Data Privacy Notice
Privacy Notice for PPS Financial Planning
Unit 4C, Courtfield Shopping Centre
Raheen
Limerick
18th March 2025
This is the Data Privacy Notice of PPS Financial Planning and tells you what we use your personal information for and explains your rights around how we use it. Please read this Data Privacy Notice to understand how and why we use your personal information. If you give us personal information about someone else, please make sure you have their permission and make them aware of this Data Privacy Notice, as it also applies to them.
PPS Financial Planning complies with the requirements of the General Data Protection Regulation and the Irish Data Protection Acts. Should you have any queries, please contact James Mullane (if firms has a contact email for data queries, insert here)
Collection and use of Personal Data
We use personal information to give you financial planning advice, arrange transactions on your behalf as agreed with you, to service our customers, assist with claims and the payment of plan benefits. We must have a lawful basis to collect and use personal information.
Lawful Basis for Processing
Needed for your Contract:
We need to collect and use your personal information to provide your plan contract and use personal information on a joint data controller basis, with product providers with which we hold an agency. This includes, but is not limited to, your name, date of birth, contact and bank account details. Depending on the plan type this can include health, employment, occupation, pension and salary information, expenses, assets, and information about your dependents. We restrict access to, and use of, any sensitive personal information. We will use your personal information to verify you for security purposes. We may also create new personal information.
Personal information needed for plan contracts is held and used to:
- provide a quote,
- complete a client risk profile,
- process your application,
- set up and issue your plan,
- provide you with information about your plan and benefits,
- to help the administration of your plan and assist with the payment of your plan benefits,
- provide customer care and service; and
- contact you to inform you of any relevant actions you may need to take.
Required By Law:
We use your personal information to comply with law and regulations such as;
- comply with laws
- reporting to regulators
- keeping proper books and records; and
- to manage our risk framework.
We carry out internal reporting, quality checking, compliance controls and audits to help meet these obligations in relation to our regulated activities.
We must collect certain personal information to comply with Anti-Money Laundering law. This depends on the type of service we offer you. To do this, we use your name, date of birth, address, nationality and occupation information.
- up to date proof of identification and address,
- screening of all customers against financial sanctions and politically exposed persons (pep) lists,
- where needed we carry out searches of publicly available information.
You must give us your tax residence information and tax identification number for tax reporting with product producers.
In order to receive financial advice from us, you must give personal and financial information about you and your dependents, for your current and future needs to be assessed. This enables us to recommend the most suitable financial product for you. This will include information about your general state of health. We need this to make an appropriate financial recommendation for you. This will involve creating new and inferred personal information about you such as your investment risk profile. We must carry out this analysis using your personal information to comply with regulations. As a regulated intermediary we must use your personal information to identify whether a financial product is suitable for you based on the product target market identified by the relevant product provider. We complete an analysis of you using your personal information to comply with regulations. When you give us your personal information we will check to see if we already have a record of you. This helps us to comply with your Data Protection Rights.
Legitimate Interest:
We use your personal information for our legitimate interests as shown below. This doesn’t affect your privacy rights. We believe these uses benefit our customers. You can contact us if you have any questions using the above contact details of this Privacy Notice.
Your Consent:
You need to give consent for us to collect and use personal information classed as sensitive or for certain uses of your personal information. You are given the choice to provide consent, or not. When we collect your consent, we will explain what we need it for and how you can change your mind in the future.
Direct Marketing:
– We would like to be able to contact you about offers and services separately from your plan communications. We will only send you direct marketing content where we have your consent.
Consent and how to withdraw Consent
If we process your personal information based on consent, you have the right to withdraw that consent at any time. The opt-out methods will depend on how the consent was collected and will be explained when you give us your consent, e.g. you can change your mind using the opt-out link in any direct marketing emails sent to you. You will also be able to withdraw consent by contacting us directly. Insert details i.e., email address.
If you have received advice from us and then choose to withdraw consent to the further use of personal information, we will not contact you in relation to future financial reviews. However, we are still required by law to hold details of past financial reviews for specific purposes and periods.
How and where do we get your Personal Information
You provide us with your personal information directly when you contact us, complete our forms, speak with us or visit our website, and social media accounts. For more information on what personal information is collected and used on our website please see our Website Privacy Policy. We also get personal information from solicitors, employers, trustees, or regulators (where relevant).
We also create new personal information about you based on information you have given us and through your interactions with us such as noting your online preferences.
To Whom do we Pass your Personal Information
We pass personal information to:
- Data processors:
– Companies that act as service providers under contract with us and only process your personal information as instructed by us. Your personal information is transferred securely and is not used by other parties for any other reason.
The categories of services that we use other Data Processors for include management, administration, underwriting, customer services, marketing etc.
Mailchimp (trading as Mailchimp) support the issue of our service emails. Mailchimp are based in the United States and any personal data we share with them is done so in accordance with the EU Standard Contractual Clauses. The only information passed includes your name and/or email address. MailChimp may collect information about your devices and your interaction with emails; this information may be used to improve the content and operation of services and to facilitate related research and analysis.
- Trustees:
– appointed in connection with the plan contract.
- Employers:
– where a plan has been set up through your employer, we will share information with them to the extent that is required in order to set up/ administer the group or company plan.
- Regulators:
– Regulators and the Revenue Commissioners or as needed to comply with regulations and laws.
DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE OF THE EU?
Your personal information is processed and stored within the EU with the exception of Mailchimp.
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
We keep and use your personal information for as long as you have a relationship with us. We also hold it after this where we need to for complaints handling, for system back-ups needed for disaster recovery and for as long as we have to under regulations. Where you have availed of a regulated product or service, we will retain your personal information for 7 years after your relationship has ended.
We delete personal information in accordance with regulatory requirements and our Data Retention Policy. All personal data is deleted in a secure manner.
WHAT ARE YOUR RIGHTS?
You have a number of rights over your personal information which you can exercise free of charge by contacting us using the details in this Privacy Notice. You will need to give us information to help us identify you and we will respond to you within one month in line with current regulations. Any restrictions to your rights will be explained in our response.
- Right to Information
You have a right to the information set out in this Privacy Notice. We will inform you of our updated Privacy Notice, if we change the type of personal information we collect and / or how we use it. We have controls in place to protect your personal information and minimise the risk of security breaches. However should any breaches result in a high risk for you, we will inform you without delay.
- Right to Restrict or Object
You can restrict or object to any unfair and unlawful collection or use of your personal information. You can object to any automated decision making that has a legal or similar significant impact for you and ask for the decision to be made by a person. You can withdraw consent and object to, for example direct marketing.
- Right to Correct and Update
You can ask us to correct and update personal information we hold about you. Your plans are long term contracts and to provide you with the best service it is important we have your up to date personal information, such as contact details.
- Right to Delete and Be Forgotten
You can have your personal information deleted if it is incorrect or has been processed unfairly or unlawfully. If you have withdrawn consent you can ask for your personal information to be deleted. We will keep a record of your request so we know why your personal information was deleted. If we have provided a regulated product or service to you, we must keep your personal information for a minimum period by law.
- Right to Portability
You can ask for a copy of all personal information that you gave us (including through your interactions with us), and which we hold in an automated format. You can receive this in a machine readable format that allows you to keep it. You may also request us to send this personal information in a machine readable format to another company. The format will depend on our ability to provide this in a secure way that protects your personal information. We will not likely be able to use a copy of your personal information sent to us in this way from another company. This is because we can only collect personal information that we need. We also need your most up to date personal information for underwriting and to comply with regulations.
- Right to Access
You have the right to know what personal information we hold about you and to receive a copy of your personal information. We must tell you:
– why we hold it;
– who we pass it to, including whether we transfer it outside the EU;
– how long we keep it for;
– where we got it from; and
This right does not allow you to access personal information about anyone else. To access your personal information please write to us using the contact details in this Data Privacy Notice. To help us respond as quickly as possible please let us know if you are only looking for copies of specific personal information.