- 1. Introduction
Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors is regulated by the Central Bank of Ireland. Registered no: C35724. Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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 Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors in relation to the information we collect about you. For the purposes of the GDPR the data controller is: • Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors • Contact details of 044 93 48772 • When we refer to ‘we’ it is Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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.
- 2. Who are we?
Duffy Financial Advisors was founded by Michael J Duffy in 1964. Tom Duffy, Managing Director and Michael's son, joined the firm in 1982 and has being assisting clients achieve their financial goals ever since. We are based in Mullingar, Co Westmeath. Our aim is to provide high quality financial advice as your trusted advisor. We aim to do this so that our clients can achieve their financial needs, objectives and priorities. We hold excellent relationships with our insurers and financial institutions. We provide an extensive range of products and services, including business insurance, personal insurance, retirement planning and financial planning.
- 3. Why we are processing your data? Our legal basis.
In order for us to provide you with insurance, pension and investment advice, Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors need to collect personal data for the provision and administration of insurance, pension and investment products and related services along with the purpose of financial analysis. Our reason (lawful reason) for processing your data under the GDPR is: • Legal basis - Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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. • If you refuse to provide us with the required personal data, we may be unable to provide you with insurance or process your claim. In any event, Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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.
- 4. How will Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors use the personal data it collects about me?
Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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 endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Information may be used for one or more of the following situations: • Provide quote • Arrange insurance policy • Renew policy • Process claim
- 5. 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
- 6. Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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 fulfill 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 Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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 pass your personal data to are: Aviva Life & Pensions UK Limited BCP Asset Management DAC Custom House Capital Limited Friends First Life Assurance Company DAC Independent Trustee Company Limited Irish Life Assurance Plc New Ireland Assurance Company plc permanent tsb plc. Scottish Provident Limited The Royal London Mutual Insurance Society Limited Wealth Options Limited Zurich Life Assurance plc CGU Life Harcourt Life Ireland dac If we need to transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another 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. If this happens we will issue all our third party processors with a Data Processor checklist asking them GDPR specific questions
- 7. Data Subjects Rights:
Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request. Your rights as a data subject At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights: • 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
- 8. Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body Central Bank and our internal governance.
- 9. Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors 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 GDPR owner
- 10. Failure to provide further information
If we are collecting your data for a contract x and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.
- 11. Profiling – automatic decision making
The main categories are a) Risk profiling – to establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions. b) Profiling for marketing purposes – when we seek to contact you about other services, we run automated queries on our computerised database to establish the suitability of proposed products and services to your needs. c) Establishing affordability and providing quotations for financial services products *if you no longer wish for Duffy Mortgage & Investment Advisors Ltd t/a Duffy Financial Advisors to use your information for marketing purposes, please contact us at email@example.com.
- 12. 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 prior to processing this data.
- 13. Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 044 9348772 or email firstname.lastname@example.org.