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The Brightstar Group comprises of:
Bright Star Financial Limited, trading as Brightstar, Bright Star, Brightstar Financial Solstar Insurance Brokers, trading as Solstar
Sirius Property Finance Group Ltd trading as Sirius Finance, Sirius Portway Finance Ltd trading as Portway
Professional introducers of client business
For the purposes of this Privacy Notice, Brightstar Financial, Bright Star or Brightstar are all trading styles of Bright Star Financial Limited and is a data controller as defined in the General Data Protection Regulation (GDPR). This is because Bright Star Financial Ltd may in some cases determine how your personal information will be used.
By personal information, we mean information which, either by itself or combined with other information that is available to us, can be used to identify you, your principals, directors, shareholders or anyone employed by you or engaged by you who may access our online
systems. For the purpose of this Privacy Notice, where we refer to “you” or “your” this will also include your principals, directors, shareholders, employees, contractors and workers.
If you are referring or passing personal client data to us, please do so under the terms of your original Introducer Agreement.
Forenames, last name, maiden name, date of birth, gender, marital status, and username or similar identifier.
Home address, business address, email address, telephone and fax numbers.
Banking details (to enable payment of fees payable to you).
Internet Protocol (IP) address, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices used to access www.brightstarfinancial.co.uk or its associated sub systems or applications.
Profile and usage information
Feedback and survey responses, and how you use our website, products and services
Marketing and communications information including your preferences in receiving future news and services from Brightstar.
Why we need your data?
We will only collect and use your personal information in accordance with data protection laws for the purpose of facilitating your registration onto our intermediary panel and onward processing of any applications you make on behalf of your clients through Brightstar or easysource. Our grounds for processing your personal information are as follows:
For the purposes of performing our Contract (Introducer Agreement) with you. This includes the administering and management of our relationship in relation to the role that you undertake under the Agreement with Brightstar. For more information, please refer to the Introducer Agreement.
For the purposes of our own legitimate interests – We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Our grounds for processing your personal information are as follows:
For the management of our own accounting and other business operations.
To monitor emails, calls and other communications in line with our agreement with you as an intermediary to Brightstar Financial Ltd.
To respond to case enquires or grievances / complaints.
Records of any surveys that you may be asked to complete for research purposes (although you do not have to respond to them).
Developing statistics for market research and ongoing analysis to improve ourwebsite, product / services, marketing, customer relationships and experiences.
To deal with our good governance requirements.
For the purposes of future marketing under Consent - You will be asked for your Consent to receive communications from Brightstar in relation to our services and products. We will never sell or pass your details onto third parties.
Where we store your personal data
Once we have received your personal data, we will use (and require our suppliers and partners to use) procedures and security features to try to prevent unauthorised access, unlawful processing, accidental loss or destruction of, or damage to it. However, the transmission of information via the internet is not completely secure and, while we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our service and any transmission is at your own risk.
How long we keep your data
Businesses or individuals conducting business related activities with Brightstar will be initially opted in for marketing purposes upon registration with our systems. You will be given the option to unsubscribe from marketing e-mails utilising an “unsubscribe” option contained within every marketing e-mail. The information we use for marketing purposes will be kept with us until you notify us that you no longer wish us to retain this information.
If you have any concerns or would like to be removed from future marketing, please contact us on
Disclosure of your information
We will keep your personal data confidential and only disclose it to others for the purposes of facilitating your loan application(s) on behalf of your client(s), as well as in the following specific circumstances:
To investigate, prevent or detect fraud or carry out checks against money laundering.
For audit purposes and to meet obligations to any relevant regulatory authority or taxing authority.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements to which you are a party; or to protect our rights, property, or safety, or that of our customers or others (which includes exchanging information with other companies and organisations for the purposes of fraud protection and credit
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, or.
If substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
You have provided us with expressed prior consent to share your information in connection with a specific project or proposition not listed above.
The use of your data with regards to Trustpilot
We have teamed up with the independent review company Trustpilot to collect independent customer reviews. Trustpilot may contact you via the email address provided, to ask you to share your experience of Brightstar Financial Ltd. The only information we share with Trustpilot is your name and email address to enable them to contact you with a feedback request. You are under no obligation to provide feedback
via this method.
Businesses or individuals conducting business related activities with Brightstar will be opted in to receive Trustpilot review requests upon registration with our systems.
Trustpilot will only use basic name and e-mail address details to send one review request and one reminder.
Any customer details will not be used for any other purpose and cannot be given to any 3rd party organisations or businesses.
You have the right to request a copy of the personal information that we hold about you, its origin and any recipients of it as well as the purpose of any data processing carried out.
Right to access: the right to request copies of your personal information from us.
Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete.
Right to erase: the right to request that we delete or remove your personal information from our systems.
Right to restrict our use of your information: the right to ‘block’ us from using your personal information or limit the way in which we can use it.
Right to object: the right to object to our use of your personal information.
Right to data portability: the right to request that we move, copy or transfer your personal information.
Phone – 01277 500 900
Address – 7 Woodbrook Crescent, Billericay, Essex, CM12 0EQ
We will aim to respond to all requests within 30 days except in instances where the request may be complex. We shall let you know within the 30-day period if we will need more time but no longer than 90 days.
If you wish to raise a complaint on how we have handled your personal data, you can contact us to have the matter investigated. Email – email@example.com
Phone – 01277 500 900
Address – 7 Woodbrook Crescent, Billericay, Essex, CM12 0EQ
If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law, you can complain to the Information Commissioner’s Office http://ico.org.uk/
This Policy was made available when first registering for easysource, it is your responsibility to have read and understood this policy prior to accepting the Terms and Conditions.
We keep our privacy notice under regular review. This privacy notice was last updated on 20th December 2023.
In these Terms the following expressions shall have the following meanings where the context otherwise requires:
2. THE RELATIONSHIP.
2.1. These Terms set out the basis on which we accept enquiries and applications from you and govern the provision and use of the services. By registering on LaunchPad, you agree to these Terms and Conditions of business. These terms supersede any previously issued terms of business between us and you.
2.2. We usually only accept enquiries and applications if you are authorised by the appropriate regulator as evidenced by entry on the Financial Services Register and hold all other relevant consents, permissions, registrations or licences for the purpose of carrying out your business in accordance with these terms.
For introducers who do not hold licences or authorities to deal directly with clients for the intended services, we will take over the client entirely and will only provide you with updates if you hold an ICO licence.
If we are acting as a Packager, this is an unregulated activity where we work between the broker and the lender. We are unable to deal directly with the client, and by instructing us to package a case you accept that the sole duty of care of the client(s) remains with you as the introducing and advising broker.
2.3. Notwithstanding Clause 2.2, We reserve the right at our sole discretion to decline all or any enquiries or applications and we are not required to give a reason for doing so.
2.4. We may report to the FCA/Principal Networks the basis on which business is conducted between you and your client. You acknowledge and accept that we will treat the business as being conducted on an “advised? basis unless you tell us otherwise when you submit the enquiry or application.
2.5. You are not and may not purport or hold yourself out to be our agent unless specifically authorised in writing by us.
2.6. You are presumed to act on behalf of the client throughout your relationship with us, as governed by these terms, unless and until such time as we are advised otherwise.
2.7 You are our customer and we will only transact or communicate with you, not the client.
2.8 Any client that is introduced to The Brightstar Group as an enquiry or application, will be retained by you. As such The Brightstar Group will not attempt to contact the client or offer any services to said client without your permission.
3. YOUR DUTIES.
warrant and represent that you:
3.1.1. will obtain the client’s authorisation to be their agent prior to submitting an application to us and you acknowledge that you may not submit applications without such authorisation from the client;
3.1.2. hold all relevant legal, regulatory, and other authorisations necessary for carrying out your business and for referring enquiries and applications to us (except in the instances where a full client handover has been agreed);
3.1.3. otherwise conduct your business in accordance with the requirements of all relevant laws and regulations including without limit the FCA and/or PRA handbooks (and all regulations made thereunder) and any applicable guidance issued by the FCA from time to time and will not by your acts or omission do anything to cause us to be in breach of these regulations. This will also include the obligations and requirements of the Consumer Duty Regulation.
3.1.4. will act diligently and in good faith in all your dealings with us and the clients; and
3.2.1. that during completion of an enquiry/application, You will make the client aware of all declarations and statements that you make on your behalf and explain key information throughout the enquiry/application that will affect the client, and where necessary obtain the client’s consent to use of his/her information by us and lender(s) including but not limited to information in relation to the lenders use of their personal information and the effects of credit scoring and credit checks which may be undertaken by us in order to process an enquiry/application.
3.2.2. that you will maintain the confidentiality of any username and password used by you in our system, LaunchPad.
3.2.3. to act honestly and professionally and to use all due skill and care when acting for the client, by completing a compliant, full interview, and advice process as detailed in the FCA Sourcebook (MCOB); including (but not limited to) ensuring compliance with – and demonstration of -the Consumer Duty and that the application is suitable for the client in cases where you advise on the same.
3.2.4. to use best endeavours to ensure that information provided to us is true, accurate and complete in all material respects.
3.2.5. to keep all details of clients up to date;
3.2.6. not to refer enquiries/applications to us as a direct or indirect consequence of the activities of any person who is not appropriately authorised or exempt from authorisation by any relevant regulatory authority.
3.2.7. that You will promptly notify Us of any material matters relating to your business (including without limitation any matters affecting any authorisations You hold) and will promptly provide us with any material information relating to your business which we reasonably request from time to time; and
3.2.8. that you will not seek to entice any of our employees (or agents) to enter into Your employment or agency during the term of this agreement or for a period of 12 months thereafter.
agree to inform Us immediately in writing if:
3.3.1. You cease to act on behalf of a client;
3.3.2. any of your authorisations, registrations or permissions needed to conduct all or part of your business lawfully are not current or are believed to be in jeopardy or if You are the subject of any enforcement action by the FCA.
3.3.3. You become aware of any unauthorised use of any username or password;
3.3.4. You become aware or believe that any information provided in or as part of an application is or may become untrue or incomplete; or
3.3.5. You commit a material breach of any relevant laws or regulations or these Terms
4. DOCUMENTATION AND COMMUNICATION.
4.1. You will pass on immediately to us or the Client as applicable, without amendment (unless otherwise agreed by us), any documentation which is either supplied by us for the benefit of or completion by the client or provided by the client in relation to the application. You will advise us of all material facts known by or divulged to you in relation to business is undertaken or to be undertaken with Us.
4.2. You will pass on to us all the necessary information and independently verifiable evidence that the client needs to provide to enable us to assess affordability on behalf of the lender.
4.3. You will not produce or distribute any documentation (unless supplied by us for distribution) containing our name without prior written consent.
4.4. You will not sign or amend any documents on our behalf nor make any statements or promises or representations of any kind whether written or oral which bind or purport to bind us or the lender. You will not hold Yourself out as having authority to make any such representation.
4.5. The Brightstar Group recommends that your clients should not instruct solicitors and incur costs until the case has been fully agreed by the lender in question.
5.1. We will pay to you or your regulated Principal / Network any payments due to you on the terms and at the rates formally agreed for the type of transaction undertaken or any other terms and rates separately agreed in writing between us and you. Unless we have agreed otherwise we will make any payments into the designated account, details of which you have provided us with. A note of the terms and rates applicable at any time shall be available on request. We may change the rates of payments without notice.
5.2. We will
cease making any Payments to You if:
5.2.1. We are notified in writing, or it is reasonable to infer, that You are no longer validly acting on behalf of the Client; or
5.2.2. We are prevented from making Payments by the operation of any law or regulation;
5.2.3. We are notified by your Principle Firm or Network that you have ceased to work for them.
5.3. We reserve the right to suspend all Payments in the event You enter into a voluntary arrangement, are the subject of bankruptcy or liquidation proceedings, have a receiver or administrator appointed over any assets, cease to hold any relevant material regulatory authorisation or are charged with or convicted of any offence involving fraud or dishonesty. If We exercise this right, We may hold on to the Payments until We have a clear direction from the courts or any relevant insolvency practitioner appointed as to whom We must make such payment. Suspension is without prejudice to Our rights to set off under these Terms or at law. In the foregoing references to You includes any of Your directors or partners.
5.4. We will not make any Payment to You in respect of any Application which has been fraudulent or does not proceed to completion or where We become aware You are in material breach of these Terms in respect of such Application.
6.1. You will reimburse us forthwith upon demand the amount of any payments: made by Us to You in error (and You shall promptly notify Us of the same); made by Us which relates to any application in respect of which You are materially in breach of these Terms, where the Application has been fraudulent or where completion has been delayed or does not occur.
6.2. Any sums due from or payable by You shall be recoverable by Us under any account with Us regardless of the type of business for which the account is held. Any sums due from You to Us may be deducted from any sums owed or which become owing by Us to You.
6.3. Exercise by Us of Our rights under this Clause 6 shall be without prejudice to any other rights or remedies available to Us under these Terms or otherwise available to Us.
7. MONEY LAUNDERING.
7.1.1. evidence of the identity of all Clients introduced by you shall be obtained and recorded (prior to the placing of business with us) under procedures maintained by You in accordance with the provisions of the UK Money Laundering Regulations 2007 (the “Regulations”) (and all Directives, Regulations, Rules and Guidance Notes issued in substitution, amendment or addition thereto) and any of Our requirements from time to time notified to You; and provide a copy /copies to Us as required.
8. CONFIDENTIALITY AND DATA PROTECTION.
8.1. Some or all of the information supplied to Us in connection with an Application will be held on computer and paper and will comprise Personal Data (as defined by the DPA / GDPR). Unless required to do so by law, we will not disclose such information to anyone else other than the lender and their third parties to assist in the provision and servicing of the business you have introduced to us, or any prospective transferees or assignees, for any other purpose covered within these terms.
warrant, represent, and undertake to Us that, prior to communicating a Client’s
personal and/or sensitive data:
8.2.1. You will draw the information in relation to data protection and which appears on any relevant document to the Client’s attention and, in particular, make the Client aware of the purposes for which We will process personal data and to whom that data may be disclosed; and
8.2.2. You will obtain the Client’s consent to such use of their personal information.
8.3. For the avoidance of doubt, We may use personal data supplied to Us by or on behalf of a Client for any purposes to which the Client consents and is not in conflict with any pre-existing contractual arrangements.
8.4. We and You confirm to each other that We are notified under the DPA / GDPR and each agrees at all times to comply with the provisions of the DPA / GDPR. You also confirm that you have, and will maintain, suitable systems and processes to ensure compliance with this regulation. You warrant that you can provide confirmation if required to do so.
8.5. Please note that telephone calls may be recorded or monitored for security, Compliance and / or training purposes.
9. INDEMNITY AND LIMITATION OF LIABILITY.
9.1. You will indemnify Us in respect of any liability, losses, damages, or costs We may suffer or incur arising from any breach of the warranties, representations, or obligations under these Terms (including any breach of a relevant regulatory rule or applicable law) or by reason of any misrepresentation or negligent, tortuous or fraudulent act or as a result of any incorrect or misleading information that has been knowingly or negligently provided by You whether to Us, a Client or any other person. This indemnity is a continuing to apply after termination of these Terms, for whatever reason.
9.2. We will only be liable to You for losses arising directly as a result of negligence, fraud, or wilful default by Us. In no event will We be liable for special, indirect, consequential damages or losses, or for loss of data, profit or business opportunity.
9.3. Nothing in these Terms shall have the effect of excluding or limiting either party’s liability to the other where such exclusion or limitation would not be lawful.
10.1. Where there are changes in legislation or the rules or guidance of any relevant statutory regulatory authority, any relevant provisions in these Terms will be deemed to be amended accordingly.
11.1. Either party may terminate the agreement on these Terms by giving one month’s notice to the other.
may terminate the agreement on these Terms with immediate effect on the
occurrence of any one or more of the following:
11.2.1. Any material breach by You or any person or body for which You are responsible for any of the provisions contained within these Terms;
11.2.2. Any misconduct by You, any of Your directors or partners, or any person or body for which You are responsible which is or could be reasonably viewed as prejudicial to Our business or reputation;
11.2.3. You cease to be appropriately authorised;
11.2.4. cessation or suspension or intended cessation or suspension of Your operation or in any circumstance wherein Our reasonable opinion it is likely to affect materially Your ability to perform Your obligations under these Terms; or
11.2.5. material litigation, insolvency, or reconstruction involving You (including any of your partners if you are a partnership) including (without limitation) bankruptcy, dissolution, sequestration, administration, winding up, or seizure of assets or entry into any arrangement or composition with creditors.
11.3. Any termination by Us shall be without prejudice to any other remedies that We may be able to pursue against You, including in respect of accrued rights.
termination, You will:
11.4.1. not proceed any further with any Application and shall cease all promotion of Our business or the Mortgage Products;
11.4.2. be entitled to any unpaid Payments accrued to the date of termination but shall forfeit entitlement to all other Payments falling due after the date of termination.
notice under these Terms shall be in writing and may be served by sending the
notice (i) by facsimile to the latest facsimile number notified to the other
party from time to time or (ii) first class prepaid post, in Our case, to such
address as We advised You from time to time and in, Your case, to the last
address known to Us or (iii) by email to the latest email address notified to
the other party from time to time. Any notice shall be deemed to have been
received, in the case of:
12.1.1. facsimile, upon completion of the transmission subject to production of a successful transmission confirmation;
12.1.2. first class prepaid post, 48 hours from the time of posting; and
12.1.3. by email upon completion of transmission, subject to non-receipt of notification of failure of transmission.
13.1. These Terms shall be governed by and construed in accordance with the laws of England and Wales and You agree to the exclusive jurisdiction of the English and Welsh courts.
13.2. Any failure or delay by Us or You to exercise or enforce any rights under these Terms and/or in law shall not be deemed to operate as a waiver of any such rights nor prejudice their enforcement in any way.
13.3. You may not assign, transfer sub-contract, or otherwise dispose, in whole or in part, of any of Your rights or obligations, without Our prior written consent. All or any of our rights can be assigned at any time without Your consent and references to “We”, “Us” and “Our” includes Our assignees.
13.4. These Terms set out the entire agreement between Us and You in substitution of any previous oral, written or implied agreement or representations, to the extent permitted by law.
13.5. The parties do not intend that any term should be enforceable as a result of the Contracts (Rights of Third Parties) Act 1999 or otherwise by any person who is not party to these Terms.
13.6. In the event that any provision in these Terms shall be declared void, voidable, illegal, or otherwise unenforceable by a judicial or other competent authority the parties agree that any such provision shall be amended in such reasonable manner as achieves the intention of the parties without conflict with the judicial or other competent authority and that the enforceability of the remaining provisions shall not be affected.
13.7. Nothing in these Terms should be construed as indicating or giving rise to a joint venture or partnership.
13.8. You accept that under these Terms We may from time to time make such relevant searches and checks in respect of You and Your owners/principals (including in relation to creditworthiness) as We see fit.