Privacy & Cookies

The data controller in respect of the personal information provided by you is 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 General Data Protection Regulations, Data Protection Act 1988 and the Data Protection (Amendment) Act 2003, 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
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, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, 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.

Cookies

Our websites use cookies and by using our sites you accept the terms under which these are used.

More information about cookies, including how to block them and/or delete them, can be found at http://www.allaboutcookies.org/

1. How Athora Ireland Plc uses cookies

We will not use cookies to collect information that could personally identify you

We will use cookies to: 

• help us understand how our websites are used on an aggregated (not individual) basis, so we can improve them for you;
• provide an enhanced user experience for you, and
• provide services that are necessary for the running of the websites.

By using our site, you agree to these cookies being set, but you are free to change your browser settings if you want to delete or block these. However, we recommend you allow cookies so you can:

• get the best experience and additional functionality – for example social media sharing buttons, polls, games etc., and
• help us improve our website - we need to understand how our websites are used to make them better. 

These cookies do not collect information that could identify you personally, but they do help us understand:

• which pages are most popular – so we can make these as accessible as possible;
• which pages aren’t being used – so we can remove content that isn’t of value;
• what’s being searched for – so we can improve access to most requested information;
• where errors are being displayed – so we can fix these for you, and
• where we need to focus our development effort as trends in browser usage (eg Internet Explorer, Firefox, Safari) and device types (eg tablets, desktops, mobiles) change.

All of this helps us develop the sites to deliver a better experience for you. Without this information, we will have less insight into what users want. Please help us deliver a better experience to you by allowing cookies.

On a first visit to our websites, an information box will be displayed advising that cookies are in use, with links to our privacy policy and this cookie information page.

2. How to control and delete cookies

• Update your browser settings

The help facility on your browser will explain how to do this or you may want to visit the independent site www.aboutcookies.org for more helpful information. Note that deleting or blocking cookies may prevent parts of Athora websites working correctly.

• Manage your settings on third party sites

Sites like AddThis, Google and YouTube have their own cookie policies. Access their cookie pages to find out how to delete or opt-out across all websites where their services are used.

3. Athora Ireland websites cookies

Cookies can be categorised by the role they fulfil on our websites.

Strictly necessary cookies are essential in order to enable you to move around our websites and use features such as secure services. Without these cookies, such services cannot be provided.

Performance cookies collect information about how visitors use our websites, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve our websites.

Functionality cookies allow the website to remember choices you make (such as your user type) and provide enhanced, more personal features. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Targeting and advertising cookies are used to track the effectiveness of our advertising campaigns and to limit the number of times you see an Athora advert. They may also be used to deliver adverts more relevant to you and your interests based on the sites you visit. We do not use retargeting and advertising cookies but we may introduce these from time to time.

4. Third party website cookies

• YouTube

On some of our webpages, we embed or link to video content on YouTube. When you visit a page with content embedded from YouTube, you may be presented with cookies from these websites. Athora does not control the setting of YouTube cookies but you can find out more about them on their website, along with details on how to opt out: http://www.youtube.com/t/privacy_at_youtube

• AddThis

Athora Ireland plc websites include 'share' buttons on selected pages which let you share content on your social media accounts, or via email. These sites may set a cookie when you use the service - you can find out more about AddThis cookies on their website, along with details on how to opt-out: http://www.addthis.com/privacy

5. Local shared objects (Flash cookies)

Athora Ireland plc websites use Adobe Flash Player to deliver some video content and tools. To improve user experience, ‘Local Shared Objects’ (Flash cookies) are used to provide features like auto-resume and saving your preferences. These are stored on your computer/device in a similar way to cookies, however it is not possible to manage these using your browser settings in the same way. The Adobe website provides information on how to delete or disable Flash cookies either for a specific domain like athora.com/ie or for all websites - see http://www.adobe.com/products/flashplayer/security for details.

6. Undocumented cookies

Although we have carried out a comprehensive audit of our sites, it is possible that we may have missed a cookie from our lists above. If you happen to find one that is being set on our sites but isn’t listed above, please do let us know.