Privacy

The data controller in respect of the personal information provided by you is Athora Ireland Services Ltd. Athora Ireland Services Ltd provides a range of services on behalf of Athora Ireland plc. In this instance, Athora Ireland Services Ltd is acting as a data processor on behalf of Athora Ireland plc.

Purpose

The purpose of this privacy statement is to inform you about how we comply with these rules and the Data Protection Acts.

Data protection

Any personal data processed in relation to your enquiry or your plan would be administered in Ireland, so it comes under Irish laws on privacy of personal data. These laws are the EU General Data Protection Regulation (2016/679), and the Data Protection Acts 1988 - 2018 and any subsequent related legislation.

Data protection fundamentals are governed by a number of rules. These rules state how any data we collect within our organisation should be treated. These rules are:

1. Obtain and process information fairly
2. Keep it only for one or more specified, explicit and lawful purposes
3. Use and disclose it only in ways compatible for these purposes
4. Keep it safe and secure
5. Keep it accurate, complete and up-to-date
6. Ensure that it is adequate, relevant and not excessive
7. Retain it for no longer than is necessary for the purpose or purposes
8. Give a copy of his/her personal data to an individual, on request

Use of personal information

We will use your personal information and any personal information of other interested parties which you have disclosed to us:

• to assess your application for a plan or bond;
• for administration when the plan or bond has been set up;
• to provide services to any arrangement or trust that your plan or bond is part of;
• to deal with your requests and enquiries;
• to provide you with information about Athora Ireland plc products and services;
• to carry out customer and marketing research;
• for internal record-keeping; and
• to provide aggregate information and statistics for the purposes of monitoring website usage to help us develop our website and services (these statistics will not include information that can be used to identify any individual). 
• We may share your information both inside and outside the European Economic Area, in confidence, for the above purposes, with agents or service providers we have appointed, regulatory bodies and other affiliated companies and as required by law.

We will also share permitted relevant information with anyone acting on your behalf (for example a financial adviser).

To comply with international tax obligations, we may share your information and the information you have provided us with on any individuals and entities connected with your plan, with Irish Revenue for the purposes of both the Foreign Account Tax Compliance Act (FATCA) and the Common Reporting Standard for Automatic Exchange for Financial Account Information (CRS).

For FATCA, we must report a United States (US) connection and for CRS, we must report non-Irish residency. The information we share with Irish Revenue will include name, address, date of birth, tax identification number, policy number policy value, and any payments made to the policy during the calendar year. In accordance with legislation, Irish Revenue shall exchange this information with the US Internal Revenue Service for FATCA purposes if there’s a US connection, and for CRS, they will share it with the relevant tax authorities. For more information, please visit the Irish Revenue’s website revenue.ie.

To comply with anti-money laundering regulations, we may verify your identity (or the identity of other interested parties) by carrying out a database search with a commercial agency.

We do not sell personal information collected through this website or use your personal information for any purposes other than those stated above. 

Telephone calls may be monitored or recorded to ensure that we carry out your instructions correctly and to help improve the quality of our service and in the interests of security.

Policyholder providing third party information to us

If you provide us with information relating to any individuals or entities connected with your plan or bond, you must take all steps necessary to legitimise your processing of their personal information. You can meet this requirement by:

• obtaining their consent to processing the information before you share it with us;
• providing our information to the individual or entity connected with your plan or bond;
• providing them with a copy of our “Protecting your personal information” leaflet;
• telling them the details of  your disclosure of their information to us, the purposes for which it has been disclosed, our possible further disclosure of information as necessary, and that they have rights of access to and correction of their personal information. 

By providing us with any information originating from a third party, you confirm that you have taken and completed these steps.

Your rights

You have a number of rights under the Data Protection laws, including:

• the right to request a copy of the personal information we hold on you.  When you request this information, this is known as making a Subject Access Request (SAR). In most cases, this will be free of charge, however in some limited circumstances, for example, repeated requests for further copies, we may apply an administration fee;
• the right to have personal information we hold about you transferred securely to another service provider in electronic form;
• the right to have any inaccurate personal information corrected;
• the right to have any out of date personal information deleted once there’s no business need or legal requirement for us to hold it;
• the right to object or restrict some processing, in limited circumstances and only when we do not have legitimate grounds for processing your personal information;
• the right to object to your personal information being used to send you marketing material.  (This is a general right under Data Protection laws. We do not use your personal information for marketing material, and therefore you will not need to exert this right during your dealings with us.);
• the right to ask for a decision to be made manually, where a decision is made using automated means and this adversely impacts you. 

To exercise any of these rights, please write to our Data Protection Officer at:

Athora Ireland plc
2nd Floor
IFSC House
Custom House Quay
Dublin 1
D01 R2P9
Ireland

You should also provide means by which we can verify your identity.

Making a complaint 

If you believe we have not processed your personal information in accordance with our Data Protection obligations, and that you have been affected by our non-compliance, you can make a complaint to us by contacting our Data Protection Officer. 

If you are not satisfied with our response, you can raise a complaint with the Data Commissioner’s Office, the Irish independent authority set up to enforce the Data Protection Regulations.

Address: Office of the Data Protection Commissioner, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, or on its website at www.dataprivacy.ie

Security

We're committed to ensuring your information is protected and held securely. We use a variety of security technologies and procedures to help protect your information from unauthorised access, alteration, use, disclosure, accidental loss or deletion. However, the internet isn't a secure medium and we cannot accept responsibility for the security of an email during transmission or for non-delivery of that email.

There are a few simple steps you can take to protect your computer and internet connection which you can view at www.cyberaware.gov.uk.

All our employees and service providers who have access to personal information, are obliged to protect it and keep it confidential. 

Links

This website may contain links to other websites. If you use the links to leave this website and visit a website operated by a third party, then we do not have any control over that website. So we cannot be held responsible for the protection and privacy of any information that you provide while visiting such websites.