Privacy Notice

City Life Galway Financial Services Ltd. trading as City Life Galway (“we,” “us,” and “our”) are committed to data privacy protections for its customers in accordance with the General Data Protection Regulation (GDPR). Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us when using our service.

For purposes of this Privacy Policy, “Site” refers to our website

“Service” refers to the provision of financial planning and protection, retirement planning, saving and investment services

“You” refers to you, as a user of our Site or our Service.

By accessing our Site or our Service, you accept our Privacy Policy and you consent to our collection, storage, use and disclosure of your Personal Data as described in this Privacy Policy.

You do not have to provide your personal information to us, but if you do not provide certain information, we may be limited in what services we can offer to you.

Who we are?

City Life Galway is a financial advisory firm offering professional financial planning expertise to our customers.

What information do we collect?

1. City Life Galway gathers and uses personal information in order to provide you with the products and services you have requested, information that is required to effectively provide financial planning services and to ensure that you are satisfied with the products and services we have provided.

2. When you contact us (including by email, post, phone, through our Site or our social media platforms) or we contact you to update you about our services, invite you for your annual review and to offer you additional products or services that you may be interested in, or you apply for a job with us, we may collect:

• Personal data, such as your name, email address and phone number; and
• work history, cover letter, curriculum vitae.

When you meet us for a consultation, we may collect:

• Name, DOB, civil status, PPS no. smoker/non-smoker, children/dependant names and their DOB, address, phone number, mobile, email address, your solicitors and accountant details, financial details and health details (incl. client medical doctors’ details, specialist consultants, medical details, family medical history, previous life cover details);
• Photo id and proof of address; and
• bank details including account holders name, IBAN and BIC.

3. Other sources of personal data:

• If you attend one of our information events, we may obtain your name and email as part of registration and request your consent for marketing purposes.
• If we engage your services for the purpose of holding a financial planning seminar, we may collect your name, company name, phone number and email address.
• We may use personal data provided to us from other sources, such as, from your accountants or solicitors, but only where you have provided us with consent.

4. Personal data you provide about other individuals:

• We use personal data about other individuals provided by you, such as your children and spouse. By providing other people’s personal data, you must be sure that they agree to this and you can provide it. You should also ensure that, where appropriate, they understand how their personal data may be used by us. When providing children`s data you confirm that you have parental responsibility for that child and are authorised to share their personal data.

How do we use personal information?

City Life Galway will process (collect, store and use) the information you provide in a manner compatible with GDPR. We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

We may collect, hold, use and disclose your information for the following purposes:

• administering services, (establishing affordability and providing quotations for financial services products) to identify appropriate products for your financial objectives and to take out products with relevant third-party providers on your behalf.
• managing our relationship with you, to contact you for an annual review and to give you updates about products and services. • delivering marketing and event communication through our social media platforms or sharing our newsletters by email (please see Mailchimp privacy policy).
• to comply with our legal obligations, such as a court order, subpoena, or for identification of fraud or regulatory reporting and compliance.
• to establish a customer’s attitude to investment risk (risk profiling) (relates to pensions and investments) advisors have automated calculators which calculate the customer’s attitude to various levels of risk having answered a series of questions.

When you provide your name and email address to us to enquire about our services, your contact details may be retained even if you do not become a client. These details will be held securely. This is so we can assist you in future, and as a result of this, you may receive a follow-up enquiry email.

What legal basis do we have for processing your personal data?

We will only process your personal data on the following legal basis:

Consent: When you give us explicit permission to process your personal data for example, when you sign up to receive our newsletter via our website or when you consent to certain processing activities on initial consultation. Should you not wish to receive our newsletters please simply indicate your preference to unsubscribe by following the directions provided in the e-mail.

Contract: When we arrange to purchase financial products on your behalf or take steps at your request to purchase financial products (i.e. obtaining a quote for certain financial products) or you enquire about our services by email, phone or through our site.

Legitimate interest: When it is in our or a third party`s legitimate interest and these interests do not override your right to privacy. When we invite you to a financial planning seminar or we may use your personal data to better understand your interests or to improve our services offered.

Legal Obligation: when we are required by law, such as under a court order, or for identification of fraud or regulatory reporting and compliance for example, Anti-Money Laundering regulations require us to collect information and act where necessary.

When do we share personal data?

While City Life Galway is committed to treating all personal data confidentially, ordinarily we may need to share it with other third parties:

• In order to provide Services and products requested by you, we may need to share your personal data with the third parties’ providers. We only share the minimum personal data that enable third parties to provide their services to you and us. We are committed to working with third-party processors who are GDPR compliant. Their use of your information is subject to their privacy policy.
• We also work with carefully selected suppliers that carry out certain functions on our behalf. For example, companies/software that help us with IT services, storing data and identifying fund projections.
• We may need to share personal data with other third parties (such as legal, accountants or other advisors, regulatory authorities, courts and government agencies), to defend or protect our legal rights, or where such disclosure is permitted by law, such as for the purpose of preventing fraud.
• When we share personal data with other businesses, we require them to keep it safe and use it only for the lawful basis on which it was shared and according to the data processing agreement. They must not sell or use your personal data for their own marketing purposes.

Where do we store and process personal data?

We store your personal details on our secure network, client management system and in hard copy format and we take measures to ensure that this file is in a secure location at all times.

Where necessary and in order to perform our contract with you we send your personal details to third parties. In some cases, these third parties may host data on servers which may be situated outside of the European Economic Area (EEA). Where they are, they are obliged to make sure that your personal information is adequately protected.

How do we secure your personal data?

The protection of your personal data is very important to us. We take appropriate organisational and technical measures to protect your data from loss or other forms of unlawful processing. All employees have been trained and are kept up-to-date on our security and privacy practices.

While no method of transmitting data over the Internet is 100% secure, we take every reasonable precaution to protect all information collected, such as:

• only sharing and providing access to your information to the minimum extent necessary;
• using secure servers to store your information; and • using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software
• to encrypt your personal details.

How long is your data retained for?

We will retain your personal data for only as long as it is necessary for the uses set out in this Privacy Policy and/or to meet legal and regulatory requirements. We are required by law to retain customer files for a period of 6 years.

After the relevant retention period, we will securely erase personal data in accordance with our Data Retention & Destruction Policy.

Your rights regarding your personal data

• The right to be advised of how we will use your personal information. This is set out in this Privacy Policy and we do our best to provide you with as much information as we can at the point at which you give us your data.
• The right to ask us to correct any information you believe is incorrect.
• The right to receive a copy of the personal data we hold about you or to request that we transfer this to another service provider.
• In certain circumstances, the right to ask us to stop using information about you.
• The right to lodge a complaint to the Data Protection Commissioner’s Office.
• The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
• The right to withdraw consent that you have provided to us to use your personal information.
• 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.

You can exercise these rights over your data by emailing us at info@citylifegalway.ie or by sending your access request by post to 12 Dock St, Galway, H91 FP4V Ireland.

We will comply with your requests unless we have a lawful reason not to do so. We will need you to provide additional details to confirm your identity in order to process your request.

Children’s Privacy

We do not intentionally offer services to children. Please be aware that we have not designed our website for, and do not intend for it to be used by, anyone under age 18.

Our website

We own and operate our Site where you can review our articles, sign up to receive our newsletter, send us an enquiry or login into Portus to view your financial products. Our website uses “cookie” technology. A cookie is a small piece of data or a small text file stored by the browser on your computer, at the request of our server. We may use cookies to deliver content specific to your interests – our cookies are not available to other websites. For more information, please see our Cookie Policy.

Links to other websites

Our website contains links to Portus. This Privacy Policy only applies to how we process personal data and our website, when you link to other websites you should read their own privacy policies. We don’t control websites which we do not operate and are not responsible for their contents or use of them. The inclusion of these links to such websites does not imply any endorsement of the material on such websites.

Changes to this Policy

We may update this Privacy Policy in the future, and we reserve the right to amend this Privacy Policy at any time. Updated versions will be posted on this website and are effective immediately on posting. Please check frequently, especially before you use this website, to see if this policy has changed.

Email: info@citylifegalway.ie

Last updated: 25th March 2019