Premier Life Suite & Premier Plan Service Full Data Protection Statement
Last Updated: 07/09/2020
If you have any questions about this Data Protection Statement or the way in which your Personal Data is being used by us please contact:
Email: [email protected]
Telephone: (066) 718 5723
1. About Premier Life & Premier Plan
This Data Protection Statement applies to the following services offered by PCS Financial Services (Kerry) Ltd. T/A Premier Financial:
Premier Life Suite
Premier Life Suite is a suite of online Financial Wellness Products designed to Educate Users about Retirement & Financial Planning and to educate and inform them.
The service consists of online training about financial planning and related topics, online calculators designed to assist users in planning for key financial milestones such as retirement.
Premier Plan Service
The Premier Plan Service delivers a Pension Report and a one-hour Pension Advice Meeting for users with a Qualified Financial Adviser. The service also provides online access to a Retirement Planning course.
Our ethos throughout the design and delivery of our service is simplicity and user experience. We want our users to learn key information about their financial lives. This service should be delivered online at a time that suits the user, and if they require further access, they can book meetings online.
2. About Premier Financial Advisory Services
Premier Financial are a leading Retirement Planning and Pension Advisory firm.
We pride ourselves on the ongoing support we provide our clients and their families which is reflected in the fact some of our clients have been with us for 40 years.
We offer our clients an extensive choice of suitable products that best serve their needs and circumstances. We offer advice on a fair and personal analysis basis in relation to all Financial Services products and services. Fair analysis of the market means providing services on the basis of a sufficiently large number of contracts or investment products and product producers available on the market to enable us to make a recommendation, in accordance with professional criteria, regarding which contract or investment product would be adequate to meet your needs and requirements.
In order to provide our services and manage our business, we need to process Personal Data. We are committed to protecting the rights and personal data of individuals in accordance with data protection legislation including the General Data Protection Regulation in Europe (the “GDPR”).
3. The Purpose of our Data Protection Statement
This Data Protection Statement describes our approach to data protection and sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us where we are controllers of that personal data for the purposes of the GDPR. Please read this Data Protection Statement carefully to understand our views and practices regarding the Personal Data we collect and how we will treat it.
The protection of your personal data is important to us and we are committed to protecting and safeguarding your rights.
“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
4. Who this Data Protection Statement applies to
This Data Protection Statement provides specific information relating to the data subjects whose Personal Data we process who are clients of our financial advisory service or who are users of our Premier Life Suite online services and our Pension Report Service called Premier Plan
You may be:
- a client who receives advice from one of our financial advisors
- a user who has registered with us directly for the Premier Life Suite Service
- a user who has registered with us directly for the Premier Plan Service
- a user who has registered with us to avail of financial wellness benefits offered by your employer through the premierlife platform
5. Categories of Personal Data
We process the following categories of Personal Data. For each category we have included an example of the type of Personal Data that may be part of that category:
|Personal Data Category||Description|
|Contact Data||may include a person’s email address and phone number and year of birth|
|Communication Data||may include phone calls and email correspondence. This includes when you communicate via the online service we provide|
|Marketing Data||may include your Contact Data and any preferences in receiving marketing from us and your communication preferences.|
|Employment Data||may include information about your employment status, your job role and your employment history.|
|Financial Data||may include payment related information or bank account details and financial data received as part of the services that we provide and surveys we conduct.|
|Web Data||may include Personal Data provided on any forms on our website and, to the extent that it includes Personal Data, information on the type of device you’re using, its IP address, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.|
|Special Category Data||May include personal medical information to process applications for financial service products with companies whom we hold agencies with on your behalf.
With your consent, we retain a copy of your health information in order to facilitate the processing of any future claims.
6. Our legal basis for processing personal data
All processing of Personal Data must be lawful. Processing will only be lawful if we have a legal basis for processing. When the Company processes Personal Data it is generally on one of the following legal basis:
We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract.
For instance, when you register for one of our services you will enter a contract with us for the delivery of that service
At times we will need to process your Personal Data to pursue our legitimate business interests, for example to provide information to you, for administrative purposes, to collect debts owing to us, to operate, evaluate, maintain, develop and improve our websites and services or to maintain their security and protect intellectual property rights.
We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweigh our legitimate interests.
Where we carry out marketing activities based on legitimate interests you will always have an option to opt-out of receiving marketing communications.
If do not want us to process your Personal Data on the basis of our legitimate interests, contact us at [email protected] and we will review our processing activities.
For certain processing activities we may rely on your consent. For example, we will get your consent if you are not an existing user of any of our services and you sign-up to receive marketing newsletters from us.
Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so. You can withdraw consent provided by you at any time by contacting us at [email protected]
If we have a legal obligation to process personal data, such as the payment of taxes, we will process personal data on this legal ground.
Special Category Data
When we process special category data such as your health data, we require your explicit consent to do so. We will explain the purpose for processing at the time we collect the data and provide you with suitable information to fully inform your consent.
7. Our Processing Activites
We use Personal Data to provide you with our services and to assist us in the operation of the company. Under data protection law, we must ensure that the purpose of processing is clear.
We have set out below the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing:
|Purpose of Processing||Categories of Personal Data||Lawful Basis|
|Service Delivery including:
|Deliver of Financial Advice and Broker Services:
|Marketing and Sales activities:
|Website delivery including:
8. Sources of Personal Data
User Personal Data
We collect personal data directly from users when:
- They register for and use the service
- They complete financial questionaires and surveys
- They provide feedback to us or report problems with the service
- They join an online advisory session
Website Users Personal Data
We may collect Website User information from all visitors to our web site premierfinancial.ie in order to improve our services and develop the Websites.
- Logfiles of service interactions in order to manage our service delivery and progress users through the service offerings
- Logfiles of website activity collected for security purposes.
- Cookies that track website visitors. For more details please refer to our Cookie Statement.
9. Disclosure of Personal Data
In certain circumstances, we may disclose Personal Data to third parties as follows:
- to business partners and subcontractors for the performance of any contract relating to our services, including email, payment processors, hosting service providers, external consultants, auditors, IT consultants and lawyers;
- financial product comparison and modelling tools to enable us to assess various financial products on your behalf;
- to financial product providers to broker their services;
- to analytics and search engine providers that assist us in the improvement and optimisation of the Website. This consists of aggregated anonymous information only and relates to the web pages visited on the Website and not the information included on those web pages;
- if we or substantially all of our company is merged with another company or acquired by a third party, in which case Personal Data held by us will be one of the transferred assets;
- if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation (including tax, audit or other authorities), or in order to enforce or apply any contracts that we have;
- to protect our rights, property, or safety, or that of our customers or Business Contacts or others. This may include exchanging information with other companies and organisations for the purpose of fraud protection.
Where an employer engages our services to provide a Financial Wellness Employee Benefit, we may share:
- aggregated information about levels of employee engagement with the service to employers who pay for employees to use the service;
- Personal Data with third party payment service providers such as Stripe for the purpose of processing payments related to the services we offer.
When we engage another organisation to perform services for us, we may provide them with information including Personal Data, in connection with their performance of those functions. We do not allow third parties to use Personal Data except for the purpose of providing these services.
10. Disclosure to Financial Product Providers
When we disclose your data to a financial product provider, the provider is also a controller of any personal data we share with them for the purpose of providing the financial product to you.
The financial product provider is obliged to provide you with a data protection statement explaining how they will process your personal data.
We will also inform you when your data is being shared in this manner.
The following is a list of our Product Providers with links to their data protection statements:
11. Security Measures
In particular, we have put in place appropriate physical, technical, and organisational procedures to safeguard and secure the Personal Data we process.
We will also take reasonable steps to verify your identity before granting access to information to protect the privacy and security of the Personal Data we process.
Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We also use secure connections to protect Personal Data during its transmission. Where you have been given (or where you have chosen) a password which enables you to access services, you are responsible for keeping this password confidential. Please do not share your password with anyone.
If you think that there has been any loss or unauthorised access to Personal Data of any individual, please let us know immediately.
12. Transfers Outside the EEA
In order to provide our products and services we may need to transfer Personal Data outside the European Economic Area (EEA). We ensure that any transfer of Personal Data outside the EEA is undertaken using legally compliant transfer mechanisms and in accordance with the GDPR.
If we transfer Personal Data outside of the EEA, we generally rely on the Standard Contractual Clauses under Article 46.2 of the GDPR adopted by the EU Commission or the Privacy Shield in the case of transfers to the USA. We may also rely on some of the other legally compliant transfer mechanisms provided under the GDPR.
Cookies are small text files placed on your computer or mobile device by websites that you visit, and they help us improve the products and services that we offer you. They are used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies may allow a website to remember your activity over a period of time. Cookies are optional and you do not have to accept them.
Further information on the cookies we use on the website and the purpose behind their respective uses are set out in our Cookie Statement.
14. Third Party Websites
Our Websites may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings, and these are not endorsed by us. We do not accept any responsibility or liability for these third-party websites. Please undertake the appropriate due diligence before submitting any Personal Data to these websites.
In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests. We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.
Our retention policy is as follows:
|Purpose of Processing||Categories of Personal Data||Retention Period|
|Online Financial Wellness Service Delivery||
||Reviewed 24 months after completion of service delivery activities in the case where there is no further meaningful engagement.
You will be notified in the event of planned deletion and given an option to retain the account.
Certain Personal Data may be retained for 7 years
|Financial Advisory Service Delivery||
||For the duration of the provision of services and six years after completion of service delivery.|
|Marketing & Sales||
||12 months in the case where no meaningful engagement or earlier in the case you unsubscribe.|
||12 months or less|
In certain cases, we may retain Personal Data for longer than specified here if required under relevant laws.
16. Your Rights under the GDPR
You have rights under data protection law in relation to how PCS Financial Services (Kerry) Ltd T/A Premier Financial uses your Personal Data. You may generally access your rights free of charge.
You can ask for access to the Personal Data we hold on you
You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to all Personal Data we’ve recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.
We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.
We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.
You can ask to change Personal Data you think is inaccurate
You should let us know if you disagree with something included in your Personal Data.
We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
You can ask to delete Personal Data (right to be forgotten)
In some circumstances you can ask for your Personal Data to be deleted, for example, where:
- your Personal Data is no longer needed for the reason that it was collected in the first place
- you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it)
- there is no lawful basis for the use of your Personal Data
- deleting the Personal Data is a legal requirement
Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.
Please note that we cannot delete your Personal Data where:
- we are required to have it by law
- it is used for freedom of expression
- it is used for public health purposes
- it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing
- it is necessary for legal claims.
You can ask us to limit what we use your Personal Data for
You have the right to ask us to restrict what we use your Personal Data for where:
- you have identified inaccurate information, and have told us of it
- where we have no legal reason to use that Personal Data, but you want us to restrict what we use it for rather than erase it altogether
When Personal Data is restricted it can’t be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.
You can make a complaint
You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.
17. Amendments to this Data Protection Statement
We will post any changes on the Website and when doing so will change the effective date at the top of this Data Protection Statement. Please make sure to check the date when you use our services to see if there have been any changes since you last used those services.
In some cases, we may provide you with additional notice of changes to this Data Protection Statement, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.
Thank you for reading our Data Protection Statement. Please Contact Us if you have any questions.
18. Supervisory Authority
The Data Protection Commission in Ireland may be contacted using the contact details below if you have any concerns or questions about the processing of your Personal Data.
IRELAND - CONTACT DETAILS
|Address:||21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland|
|Telephone:||+353 578 684 800 or +353 761 104 800|