360 Financial Consultants

Privacy Policy

Introduction

Convent View Financial Services trading as 360 Financial Consultants 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 360 Financial Services in relation to the information we collect about you.

For the purposes of the GDPR the data controller is:

  • Eamon Spillane
  • Contact details of data controller eamon@360financial.ie or by writing to GDPR Compliance Officer, 360 Financial Consultants, 79 New St, Monearmore, Killarney, Co. Kerry, V93 HD6F.

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 We Are

Conent View Financial Services Ltd. trading as 360 Financial Consultants is regulated by the Central Bank of Ireland as an Insurance Intermediary registered under the European communities (Insurance Mediation)  regulations 2005: as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995 and as a Mortgage Intermediary authorised under the Consumer Credit Act, 1995, and as a Mortgage Credit Intermediary under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016.

The company is incorporated in Ireland, registration number 580161 with a registered address at Dromdiralough, Muckross, Killarney, Kerry, V93 FT04 and is based at 79 New St, Monearmore, Killarney, Co. Kerry, V93 HD6F.

The company has been trading since the 6th of April 2016, as a mortgage broker working closely with Banks, Lenders, accountants, solicitors, and estate agents, specialising in the facilitation of home purchase via best practices and competitive mortgage rates, appropriate products, and efficient processing.

Having this experience ultimately means our clients benefit from the process of obtaining home loan research for those which we have an agency, dealing with the customers’ needs and objectives. This service runs in tandem with our other Moneycoach advisory services such as Life Assurance, Pensions, Investments, Savings and Deposits.

Our GDPR Compliance Owner can be contacted directly here:

  • Eamon Spillane
  • eamon@360financial.ie
  • 064 661 7940

Why We are Processing Your Data. Our Legal Basis

To use your information lawfully, we rely on one or more of the following legal bases:

  • your consent;
  • performance of a contract;
  • legal obligation (e.g. “Minimum Competency Code”, “Fitness & Probity”, TCA 1997);
  • protecting the vital interests of you or others;
  • public interest; and
  • our legitimate interests or the legitimate interests of a third party (e.g. your employer).

In order for us to provide you mortgages and associated insurance products such mortgage protection, life assurance, critical illness, income protection and pension and investment products 360 Financial Consultants need to collect personal data. Our reason (lawful reason) for processing your data under the GDPR is:

  • Contractual basis – 360 Financial Consultants 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.
  • When you become a client of ours, we would like to make you aware of products and services which may be of interest to you, we will send you direct marketing based on our legitimate interest and you can always opt- out of receiving marketing information from us.

In any event, 360 Financial Consultants 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 360 Financial Consultants use the personal data it collects on me?

360 Fiancial Consultants 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

Subject to suitable and specific measures being taken to safeguard the fundamental rights and freedoms of data subjects, the processing of data concerning health shall be lawful where the processing is necessary and proportionate for the purposes of the following:

(a) a policy of insurance or life assurance,

(b) a policy of health insurance or health-related insurance,

(c) an occupational pension, a retirement annuity contract or any other pension arrangement, or

(d) the mortgaging of property

Who Are We Sharing Your Data With?

We may pass your personal data on to third-party service providers contracted to 360 Financial Consultants 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 360 Financial Consultants 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.

The third parties that we pass your personal data to are:

  • Financial institutions/Lenders/Life Assurance companies with whom we hold a written appointment with as outlined on our Terms of Business;
  • Introducers of business to us with whom we may share details of any transactions arranged for you;
  • Our home insurance partner to whom, we forward details of your home insurance requirements for the purposes of arranging your mortgage;
  • Irish and EU regulatory and enforcement bodies such as the Central Bank of Ireland, an Garda Siochána, the courts, fraud prevention agencies and other bodies to enable us cooperate by law as we are required to do so;
  • We use a number of IT platforms to assist us in delivering our services
  • We also have a number of service providers we use to store and manager our data.

We have issued all our third party processors with a Data Processor checklist and Data Processing Agreements 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.

International Transfers of Data

We sometimes need to share your information with organisations which are located or who undertake processing outside the European Economic Area (EEA) to help us provide you with our products and services. Some of our product providers, for example, are provided/located outside the EEA. We expect the same standard of data protection is applied outside of the EEA to these transfers and the use of the information, to ensure your rights are protected and will only transfer personal information to a country or territory outside of the EEA if that country provides an adequate level of protection for personal information as set down by the European Commission or where the transfer is made under a legally binding agreement which covers the EU requirements for the transfer of personal information to data processors outside of the EEA such as the model contractual clauses approved by the European Commission, the EU-US Privacy Shield Framework or such other approved mechanism or model approved by the European Commission.

Data Subjects Rights

360 Financial Consultants facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.

  • 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 – you also have the right to be subject to the legal effects of automated processing or profiling.
  • Right to judicial review: in the event that 360 Financial Consultants 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. 360 Financial Consultants will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body, the Central Bank of Ireland and our Internal Governance.

In the event that you wish to make a complaint about how your personal data is being processed by 360 Financial Consultants or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and 360 Financial Consultant’s data protection representatives Data Protection Officer / GDPR Owner

If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profilling – Automatic Decision Making

  1. Automated Decision Making

We, in conjunction with lenders and life assurance companies use calculators and quotation tools to establish your affordability for credit and when providing quotations to you for associated insurance products.  Whilst some providers may carry out these processes on an automated basis, we operate with human intervention and take into account information you provided us in your application form for a mortgage or proposal form for an insurance product, your health history, your credit history, other credit facilities you have with financial institutions, amount of mortgage requested, amount of life assurance request, the repayment or cover period etc. If you disagree with any of these decisions please contact us via the channels outlined in this document.

2. Risk Profiling

To establish a customer’s attitude to investment risk in relation to pensions, advisors may use automated calculators which calculate the customers’ attitude to various levels of risk having answered a series of questions.

3. Profiling for Marketing Purposes

When we seek to contact you about other services, as outlined we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

4. We use your personal information to comply with law and regulations; We must collect certain information to comply with Anti-Money Laundering law. This depends on your plan type but includes up to date proof of identification and address.  We also screen all customers against Financial Sanctions and Politically Exposed Persons (PEP) list.  To do this, we use your name, date of birth, address, nationality and occupation information.

Additioanl 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.

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us.

Privacy Policy Statement Changes

360 Financial Consultants 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 November 2021