Lydford Advisory Limited (trading as Ignition
Financial) (“We”) are committed to protecting and respecting your privacy.
out on our website www.ignition.financial) and any other documents referred to
on it) sets out the basis on which any personal data we collect from you, or
that you provide to us, will be processed by us. Please read the following
carefully to understand our views and practices regarding your personal data
and how we will treat it.
For the purpose of the EU General Data Protection
Regulation 2016/679 (GDPR), the controller of your data is Lydford Advisory
Limited, a company registered in England and Wales under company number
OC397133 whose registered office is at Suite 1.1, First Floor, Moray House, 23
– 31 Great Titchfield Street, London, W1W 7PA.
All your data will be held and used in accordance with
the GDPR and any relevant national laws which implement the GDPR and any
legislation that replaces it in whole or in part.
Information We may Collect from You
may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms on our site www.ignition.financial (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, [search for a product, place an order on our site,] participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, make an enquiry, provide feedback and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph or personal information.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
helps us to provide you with a good experience when you browse our website and
also allows us to improve our site. For detailed information on the cookies we
Uses made of the Information
We use information held about you in the following
- Information you give to us. We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased;
- to provide you, or permit selected third parties (further details of whom are set out in the ‘Disclosure of your Information’ section below) to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale to you, and you will be given an option to unsubscribe with each communication. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the registration form);
- to notify you about changes to our service;
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
The Legal Basis for Processing your Information
In accordance with GDPR, the
main grounds that we rely upon in order to process your information are as
- Necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information.
- Necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
- Necessary for the purposes of legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that we have established that those interests are not overridden by your rights and freedoms (including your right to have your information protected). Our legitimate interests include [responding to requests and enquiries from you or a third party, optimising our website and user experience, informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
- Consent. In some circumstances, we may ask for your consent to process your information in a particular way.
Disclosure of your Information
may share your personal information with any member of our group, which means
our subsidiaries, our ultimate holding company and its subsidiaries, as defined
in section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Lydford Advisory Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Where we Store your Personal Data
The data that we collect from you may be transferred
to, and stored at, a destination outside the European Economic Area (“EEA”). It
may also be processed by staff operating outside the EEA who work for us or for
one of our suppliers. Such staff may be engaged in, among other things, the
fulfilment of your order, the processing of your payment details and the
provision of support services. By submitting your personal data, you agree to
this transfer, storing or processing. We will take all steps reasonably necessary
to ensure that your data is treated securely and in accordance with this
To the extent that any of your data is provided to
third parties outside the EEA, or accessed by third parties from outside the
EEA, we will ensure that appropriate safeguards are in place in accordance with
the GDPR (such as the European Commission’s standard contractual clauses, or
the EU/US Privacy Shield).
Where we have given you (or where you have chosen) a
password which enables you to access certain parts of our site, you are
responsible for keeping this password confidential. We ask you not to share a
password with anyone.
Unfortunately, the transmission of information via the
internet is not completely secure. Although we will do our best to protect your
personal data, we cannot guarantee the security of your data transmitted to our
site; any transmission is at your own risk. Once we have received your
information, we will use strict procedures and security features to try to
prevent unauthorised access.
Long we Hold your Information
We will only
retain your information for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal,
accounting or reporting requirements. The criteria that we use to determine
retention periods will be determined by the nature of the data and the purposes
for which it is kept, the sensitivity of the data and the potential risk of
harm from unauthorised use or disclosure.
You have certain rights in relation to the personal
data that we hold about you. Details of these rights and how to exercise them
are set out below. Please note we will require evidence of your identity before
we are able to respond to your request.
- Right of Access. You
have the right at any time to ask us for a copy of the personal information
that we hold about you and to check that we are lawfully processing it. Where we have good reason, and if the GDPR
permits, we can refuse your request for a copy of your personal information, or
certain elements of the request. If we refuse your request or any element of
it, we will provide you with our reasons for doing so.
- Right of Correction or Completion. If personal information we hold about you is not
accurate or is out of date and requires amendment or correction you have a
right to have the data rectified or completed.
- Right of Erasure. In
certain circumstances, you have the right to request that personal information
we hold about you is erased e.g. if the information is no longer necessary for
the purposes for which it was collected or processed or our processing of the
information is based on your consent and there are no other legal grounds on
which we may process the information.
- Right to Object to or Restrict Processing. In certain circumstances, you have the right to object
to our processing of your personal information.
For example, if we are processing your information on the basis of our
legitimate interests and there are no compelling legitimate grounds for our
processing which override your rights and interests.
You may also have
the right to restrict our use of your personal information, such as in
circumstances where you have challenged the accuracy of the information and
during the period where we are verifying its accuracy.
- Right of Data Portability. In certain instances, you have a right to receive any
personal information that we hold about you in a structured, commonly used and
circumstances, you can ask us to transmit that information to you or directly
to a third party organisation.
While we are
happy for such requests to be made, we are not able to guarantee technical
compatibility with a third party organisation’s systems. We are also unable to
comply with requests that relate to personal information of others without
You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
Our site may, from time to time, contain links to and
from the websites of our partner networks, advertisers and affiliates. If you
follow a link to any of these websites, please note that these websites have
their own privacy policies and that we do not accept any responsibility or
liability for these policies. Please check these policies before you submit any
personal data to these websites.
to Withdraw Consent
In the limited
circumstances where you may have provided your consent to the collection,
processing and transfer of your information for a specific purpose, you have the
right to withdraw your consent for that specific processing at any time. You can do this by contacting us using the
details in the ‘Contact’ section below.
Once we have
received notification that you have withdrawn your consent, we will no longer
process your information for the purpose or purposes you originally agreed to,
unless we have another legitimate basis for doing so in law.
If you are
unhappy about our use of your information, you can contact us using the details
in the Contact section below. You are also entitled to lodge a complaint with
the UK Information Commissioner’s Office using any of the below contact
Telephone: 0303 123 11113
Post: Information Commissioner’s Office
If you live or
work outside of the UK or you have a complaint concerning our activities
outside of the UK, you may prefer to lodge a complaint with a different
supervisory authority. A list of
relevant authorities in the EEA can be accessed here.
future will be posted on this page and, where appropriate, notified to you by
e-mail. Please check back frequently to see any updates or changes to our