Privacy Policy

Foxrock Financial Limited - Privacy Notice/Statement

Introduction

The General Data Protection Regulation (“GDPR”) is effective from the 25th May 2018 and is the first major revision of Data Protection rights and responsibilities at European Level since 1995. This regulation, along with applicable Irish legislative changes, amends existing data protection law in Ireland and creates enhanced accountability and transparency obligations for all companies who process personal data, as well as granting new and enhanced rights for individuals. Foxrock Financial Limited 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 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 Foxrock Financial Limited in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

Foxrock Financial Limited

Contact details:

Alan Flynn
Managing Director
Foxrock Financial Limited
101 The Rise
Mount Merrion
Blackrock
Co Dublin

Tel           +353 1 9065772
Mob        +353 87 2608315
Email      alan@foxrockfinancial.ie
Web       www.foxrockfinancial.ie

Foxrock Financial Limited is regulated by the Central Bank of Ireland

When we refer to ‘we’ it is Foxrock Financial Limited

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?

  • Foxrock Financial Limited. is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Communities (Insurance Mediation) Regulations, 2005; and as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995. Copies of our regulatory authorisations are available on request.
  • We provide Financial Advice in respect of, or arrange contracts for, Investments, Life Assurance, Critical illness, Income protection, Pensions, Self-Administered Pensions, Personal Retirement Saving Accounts, Group Employee Benefits, Approved Retirement Funds, and Annuities and related services.

Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:

Alan Flynn 
Managing Director 
Foxrock Financial Limited 

Breda Flynn
Director
Foxrock Financial Limited

101 The Rise
Mount Merrion
Blackrock
Co Dublin

Tel           +353 1 9065772

Web       www.foxrockfinancial.ie

Why we are processing your data? Our legal basis.

In order for us to provide you with Financial Advice in respect of, or to arrange contracts for, Investments, Life Assurance, Critical Illness, Income Protection, Pensions, Self-Administered Pensions, Personal Retirement Saving Accounts, Group Employee Benefits, Approved Retirement Funds, Annuities and related services Foxrock Financial Limited need to collect personal data for provision of the above services.

Our reason (lawful reason) for processing your data under the GDPR is:

  • Legal basis - Foxrock Financial Limited needs to process your data as this is necessary in relation to a contracts or service 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 or to amend provide advice on or alter a contract for any of the services described above.

In any event, Foxrock Financial Limited are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

What Data Do We Collect?

We may collect data under a number of categories, including:

Identification & Contact Information, including your Name, Date of Birth, Gender, Marital Status, PPS Number, Address, Email Address, Home Phone Number, Work Phone Number, Mobile Number, Fax Number.

Financial Details & Financial Information, including your Occupation, Job Title, Total Remuneration, Date Employment Commenced, % Shareholding, Existing Pension Benefits, Employer Name, Bank Details, Tax- Residence, Date Employment Ended.

Other Personal Information, including information provided by you during the course of your relationship with us such as data to complete a transaction or enter an investment on your behalf, or data collected from online activities, such as cookies.

Special Categories of personal data

If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below

  • we will obtain your explicit consent

How will Foxrock Financial Limited use the personal data it collects about me?

Foxrock Financial Limited 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.

Who are we sharing your data with?

We will keep your personal data confidential but may pass your personal data on to third-party service providers contracted to Foxrock Financial Limited 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 fulfil this service, they will dispose of the details in line with Foxrock Financial Limited 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:

  • Data ProcessorsCompanies 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. Our main Data Processor is Money Advice Ltd. The categories of service include: document management, administration, customer services, marketing, AML and PEP screening.
  • Insurance Companies and Product Producers with whom we hold written agency agreements.
    • Aviva Life & Pensions Ltd
    • Friends First Life Assurance Co
    • Harvest Financial Services Ltd
    • Irish Life Assurance Plc
    • Independent Trustee Company
    • New Ireland Life Assurance Company Plc
    • Phoenix Life Ltd
    • Quilter Cheviot
    • Royal London Mutual Insurance Society Ltd
    • Scottish Mutual International
    • Standard Life Plc
    • Zurich Life Assurance Plc
  • Regulators and the Revenue Commissioners or as needed to comply with regulations and laws.
    • Where Alan Flynn acts as Pensioneer Trustee and Registered Administrator to Self-Administered Pension Schemes we may pass your sensitive personal data onto a third party. We will only do so once we have obtained your explicit instructions and 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:

Foxrock Financial Limited 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 Foxrock Financial Limited 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. Foxrock Financial Limited will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body and our internal governance.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Foxrock Financial Limited) or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Foxrock Financial Limited’s data protection representatives Data Protection Officer / GDPR Owner

Failure to provide further information

If we are collecting your data for a contract 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

We may carry out automatic decision making. When we do so you will be informed as to the effect, the significance and the envisaged consequences of this profiling. You have the right to object to this profiling.

The main categories of profiling are:
a) Risk profiling.
b) Profiling for marketing purposes.
c) Establishing affordability and providing quotations for financial services.

a) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) we 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.

c) Establishing affordability and providing quotations for financial services products.
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.

Additional Processing

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.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 01 9065772 or email info@foxrockfinancial.ie
Privacy policy statement changes
Foxrock Financial Limited may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services, you agree to this privacy policy.

This privacy policy was last reviewed in May 2018