Privacy Policy

Introduction

Imperius Wealth 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 Imperius Wealth in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

• Gerard Frew
• gerard.frew@imperiuswealth.com
• When we refer to ‘we’ it is Imperius Wealth Ltd.

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 are we?

• We offer expert advice across the financial spectrum and across international borders. From risk profiling to asset management, retirement planning to tax advice, we offer financial planning from expert financial planners.
• Imperius Wealth is a group of internationally accredited advisers who have experience in working in the Republic of Ireland, the UK and the European Union.
• We work with both individuals and companies to provide bespoke investment and pension advice both at home and across borders.

Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:

• Gerard Frew
• gerard.frew@imperiuswealth.com
• +353 15241040

Purpose for processing your data

• We will use your data to inform you and update you in regard to market developments and to keep you updated in respect of product developments and certain changes in regulation. Your data will also be processed for the purpose of arranging financial transactions as agreed by you at outset. All data is held securely and is not divulged to any third party unless we have your permission to do so or this is a requirement to complete a transaction you have requested us to carry out.

• The information we process can include sensitive personal data, including health and lifestyle data, which may be used for the purposes of arranging life assurance or health cover. We have an obligation to know our clients and data may be held on record for up to 6 years after a transaction has been completed for regulatory purposes.

• Your information will only be processed to provide you with the most suitable financial plan relevant to your circumstances, we will not process any sensitive personal data without your express permission beforehand.

• Information will be processed to send you a file of our eBook and will be added to our mailing list for future marketing purposes

Why we are processing your data? Our legal basis.

In order to provide you with our financial planning and wealth management services it is necessary for us to collect and process your personal data. We are required, therefore, to inform you of the legal bases for processing your personal data. One such legal basis is that the processing is necessary for the performance of the advisory services contract (and any other contract) that we commit to delivering to you from time to time. Another legal basis is 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, Imperius Wealth 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 Imperius Wealth use the personal data it collects about me?

Imperius Wealth 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

Who are we sharing your data with?

You need to provide information on recipients or categories of recipients of the personal data – if any

Any information regarding the intention to disclose personal data to third parties and whether it is transferred outside the EU. In such circumstances, Organisation Name will provide information on the safeguards in place and how the data subject can also obtain a copy of these safeguards;

If Organisation Name is based outside of the EU and the data subject resides within it (the EU), the Organisation Name provides the data subject with contact details of a data protection representative in the EU;

Any information on website technologies used to collect personal data about the data subject;

Any other information required to demonstrate that the processing is fair and transparent.

We may pass your personal data on to third-party service providers contracted to Imperius Wealth 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 no longer need your data to fulfil this service, they will dispose of the details in line with Imperius Wealth 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.

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 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.

Data Subjects Rights:

Imperius Wealth facilitate you, our clients, 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.
• 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 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. Imperius Wealth will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (xxx) and our internal governance.

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Imperius Wealth or how your complaint has been handled, you have the right to lodge a complaint with the Organisation Name’s data protection representatives Data Protection Officer / GDPR Owner.

You may also lodge a complaint with the 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

Web:  www.dataprotection.ie/en

Email: info@dataprotection.ie

Failure to provide further information

If we are collecting your data for an investment, life assurance or pension contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – automatic decision making

1. Risk Profiling

To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the client’s attitude to various levels of risk having answered a series of questions. This will give an insight into the way you perceive financial risk and reflection of your tolerance to any investment losses. This enables the design of a solution specifically tailored to your needs and something which should perform in line with your risk expectations

• Establishing affordability and providing quotations for financial services products.

To provide you with the most suitable and where appropriate, cost effective solution we may use your details to compare various insurance providers for life and serious illness cover.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on +353 15241040 or email gerard.frew@imperiuswealth.com

Privacy policy statement changes

Imperius Wealth 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 2018

Source: Atlantic Compliance Ltd