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PRIVACY POLICY – FINANCIAL COMPANION
INTRODUCTION
Financial Companion is committed to protecting and respecting your privacy. We wish to be transparent on how we process your personal information and demonstrate that we are Accountable in accordance with the EU General Data Protection Regulation (EU 2016/679). It is the intention of this Privacy Policy to explain to you the Privacy Management practices of Financial Companion in relation to the personal information we collect and process about you.
In accordance with the EU GDPR (2016/679) and the Data Protection Act 2018, Financial Companion is identified as a Data Controller, there may be occasions, when we are also identified as a Data Processor.
This on-line Privacy Policy relates to personal information which we collect through our website and associated technologies and does not relate to personal information which Financial Companion collects manually.
By willingly providing personal and other information to us you are consenting to the terms and conditions of this Privacy Policy. Please read this policy carefully, as this sets out the basis on which any personal information, we collect from you, or that you provide to us, will be collected and processed by Financial Companion.
WHO ARE WE?
Dave Kavanagh T/A Financial Companion is a QFA (Qualified Financial Adviser), based in Drogheda, Co Louth, and is authorised and regulated by the Central Bank of Ireland, to provide financial advice and arrange for financial products to be put in place from authorised and regulated product providers. Financial Companion provides tailored financial solutions to meet the specific requirements of our clients.
HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU
When you browse our website www.financialcompanion.ie, we may ask for personal information (such as your name, email address. We may also collect information about you when you are on the internet such as the website you came from, IP address, domain types, i.e., co.uk and .com), your browser type, the country where your internet service is located, the pages of our site that were viewed during your visit and search terms you used. This information is only used for our own research and to improve our service to you. Your IP address is used to gather local broad demographic information.
To measure the effectiveness of our on-line presence, Financial Companion may use Cookies to determine the path users take on our site and to identify repeat visitors to the website.
We collect personal information from you when you register on our website, either by email, or by filling out a form. Information that we will process in connection with our services includes, your name, company name, email address, postal address, phone number (s) and any other information that itself can identify or, when tied to the above information, may identify you as a specific individual. This additional information will include financial information. We will also collect personal information when you have consented to receiving marketing material and when you have subscribed to receiving our newsletters.
HOW WE USE YOUR PERSONAL INFORMATION
To process your personal information, we are mandated to identify our lawful basis to collect and further process your personal information. In accordance with EU GDPR legislation, we will rely most commonly on the following legal bases to collect and further process your personal information, Consent, Explicit Consent, Contractual Necessity, Legal & Regulatory Obligation, Legitimate Interest.
We may engage with third-party stakeholders and working partners for the following purposes:
To facilitate our service
To provide the service on our behalf
To perform related services or
To assist us in analysing how our Service is used.
We may process your personal information for more than one lawful basis depending on the specific purpose for which we are using your personal information.
We set out below a description of various ways we process your personal information and details of the legal bases we rely on to do so. Please note that this is not an exhaustive list of our processing activities.
|
PURPOSE |
CATEGORY OF DATA |
LAWFUL BASIS |
|
To register you as a client |
Name, address, phone no, email address |
Contractual Necessity |
|
To deliver our products and services to you |
Name, address, phone no, email address |
Contractual Necessity |
|
To reply to enquiries |
Name, address, phone no, email address |
Contractual Necessity |
|
To provide quotations |
Name, address, email address, financial personal information |
Consent and/or Explicit Consent, Contractual Necessity |
|
To Issue invoices/Payment Services |
Name, Address, email address |
Contractual Necessity/Legitimate Interest |
|
To manage and administer your use of our services and to manage our relationship with you |
Name, Address, Email address |
Contractual Necessity/Legitimate Interest |
|
To comply with our legal and regulatory obligations |
Name, (possibly, address and email address). Where relevant, photo & address verification ID |
Legal obligation |
|
To send our Newsletters to you |
Name, email address |
Consent |
SOURCE OF COLLECTION
You provide personal information to us when you visit our website www.financialcompanion.ie. We also collect your personal information when you send us an email or send an enquiry. We also collect personal information when you subscribe to our mailing list and when you consent to receiving our newsletters.
We use the social media platforms of WhatsApp, Facebook, Twitter, Instagram and YouTube. Personal information may be collected through these platforms.
DO WE USE COOKIES?
Yes, we use Cookies on www.financialcompanion.ie. Cookies are files with a small amount of data that is commonly used as an anonymous unique identifier. These are sent to your browser from the website that you visit and are stored on your computer’s hard drive. We use Cookies which are necessary to enable core functionality, such as security, network management and accessibility.
Our website also uses Google Analytics to collect information and to improve our service. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your computer. If you choose to refuse our cookies, you may not be able to use some portions of the service. For full information on our use of Cookies, we would refer you to our separate Cookie Policy which you will find on our website www.financialcompanion.ie
THIRD PARTY SITES
Our service may contain links to other sites. If you click on a Third-Party link you will be directed to that site. Please be aware that these third-party sites are not operated by Financial Companion. We strongly advise you to review the privacy policies of these third-party sites. We do not take any responsibility for the content of privacy policies or practices of any third-party sites or services.
CHILDREN
We do not knowingly collect personal information from children under the age of 18 If you are under 18, do not access, use, or provide any personal information on www.financialcompanion.ie or through any of its features. If we learn that we have collected or received personal information from a child under 18 without parental consent, we will delete that information.
INTERNATIONAL TRANSFERS
It is not the practice of Financial Companion to transfer personal information beyond European and EEA territories without the consent of our clients. If we transfer personal information to a Third Party or outside the EU, Financial Companion as the Data Controller will ensure the identified recipient Data Processor or Controller has implemented all the appropriate safeguards to protect your personal information.
HOW WE STORE YOUR DATA SECURELY
We have implemented appropriate operational and technological security measures to prevent your personal information from being compromised in any manner. We take commercially reasonable steps to protect your personal data when you transmit it from your computer and device to our site. You should be aware that no internet transmission is ever 100% secure or error free, you should therefore take special care in deciding what information you send to us by email.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
It is not the practice of Financial Companion to retain personal information for longer than is considered necessary. We are however, mandated to comply with the legal requirements of Independent Statutory legislation and regulatory obligations. We will not retain personal information for more than 6 years after your last transaction with Financial Companion or 6 years after the date on which the particular transaction is discontinued or completed, in accordance with the Central Bank Consumer Protection Code.
WHO ARE WE SHARING YOUR PERSONAL INFORMATION WITH?
Unless you choose to apply for a product from one or more of the product producers, Financial Companion will not share any of your personal information with Third Parties. In any respect, Financial Companion will not share your personal information with any Third Party for marketing purposes, or any purpose not related to you applying for a product provided by that Third Party.
Financial Companion will only share your relevant personal information to Third Party service providers contracted to Financial Companion, when you apply through us to commence one of more of their products. Any Third Parties that we may share your personal information with are obliged to keep your details securely and to use them only to fulfil the service they provide on your behalf. Financial Companion will ensure that all Data Sharing Agreements have been completed and signed in advance of the sharing of personal information to Third Party Stakeholders or Working Partners.
There are circumstances where Financial Companion are legally mandated to share personal information in accordance with Independent Statutory legislation and in accordance with our regulatory requirements. We detail below a list of our Stakeholders and Working Partners with whom we share personal information for the purposes of providing their products and services to our clients. This list is, however, not exhaustive:
DATA SUBJECTS RIGHTS
In accordance with The EU General Data protection Regulation (EU 2016/679) and The Data Protection Act (2018) you are afforded the following rights in certain circumstances.
Right of Access: You have the right to obtain confirmation from us, whether we process personal information about you and where that is the case, access to the personal data, including the purposes of processing and the categories of personal data concerned. The recipients or categories or recipients to whom the personal information have been or will be disclosed. You may also submit a written request for a copy of personal information you believe we may be processing about you.
Right to Rectification: You have the right to the rectification of inaccurate personal information about you without undue delay.
Right to Erasure: You may ask us to delete your personal information, however, this is not an absolute right and any such request will be considered in accordance with EU GDPR legislation and The Central Bank Consumer Protection Code.
Right to Restrict & Object: You have the right to restrict or object to Financial Companion using your personal information.
Right to Data Portability: Upon receipt of your written request, where possible, we can share a digital copy of your personal information with you or another organisation.
FAILURE TO PROVIDE FURTHER INFORMATION
If we are collecting your personal information for a contract with a product provider and you cannot provide this personal information, the consequences of this could mean the contract cannot be completed or details are incorrect. When we collect personal information from you for the purpose of providing advice, any omissions, or errors by you may compromise the quality and accuracy of the advice given.
PROFILING – AUTOMATIC DECISION MAKING
Financial Companion may use an automated decision-making system, in accordance with The Central Bank Consumer Protection Code. The two areas where this would occur are:
ADDITIONAL PROCESSING
If we intend to further process your personal information for a purpose other than for which the information was collected, we will do so only with your consent.
HOW YOU CAN CONTACT US
Taking into consideration the size of our organisation0 and the nature of our data processing activities we are not mandated to appoint a designated Data Protection Officer. However, in the event you have any questions regarding how we process your personal information you can email us at privacy@financialcompanion.ie
You can also write to our Data Protection Compliance Officer, Mr Dave Kavanagh, Financial Companion, 22 Avondale, Wheaton Hall, Drogheda, Co Louth, Ireland.
You may also contact the Data Commissioners Office, 21 Fitzwilliam Square South, Dublin 2. (Tel No: 00 353 578684800)
CHANGES TO THIS PRIVACY POLICY
Financial Companion may update this Privacy Policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It Is your responsibility to review this Privacy Policy periodically to ensure you are aware of any changes. By using our services, you agree to this privacy policy.
FEBRUARY 2021
© 2020 All rights reserved
Made by Biglemondigital.com
