Privacy Policy / Statement

This Privacy Policy was last updated on the 20^th June 2019.

 

Introduction

Smart Finance Life Planning Ltd., is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.

It is the intention of this privacy statement to explain to you the information practices of Smart Finance Life Planning Ltd., in relation to the information we collect about you.

For the purposes of the GDPR the Data Owner is:

• Pat Matthews
• Phone: 041 98 42791
• Email: pat@smartfinance.ie
• When we refer to ‘we’ it is Smart Finance Life Planning Ltd

Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Who are we?

Smart Finance Life Planning Ltd., is an independently owned and run financial planning firm based in Drogheda. Combining advanced financial planning tools with our experience and knowledge of protection, retirement planning, investments, estate planning and day-to-day finances and budgeting, we work with clients to help them identify their goals and deliver a financial plan that is tailored to their needs.

Our GDPR Owner and data protection representatives can be contacted directly here:

• Post: Smart Finance Life Planning Ltd., Bawntaaffe, Monasterboice, Drogheda, Co. Louth.
• Email: pat@smartfinance.ie
• Phone: 041 98 42791

For GDPR purposes Smart Finance Life Planning Ltd., has made the decision not to appoint a Data Protection Officer. 

Purpose for processing your data

• Your personal data is processed in our office here in Ireland. However, because of IT hosting and maintenance this information can also be located on servers within the European Union. We can confirm that no 3^rd parties have access to your data unless they are entitled to do so by law.
• We have a Data Protection regime in place to oversee the effective and secure processing of your personal data.

Why we are processing your data? Our legal basis

In order for us to provide you with financial planning and financial advice services, Smart Finance Life Planning Ltd., needs to collect personal data for financial planning and financial advice services. Our reason (lawful reason) for processing your data under the GDPR is:

• Legal basis – Smart Finance Life Planning Ltd., needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract or the individual wishes to engage our services to provide a Lifestyle Financial Plan.

In any event, Smart Finance Life Planning Ltd., are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

How will Smart Finance Life Planning Ltd., use the personal data it collects about me?

Smart Finance Life Planning Ltd., will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

Special Categories of personal data

If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below

• we will obtain your explicit consent

Who are we sharing your data with? 

We may pass your personal data on to third-party service providers contracted to Smart Finance in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf.

When they no longer need your data to fulfil this service, they will dispose of the details in line with Smart Finance procedures.

If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise. 

Use of Cookies

Our website uses cookies which is a widely used browser technique that is used to overcome the stateless nature of http protocol which simply means that allows the browser and the web server communicate more effectively. We use cookies to enable Google Analytics and to assist with the delivery of a responsive website suitable for your viewing device.

You can adjust the settings on your computer to decline any cookies if you wish. This can easily be done by activating the reject cookies setting on your computer.

We may pass your personal data on to third-party service providers contracted to Smart Finance in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with Smart Finance procedures.

If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.

The third parties that we may pass your personal data to are:

New Ireland Assurance, Irish Life, Zurich Life, Standard Life, Aviva, Friends First, Royal London, Wealth Options Ltd, Davy Select, Independent Trustee Company, Conexim Advisors Ltd, Quilter Cheviot, Ptsb.

To the best of our knowledge we can confirm that our third party processors are GDPR compliant.

If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.

Data Subjects Rights

Smart Finance Life Planning Ltd., facilitates you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Organisation Name refuses your request under rights of access, we will provide you with a reason as to why.

All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

Additional information we are providing you with to ensure we are transparent and fair with our processing.

Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Smart Finance Life Planning Ltd., will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body Central Bank of Ireland and Financial Planning Standards Board and our internal governance.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Smart Finance Life Planning Ltd., or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Organisation Name’s data protection representatives Data Protection Officer / GDPR Owner

Failure to provide further information

If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect. 

Profiling – automatic decision making

We may advise you that we need to carry out automatic decision making with you. Where we need to do this we will inform you of the significance and the envisaged consequences involved. You have the right to object to this and in these circumstances we will outline how we proceed with our engagement with you from that point.

The main categories of Profiling or Automatic Decision Making Profiling:

1. Risk Profiling.
2. Profiling for marketing purposes.
3. Establishing affordability and providing quotations for financial services and mortgage product.
4. Preparing a Lifestyle Financial Plan.
5. a)   Risk Profiling.

This is to establish a client’s Attitude to Investment Risk (relates to pensions and investments) advisors have automated calculators which calculate the clients attitude to various levels of risk having answered a series of questions.

1. b)   Profiling for marketing purposes.

When we seek to contact you about other services, as outlined above we may run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

1. c) Establishing affordability and providing quotations for financial services products.
2. d) Preparation of Lifestyle Financial Plan, i.e. Voyant Cash-Flow Plan.

Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information to you prior to processing this data.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 041 98 42791 or email info@smartfinance.ie

Privacy policy statement changes

Smart Finance Life Planning Ltd., may change 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 so you’re aware of any changes. By using our services you agree to this privacy policy.

This privacy policy was last reviewed in June 2019.