Plan Review 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 for 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 Plan Review in relation to the information we collect about you.
For the purposes of the GDPR, the data controller is:
• Kevin O’Neill
• Contact details of Kevin O’Neill – 0868290989
• When we refer to ‘we’ it is Plan Review
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?
Kevin O’Neill T/A Plan Review is a Financial Broker. We provide financial advice on a range of financial products – life insurance, income protection, pension/retirement planning, serious illness, investments, savings, and other financial products.
Our GDPR Owner and data protection representatives can be contacted directly here:
• Name – Kevin O’Neill
• Email address – firstname.lastname@example.org
• Phone number – 0868290989
Information we may collect from you
We only collect Data about you on the Site which you volunteer when you email us or by using our online Contact Us or other forms; or if you report a problem with our Site. When you contact us, we may keep a record of that correspondence. We also collect Data automatically when you navigate through our Site.
We may collect and process the following data about you:
• your name;
• your phone number;
• your email address;
• your address;
• information that you provide by filling in forms on our Site;
• the time and date of your visit;
• your IP address;
• your browser type; and
• your referring URL
Unless subscribing to a service, the provision of your Data is not a statutory or contractual requirement and you may refuse to disclose the same.
2. Uses made of your data
We may use your Data where necessary for our legitimate business interests, including to:
• improve the content of our Site and the services we offer;
• ensure the Site is presented in the most effective manner for you and for your computer;
• compile statistical data on the use of our Site;
• allow you to participate in interactive features of our service when you choose to do so; and
• notify you about changes to our service.
We make no attempt to identify individual visitors or to associate the technical details we collect with any individual unless required to disclose such information by law. We may use your Data to comply with any legal obligations.
We will store your Personal Data only for as long as necessary for the purposes of providing access to our Site and related services to you; as required by law, and for the exercise or defence of any legal claims.
3. Disclosure of your information
We will not disclose your Data to third parties unless you have consented to this disclosure or unless the third party is required to fulfill a request you have made or contract that you have entered into. Where appropriate, Data may also be processed by our service providers in which case we will take steps to ensure that the processing complies with applicable data protection and confidentiality laws. We will also disclose your Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order or other statutory or legal requirements.
We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our Site. For example, we might inform third parties regarding the number of unique users who visit our Site, the demographic breakdown of the community users of our Site or the activities that visitors to our Site engage in while on our Site. The third parties to whom we may provide this information may include web developers, server providers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers, and other similar parties.
4. Links to other sites
Our Site may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any Data to those websites.
5. Your rights
You may request access to, rectification, erasure or restriction of your Data, or object to the processing of your Data or Data portability at any time. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event within one month of receipt of your request. We may request proof of identification to verify your request.
You have the right to lodge a complaint with the Data Protection Commissioner if you are unhappy with how we are processing your Data.
6. Security and where we store your personal data
We are committed to protecting the security of your Data. We use a variety of security technologies and procedures to help protect your Data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organisation. We will continue to update policies and implement additional security features as new technologies become available. Where we have given you a password which enables you to access certain parts of our Site, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.
Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Site. Any transmission of Data is at your own risk. Once we receive your Data, we will use appropriate security measures to seek to prevent unauthorised access or disclosure.
7. Changes to this Privacy Statement
We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Privacy Statement. Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check this Statement periodically for updates.
Why we are processing your data? Our legal basis.
In order for us to provide you with financial advice, Plan Review needs to collect personal data for to be able to provide financial advice on a range of financial products – life insurance, income protection, pension/retirement planning, serious illness, investments, savings, and other financial products.
Our reason (lawful reason) for processing your data under the GDPR is:
• Legal basis Plan Review 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.
In any event, Plan Review 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 Plan Review use the personal data it collects?
Plan Review 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.
Special Categories of personal data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin) – we will that 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 Plan Review 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 fulfill this service, they will dispose of the details in line with Plan Review 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.
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:
Plan Review will 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. Plan Review will process personal data in accordance with our retention schedule.
In the event that you wish to make a complaint about how your personal data is being processed by Plan Review or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Plan Review data protection representatives / GDPR Owner.
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.
Profiling – automatic decision making
a) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators that 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 database to establish the suitability of proposed products or services to your needs.
c)Establishing affordability and providing quotations for financial services products.
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.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on – 0868290989 Kevin O’Neill