Table of Contents:
1. Customer Data Privacy
- Who we are
- The information we collect about you
- When we collect your information
- How and why we use your information
- How we use automated processing or “analytics
- Who we share your information with
- How long we hold your data
- Implications of not providing your data
- Transfer of information outside the European Economic Area
- Data Subject Rights – How to exercise your rights
- Our Contact Details
2. Website Data Privacy
1. Customer Data Privacy
Doyle Pension & Insurance Management ltd takes your privacy and confidentiality seriously. You provide us with personal and financial information and we want you to understand why we collect your data, what we do with it, who we share it with, why we share data, and understand your legal obligations.
This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR), which will come into force on 25th May 2018. From that date, the GDPR, together with applicable Irish requirements, will amend existing data protection law and place enhanced accountability and transparency obligations on organisations when using your information. The GDPR will also introduce changes which will give you greater control over your personal information, including a right to object to processing of your personal information where that processing is carried out for our business purposes.
Please take time to read this notice carefully. If you are under 16 years of age, please read this summary with a parent or guardian and ensure you understand it. If you have any questions about how we use your information, please contact us as shown below.
This summary explains the most important aspects of how we use your information and what rights you have in relation to your personal information.
If you would like clarification on any points in this summary document please contact us.
1.2 Who we are
Doyle Pension & Insurance Management ltd are a firm of financial advisers which provides advice on financial matters and arranges transactions or products suited to your needs. Further details of our services are provided in our Terms of Business document which we issue to all customers prior to providing a service or product.
1.3 The information we collect about you
We will hold:
- data to identify you, including your contact information i.e. name, address, telephone number(s), email address, gender, date of birth, occupation, PPS number, photographic identification, nationality;
- your financial details/financial circumstances as necessary i.e., employment, income, assets, liabilities, bank account details (where applicable);
- your marital or civil status;
- other sensitive information e.g. medical information which you provide to us, where necessary for the service to be provided;
- information about you provided by others e.g. your spouse/partner,
- professional advisers, etc.;
- information which you have consented to us using;
- other personal information, if applicable e.g. criminal conviction data, driving penalty points; telephone recordings of conversations;
- and information provided when exercising your rights.
Sometimes we may use your information even though you are not our customer. For example, you may be a beneficiary under a trust, a director of a client company, an employee of a client, a member of your employer’s pension scheme, or be a potential customer applying for one of our products or services.
1.4 When we collect your information
We collate information at the initial point of contact with you and aim to update this whenever you require a further service or product.
1.5 How and why we use your information
We collate, use and share information only where there is a legal basis for doing so. This includes where you have given us information in order to provide you with a service, product, or arrange a transaction for you.
Typically, the legal basis for using your data is to provide a service or arrange a transaction which you have requested. The legal basis will also include complying with our legal and regulatory obligations, e.g. under our Central Bank authorisations, interaction with the Data Protection Commission, Financial Services and Pensions Ombudsman, Revenue, Pensions Authority, when conducting Anti-Money Laundering checks, law enforcement agencies.
Where you have agreed or explicitly consented to the using of your data in a specific way, you may withdraw your consent at any time.
We may use your data if necessary to protect your “”vital interests” in exceptional circumstances e.g. where we suspect a fraud may be in the course of perpetration.
Data may also be used for our legitimate interests (which you may object to) such as managing our business, providing service information, conducting marketing activities, training and quality assurance, and strategic planning.
1.6 How we use automated processing or “analytics”
We may analyse your information using automated means:
- to help us understand your needs and develop our relationship with you;
- to help us to offer you products and service information we believe will be of interest to you, providing that you have given us consent to use your data for this purpose;
- by using product providers IT systems and similar systems where you apply for a financial product e.g. to obtain underwriting terms from an insurer, analyse your investment risk profile, affordability testing.
The types and sources of the information we process by automated means about you are listed in Section 1.3 above.
We also use automated processing to assist in compliance with our legal obligations in connection with prevention of money laundering, fraud and terrorist financing.
1.7 Who we share your information with
When providing our services to you, we may share your information with:
- your authorised representatives;
- third parties with whom (i) we need to share your information to facilitate transactions or services you have requested, and (ii) you have agreed that we may share your information;
- product providers with which we propose to arrange business on your behalf;
- service providers who provide us with support services;
- statutory and regulatory bodies where we are legally obliged to do so;
- credit reference/rating agencies;
- pension fund administrators, where applicable;
- pensions scheme trustees or your employer in relation to the provision of pension benefits, where applicable.
1.8 How long we hold your data
How long we hold your data for is subject to legislation and regulatory rules we must follow, set by authorities such as the Central Bank of Ireland, Office of the Data Protection Commission, Financial Services and Pensions Ombudsman. The timescales may also depend on the type of financial or insurance, investment, or pension product provided to you. Our aim is to hold your data for no longer that is necessary and subject then to the timescales imposed by our legal obligations.
1.9 Implications of not providing your data
If you do not provide information we may not be able to:
- provide requested products or services to you;
- continue to provide and/or renew existing products or services;
- assess suitability;
- and where relevant, give you a recommendation for a financial product or service which you
1.10 Transfer of information outside the European Economic Area
lt is our aim to retain any information which we hold within the EEA. However, given the nature of our business relationships with certain product providers, such providers may have legitimate business reasons to transfer information outside the EEA. The product providers with which we arrange business on your behalf are obliged to comply with the provisions of the GDPR in relation to the transfer of data within or outside the EEA.
1.11 Data Subject Rights – How to exercise your rights
Under the GDPR you will have additional rights in relation to how your data is used, including the rights to:
- find out if we use your information, access your information and receive copies of your information;
- have inaccurate or incomplete information corrected and updatedobject to particular use of your personal data for our legitimate business interests or direct marketing purposes;
- to have your information deleted or our use of your data restricted, in certain circumstances;
- not to be subject to solely automated decisions in certain circumstances, and where we make such automated decisions, a
- right to have a person review the decision;
- exercise the right to data portability i.e. obtain atransferable copy of certain information we hold or to transfer the data to another provider;
- and withdraw consent at any time for processing of your data, based on content of data.
If you wish to exercise any of your rights you can contact us at the address shown.
If we are unable to deal with your requests for data access fully within a calendar month we may extend this period by a further two calendar months and explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically.
If you are dissatisfied with our services or how we use your data, you have the right to complain to the Data Protection Commission, contact details as follows:
Address: Office of the Data Protection Commission, Canal House, Station House, Portlaoise, R32, AP23, Co. Laois.
Telephone: 076 1104800 or Lo Call Number 1890 252 231
We will update our Data Privacy Notice – Customer Summary and Website Privacy Notice from time to time. You may request copies of our current Notices at any time or refer to our website www.dovlepension.ie for the latest versions of these documents.
1.14 Our Contact Details
Doyle Pension & Insurance Management Ltd
114 Pembroke Road
Telephone: 01 6608141
2. Website Data Privacy
This website is published by Doyle Pension & Insurance Management ltd. Doyle Pension & Insurance Management ltd is regulated by the Central Bank of Ireland.
2.2 Purposes for holding information
In order that we can provide you with our services and advice we need to collect certain personal data. We generally use the information which you provide to enable us to make initial contact with you so that we can have a more detailed discussion with you in relation to advice, products, and services which are appropriate to your needs.
2.3 The information we collect about you
We collect and retain two types of information:
1. Personal data
This is data that identifies you or can be used to identify you for contact purposes and may include your name, address, email address, telephone number(s), user IP addresses in circumstances where they have not been deleted, clipped or analysed, date of birth and any other personal data which you provide. Such information is only collated from you if you voluntarily submit it to us. You have the right of access to ask us what information we hold about you, to have any data corrected, and, subject to certain exceptions, erased from our records.
2. Non-personal data
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This non-personal data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
2.4 Purposes for which we hold your information
We hold data for the following purposes:
We will process any personal data received for the purposes of contacting you, if required, in connection with your query or to respond to any communications which you might send to us. We also process the data when providing you with the service, product, or transaction required.
We use the non-personal data gathered from visitors to our website in aggregate form to get a better understanding of where it’s come from and to help better design and organise our website.
We will only use the information you give to us to provide you with the range of insurance, investment, and other products which you request and/or which we believe may be in your best interests, or to meet our regulatory obligations. We will therefore only pass information to our staff, consultants, support service providers, or at your request to other parties, or as required by law in order to meet our legal and/or regulatory obligations.
We may provide non-personal data to third parties, where such information is combined with similar information of other users of the website e.g. we might inform third parties regarding the number of unique users visit our website, the demographic breakdown of other community users of our website, or the activities that visitors to our website engage in while on our website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising services (including websites tracking services), commercial partners, sponsors, licensees, researchers, and other similar parties.
2.5 Sale of business
We reserve the right to transfer information including your personal data to a third party in the event of a sale, merger, liquidation, receivership, or transfer part of or all of the assets of our company, provided that the third party agrees to adhere to the terms of the website policy, and provided that the third party uses your personal data for the purposes that you provided it to us. You will be notified in the event of any such transfer and will be afforded an opportunity to opt-out of transfer.
Your personal data is held on a secure server. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet or intranet. No transmission of data over the Internet can be guaranteed to be 100% secure. However, we take all reasonable steps, including appropriate technical and organisational measures, to protect your personal data.
2.7 Updating, verifying and deleting personal data
You may inform us of any changes in your personal data, and in accordance with our obligations under the Data Protection Acts, we will update or, if applicable, delete your personal data accordingly. To find out what personal data we hold on you or to have your personal information amended or removed from our database, please call us on 01 6608141, or email us at info@ dovlepension.ie
2.9 Cookie information
Cookies are small pieces of information stored in simple text files, placed on your computer by a website. Cookies can be read by the website on your subsequent visits. The information stored in the cookie may relate to your browsing habits on the webpage, or a unique identification number so that the website can remember you on your return visit. Generally speaking, cookies do not contain personal information from which you can be identified, unless you’ve furnished such information to the website. You can change the settings on your internet browser to refuse all cookies if you wish.
Cookies do not in any way compromise the security of your computer. Visitors can use most of our website with no loss of functionality if cookies are disabled from the web browser.
2.10 Analyst tracking software — Google Analytics
We may use Google Analytics, a service provided by Google, like many other websites. The cookies set by it gather anonymous data of how people are using this website and then provide us with visitor statistics, details of page views, etc., which enables us to provide better and more relevant content for visitors in the future. You can opt-out of Google Analytics by visiting the Google Ads Settings page on the Google website.