Privacy Policy

Introduction

lunar-dock is committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy explains what information we collect, why we collect it, how we use it, and your rights regarding your personal data.

We take our responsibilities under UK data protection legislation seriously and comply with the UK General Data Protection Regulation and Data Protection Act 2018.

Who We Are

lunar-dock is a financial advisory practice authorized and regulated by the Financial Conduct Authority. Our registered office is located at 15 Eastcheap, London EC3M 1BU, United Kingdom.

For data protection purposes, we are the data controller responsible for your personal information. If you have questions about this policy or our data practices, please contact us at [email protected].

Information We Collect

We collect and process various types of personal information depending on our relationship with you:

From Prospective Clients

• Contact details including name, email address, and postal address
• Information you provide about your financial situation and goals
• Communication preferences
• Records of correspondence and conversations

From Current Clients

• Personal identification information including name, date of birth, and national insurance number
• Contact information including addresses, email, and phone numbers
• Financial information such as income, expenses, assets, and liabilities
• Employment and career details
• Family and dependant information relevant to financial planning
• Investment preferences and risk tolerance
• Tax information and records
• Bank account details for payment processing
• Copies of identification documents when required for regulatory purposes
• Records of our meetings, advice given, and transactions

Website Visitors

• Technical information including IP address, browser type, and operating system
• Usage data showing how you interact with our website
• Cookie data as described in our Cookie Policy

How We Collect Information

We obtain personal information through various methods:

• Directly from you during conversations, meetings, email correspondence, or through forms
• From third parties such as pension providers, investment platforms, or previous advisors when you authorize such disclosure
• Through publicly available sources when conducting necessary background checks
• Automatically through cookies and similar technologies when you use our website

Why We Use Your Information

We process personal data for specific purposes with appropriate legal basis:

Providing Financial Services

We use your information to deliver financial planning, investment management, and advisory services. This processing is necessary for performing our contract with you or taking steps at your request before entering into a contract.

Regulatory Compliance

Financial services are heavily regulated. We process information to meet obligations under FCA rules, anti-money laundering legislation, and other legal requirements. This processing is necessary for legal compliance.

Communication

We use contact details to send service-related communications, respond to inquiries, and provide updates relevant to your financial planning. This processing is necessary for contract performance and based on our legitimate interest in maintaining client relationships.

Business Operations

We process information for internal administration, record-keeping, quality assurance, and business development. This is based on our legitimate interests in running an efficient practice while ensuring we don't override your privacy rights.

Legal Claims

We may process information to establish, exercise, or defend legal claims. This is based on our legitimate interests in protecting our rights and those of our clients.

Sharing Your Information

We may share personal information with:

Service Providers

Third-party providers who support our operations, such as technology platforms, data storage services, and professional advisors. These providers are contractually bound to protect your information and use it only for specified purposes.

Financial Institutions

When implementing your financial plan, we share relevant information with investment platforms, pension providers, insurance companies, and other financial institutions. This is necessary to execute transactions and manage your arrangements.

Professional Advisors

With your consent, we may share information with your accountant, solicitor, or other advisors to ensure coordinated planning.

Regulatory Authorities

We disclose information to the FCA and other regulatory bodies when required by law or regulation.

Legal Requirements

We may disclose information when legally required, such as responding to court orders or assisting law enforcement investigations.

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

Data Security

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

Security measures include encrypted data transmission, secure data storage systems, access controls limiting who can view information, regular security assessments, and staff training on data protection.

While we strive to protect your information, no method of transmission or storage is completely secure. We cannot guarantee absolute security but continuously work to maintain appropriate safeguards.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this policy and meet legal obligations.

For clients, we typically retain records for at least seven years after our relationship ends, as required by FCA regulations. Some information may be retained longer when necessary for regulatory compliance, legal proceedings, or defending potential claims.

For prospective clients who don't proceed with our services, we retain basic contact information and correspondence for up to two years unless you request earlier deletion.

Website usage data is typically retained for shorter periods, usually no more than 26 months.

Your Rights

Under UK data protection law, you have several rights regarding your personal information:

Access

You can request copies of personal information we hold about you. We'll provide this within one month of receiving a valid request.

Correction

If information we hold is inaccurate or incomplete, you can request correction. We'll update records promptly when errors are identified.

Erasure

In certain circumstances, you can request deletion of your personal data. This right is limited when we have legal obligations to retain information, such as regulatory record-keeping requirements.

Restriction

You can request that we limit how we use your information in specific situations, such as while disputing data accuracy.

Portability

Where technically feasible, you can request that we transfer certain information to another provider in a structured, commonly used format.

Objection

You can object to processing based on legitimate interests. We'll cease processing unless we have compelling legitimate grounds that override your rights or need the information for legal claims.

Automated Decision-Making

You have rights regarding automated decision-making and profiling, though we don't typically make significant decisions through fully automated means.

To exercise any rights, contact us at [email protected]. We may need to verify your identity before responding to requests.

International Transfers

We primarily store and process data within the United Kingdom. If we transfer information outside the UK, we ensure appropriate safeguards are in place, such as standard contractual clauses approved by the UK authorities.

Some service providers we use may process data internationally. We select providers carefully and ensure they maintain adequate protection standards.

Children's Privacy

Our services are not directed at children under 16. We don't knowingly collect personal information from children for marketing purposes. When providing financial planning for families, we may process information about children as dependants, but this is limited to what's necessary for the service.

Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We'll post the updated version on our website with a revised date. Significant changes will be communicated directly to clients.

We encourage you to review this policy occasionally to stay informed about how we protect your information.

Contact and Complaints

If you have questions or concerns about this policy or our data practices, please contact us:

Email: [email protected]
Post: lunar-dock, 15 Eastcheap, London EC3M 1BU, United Kingdom

If you're unhappy with how we've handled your personal information, you have the right to complain to the Information Commissioner's Office (ICO), the UK's data protection regulator:

Website: ico.org.uk
Telephone: 0303 123 1113
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF