Privacy Policy

Introduction

Electron Spark is committed to protecting your privacy and ensuring that your personal information is handled in a safe and responsible manner. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website or engage with our financial management services.

We are registered with the Information Commissioner's Office and comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Who We Are

Electron Spark is a financial management firm based in Bristol, United Kingdom. We are the data controller responsible for your personal information.

Our registered office is at 45 Queen Square, Bristol BS1 4LH, United Kingdom.

If you have any questions about this Privacy Policy or how we handle your data, you can contact us at [email protected].

Information We Collect

We collect and process different types of personal information depending on how you interact with us:

Information You Provide Directly

When you contact us or use our services, you may provide:

• Contact information including name, email address, postal address, and telephone number
• Financial information such as income, assets, liabilities, and investment details
• Identification documents for regulatory compliance
• Employment and business information
• Details about your financial goals and circumstances
• Any other information you choose to share with us

Information Collected Automatically

When you visit our website, we may automatically collect:

• Technical information including IP address, browser type, and device information
• Usage data such as pages visited, time spent on pages, and navigation patterns
• Referral source and exit pages
• Cookie data as described in our Cookies Policy

How We Use Your Information

We process your personal data for the following purposes:

Providing Our Services

We use your information to deliver financial advice and management services, including analyzing your financial situation, preparing recommendations, implementing strategies, and providing ongoing support.

Regulatory Compliance

As a regulated financial services firm, we are required to collect and retain certain information to comply with regulations set by the Financial Conduct Authority and other regulatory bodies. This includes conducting identity verification, maintaining records of advice given, and reporting as required by law.

Communication

We use your contact information to respond to enquiries, schedule appointments, provide updates on your financial plans, and share relevant information about our services.

Website Improvement

We analyze website usage data to understand how visitors interact with our site, identify areas for improvement, and enhance user experience.

Legal Obligations

We may process your data to comply with legal requirements, including anti-money laundering regulations, tax reporting obligations, and court orders.

Legal Basis for Processing

We process your personal data based on one or more of the following legal grounds:

• Contractual necessity: Processing is necessary to fulfill our contract with you or to take steps at your request before entering into a contract
• Legal obligation: Processing is required to comply with regulatory and legal requirements
• Legitimate interests: Processing is necessary for our legitimate business interests, such as improving our services, provided this doesn't override your rights and interests
• Consent: In some cases, we may ask for your explicit consent to process certain types of data, which you can withdraw at any time

Who We Share Your Information With

We may share your personal information with:

Service Providers

We work with trusted third-party service providers who help us deliver our services, including technology platforms, data storage providers, and administrative support. These providers are contractually obligated to protect your data and only use it for the purposes we specify.

Financial Product Providers

When implementing financial recommendations, we may need to share relevant information with banks, investment platforms, insurance companies, or other financial institutions. We only share the minimum information necessary to execute your instructions.

Professional Advisors

With your consent, we may share information with your accountant, solicitor, or other professional advisors to provide comprehensive service.

Regulatory Authorities

We may be required to disclose information to the Financial Conduct Authority, Her Majesty's Revenue and Customs, or other regulatory bodies when legally obligated to do so.

Legal Requirements

We may disclose your information if required by law, court order, or to protect our rights, property, or safety, or that of others.

We do not sell your personal information to third parties for marketing purposes.

Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encrypted data storage and transmission
• Secure access controls and authentication
• Regular security assessments and updates
• Staff training on data protection and confidentiality
• Secure disposal of data when no longer needed

While we take reasonable steps to protect your data, no method of electronic storage or transmission is completely secure. We cannot guarantee absolute security but remain committed to protecting your information to the best of our ability.

Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

For regulatory compliance, we are required to maintain records of financial advice and client information for a minimum of six years after our relationship ends. Some records may be kept longer if required by specific regulations or if there are ongoing legal obligations.

When we no longer need your information, we securely delete or anonymize it.

Your Rights

Under UK data protection law, you have the following rights:

• Right of access: You can request a copy of the personal information we hold about you
• Right to rectification: You can ask us to correct inaccurate or incomplete information
• Right to erasure: In certain circumstances, you can request that we delete your personal data
• Right to restrict processing: You can ask us to limit how we use your information in specific situations
• Right to data portability: You can request a copy of your data in a structured, commonly used format
• Right to object: You can object to processing based on legitimate interests or for direct marketing purposes
• Rights related to automated decision-making: You have rights regarding automated processing and profiling

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month.

Please note that some rights may be limited by regulatory requirements. For example, we may need to retain certain information to comply with FCA regulations even if you request deletion.

Cookies and Tracking

Our website uses cookies and similar technologies. For detailed information about the cookies we use and how to manage them, please see our Cookies Policy.

Third-Party Links

Our website may contain links to external websites operated by third parties. We are not responsible for the privacy practices of these websites. We encourage you to review the privacy policies of any third-party sites you visit.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make significant changes, we will update the "Last updated" date at the top of this page.

We encourage you to review this policy periodically. Continued use of our services after changes are posted constitutes your acceptance of the updated policy.

Contact Us and Complaints

If you have questions, concerns, or complaints about how we handle your personal information, please contact us at:

Email: [email protected]
Address: Electron Spark, 45 Queen Square, Bristol BS1 4LH, United Kingdom

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:

Website: www.ico.org.uk
Telephone: 0303 123 1113