This is the Privacy Notice of Insight Private Clients Ltd. We are committed to respecting and protecting your privacy and would like you to feel safe when providing us with your personal details. We strive to be transparent in the manner in which we process your data and reflect our accountability with the General Data Protection Regulations (GDPR). Not only in relation to the processing of your data but also assisting in your understanding of your rights as a client. We will always clearly identify ourselves in correspondence. Please read this Privacy Notice to understand how and why we use your personal information.
This Privacy Notice will inform you of the information we gather and how it is used. Insight Private Clients Ltd complies with the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018.
Collection and use of Personal Data
We use personal information provided to arrange transactions on your behalf, to service you as a Client with your Personal Financial affairs and assisting you with the management and administration of any and all Contracts involved. We must have a lawful basis to collect and use personal information in the execution of such service provision.
Required for your Contract
We collect and process various categories of personal information to assist in the provision of appropriate Contracts based upon your needs and wishes. Personal information may include:
- Your name, address, date of birth and contact details
- information about your family & lifestyle (such as dependents, marital status, nationality) & depending on the Plan type, information about your health)
- information about your financial circumstances, including salary details, assets & liabilities, existing contracts, investment experience, needs & goals.
- Employment information
- Your Personal Public Service Number
- Financial information including bank account details.
- Except in relation to certain specific features of our website, you do not have to provide us with any personal information (personal data) to use our website. However, where you elect to give us your personal data through our website via online feedback forms or web email then we will treat your personal information in accordance with this notice.
Required by Law:
We use your personal information to comply with current legislation and regulations such as:
- Reporting to regulators
- Keeping proper accounts and records.
As a function of our service platform, we carry out internal reporting, quality reviews, compliance controls and audits to help meet these obligations.
We are also required, by law, to collect certain personal information to comply with Anti Money Laundering legislation. This will depend on the action being undertaken and the form of service being provided. To do this we use your name, date of birth, address, nationality and occupation information.
- Proof of ID by way of passport/driving licence
- Utility bill as proof of address
- Screening of all customers against Financial Sanctions and Politically Exposed Persons (PEP) lists.
- Where needed we carry out searches of publicly available information.
By simply visiting our website you do not disclose, nor do we collect any of your personal data. All that we may know about your visit may be limited to technical data such as:
- The logical address (or IP address) of the server you used to access this website
- The top level domain name from which you access the internet (for example .ie, .com, .net)
- The previous website address from which you reached us
- The type of web-browser you used
- Web traffic data (the amount of data sent and received by visitors to a web site). This is determined by the number of visitors and the number of pages they visit
The technical data may be used for administrative and statistical purposes and may be shared with our internet service provider. We may use this information to help us to improve our website. This technical data does not provide us with the personal data of visitors to our website, nor will same involve any contact from us.
Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our services. However, you should note that disabling cookies may result in some parts of the site not working efficiently or in slower downloads.
Information you provide us about others or information that others provide us about you
If you provide us with information about someone else (e.g information about a spouse or a financial associate/director) for the purposes of a joint application with that person, or someone gives us information about you, we may add it to any personal information we already hold and we will use it in the ways as outlined in this Data Privacy Notice.
Prior to disclosing information to us about another person, you should ensure that you have their agreement to do so. You should also make them aware of this Data Privacy Notice.
Special Categories of Data
We may hold certain applicable information about you which includes special categories of personal data such as health details for the purposes of Life Insurance/Serious Illness/Mortgage Protection or Income Protection applications. We will only hold this data when we need it for the purposes of the services we provide you or where we have a legal obligation to do so.
When and how we collect information about you
- At the initial contact, on completion of a Personal Financial Questionnaire in order to determine your needs & objectives and recommend the most suitable solutions for you.
- As you use our services, apply for specific Contracts, make enquiries and engage with us, information is gathered about you.
- When you use our website and online services provided by us and visit our office.
- When you or others give us information verbally or in writing. This information may be on application forms, in records of your transactions with us or if you make a complaint.
How we use your information
In order to receive tailored financial advice from us, you must provide appropriate personal and financial information for your current and future needs to be assessed in the process of our service delivery. This enables us to recommend the most suitable financial solutions for you. As stated, we complete an analysis of you using your personal information to comply with current regulations.
We use your personal information, only for appropriate purposes, for the actions being taken as shown below:
- Completion of a Personal Financial Questionnaire to determine your needs & objectives
- Process any applications associated with the provision of a specific Contract(s)
- Manage and administer your Contracts
- Contact you by post, phone, text message, email with your explicit consent
- Manage and respond to a complaint or appeal received in accordance within stated timeframes.
Please note that where you provide us with your personal information, (e.g. name, e-mail address, work address, telephone and mobile phone numbers and/or other contact information), through a facility provided on our website or directly to us by e-mail, you consent to us;
- Processing and administering your personal data to perform all necessary actions to give effect to your request or instruction; and
- Retaining a record of incoming and outgoing communication (e.g. email)
Information in the email we receive and send will not be disclosed to any third party without the permission of the sender unless otherwise in accordance with the Data Protection Act.
You need to provide consent for us to collect and use your personal information. When we collect your information we will explain what we need it for and how you can change your mind in the future. If we process your personal information based on consent, you have the right to withdraw that consent at any time.
Please note that by using Insight Private Clients Ltd website you are giving us your consent to process your personal data as outlined in this Privacy Notice. Your consent is also provided to any successor or assignee Insight Private Clients Ltd and/or any of its businesses. We inform all persons who submit their personal data to us of these conditions by this Private Notice.
Insight Private Clients Ltd intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate steps to safeguard and secure information we collect.
Who we share your information with
We only share your information with third party companies and individuals, and only as necessary, to facilitate our service. These third parties have access to your personal information only upon receipt of a relevant Application Form signed by you. The use of such detail will only be relevant to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose in accordance with the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018.
Our main Data Processors whom we will pass your details as necessary to facilitate a Contract of Insurance are:
Zurich Life Assurance plc – www.zurichlife.ie
Irish Life Assurance plc – www.irishlife.ie
Friends First Assurance plc – www.friendsfirst.ie
Standard Life Assurance Ltd – www.standardlife.ie
New Ireland Assurance Company plc– www.newireland.ie
Aviva Life & Pensions Ireland Ltd – www.aviva.ie
BCP Asset Management Ltd – www.bcp.ie
Royal London – www.royallondon.ie
Broker Information Services– www.brokerinformationservices.ie
The categories of services that we use other Data Processors for include:
Appointed in connection with the Plan Contract
- Investment Service Providers
We pass limited personal information to investment service providers where you want to access these services through your Plan eg. Stock trade,
Central Bank, Data Protection Commissioner or Revenue Commissioners or as needed to comply with regulation sand laws.
We pass your personal information to our associated company, Insight Insurance only with your consent.
Do we transfer your personal data information outside of the EU?
Your personal information is processed and stored within the EU.
How long do we hold your information
The length of time we hold your data depends on a number of factors, such as regulatory rules and the type of financial product/service we provided to you.
These factors include:
- The regulatory rules contained in the laws and regulations or set by authorities like the Central Bank of Ireland for example, in the Consumer Protection Code.
- The type of financial product/service we have provided to you. For example, we may keep data relating to a pension contract for a longer period compared to an investment contract.
- Whether you and Insight Private Clients Ltd are in a dispute with another entity,person or each other.
- The type of data we hold about you.
- Whether you or a regulatory authority asks us to keep it for a valid reason.
As a general rule, we keep your information for a specified period after a policy has lapsed/matured/encashed or you cease to be a client of Insight Private Clients Ltd. In most cases this period is 6 years.
Implications of not providing information
Sharing information with Insight Private Clients Ltd is in both our interest.
Insight Private Clients Ltd need your information in order to:
- To provide both our services to you and also fulfil our commitments to you.
- Manage our business for our legitimate interests.
- Comply with our legal obligations
Of course, you can choose not to share information, but by doing so may limit the services we are able to provide to you.
- We may not be able to provide you with certain Contracts or services that you request.
- We may not be able to assess your suitability for a contract or service or, where relevant, provide you with a recommendation to proceed with a financial product or service.
Should Insight Private Clients Ltd be involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Private Policy.
Our service does not address anyone under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from children under age 13 without verification of parental consent, we take steps to remove that information from our servers
How to exercise your information rights
Providing and holding personal information comes with significant rights on your part and significant obligation on the part of Insight Private Clients Ltd. You have several rights in relation to how we use your information.
You have the:
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.
Right to Correct and Update
You can request that inaccurate information is corrected and incomplete information updated.
Right to Delete and be Forgotten
The right to have your data deleted or its use restricted– you have a right to this under certain circumstances.
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 may 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 have the right to object to particular uses of your personal information where the legal basis for our use of such detail is for our legitimate business interests. In doing so this may have an impact on the services we can/are willing to provide
Right to Portability
You have the right to ask for a copy of all personal information that you have provided Insight Private Clients Ltd with and which is held in an automated format. You can receive this in a machine readable format that allows you to keep it. You may also request Insight Private Clients Ltd 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. Insight Private Clients Ltd will also need your most up to date personal information for underwriting and to comply with current regulations.
You have the right to withdraw consent to the usage of your personal information at any time where processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
We are obliged to respond without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will communicate the reasons for such delays.
You have the right to complain to the Data Protection Commission or another supervisory authority.You can contact the Office of the Data Protection Commissioner at:
Telephone: +353 (0)761 104800 or Lo Call Number 1890 252 231
Fax: +353 57 868 4757
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.
How to contact us
If you have any questions or comments about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact our Data Protection team at:
Telephone +353 (021) 2455410
Postal Address: Insight Private Clients Ltd, Reeveswood, Tramore House, Douglas Road, Cork, T12 R8XW
Changes to this Notice
This Data Privacy Notice is valid from 25th May 2018. Insight Private Clients Ltd may modify or update this Privacy Notice from time to time. Updates will be posted on our website, www.insightprivateclients.ie