Privacy Policy
Introduction
Killeen Financial Services Ltd t/a Cleere Life & Pensions 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 Cleere Life & Pensions in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
Gearoid Cleere
Contact details of (056) 7721854
When we refer to ‘we’ it is Cleere Life & Pensions
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 ?
Cleere Life & Pensions provide financial advice to Sole Traders, Company Directors and Individuals looking for financial advice. Our team of Qualified Financial Advisors provide our clients with the tools they need to set their objectives and reach their financial goals. Cleere Life & Pensions have agencies with the top Life Companies in Ireland, allowing us to guide our clients through the application process.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:
Gearoid Cleere
(056) 7721854
Purpose for processing your data
We collect your personal details in order to provide the highest standard of service to you. We take great care with the information provided, taking steps to keep it secure and to ensure it is used only for legitimate purposes. The information you have provided will be treated as confidential and will be retained by Cleere Life & Pensions in electronic format for the purposes of providing Financial Services.
Why we are processing your data? Our legal basis.
In order for us to provide you with Life Cover/Pension/Investment service) Cleere Life & Pensions need to collect personal data to provide you with appropriate financial advice and/or process a financial product application where applicable, where you, the data subject, is a party. Our reason (lawful reason) for processing your data under the GDPR is:
Legal basis — Deere Life & Pensions needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.
In any event, Cleere Life & Pensions 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 Cleere Life & Pensions use the personal data it collects about me?
Cleere Life & Pensions 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 the below
we will obtain your explicit consent
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to Cleere Life & Pensions 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 Cleere Life & Pensions 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
Cleere Life & Pensions 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
Right of portability— you have the right to have the data we hold about you transferred to another
Right to object — you have the right to object to certain types of processing such as direct
Right to object to automated processing, including profiling — you als— 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.
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. Cleere Life & Pensions 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 Cleere Life & Pensions or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Organisation Name’s data protection representatives Data Protection Officer / GDPR Owner
Failure to provide further information
If we are collecting your data for a contract x and you cannot provide this data the consequences of this could mean that the contract cannot be completed or details are incorrect.
Profiling — automatic decision making
Cleere Life & Pensions may from time to time carry out automatic decision making (for example Profiling —automatic decision making
Profiling;
Financial advisors using profiling in their business. The main categories are:
Risk profiling.
Profiling for marketing purposes.
Establishing affordability and providing quotations for financial service products
A.) Risk Profiling
To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.
B.) Profiling for marketing purposes.
When we seek to contact you about other services, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.
A.) Establishing affordability and providing quotations for financial services products.
You will be notified in advance of any instance of this any have the right to object to this at any time.
Additional Processing
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.
Analytics
This website collects personal data to power our site analytics, including:
Information about your browser, network, and device
Web pages you visited prior to coming to this website
Your IP address
This information may also include details about your use of this website, including:
Clicks
Internal links
Pages visited
Scrolling
Searches
Timestamps
We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.
Cookies
This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.
These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.
These analytics and performance cookies are used on this website, as described below, only when you acknowledge our cookie banner. This website uses analytics and performance cookies to view site traffic, activity, and other data.
For form block submissions
When you submit information to this website via webform, we collect the data requested in the webform in order to track and respond to your submissions. We share this information with Squarespace, our online store hosting provider, so that they can provide website services to us.
For website visitors
This website is hosted by Squarespace. Squarespace collects personal data when you visit this website, including:
Information about your browser, network and device
Web pages you visited prior to coming to this website
Web pages you view while on this website
Your IP address
Squarespace needs the data to run this website, and to protect and improve its platform and services. Squarespace analyzes the data in a de-personalized form.
Scheduling
When you schedule an appointment by booking on this website, we collect personal information from you to complete the booking. We may collect information like your:
Name
Email address
Phone number
Details relating to your appointment (for example, who referred you)
Files you uploaded
We share this information with Squarespace, our scheduling service provider, so that they can provide online booking services to us.
Privacy policy statement changes
Cleere Life & Pensions 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.
Killeen Financial Services Ltd t/a Cleere Life & Pensions is regulated by the Central Bank of Ireland