Privacy Statement as at 10.12.2021
HC Financial Advisers Limited is committed to protecting and respecting your privacy. It is the intention of this privacy statement to explain to you the information practices of HC Financial in relation to to the information we collect about you and other users.
For the purposes of the General Data Protection Regulation (GDPR) the data controller is:
HC Financial Advisers Limited
Oranmore Business Park,
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?
HC Financial Advisers Limited is regulated by the Central Bank of Ireland as an Authorised Advisor under the Investment Intermediaries Act 1995 (as amended). Registered as an Insurance/Reinsurance Intermediary under the European Communities (Insurance Distribution) Regulations, 2005 (as amended). Authorised as an Investment Business Firm under Section 10 of the Investment Intermediaries Act, 1995 (as amended). Investment Product Intermediary – Financial Service Providers holding appointments from IIA product producers, including intermediaries that may issue appointments, appearing in the register maintained under Section 31 of the Investment Intermediaries Act (as amended). Authorised as a Mortgage Intermediary under the Consumer Credit Act, 1995 (as amended). Copies of our Authorisations are available on request. Alternatively, the Central Bank of Ireland holds registers of regulated firms which can be viewed on the website: www.centralbank.ie. You may contact the Central Bank of Ireland on 1890 777 777 or visit their website to verify our credentials. A copy of our Statement of Authorised Status under the Investment Intermediaries Act 1995 is attached to this document.
Our Compliance Officer can be contacted directly here:
- Olivia Rogers
Purpose for processing your data
Why do HC Financial Advisers Limited need to collect and store personal data?
In order for us to provide you with financial services and advice, we need to collect personal data for the services we provide. In any event, we 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.
In terms of being contacted for marketing purposes HC Financial Advisers Limited would contact you for additional consent.
How will HC Financial Advisers Limited use the personal data it collects about me?
HC Financial Advisers Limited 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. HC Financial is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will HC Financial Advisors Limited contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.
Why we are processing your data? Our legal basis.
Our reason and purpose for processing your personal data is to adequately provide you with the advice and services you request. The processing of this data is integral to the business and contractual needs of the services and products we provide.
The lawful bases for processing are set out in Article 6 of the GDPR.
At least one of these must apply whenever you process personal data:
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract. Relevant provisions in the GDPR – See Article 6 and Recitals 39, 40, and Chapter III (Rights of the data subject) External link 02 August 2018 – 1.0.248 4
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests. (This cannot apply if you are a public authority processing data to perform your official tasks.)
Special Categories of personal data
If we collect any special categories of personal data, we will ensure that we will obtain your explicit consent and that the data collected is necessary for the completion of our services.
Transfers of personal data to countries outside of the European Economic Area (EEA) are often essential in view of international trade or cooperation. Your SME may have to transfer personal data to a country outside the EEA in the course of its activities, for example, when you need to share personal data with your business partners or with your suppliers who are based outside the EEA.
The GDPR contains specific provisions for such transfers. With these provisions, the GDPR aims to guarantee an equivalent level of protection to personal data being transferred to the one they enjoy within the EEA.
When does a transfer of personal data outside the EEA occur?
The GDPR does not provide a definition of such transfers. However, the EDPB has identified the following three cumulative criteria to identify a transfer outside the EEA:
- a controller or a processor is subject to the GDPR for the given processing;
- this controller or processor discloses by transmission or otherwise makes personal data available to another organisation (data controller or processor);
- this other organisation is in a country outside EEA or is an international organisation.
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to HC Financial 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 HC Financial procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise 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:
HC Financial Advisers Limited facilitate the data subject’s rights in line with our data protection policy and our subject access request procedure. These are 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 – 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 HC Financial refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain by contacting us by e-mail at email@example.com.
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. HC Financial will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank, Revenue) and our internal governance.
If we are relying on your consent to process your data, you can withdraw this at any time – this does not affect the lawfulness of processing based on your consent before its withdrawal.
In the event that you wish to make a complaint about how your personal data is being processed by HC Financial (or third parties), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority the Data Protection Commission (01) 765 01 00 or 1800 437 437 and HC Financial Advisers Limited’s Compliance Officer.
Failure to provide further information if needed
If we are collecting your data for a statutory requirement (payroll) or to fulfill a contract (life policy or motor insurance policy) and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.
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.
The Compliance Officer is responsible for ensuring that the privacy notice(s) is correct and that mechanisms exist such as having the Privacy Notice(s) on our website to make all data subjects aware of the contents of this notice prior to HC Financial commencing collection of their data.
All staff that need to collect personal data are required to follow this procedure.
Questions Regarding the Privacy Statement and Conditions of Use
If you have any questions about our Privacy Statement and Conditions of Use, or any concern about privacy or the use of this Site in general, please contact us by e-mail at firstname.lastname@example.org
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 091 788000 or email email@example.com
HC Financial’s Data Sub-Processors
HC Financial uses a number of data sub-processors to perform our Services to customers. All sub-processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures. A list of these sub-processors is outlined below:
- Broker Assist
- Broker Information Services
We use Broker Assist to streamline and funnel the submission of our business and eliminates the need to utilize several portals for doing same and they act in the capacity of a processor on our behalf. The only information we provide them with is the information provided to meet business and legal requirements.
For more information about Broker Assist, please visit WWW.BROKERASSIST.IE
Broker Information Services
Broker Information Services is utilized as a customer relationship management system & as a database for collating all of our customer’s policies. The only information we provide them with is the information provided to meet business and legal requirements.
For more information about broker information services, please visit HTTP://WWW.BROKERINFORMATIONSERVICES.IE
Cash flow modelling and lifetime planning is an increasingly prominent part of our financial advice industry in Ireland. CashCalc makes it easy to engage our clients in the financial planning process with interactive calculators and insightful graphics. CashCalc allows us to create detailed and precise cash flow models for our clients, without any of the added complexity.
For more information about Cashcalc, please visit WWW.CASHCALC.CO.UK
ClearChoice is a comparison tool & quote engine. They are used to compare price and different policy types. The only information they are provided with are the name, DOB & smoker status.
For more information about ClearChoice, please visit WWW.CLEARCHOICE.IE
CreditLogic is a Digital Mortgage Lending Platform provider. They enable banks and brokers to deliver a digital mortgage application experience by automating the application process. The platform leverages Open Banking, AI and Analytics to process new loan applications.
For more information about CreditLogic, please visit HTTPS://WWW.CREDITLOGIC.IO/
DocuSign is an American company that allows companies to manage electronic agreements. We use DocuSign as a tool to gather eSignatures on important documents we have with our customers.
For more information about DocuSign, please visit WWW.DOCUSIGN.COM
Cookiebot consent management platform (CMP) is a plug-and-play compliance solution built around scanning technology that detects and controls all cookies and trackers in use on our website, and automatically manages end-user consents.
For more information about Cookiebot, please visit HTTPS://WWW.COOKIEBOT.COM/
Sendinblue is an all-in-one marketing platform that helps us manage and talk to our customers. We use Sendinblue for our marketing emails and newsletters.
For more information about Sendinblue please visit WWW.SENDINBLUE.COM
Applied WealthTrack is a cloud-based CRM for financial advisers and brokers that combines client and policy management features with sales tracking and reporting.
HC Financial Advisers Ltd., (Trading as HC Financial) Social Media Accounts Use Policy
The privacy policies, statements and guidance published by Social Media Networks apply when you interact with HC Financial’s Social media accounts and we encourage you to read the privacy policies and guidance published by each Social Media Network that you use, as these make important disclosures about how the Social Media Networks separately collect, hold and may use your personal information and content.
PLEASE DO NOT POST ANY SENSITIVE INFORMATION OR PERSONAL FINANCIAL INFORMATION ONTO HC Financial SOCIAL MEDIA CHANNELS OR ANY SOCIAL MEDIA NETWORKS – THEY ARE PUBLIC FORUMS WHICH MEANS THAT ANYONE CAN SEE YOUR POSTS AND YOUR POSTS MAY SHOW UP IN SEARCH-ENGINE RESULTS. ONLY POST INFORMATION THAT YOU ARE HAPPY TO BE IN THE PUBLIC DOMAIN.
1. HC Financial and Social Media Accounts
HC Financial Social Media Accounts are intended for residents of Ireland aged 18 and over.
By interacting with HC Financial Social Media Accounts, entering draws or competitions, availing of discounts and offers or posting comments, photographs or other content you should understand that content you post to HC Financial Social Media Accounts may be published (at our discretion) together with the identifying information you provide in connection with the content and we may vary the duration that content will be published. We have no responsibility to you for the deletion or failure to store any comments or other content posted as this is under the control of each social media network.
HC Financial’s presence on social media networks does not mean that we are endorsing any third party’s products or services. Without limitation, no endorsement or approval of any third parties or their advice, opinions, information, content, products or services is expressed or implied by the display of information or advertisements by social media networks alongside our pages and we have no control over the content of third party advertisements.
If you cannot access a social media network, it is up to the network to fix the problem and HC Financial is not legally responsible for any inconvenience or loss resulting.
We welcome any feedback you wish to raise through any HC Financial Social Media Account. HC Financial have a complaints management process in place to deal with any complaints raised. Email ADMIN@HCGROUP.IE if you have any queries or complaints and we will endeavour to get back to you as soon as possible and address any issues or concerns.
HC Financial Social Media Accounts are public which means anyone can see any posts and comments that you may make. Your posts and comments may also show up in search-engine results (e.g. Google, Yahoo! or Bing). Only publish information that you would be happy to have published in the public domain.
You should protect your privacy and confidential information. Under no circumstances should you provide any bank account details or other sensitive personal or financial information nor should you include anyone else’s identification or sensitive personal or financial information in any content you post on HC Financial Social Media Accounts or any social media networks.
If you choose to provide us with non-sensitive personal information, such as your name and contact details, when contacting us via HC Financial Social Media Accounts, email or direct message, we will use your personal information solely to respond to and deal with your comments or queries.
2. HC Financial Content
Service times within which the HC Financial Team will be available through HC Financial Social Media Channels may vary. You should consult individual HC Financial Social Media Channels for details.
Please be aware that all of the views expressed in Third Party Blogs and by Third Parties on any of the HC Financial Social Media Accounts are purely the personal views of the authors and commentators and are based on their personal experiences and knowledge at the time of writing.
Information on HC Financial Social Media Accounts may be updated, altered, withdrawn (either temporarily or permanently) at any time without notification and given the nature of the internet, may at times be out of date. We reserve the right to do so without notice and without liability to you.
HC Financial Social Media Accounts, including Blogs, may contain links or references to other websites for the convenience of users. By clicking on such links you may be accessing an external website. Your use of external websites is subject to the terms of that site. Such links or references are not an endorsement by HC Financial of any third party or any third party products and services. HC Financial accepts no responsibility to you for your use of the link or for any of the content (including any downloadable content) of such other websites and shall not be liable to you for any damages or injury caused howsoever arising by your use of the link, content or downloads contained on such websites.
HC Financial is happy for you to share content that we post to HC Financial Social Media Accounts provided that you do not commercially exploit the content, alter or modify it in any way and that you cite the source. The intellectual property rights and all other rights relating to content (including without limitation, information, graphics, software, text, sounds, images, trade marks, service marks, trade names and logos) posted by HC Financial on HC Financial Social Media Channels belongs to HC Financial except for the intellectual property rights and all other rights relating to (i) content which is supplied under licence to HC Financial and which belongs to the relevant licensors and (ii) any content in relation to which such rights vest in the social media networks. Content on HC Financial Social Media Accounts is the copyright of HC Financial Assurance, p.l.c. unless otherwise stated and all of our rights are reserved.
Any attempts to gain access to administrator areas, features or functions of HC Financial Social Media Accounts without authorisation is prohibited.
3. Your Content
You are fully responsible for any content and comments which you post on HC Financial Social Media Accounts. HC Financial assumes no responsibility for any content or comments posted by you or any other user or third party on the HC Financial Social Media Accounts and accepts no liability to you, howsoever caused as a result of your use of HC Financial Social Media Channels or any of the comments/content contained on HC Financial Social Media Accounts.
Posts on HC Financial’s Social Media Accounts advertising products or services or posted for commercial purposes or gain are prohibited and will not be published or will be removed.
HC Financial does not allow anonymous comments. Posts will be published on the HC Financial Social Media Accounts with the full name of the commentator/author submitting the post.If you are an HC Financial employee or a competitor of HC Financial’s and you comment on any aspect of HC Financial’s business, you must clearly identify yourself as such in your comments and if you are an HC Financial employee include a disclaimer that the views expressed are your own.
If you have an idea you wish to share or if you would like to provide feedback, please feel free to do so but please note before you do that we reserve the right to use all ideas and feedback without any obligation to compensate you. By posting comments on HC Financial Social Media Channels you agree to allow the content to be re-used or quoted by HC Financial without further notification to you.
Please do not to upload, post, mail, transmit or otherwise make available any content or material (including any links thereto) which:-
- is unlawful, harmful, threatening, abusive, harassing, defamatory/libellous/ slanderous, vulgar, obscene, false or inaccurate, an invasion of another’s privacy, or which is otherwise objectionable; harms or exploits minors in any way;
- impersonates any person or entity, or falsely states or otherwise misrepresents your affiliation with a person or entity;
- constitutes unsolicited or unauthorised advertising, promotional materials, junk mail, spam, chain letters, pyramid schemes or any other form of solicitation;
- amends, alters or defaces any content on HC Financial Social Media Accounts;
- infringes on any patent, trademark, trade secret, copyright or other proprietary rights of any party; You agree that you shall not delete or alter any author attributions, legal notices or proprietary designations or labels or falsify the origin or source of software or other material contained in any file that is uploaded;
- contains software or other material protected by intellectual property laws (or by rights of privacy of publicity) unless you own or control the rights thereto or have received all necessary consents;
- contains software viruses or any other computer code, files or programs designed to interrupt or damage another’s computer; violates the legal rights of others or violates any applicable national or international law; or
- you do not have the right to make available under any law or under contractual or fiduciary relationships (such as inside information, proprietary or confidential information learned or disclosed as a part of employment relationships or under obligations of confidentiality).
- Contains names or information relating to HC Financial staff members.
HC Financial Social Media should not be used to stalk or otherwise harass another or to collect or store data about other users. HC Financial reserves the right to block any users that do not adhere to this policy.
If you come across any content that you consider offensive or you wish to bring any matter of issue to our attention in relation to any HC Financial Social Media Channel please write to HC Financia. Oranmore Business Park, Oranmore, Co. Galway
Although HC Financial has no obligation to screen, edit or monitor any of the content posted on any HC Financial Social Media Account, HC Financial will actively monitor the content of all posts submitted and reserves the right, and has absolute discretion, to pre-screen, review, flag, filter, modify, edit, refuse to publish or remove any comment(s), without notice, submitted to any HC Financial Social Media Account.
HC Financial welcome your feedback but may remove any staff names or information posted to its Social Media Account.
HC Financial reserve the right to block access to users who repeatedly violate these Terms.
Employees may operate their own social media profiles. If they are using their Social Media Account for business purposes and are sharing and posting HC Financial related content, they must identify these accounts as their own and indicate that any opinions expresses are their own personal opinions and not necessarily the opinion of HC Financial.
5. Your Data Privacy Rights
HC Financial Assurance plc. is regulated by the Central Bank of Ireland.
HC Financial Assurance plc Registered Office – Oranmore Business Park, Oranmore, Co Galway.
Website Use Policy as at 10.12.2021
Website Use Policy
This policy sets out how HC Financial Advisers (Trading as HC Financial) use your personal information that you provide when interacting with this website.
We use Google Analytics tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This information is aggregated and the software does not allow the collection of individual site visitor information. It is used to assess user behaviour and characteristics in order to measure interest in and use of the various areas of the site. The type of information gathered typically includes:
- The number of visitors to our website
- The number of pages viewed
- Which parts of the site are most popular
- The demographics and interests of our visitors
Cookies are small text files that are transferred to your computer’s hard drive or your mobile device through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you.
A cookie contains a unique id to allow us to identify your device when you interact with our site.
Most Web browsers automatically accept cookies, but, if you wish, you can set your browser to prevent it from accepting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. The cookies we use do not detect any information stored on your device.
For more information about cookies and how to stop cookies being installed visit the following website: HTTP://WWW.ALLABOUTCOOKIES.ORG (OPENS IN A NEW WINDOW)
Throughout this website you may have an opportunity to send us information relating to you such as through the “contact us” page or any other area where you may send e-mails, request or download brochures, enter contests or respond to any promotions. By choosing to participate in these, you will be providing us with some level of personal information relating to you. This information will only be used by HC Financial for the purposes for which it was provided by you, for statistical analysis.
Links to Third Party Websites
We take great care to ensure the security of this site. The HC Financial Network is protected by a firewall system, which forms a barrier between the outside Internet and the internal network. The purpose of a firewall is to ensure only authorised traffic is allowed to pass to HC Financial systems and networks – all other traffic from the Internet is rejected.
The firewall verifies the source and destination of each network packet, and determines whether or not to let the packet through. Access is denied if the packet is not directed at a specific, available service. The firewall is used to shield the HC Financial internal network from the Internet. The security system includes the use of a secure browser to access information and perform transactions. It allows for the transfer of digitally signed certificates for authentication procedures and provides message integrity, so that information cannot be tampered with in transit. Microsoft Internet Explorer, Mozilla Firefox, Google Chrome and Apple Safari are all secure browsers.
The data you provide to us through a secure browser is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.
Your Data Privacy Rights
To find out about your data privacy rights and how we use your personal information please see our HC FINANCIAL PRIVACY STATEMENT
You can at any time change or withdraw your consent from the Cookie Declaration on our website
Your consent applies to the following domains: hcgroup.ie
What are cookies ?
As most of the online services, our website uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the website to function the right way, and they do not collect any of your personally identifiable data.
The third-party cookies used on our website are mainly for understanding how the website performs, how you interact with our website, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience and help speed up your future interactions with our website.
What types of cookies do we use ?
Essential: Some cookies are essential for you to be able to experience the full functionality of our site. They allow us to maintain user sessions and prevent any security threats. They do not collect or store any personal information. For example, these cookies allow you to log-in to your account and add products to your basket, and checkout securely.
Statistics: These cookies store information like the number of visitors to the website, the number of unique visitors, which pages of the website have been visited, the source of the visit, etc. These data help us understand and analyze how well the website performs and where it needs improvement.
Marketing: Our website displays advertisements. These cookies are used to personalize the advertisements that we show to you so that they are meaningful to you. These cookies also help us keep track of the efficiency of these ad campaigns.
The information stored in these cookies may also be used by the third-party ad providers to show you ads on other websites on the browser as well.
Functional: TThese are the cookies that help certain non-essential functionalities on our website. These functionalities include embedding content like videos or sharing content of the website on social media platforms.
Preferences: These cookies help us store your settings and browsing preferences like language preferences so that you have a better and efficient experience on future visits to the website.
How can I control the cookie preferences ?
In addition to this, different browsers provide different methods to block and delete cookies used by websites. You can change the settings of your browser to block/delete the cookies. To find out more about how to manage and delete cookies, visit wikipedia.org, www.allaboutcookies.org.