concerning your personal data, or any queries regarding how we handle your data, you can contact the DPO using the information provided on our Contact Us page.
Purpose of Processing
We will only process your personal data in accordance with the services we provide to you, based on the contract we have with you, or based on your consent in relation to any marketing activities we undertake.
We will collect this consent when you first provide your personal data. You can withdraw that consent at any time by contacting us using the contact information provided above or by updating your online profile, if you have created one.
How We Process Your Information
Completing an account registration form
Purpose:
Processing the creation of your account
Providing you with information relating to our services
Lawful basis: Contract
Completing an order form on the website
Purpose:
Dealing with an order or booking
Internal accounting processes
Providing you with information relating to the order
Lawful basis: Contract
Data Screening, Cleansing or Telemarketing
Purpose:
Dealing with data you supply to us for the purposes of providing the services you have requested
Lawful basis: Contract
User Registration
Purpose:
To enable login to your personalised area of the Crystal Data website
Lawful basis: Contract
Email Marketing
Purpose:
To send information and marketing messages by email
Lawful basis:
During the signup process we rely upon Legitimate Interests
In all other cases, Consent
Postal Marketing
Purpose:
To send occasional marketing communications by post
Lawful basis: Legitimate Interest
Segmentation, Analytics and Marketing Profiling
Purpose:
To provide targeted and appropriate marketing messages
Lawful basis: Legitimate Interest / Consent
Consent
For email marketing and for passing data to third parties, we will use consent. This will usually be in the form of an opt-in tick box, or where you submit an email address expressly for the purpose of receiving marketing.
We will always make it clear what your data will be used for and provide a link to our Privacy Policy.
You can change your mind at any time.
Contract
Processing of personal data is necessary for us to administer the pre-contract and contractual relationship between ourselves and our suppliers or members in connection with the performance of a contract.
Legitimate Interests
We will use legitimate interests to send occasional marketing by email or post, and for segmentation and profiling in order to send relevant targeted communications.
Our legitimate interests are to communicate with our customers, keep them informed, grow our business and promote best practice in the marketing industry.
1. Marketing
We would like to use your personal data to send you details of products or services that we offer and have identified as likely to be of interest to you.
We will only send you information in line with the preferences you indicated when you provided your personal data or subsequently updated in your online profile.
If at any point you would like to opt out of receiving communications from us, or would like to change the channels we use to contact you, such as email or post, please contact us using the details provided on our Contact Us page.
2. Recipients / Categories of Recipients
In carrying out our business, including our obligations to you, we may use sub-contractors.
These may include IT network specialists or providers of some or all of the services that we provide to you.
We will ensure that they respect your privacy and abide by applicable data protection laws.
3. Transfers to Third Countries
As part of our processing activities, if we are required to transfer your personal data to another country, we will ensure that appropriate safeguards are in place.
Where necessary, we will have written data processing agreements with processors to help ensure an appropriate level of protection applies.
4. Retention Periods
We will keep your personal data in connection with the services or products you have bought for approximately 1 year after your purchase.
We need to retain this data for our own accounting purposes and for legal and tax purposes.
In terms of the personal data we use for marketing, we will keep this data for as long as we are able to market to you.
If you withdraw your consent or opt out of marketing communications, we will keep limited contact details where necessary to ensure that we do not contact you again for marketing purposes.
5. Data Subject Rights
You have rights in respect of your personal data.
We may need to confirm your identity before we can consider your request. If you wish to exercise any of these rights, we may ask for appropriate identification.
The Right to Be Informed
You have the right to be told about the collection and use of the personal data you provide.
This Privacy Policy sets out:
The purposes for which we process your personal data
How long we keep your data
Who we may share your data with
If you have any questions about how or why we process your data, please contact the DPO.
More information is available from the Information Commissioner’s Office:
https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/
Right of Access
You have the right to know whether we are processing your personal data and to request a copy of that data.
We may need information from you to enable us to locate your data.
If you want to exercise this right, please contact the DPO using the contact details above.
Right to Rectification
You have the right to have incorrect personal data corrected or completed if it is incomplete.
You can make this request verbally or in writing.
If you want to exercise this right, please contact the DPO using the contact details above.
Right to Erasure
This right, often referred to as the right to be forgotten, allows you to ask us to erase personal data where there is no valid reason for us to continue keeping it.
If you want to exercise this right, please contact the DPO using the contact details above.
Right to Restrict Processing
You have the right to ask us to restrict the processing of your personal data in certain circumstances.
If you want to exercise this right, please contact the DPO using the contact details above.
Right to Data Portability
You may have the right to move, copy or transfer certain personal data from one IT environment to another.
This right applies in certain circumstances where the data has been provided by you and is being processed by automated means based on consent or the performance of a contract.
If you want to exercise this right, please contact the DPO using the contact details above.
Right to Object
You have the right to object to our processing of your personal data in certain circumstances, including where processing is based on:
Legitimate interests
Direct marketing, including profiling
Certain research and statistical purposes
Direct Marketing
You have the right to ask us to stop processing your personal data for the purposes of direct marketing.
We will action your request as soon as reasonably possible.
Rights Relating to Automated Decision Making and Profiling
You have rights in relation to automated decision making, including profiling.
Where we carry out solely automated decision making that has legal or similarly significant effects on you, we will only do so where permitted by law.
Where applicable, we will tell you about this and explain how you can request human intervention or challenge the decision.
6. Processing Based on Consent
Where we process your personal data based on your consent, you have the right to withdraw that consent at any time.
You can opt out by using the unsubscribe or opt-out function in marketing communications we send you, or by contacting the DPO using the contact details above.
Who Do We Share Your Personal Information With?
We may share your personal information with selected third parties where this is necessary to provide the service you have requested, where you have provided your consent, or where another lawful basis applies.
The Will Associates Limited
Your personal information may be shared with The Will Associates Limited (Company Number 07118208) where this is necessary in connection with will writing, estate planning or related services that you have requested or expressed an interest in.
The Will Associates Limited may contact you using the details you have provided in order to discuss, provide or administer these services.
Marketing Service Providers
We may share your information with selected marketing service providers where appropriate.
These may include:
Tieta UK LTD
BHDB Associates LTD
OneFamily
These organisations may use information for permitted marketing, promotional, profiling or relationship-management purposes where an appropriate lawful basis exists.
Other Third Parties
We may also share your personal information with service providers and other organisations that help us operate our business and provide our services.
Your information may be shared where the organisation has its own lawful basis for processing.
This may include activities such as:
Identity verification and validation
Anti-money laundering checks
Fraud prevention and detection
Crime prevention and detection
Asset recovery
Asset reunification
Other legally permitted purposes
Where we share your personal information, we require organisations handling that information to do so in accordance with applicable UK data protection law.
What Do We Use Your Personal Information For?
We may use your personal information to:
Pass your details to selected clients or service providers where appropriate
Provide you with information about products and services
Respond to enquiries you have made
Provide services you have requested
Conduct market research
Manage marketing preferences
Add you to our suppression or do-not-contact records
Send newsletters, news, promotions or other marketing communications where permitted
Undertake segmentation and profiling
Help make advertising and marketing more relevant
Assist selected clients or service providers in delivering relevant services
Meet legal, regulatory, fraud prevention or identity-verification requirements
Where profiling is undertaken, information may be combined with other lawfully obtained information in order to better understand customer interests and characteristics.
Marketing Service Providers
We may share data with marketing service providers that use information to help organisations better understand the likely characteristics of their customers, communicate with them more effectively and identify similar audiences.
This may mean that you receive advertising that is more relevant to you through channels such as:
Direct mail
Email
Telephone
Online advertising
Our currently identified marketing service providers may include:
Tieta UK LTD
BHDB Associates LTD
OneFamily
What If I Don't Want to Receive Any More Information From You?
You can opt out of marketing communications at any time.
Where appropriate, we may retain limited information about you on a suppression or do-not-contact list.
This helps us ensure that your preferences are respected and reduces the risk of your information being added back into marketing databases in the future.
What Other Rights Do I Have?
Depending on the circumstances, you may have the right to:
Withdraw consent
Object to processing
Request access to your personal information
Request correction of inaccurate information
Request deletion of your information
Request restriction of processing
Request data portability
Lodge a complaint with a supervisory authority
7. The Right to Lodge a Complaint With the Supervisory Authority
If you are unhappy with any aspect of our handling of your personal data, you can make a complaint to the Information Commissioner’s Office (ICO).
More information is available at:
https://ico.org.uk/make-a-complaint/
8. Statutory / Contractual Requirement to Provide Personal Data
The personal data that you provide to us may be necessary for us to provide the services you have requested or to carry out a contract you have entered into with us.
For example, we may require:
A valid email address to communicate with you
Valid address details for administrative or billing purposes
A valid telephone number to contact you regarding your enquiry, account or service
9. Automated Decision Making Including Profiling
We do not currently undertake automated decision making or automated profiling that would produce legal or similarly significant effects on you, other than anything expressly explained within this Privacy Policy.
10. Cookies
A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect certain information from the browser.
Please refer to our Cookie Policy for more information.
11. Third Party Websites
Our website may contain links to other websites that are outside our control and are not covered by this Privacy Policy.
If you access other websites using links provided on our website, those organisations may collect information from you in accordance with their own privacy policies.
Their privacy policies may differ from ours.
12. Changes to This Privacy Policy
This Privacy Policy is regularly reviewed and may be updated where necessary.
If we make any significant changes to the policy, we will communicate those changes where appropriate.