D. Moloney Financial Services is committed to protecting and respecting our 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 D. Moloney Financial Services in relation to the information we collect about you. For the purposes of the GDPR the data controller is:
- Donald Moloney
- Contact details of 091 638133
- When we refer to ‘we’ it is the Firm D. Moloney Financial Services
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?
Donald Moloney t/a D. Moloney Financial Services acts as a broker authorised by the Central Bank of Ireland. Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life & pensions/investments/Deposits and General insurance products.
GDPR Owner and data protection representatives can be contacted directly here:
- Donald Moloney
- Phone number 091 638133
Purpose for processing your data
Your personal data will be gathered and processed following your consent to progress an application/contract of Insurance, investment, Pension or Financial Product that we are authorised to transact. We process your data only when necessary to achieve our commercial or business objectives in offering and recommending to your suitable products from our product listings. The types of personal data that may be collected include name address, email address and telephone number. Additionally, we may also request sensitive data eg health information or criminal data e.g penalty points information in order to submit an application on your behalf to the product providers with whom we hold an agency. All information you provide to us will be stored on secured servers/paper files, and we will only disclose your personal information as we describe in this Privacy Notice and in more detail in our Policies.
Why we are processing your data? Our legal basis.
In order for us to provide you with an Insurance/ Financial product we need to collect and process your personal data for the provision of an initial quotation with a view to offering suitable contracts of Insurance/Financial products based on your request, consent and requirements. This is our reason (lawful reason) for processing your data under the GDPR.
In any event, D. Moloney Financial Services is 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 D. Moloney Financial Services use the personal data it collects about me?
D. Moloney Financial Services 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 origincriminal records) - financial information is not classified as special categories of personal data) – we will ensure 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 D. Moloney Financial Services 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 D. Moloney Financial Service’s 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:
We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions.
If we 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.
Data Subjects Rights:
D Moloney Financial Services 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.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. D.Moloney Financial Services 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 our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by D. Moloney Financial Services or how your complaint has been handled, you have the right to lodge a complaint directly with the GDPR Owner.
Failure to provide further information
If we are collecting your data for a contract of Insurance/ Financial Product 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
a) Risk profiling.
b) Profiling for marketing purposes.
c) Establishing affordability and providing quotations for financial services and mortgage product
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, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
a) Establishing affordability and providing quotations for financial services products.
If we intend to 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.
The cookies we use on our site are Recaptcha by Google and Google Analytics.
Recaptcha is used to help prevent spam messages via the forms on our site. Based on your interaction with our site and page Google recaptcha gives you a score that informs us whether you are a likely to be a spam bot or a real person. If Google scores you as a real person the information you fill in on our forms will be sent to us. Information from what google deems to be spam bots will not be sent to us. This saves us a lot of time which is why we use Google Recaptcha.
Google Analytics is used to see how our website is performing. Which pages are the most popular, which counties our visitors are located in etc.
Google are not sent your personal information, such as name, email, message content. This is sent directly to us.
We have also installed an SSL or Secure Cert so that when you submit data on our site it is sent to us in an encrypted form across the internet. An SSL certificate is a bit of code on our web server that provides security for our online communications. When your web browser (google chrome, safari, internet explorer) contacts our secured website, the SSL certificate enables an encrypted connection. It is similar to sealing a letter in an envelope before sending it through the mail.
What are cookies
Cookies are small pieces of text sent by your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit is easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
- To enable certain functions of the site we use both session and persistent cookies on the Service and we use different types of cookies to run the site: Essential cookies. We may use essential cookies to authenticate users and prevent fraudulent use of of forms by spam bots.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
- For any other web browser, please visit your web browser’s official web pages.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 091 638133 – email email@example.com