Privacy Policy

Introduction

We are committed to protecting and respecting your privacy. We strive to be transparent about how we process your data and ensure that we comply with GDPR standards. Our goal is to not only process your data responsibly but also to ensure that you fully understand your rights as a client.

It is the intention of this privacy statement to explain to you our information practices in relation to the information we collect about you.

Data Controller

Chartered Capital Financial Planning Ltd t/a Chartered Capital (‘the Company’, ‘We’, ‘Us’ or ‘Our’) is a Data Controller within the meaning of the General Data Protection Regulations (697/2016/EU) (‘GDPR’) and applicable Irish data protection legislation (currently the Irish Data Protection Acts 1988 to 2003). As a Data Controller, the Company is obliged to provide you with information on how we collect, use, store and share your personal data. This document has been made available for that purpose.

Information We Collect

We collect information: (i) you give us; (ii) information generated during the provision of our services and; (iii) information provided to us by third parties.

There may be instances where we use your information even if you are not directly our customer. For example, you could be a beneficiary, guarantor, director, or representative of one of our customers, or you might be a potential customer inquiring about our services.

The types of information we may collect or hold about you include, but are not limited to:

• Identity details, including your contact information.
• Financial information, such as account details and transaction history.
• Information about your financial circumstances, including personal wealth, assets and liabilities, income, and expenses.
• Details about your family, lifestyle, and social circumstances, including your goals and objectives, as well as health information where relevant.
• Information provided by others, such as your spouse or parent, when relevant to your financial circumstances or requested services.
• Information you have consented to us using.

Purposes of Processing and the Legal Basis for Processing

We use and share your data in the following situations:

• With your consent: When you have explicitly agreed to the use of your data in a specific manner (e.g., to receive information about new investment opportunities). You may withdraw your consent at any time by contacting us.
• To provide a service or fulfil a contract: When the use of your data is necessary to deliver a service or fulfil a contract you have entered into (e.g., to provide ongoing intermediation and advisory services) or to take steps at your request before entering into a contract.
• To comply with legal obligations: When the use of your data is required to meet legal obligations (e.g., complying with Anti-Money Laundering regulations, reporting to regulatory authorities, and cooperating with law enforcement).
• To protect your vital interests: In exceptional circumstances, when the use of your data is necessary to protect your vital interests.
• For our legitimate interests: When the use of your data is necessary for our legitimate business interests, such as managing our operations, preventing fraud or crime, conducting training and quality assurance, strategic planning, and performing statistical analysis of our services. You have the right to object to the use of your personal information for these purposes.

Recipients of Your Personal Data – Third Parties

In the course of providing our services to you, complying with legal obligations, or pursuing our legitimate interests, we may share your personal data with the following categories of recipients:

• third parties with whom: (i) we need to share your information to facilitate transactions you have requested (e.g. custodians, insurance companies, investment managers); (ii) you ask us to share your information with; or (iii) we are legally obligated to provide information to (e.g. The Revenue Commissioners, The Central Bank of Ireland);
• your authorised representatives such as Tax Advisors, Solicitors, etc.;
• service providers who provide us with support services to enable delivery of our services;
• statutory and regulatory bodies and law enforcement authorities;
• pension fund administrators, pension trustees, etc.;
• business or joint venture partners.

Transfer of Data Outside of the EU

Occasionally, we may transfer personal data outside of the EU. In such instances, we take steps to ensure that appropriate security measures are in place to protect your data and that the transfer is conducted on a lawful basis.

To deliver our services, we work with various service providers, some of whom are located outside the EEA. As a result, the use of their services may involve transferring your data outside of the EEA. Currently, the destination countries include South Africa, the United States, the Isle of Man, and Jersey. We ensure that these transfers are legally protected through measures such as model contract clauses, binding corporate rules, and adequacy decisions.

How Long We Retain Your Data

The retention period for your data is determined by applicable laws and regulations. Generally, we will retain your data for 6 years following the conclusion of our relationship with you or the last service provided, in line with the Statute of Limitations for contracts. However, we are committed to ensuring that your personal data is not kept longer than necessary to fulfil its intended purpose or to meet specific legal retention requirements.

Your Rights Regarding Our Use of Your Data

From 25 May 2018, you have several enhanced rights in relation to how we use your information, including the right, without undue delay, to:

• find out if we use, access or receive your information;
• have inaccurate/incomplete information corrected and updated;
• object to particular use of your personal data for our legitimate business interests or direct marketing purposes;
• to withdraw consent at any time where processing is based on consent.
• in certain circumstances, to have your information deleted or our use of your data restricted;
• in certain circumstances, a right not to be subject to solely automated decisions and where we make such automated decisions, a right to have a person review the decision;
• exercise the right to data portability (i.e. obtain a transferable copy of your information we hold to transfer to another provider);

If you wish to exercise any of your data rights, you can contact us by writing to:

Head of Data Protection,
Chartered Capital Financial Planning Ltd,
53 Kenyon St,
Nenagh,
Co. Tipperary,
E45 XY81

Or by emailing planner@charteredcapital.ie

We aim to respond to your request within one calendar month. If we are unable to fully address your request within this timeframe due to its complexity or the volume of requests, we may extend the period by an additional two months and will provide you with an explanation for the delay. If your request is made electronically, we will endeavour to provide the relevant information in the same format.

If you are not happy with any aspect of how your data is used, you also have the right to complain to the Data Protection Commission. You can contact the Data Protection Commission at:

Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231
Fax: +353 57 868 4757
E-mail: info@dataprotection.ie
Postal Address:
Data Protection Commission,
Canal House, Station Road,
Portarlington, R32 AP23,
Co. Laois.

Information We Need

If you do not provide certain information, we may not be able to:

• provide the requested services to you;
• continue to provide existing services.

We will tell you when we ask for information that is not a contractual requirement or is not needed to comply with our legal obligations.

Automated Decision-Making

We may analyse your information using automated means to:

• help us understand your needs and develop our relationship with you;
• to assist in compliance with our legal obligations in connection with prevention of money laundering, fraud and terrorist financing.

Policy Review

We 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 on the 1st of February 2020.