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Privacy Policy

1. WHAT IS A PRIVACY NOTICE & WHY IS IT IMPORTANT?

We know your personal information is important to you and it is important to Stuart Mc Cormack Financial Services Limited too. This Privacy Notice tells you what we use your personal information for and explains your rights around how we use it. Please read this 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 Privacy Notice, as it also applies to them.

2. WHAT PERSONAL INFORMATION WE COLLECT AND WHY?

We use personal information to provide our plans, service our customers, assess claims and pay benefits. We must have a lawful basis to collect and use personal information. This is explained below:

NEEDED FOR YOUR CONTRACT:

We need to collect and use your personal information to provide your plan contract. This includes information such as yournname, date of birth, contact and bank account details. We will ask for other information depending on the plan type and thisncan include health, employment, pension and salary information. We restrict access to, and use of, any sensitive personal information. We also create new personal information such as your plan value and benefits.

Personal information needed for plan contracts is held and used to:

  • process your application;
  • issue your plan;
  • make and receive payments;
  • provide you with information about your plan;
  • administer your plan and pay 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:

  • reporting to regulators;
  • keeping proper books and records; and
  • actuarial analysis and risk management to ensure the company stays financially sound.

We carry out internal reporting, quality checking, compliance controls and audits to help meet these obligations.
We must collect certain personal information to comply with Anti-Money Laundering law. This depends on your plan type but includes up to date proof of identification and address. We also screen all customers against Financial Sanctions and Politically Exposed Persons (PEP) lists. To do this, we use your name, date of birth, address, nationality and occupation information.

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. Under regulations we must give you information and updates on your plan. To do this, we use your plan and contact details. We must keep and use your relevant personal information to calculate the death and disability liability for other plans like yours. As a regulated product producer, we must use our customer personal information, including yours, to identify the target market for our regulated products and services. If you get financial advice from one of our agents, you must give personal and financial information for your current and future needs to be assessed. This enables the agent to recommend the most suitable financial product for you. This also involves creating new and inferred personal information about you. The agent has to do this 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. Please see section 8 of this Privacy Notice.

STUART MC CORMACK FINANCIAL SERVICES LIMITED LEGITIMATE INTEREST:

We use your personal information for our legitimate interests as shown below. This doesn’t affect your privacy rights. We have taken account of any privacy risks and have ensured that your data protection rights are not affected. We believe these uses benefit our customers. You can contact us if you have any questions using the details in section 9 of this Privacy Notice.

WITH 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.

  • Automated-Decision Making, including profiling:
    • We have an automated-decision making system for underwriting. This is designed to improve efficiency, reduce costs, improve quality and provide consistent underwriting decisions.
    • This system determines underwriting acceptance and the terms we can offer.
    • Acceptance and terms are based on set risk criteria agreed between Stuart Mc Cormack Financial Services Limited and our product providers.
    • You will be asked to provide consent for automated underwriting decisions to be made about you.
    • You can ask to have a person review and make the final underwriting decision.
  • Direct Marketing:
    • We would like to be able to contact you about offers and services from across our group of companies, separately from your plan communications. We will only send you direct marketing content where we have your consent.
  • Cookies
    • When you visit our website we will use cookies to tell us whether you have visited our website before. We also use cookies for third party advertising to show you Stuart Mc Cormack Financial Services Limited ads where you have visited our website before or visited other websites offering similar products and services. We will ask for your consent to use these once you visit the website.
  • Advice from an Stuart Mc Cormack Financial Services Limited Agent:
    • Where you get advice from one of our agents you consent to giving your personal information for that advice and any future advice service.

3. 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 using the details in section 9 of this Privacy Notice.

4. HOW AND WHERE DO WE GET YOUR PERSONAL INFORMATION FROM?

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. Revenue rules. 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.

5. WHO DO WE PASS YOUR PERSONAL INFORMATION TO?

We pass personal information, including personal health information if necessary, 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.
  • Trustees:
    • appointed in connection with the plan contract.
  • Health Professionals:
    • where needed for underwriting and paying benefits.
  • Regulators:
    • Regulators and the Revenue Commissioners or as needed to comply with regulations and laws.
  • Other Insurers:
    • For assessing claims if we accepted your cover based on a proposal and underwriting with another insurer.
    • For checking if you have similar cover or claims in place for certain plans in line with Revenue rules.
  • Other Companies:
    • We pass your personal information to third parties with your consent.

6. DO WE TRANSFER YOUR PERSONAL INFORMATION OUTSIDE OF THE EU?

Your personal information is processed and stored within the EU. However we do pass personal information securely to our product providers who are head quartered outside the EU. We do this for their administration purposes, for recording of legal claims and for screening our customers against Financial Sanctions and PEP lists to comply with
Anti-Money Laundering rules. Passing your personal information to certain countries, including Canada, is allowed under an adequacy decision made by the European Commission. Great-West Lifeco has a legal obligation to maintain a list of our identified high-risk customers.

7. 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, legal claims, for system back-ups and for as long as we have to under regulations. We will let you know how long we keep personal information for when you avail of a single or specific service such as a quote or call-back on our website.

8. 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 section 9 of 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 regulation. 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. The most recent version of our privacy notice will always be accessible on our website at www.pensionoptions.ie. If we make any changes to the type of personal information we collect and/or how we use it we will inform you of the changes. We have controls in place to protect your personal information and minimize the risk of security breaches. However should any breaches result in a high risk for you, we will inform you without undue 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 Stuart Mc Cormack Financial Services Limited 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, if it is no longer needed 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 Stuart Mc Cormack Financial Services Limited 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. It is unlikely we will be able to use a copy of your personal information sent to us in this way. 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
  • if we carried out any automated-decisions, and if so, the logic behind it and what it means for you.

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 section 9 of this 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.

9. HOW TO CONTACT US

You can contact with any questions about your personal information and this privacy notice:
Stuart Mc Cormack Financial Services Limited

10. STUART MC CORMACK FINANCIAL SERVICES LIMITED DATA PROTECTION OFFICER

31 Radharc An Chlair, Grattan Road
Salthill, Galway
1850 677 677

11. COMPLAINTS

If you do not think that we have processed your personal information in line with this Privacy Notice, please contact us. If you are not happy with how we have processed your personal information or handled your privacy rights, you can complain to the Data Protection Commission by contacting them below:

Data Protection Commission,
Canal House,
Station Road,
Portarlington,
Co. Laois, R32 AP23
Telephone: +353 761 104 800

LoCall: 1890 252 231
Email: