PRIVACY STATEMENT
Introduction
Curran Futures 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 Curran Futures in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
- Karen Sheridan
- Contact details: 091 861 001
- When we refer to ‘we’ it is Curran Futures
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 we are?
- Ross Curran Financial Services Limited trading as Curran Futures is an innovative firm specialising in all aspects of Financial Planning. Based in Galway, our lead service offers advice to individuals and businesses in all aspects Financial Planning and arranges transactions on behalf of clients in relation to:
- Life Insurance (Term Cover, Specified Illness, Permanent Health Insurance and Income on Death)
- Pensions
- Investments
- Mortgages
- Copies of our regulatory authorisation are available on request.
Our data protection representative can be contacted directly here:
- Karen Sheridan
- karen@curranfutures.ie
- 091 861001
Purpose for processing your data
We collect, hold and disclose your personal information for the following purposes;
- To provide you with ongoing organisational updates, funding information and analysis services in line with the relevant policies/ plans.
- This information is used in order to assist us making recommendations in your best interest.
We will not collect any personal data from you which we do not need in order to provide and oversee our services to you.
All the personal data we process is processed by our staff in Ireland however for the purposes of IT hosting and maintenance this information is located in servers within the European Union.
Why we are processing your data? Our legal basis.
Our reason for processing your data under the GDPR is:
In order to provide you with our services (Financial Planning, Pensions, Investments, Mortgages, Insurance and/or general Financial Advice), it is necessary for us to collect and process your personal data. Our reason (lawful reason) for processing your data under GDPR is;
- That the processing is necessary for the performance of the advisory services contract (or any other contract) that we commit to delivering to you from time to time.
- That some processing is necessary for the purposes of the legitimate interest that we have, as a firm that is authorised and regulated by the Central Bank of Ireland, in the proper administration and correct operation of our firm.
- There may also be circumstances where the legal basis, for processing your personal data is consent (where we have sought it and it has been provided to us), in which case that consent may be withdrawn at any time.
In any event, Curran Futures 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.
How will Curran Futures use the personal data it collects about you?
Curran Futures 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.
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
COLLECTION AND USE OF PERSONAL INFORMATION
We collect your personal information directly from you or voluntarily via our website www.curranfutures.ie.
The site is hosted on our AWS servers located in Europe. Amazon has a range of security policies in terms of GDPR which can be accessed from: https://aws.amazon.com/compliance/eu-data-protection
We will not collect any personal data about you on this website without your clear permission apart from information you volunteer via the following web pages;
- “MoneyValues ™ Assessment”
- “Contact us”
- “Sign up to our newsletter”
WEBSITE:
- MoneyValue ™ Assessment:
Through contact forms on www.curranfutures.ie you have an opportunity to send us information. By submitting your data, you are providing us with some level of personal information. This information is stored on our website CMS database held with Amazon. Your data is also emailed to our website email address where it is saved, so we can respond to your enquiry. Additionally, we may use your contact details to send you marketing material in the future. You may unsubscribe from any emails you receive after the first reply.
- Contact Forms:
Through contact forms on www.curranfutures.ie you have an opportunity to send us information. By submitting your data, you are providing us with some level of personal information. This information is not stored on our website database, however your data is emailed to our website email address where it is saved, so we can respond to your enquiry. Additionally, we may use your contact details to send you marketing material in the future. You may unsubscribe from any emails you receive after the first reply.
- Subscribing to our Newsletter / Mail List:
By choosing to sign up for our subscribe to our newsletter list you are consenting to your data being sent and stored by Mailchimp. You can find out more about how Mailchimp stores and handles your data here. https://mailchimp.com/legal/privacy/
THIRD PARTY SERVICE PROVIDERS;
We may pass your personal data on to third-party service providers contracted to Curran Futures 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 fulfil 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 a manner compatible with the EU’s General Data Protection Regulation (GDPR).
Our ‘Client Portal’ is a password protected section of our website where significant amounts of personal information can be located. This will include a document repository along with information you provide through the Personal Finance Questionnaire.
- Product providers:
Product providers for the purposes of establishing a contract with the provider. If a contract is established, you will consent to providing this information to the product provider through the completion and signing of their proposal/application form.
- Other service providers:
Any other 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.
The third parties that we pass your personal data to may be:
- Mailchimp
- Wealthtrack
- Voyant
- FinaMetrica
- Snap Printing
- Granite Digital
- Docusign
- Quickbooks
- Tishkint
You can find out more about how each stores and handles your data here.
We have issued all our third-party processors with a Data Processor checklist asking them GDPR specific questions
If we transfer personal data to a third party in 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.
We will not intentionally disclose your personal information to third parties other than as listed above, whether for such third parties marketing purposes or otherwise, except where we believe we are under a legal duty to do so e.g. with the consent of the individual or where required by law.
How long do we hold personal information?
Personal data is only held for as long as necessary, i.e.:
(i) For as long as required under legal or regulatory requirements; or
(ii) For as long as required for legitimate business purposes.
By way of examples:
- CBI/CPC requirements (retain data for at least 6 years from date of last transaction).
- Note: FSO requirements on long term investment products or mortgages; and
- Restrictions on retaining data on Spent convictions (the “7-year rule”);
Data is never kept on a “just in case” basis.
Your rights as a data subject:
Curran Futures facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.
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 at any time
- 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 Organisation Name 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. Curran Futures will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance.
Complaints
In the event that you wish to make a complaint about how your personal data is being processed by Curran Futures) or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority (details below) and the Curran Futures data protection representative.
Data Protection Commission in Ireland, whose details are:
Data Protection Commission
Canal House
Station Road
Portarlington
Co. Laois, R32 AP23
Phone: +353 57 868 4800 / +353 761 104 800
Fax: +353 57 868 4757
Email: info@dataprotection.ie
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 091 861 001 or email karen@curranfutures.ie. We will treat your requests or complaints confidentially subject to our obligations to customers who may have provided us the information.
Our Data Protection representative will contact you within a reasonable time after receipt of your request or complaint to discuss your concerns and outline options regarding how they might be resolved.
Privacy Policy Statement Changes
Curran Futures 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 April 2019