Privacy Notice:

Greenway Financial Advisors Ltd 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.

For the purposes of the GDPR the data controller is Greenway Financial Advisors Ltd. Our contact details are: 

277 Clontarf Road, Clontarf, D03 E9A0; 

ph: 01 853 2727

e: hello@greensocial.wpenginepowered.com

When we refer to we/us, we mean Greenway Financial Advisors Ltd.

Please read this Privacy Notice 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?

Greenway Financial Advisors Ltd, (C168372), is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Union (Insurance Distribution) Regulations 2018 and as a Mortgage Intermediary under the Consumer Credit Act, 1995 and as a Mortgage Credit Intermediary under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. You may contact the Central Bank of Ireland on 1890 777 777 or alternatively visit their website at www.centralbank.ie to verify our credentials.

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life, pensions & mortgages products, and to provide financial advice to clients on request. A full list of insurers, product producers and lending agencies with which we deal is available on request.

Our GDPR Owner can be contacted directly here:

• Name: Debbie Cheevers
• Email address: debbie@greensocial.wpenginepowered.com
• Phone number: 01 853 2727

How do we collect your information and what information do we collect?

The personal information we collect varies depending upon the nature of our services. We will endeavour to provide you with an overview of those categories of personal data our organisation collects and our purpose for using that data. 

Our organisation collects personal data in the following ways, if you:

• request a service from us that necessitates that we verify your identity & details, such as arranging a life insurance policy or mortgage.
• register with or use any of our websites or online applications, and request contact from us.
• use our website/apps and it installs cookies or other tracking technologies onto your device.  
• engage with us on social media. We maintain profiles on Instagram, Facebook, LinkedIn and Twitter, and if you request direct contact with us through these platforms, certain identifying details such as your username, and any information you choose to share with us will be collected as part of the contact.
• contact us with a complaint or query;
• apply for a position with us.

What information do we collect?

The information we collect about you includes the following, but not all interactions with us will require all types of information:

	Contact and Identifying information, e.g., name, address, contact details; email, mobile, landline
	Unique identifiers e.g.  PPS number – the reason why we collect your PPS number is to establish your identity & tax position for the set up of products like mortgages, pensions & investment products. pension scheme reference number- the reason why we collect this is where we have been directed by you to contact your pension provider to answer your queries. insurance policy numbers, the reason why we collect this is where we have been directed by you to contact your insurance provider to answer your queries.
	Demographic details, age, gender, marital status, lifestyle, and insurance requirements; date of birth, dependents, photo ID, as well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy, e.g., your children/spouse.  This data is collected for the purposes of analysis on your request, actuarial reasons for applications, and identity verification to adhere with Anti-MoneyLaundering Legislation.
	Family and Beneficiary Data, e.g., dependants, next of kin or nominated beneficiaries, Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax Advisor/Accountant.
	Employment information e.g., role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history; This information is necessary for our Fact Find with our clients.
	Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office.
	Health information such as information about your health status, medical records and medical assessment outcomes; We collect medical information relating to personal habits (e.g., smoking and consumption of alcohol), medical history. We may also process certain special categories of information, for example information about your personal characteristics (biometric information) or disability information. The policies where this information may be required include, but are not limited to: Life Insurance Mortgage Protection Serious Illness Cover Income Protection / Permanent Health Insurance
	Pensions and Insurance Benefits information such as current benefits, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, PAO
	Financial details e.g., bank account details, details of your credit history and bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details, and any other data required for your queries.
	Claims Data (From you and any relevant third parties).
	Marketing preferences: we will only send you direct marketing if you explicitly consent. We will also contact you regarding your existing products arranged with us, and regarding your outstanding queries.
	Online information: e.g., information about your visits to our websites;
	Social media information (e.g., likes and posts) with our social media presence; this includes, LinkedIn, Twitter, Facebook & Instagram.
	Searches that we undertake in relation to sanctions, money laundering and credit checks. We use all available means to verify identity, as appropriate to the service required, including cross-referencing against UN Security Council Sanctions list.
	Calculators on our website. We use this data to perform calculations to prepare quotations for life insurance or mortgages. For quotes requested independently, by the consumer, their email address is collected, to enable the quote to be emailed to them. This does not constitute a declaration of marketing preferences, nor does it constitute the beginning of a customer record.

When our organisation collects sensitive personal data as defined within the GDPR we will ensure that we require this information, and that we have your explicit consent and/or authorisation prior to our collection. Please see the further information contained in this Privacy Notice that outlines special categories of personal data.

Information we automatically collect.

We sometimes automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, “cookies”, and web beacons. Other cookies such as functional cookies, marketing cookies and analytical cookies will only be used with your expressed consent.

Currently, as of 19/12/22, we are collecting heat mapping information on our website. Heat mapping shows us areas of interaction on our website to help improve user interaction.

Heat mapping does not collect any personal information on 1. location, 2. inputted text/numbers, 3. keystrokes 4. Email addresses.

Further information about our use of cookies can be found in our Cookie Notice at the footer of our web page. 

How do we use your personal data?

Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your request for insurance, investment, protection, pension products, independent financial advice, quotes. 

1.	Performing services for our clients and prospective clients – when you require insurance/investment products, we use your data to enable us to provide the required product.
2.	Statutory and other regulatory requirements – we are required to carry out various obligations which include: AML/Sanction checking Knowing your customer “Fact Find”  Adherence to the Consumer Protection Code
3.	Communicate and marketing to you – We communicate via email & phonecalls, on your request. We also arrange video meetings on request. We may send newsletters to potential clients & existing clients who have explicitly requested that we include them on this mailing list.
4.	Process claims – where you need to request a claim, we will take your details, and facilitate the appropriate applications for you to the relevant provider.
5.	To contact you if required or to respond to any communications that you might send to us.
6.	To administer our site including data analysis, testing, research, statistical and survey purposes.
7.	Carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request.
8.	Provide professional services – we will undertake financial analysis and reviews on your request, and we will request the appropriate data from you to answer your questions. The nature and extent of data required will depend on your own questions, and will be appropriate to provide you with answers.
10	Handling complaints
11	To notify you about changes to our service

 

Legal Basis  We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to collect and use your personal data.   Performance of a contract When we enter a contract with you, we will collect and use your personal data to enable us to fulfil that service.  Legal obligation The use of some of your personal data is necessary for us to meet our legal obligations e.g., pension contributions for Revenue Certificates, Regulatory purposes to the Central Bank.   Consent Sometimes we may rely on consent as a legal basis for processing your information. For example, we rely on consent to collect and use personal data for any criminal convictions or alleged offences.  This is used when we need to assess risk relating to an insurance policy for you. We share this information with other third parties where it is necessary to manage these services provided to you – these services include insurance underwriters, reinsurer and other insurance providers.  We may also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely.  We will also ensure that we use clear and plain language and if you give us your consent you can withdraw this easily at any time.  Sometimes if you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect. Legitimate interests In cases where you have clearly requested marketing contact, and have requested that we arrange or advise on a life product for you, we may contact you regarding other life products that are similar or related to your original request or arranged product. You will have the option in this email to opt-out of further contact, and if selected, you will receive no further unsolicited marketing contact from us.  This will not affect any contact we need to send you regarding existing policies you’ve arranged with us, and you’ll still receive all the relevant information you require from us and your policy provider. Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws.

If you require further information on any of the above bases for processing your data, we can provide you with further details.

How we share your data  

When required, we may make your information available to third parties with whom we have a relationship, where that third party is providing services on our behalf. We will only provide those third parties (data processors) with information that is necessary for them to perform the services.  We will take measures to protect your information, such as putting in place Standard Contractual Clauses and confidentiality agreements. 

	Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters, reinsurers, and loss adjuster. You can refer to their privacy statements on their website for more information about their privacy practices. [links to product providers privacy statements]
	Vetting and risk management agencies such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies, where necessary to prevent and detect fraud in the insurance industry and take steps to assess the risk in relation to prospective or existing insurance policies and/or the services.
	Legal advisers, loss adjusters, and claims investigators, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature;
	Medical professionals, e.g., where you provide health information in connection with a claim against your insurance policy; or when we are providing a quote for insurance.
	EU Law enforcement bodies, when required to do so by law and/or regulation, or another legal request.
	Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity
	Third-party processors: We outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT service providers who manage our IT and back-office systems and telecommunications networks, and accounting and payroll providers, CRM providers.  These processing operations remain under our control and we have data processing agreements in place with all our third party processors to ensure all processing is carried out in accordance with our security standards and the GDPR.

Transferring personal data outside of Ireland

Where we transfer personal data to a country outside of the EEA (referred to in the GDPR as ‘third country,’) we will ensure it is done lawfully, i.e. there is an appropriate “level of protection for the fundamental rights of the data subjects”.  We will therefore ensure that either the EU Commission has granted an adequacy decision in respect of the third country, or appropriate specified safeguards have been put in place, (e.g., Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs)). 

Currently, we do not share or transfer personal data to any third party outside the EU, but we will conduct all appropriate checks in the event that we do this. We will have full details of the third party, and the relevant data protection agreements we have, available on this page.

Security

The security of your personal data is important to us, we have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk.  We have processes in place to protect your personal data from loss, unauthorised access, misuse, alteration and destruction.

Retention

Greenway Financial Advisors Ltd shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary.

Greenway Financial Advisors Ltd may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.

The retention period for each category of personal data will be set out in our Retention Schedule along with the criteria used to determine this period, including any statutory obligations we have. Should you require further information we would be happy to provide. 

Personal data will be disposed of securely.

Data Subjects Rights

Greenway Financial Advisors will facilitate your 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.  (The erasure of such data will be dependent on our other legal obligations, and whether the data is the subject of legal privilege). 
• 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. 
• Right to make a complaint: if we refuse your request under rights of access, we will provide you with a reason as to why. 

All 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.

Complaints

If you wish to make a complaint about how your personal data is being processed by Greenway Financial Advisors Ltd or how your complaint has been handled, you have the right to lodge a complaint with our GDPR Owner.

You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details are: 

Data Protection Commission

21 Fitzwilliam Square South,

Dublin 2. 

D02RD28

Web: www.dataprotection.ie

Email: info@dataprotection.ie

See website for updated contact details to reach the appropriate section within the DPC.

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.

When you fail to provide us with information we require to fulfil our obligations to you, we may be unable to offer our services to you. 

Profiling – automatic decision making

An automated decision is when we input your personal data into a computer programme and this programme analyses your personal data to provide us with a result.  There is no human involvement in the decision making. An example of this is the questionnaire we use to determine your attitude to risk for investment products. If a decision is taken by automated means, you have the right to object to this and ask us to reconsider the service you have asked us to provide. Some further examples of automated decisions that we undertake are listed below. 

An example:

As Financial and Mortgage Advisors, we use profiling in our business.  The main categories are 

1. Risk profiling.
2. Profiling for marketing purposes.

1. Risk Profiling

To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions. 

2. 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. 

Special Categories of personal data

Special categories of data are sensitive in relation to your fundamental rights and freedoms and therefore require specific protection when processed as these could create significant risks to the rights and freedoms of individuals. 

If we collect any special categories of personal data, such as health data, we will either obtain your explicit consent or we will adhere to the Data Protection Act 2018. This Act allows us to process special categories of personal data for insurance and pension purposes. We will ensure we have suitable and specific measures in place to safeguard the rights and freedoms of you and the processing of your data. These measures relate to the below:

• a policy of insurance or life assurance,
• a policy of health insurance or health related insurance
• an occupational pension, a retirement annuity contract or any other pension arrangement
• the mortgaging of a property

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on +353 1 853 2727 or email hello@greensocial.wpenginepowered.com 

Privacy notice/ statement changes

When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be effective from the point at which they are posted. We would encourage you to review our Privacy Notice so that you are aware of updates.

This privacy policy was last reviewed in August 2021. V7