Sullivan Life & Pensions Limited are authorised to advise you in relation to a wide range of Insurance, Protection, Pension and Investment Products. We work with a number of executives, small business owners and individual’s to help them build a Financial Plan suitable to them and their future. We offer a clearly defined and transparent process delivering personalised solutions based on each individual’s personal circumstances. At Sullivan Life & Pensions we are committed to protecting and respecting your privacy at all times and as such 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.
This Privacy Statement explains the information practices of Sullivan Life & Pensions Ltd., in relation to the information we collect about you. Sullivan Life & Pensions Limited complies with the EU General Data Protection Directive – GDPR for the collection, use, and retention of personal information from European Union member countries.
The Purpose for processing your data
In order for us to provide you with the services outlined above we must firstly identify and select suitable products from the Product Providers (Insurers) we hold an agency with. On acceptance and on receipt of your instructions we will transmit these orders on your behalf to one or more Product Provider (Insurers).
In order to do so however we need to collect personal data from you. At all times, we will ensure that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
Why we are processing your data? Our legal basis.
Sullivan Life & Pensions Ltd., needs to process your data as this is necessary in relation to a contract of insurance to which you the individual has entered into or because you, the individual has asked for something to be done so they can enter into a contract.
Sullivan Lie & Pensions will request your consent to process your data.
Sullivan Life & Pensions Ltd., 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 endeavor 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 to obtain your explicit consent.
What other information we gather- when using our website;
In general, you may visit this website without identifying yourself or revealing any personal information from your visit to customise and improve your experience on our website.
This website may collect certain information from your visit, including the date and time of your access, the pages you have accessed, the name of the Internet Service Provider and the Internet Protocol (IP) address by which you are accessing the Internet, and the Internet address from which you linked to our site, if applicable. We use this information to better understand how our website is being used so that we can improve its performance.
Some portions of this website may request that you give us information about yourself, from which we are able to identify you, such as your name, email or other address.
Use of the information we gather- when using our website;
When we collect information about you, we intend to tell you why we are asking for the information and what we intend to do with it. You will have the option of not providing the information, in which case you may still be able to access other parts of our website, although you may not be able to access certain services. In certain areas of our website, we may, where appropriate, enable you to ‘opt in’ to certain uses of your information e.g. personal data and direct marketing. Data will not be held for longer than is necessary, general client details will only be held while you are a customer.
The information we collect about you or your computer is used to run the website, respond to your requests or process any transactions you have requested. It may also be used to verify your identity, send you information or contact you in relation to a product or service that you are using or that we believe may be of interest to you, but only after you have chosen to ‘Opt in’.
Sullivan Life & Pensions intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate steps to safeguard and secure the information we collect on line, including the use of encryption when collecting or transferring sensitive data.
However, you should always be aware that the internet is an open forum and that data may flow across networks with little or no security measures, and therefore such information may be accessed by people other than those you intended to access it.
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to Sullivan Life & Pensions Ltd., 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 are no longer need your data to fulfil this service, they will dispose of the details in line with Sullivan Life & Pensions Ltd., 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. 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.
Your rights as a data subject
Sullivan Life & Pensions Ltd., facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure, which 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.
- 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.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Sullivan Life & Pensions Ltd., will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by Sullivan Life & Pensions Ltd., or how your complaint has been handled, you have the right to lodge a complaint directly with Sullivan Life & Pensions Data Protection Officer in writing at 4 Upper Hartstonge St., Limerick. We will deal with your complaint in line with our company’s complaint procedure which is available upon request.
How to update and/or amend the personal information you have provided
You are entitled at any time to know whether or not we hold information about you and, if we do, have access to that information and have it corrected if it is inaccurate or out of date. To exercise your Right of Access or to update your details please email your request to email@example.com with details of your amendment together with proof of identity.
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. If we are relying on your consent to process your data you can withdraw this at any time – this does not affect the lawfulness of processing based on your consent before its withdrawal.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 061-313255 or email us at firstname.lastname@example.org
Sullivan Life & Pensions Ltd., is regulated by the Central Bank of Ireland. Registered in Ireland No: 333832 Registered Office: 4 Upper Hartstonge Street, Limerick.