Fortitude Financial Planning Limited (“we” or “us”) are 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 Fortitude Financial Planning in relation to the information we collect about you.
Please read this Notice 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 are Fortitude Financial Planning Limited and we are a financial planning intermediary authorised by the Central Bank:
– As an investment intermediary under the Investment Intermediaries Act, 195
– As an insurance intermediary under the European Union (Insurance Distribution) Regulations, 2018
For the purposes of GDPR Fortitude Financial Planning is the data controller and our contact details are:
Address: 80 Lagavooren Manor, Beamore Road, Drogheda, Co Louth, A92 WYF2.
Telephone: 041 213 0307
Purpose for processing your data and why we are processing your data? Our legal basis
In order to provide you with our services which include financial planning, investment advice and receiving and transmitting orders to product providers on your behalf it is necessary for us to collect and process your personal data. We also collect personal data to comply with relevant laws and regulations and to comply with regulatory requirements generally. We collect personal data when you first engage our services and at subsequent meetings. The personal data we collect is limited to that we require including:
- Identification and contact information including your name, date of birth, gender, marital status, PPS number, email address, home, mobile and work phone numbers
Our legal basis for collecting and processing your personal data is that it is necessary for the performance of the advisory 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, Fortitude Financial Planning is 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 Fortitude Financial Planning use the personal data it collects about me?
Fortitude Financial Planning 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.
Who are we sharing your data with?
We will keep your personal data confidential but may pass your personal data on to third-party service providers contracted to Fortitude Financial Planning 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 fulfil the service they provide on your behalf.
We may also share your data with regulatory and other governmental bodies where we are required to do so by law or court order, including, but not limited to – the Revenue Commissioners, An Garda Siochana, the Companies Registration Office, the Pensions Board, The Financial Services & Pensions Ombudsman and the Central Bank of Ireland.
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.
If you have been referred to us by a lead generation company we will provide that lead generation company with an update on the status of your relationship with us. This update will not share any of your financial information and will be restricted to advising them whether or not you are availing of a service that we provide and if you do avail of a service when that service is completed. You can request that we refrain from sharing this information by emailing us at firstname.lastname@example.org.
Data Subjects Rights:
Fortitude Financial Planning facilitates 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.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained and in line with legal and regulatory requirements which currently require us to hold client data for 6 years after the relationship with the firm has ended.
In the event that you wish to make a complaint about how your personal data is being processed by Fortitude Financial Planning or how your complaint has been handled, you have the right to lodge a complaint with the firm.
You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:
Data Protection Commission
Co. Laois, R32 AP23
Phone: + 353 57 868 4800 / + 353 761 104 800
Fax: + 353 57 868 4757
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 086 1952 457 or email us at email@example.com
Effective Date: 01 October 2023
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