Cookie policy
We may use information about your general internet usage by using a cookie file which is stored on the hard drive of your computer or device. Cookies contain information that is transferred to your computer or device’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
- To estimate our audience size and usage pattern
- To store information about your preferences, and so allow us to customise our site according to your individual interests
- To speed up your searches
- For security
- To recognise you when you return to our site.
You may refuse to accept cookies by activating the setting on your browser, which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.
1. Where we collect information from
- When you talk to us on the telephone (all calls are recorded and monitored for training and in order to improve our services to you) or face to face
- When you use our website
- From emails and letters
- When conducting audits of information held by Flagstone, to ensure we comply with relevant laws and regulations
2. Why we collect your personal data and the lawful basis we rely on to process it
Data Protection law says that we are only allowed to process your personal information if we have one or more of the following lawful reasons:
- To fulfil a contract we have with you
- When it is needed to comply with our legal duty
- When it is in our legitimate interest
- When you give us your consent.
A legitimate interest means that we have a commercial or business reason to use your information, however even then it must not unfairly go against what is right for you. If we rely on our legitimate interest, we will tell you what that is.
We may process your information to provide financial services to you (via Flagstone) which is in our legitimate interest. Despite your main contact point for Ironstone products being Flagstone, there may be occasions where we need to contact you by telephone, email, or text, including to comply with our regulatory requirements.
We may also process your information to comply with our legal and regulatory obligations, which includes completing audits on information held by Flagstone, which may include your personal information.
3. Marketing
We may use your information to tell you about relevant products and services which we consider would be suitable for you. We can only send you marketing if you have given us your consent.
4. Who we share your personal information with
In order to comply with the law and other regulations we may share your personal data with other third parties. However, those third parties are also bound to keep your personal data secure and confidential. We may transfer and disclose your information to:
Any authorities we are required to share information with by law or for regulatory purposes, for example, HMRC, Financial Conduct Authority, Information Commissioners Office, UK Financial Services Compensation Scheme.
Our auditors, as required to comply with our legal and regulatory responsibilities
Your advisers such as lawyers, accountants and financial or other professional advisers if you have authorised anyone like this to represent you.
5. Your rights in relation to your personal data
Under data protection laws, aw you have various rights in relation to your information. These rights are explained below:
How to get a copy of your information
You are entitled to request access to your personal data at any time by contacting us. We will provide you with access to your information without delay and within 1 month of receiving your request, or at the latest within 3 months.
Access will be provided free of charge unless your requests are excessive or unfounded in which case we are entitled to charge a reasonable administrative fee or we may refuse to respond. We will provide you with an explanation in either case.
Before complying with your request, we are obliged to verify your identity.
What to do if you think your information is incorrect
You can ask us to correct your information if you think it is incorrect. Please contact us if you want to do this.
We will correct information without undue delay and at the latest within one month of receiving the request from you.
If we have disclosed it to a third party, we will endeavour to contact them and inform them of the changes unless this is not possible or it would be disproportionate to do so.
What to do if you want us to stop using your information
You have the right to object to us using your information, ask us to restrict our use of it or ask us to delete it if there is no need for us to keep it. This is known as the “right to object”, the “right to restrict” and the “right to be forgotten”. There may however be a legal or another reason why we need to keep your information, however, we will inform you of this when you make your request.
You can ask us to stop processing your information where we are doing so for our legitimate interests or where you wish to withdraw your consent.
What to do if you want a reusable copy of your data
You have the right to receive a copy of the personal data we process in a format that can be reused or ask us to transfer your information to another organisation where possible, however, this only applies to personal data that is held electronically by us.
6. How long we keep your personal data
We will keep your personal data in accordance with our Data Retention Policy. In most cases we will keep it for 7 years after you have ceased your relationship with us in order to respond to any questions or complaints, show that we have treated you fairly or to maintain records according to rules that apply to us.
We may keep your information for longer than 7 years after you have ceased your relationship with us if it is needed for legal or regulatory reasons or where your information involves pension advice. We may also keep it for statistical purposes. If we do, we will make sure that your privacy is protected and only use your information for those purposes.
7. Changes to our Privacy Policy
We will keep our Privacy Policy under regular review and will place any amendments on our website www.ironstone.bank. This Privacy Policy was last updated in June 2024.
8. What to do if you are unhappy about the way in which we use your information
If you are unhappy, please contact us at dpo@weatherbys.bank You also have the right to make a complaint to the Information Commissioners Office (ICO) by contacting them at:
- www.ico.org.uk
- By telephone: 0303 123 1113 or from outside the UK +44 1625 545 700
- By post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF