Saol Capital | Privacy Policy

Our Responsibilities

Long Strand Limited trading as Saol Capital (Saol Capital) is a financial planning and advisory firm and is regulated by the Central Bank of Ireland.

At Saol Capital we are committed to the highest standards of client confidentiality, which includes keeping your personal information secure. Under the EU’s General Data Protection Regulation (GDPR), our responsibilities include:

• The GDPR Officer at Saol Capital is responsible for ensuring that this notice is made available to customers before we collect and or process their personal data.
• All employees and staff of Saol Capital who engage with customers are responsible for ensuring that the customer is aware of this notice and that the customer’s consent to the processing of their data has been secured and documented.

What is personal data?

Personal data means data relating to a living individual, who is, or can be identified from the data and includes personal details, family and lifestyle details, education and training, employment details, financial details, contractual details (for example, goods and services provided to a data subject), online identifiers (IP addresses, cookies). Later in this document you will come across the term, ‘data subject.’ This definition refers to person whose personal data is collected, held, or processed by an organisation.

What information does Saol Capital hold about me?

The personal data that we collect can include the following:

• Contact information, including Name, Address, Phone and Email.
• Photo ID and Proof of Address.
• PPS number.
• Health & Medical information.
• Financial Information (Bank details, existing pension & investments, salary).

Why does Saol Capital require my personal data?

• All personal data given to us by you will be used only for the purpose for which you supply it and will be treated in accordance with General Data Protection Regulations. We require and use your personal data to develop, with you, a comprehensive financial plan and to advise you in respect of financial products. This includes using your personal information to:

• Carry out a comprehensive analysis of your existing finances, including all your savings, pensions, investments, personal protection, and tax planning arrangements.

• Provide a detailed statement of our understanding of your attitude to investment risk.

• Forecast your wealth over your lifetime to identify issues over the long term. We call this cashflow forecasting.

• Stress-test your situation, looking at scenarios such as serious illness, death, loss of income and poor investment performance.

• Present our recommendations and draft action plan to you, identify any obstacles, and discuss them with you.

• Open accounts on your behalf (and with your consent) with insurance and investment firms we have agencies with and/or to receive and transmit orders to them for financial products.

By providing your personal data, and where you have agreed to receiving communications from us, we may also use the information as follows:

• to personalise the marketing information that we issue;
• to send information that we consider may be of interest to you;
• to collate data gleaned from surveys or to produce market insights;
• to segment and distribute targeted marketing materials;
• to follow up with attendees of our events;
• to ask for opinions about our products or services.

Does Saol Capital need all this personal data about me?

We only collect the data that we need to provide the service(s) that you have requested. We must collect sufficient personal data in order to identify you as an individual. The GDPR prevents us from collecting data which we do not need for legitimate purposes.

How we use your information and legal basis

We use and share your data where:

• You have agreed or explicitly consented to the using of your data in a specific way (you may withdraw consent at any time by contacting our GDPR officer).
• Use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so that you can enter into a contract with us or one of our partners.
• Use is necessary because we have to comply with a legal obligation e.g., reporting to the Central Bank and other regulatory authorities.

Requirements by law

We must have a lawful basis to collect and use your Personal Data.

Our lawful basis is typically to provide services you have requested and contracted with us to provide, but it may also be based on your explicit consent to process your personal data for a specified purpose or because we have a legitimate interest in doing so such as e.g., to tailor the services we can offer to you.

Who will Saol Capital share my personal data with?

We pass personal information to:

Data processors:

Companies that act as service providers under contract with us and only process personal information as instructed by us. All personal information is transferred securely and is not used by other parties for any other reason. The categories of services that we use other Data Processors for include; document management, administration, customer services, marketing, Financial Sanctions and PEP checks to comply with Anti-Money Laundering rules and to maintain a list of identified high-risk customers, to comply with legal obligations.

Investment Platforms, Custodians, and Product Producers:

We pass personal information to product producers or platforms with whom we partner, in order to arrange transactions agreed with our clients.

Investment Service Providers:

We pass personal information to investment service providers where our customers want to access specialist investment services such as Online Trading Platforms.

Regulators:

We pass personal information to Regulators and the Revenue Commissioners as needed to comply with regulations and laws.

Other Service Providers:

We pass personal information to third parties, including other companies with whom we have business arrangements, with the recorded consent of the data subject.

All Third Parties engaged by Saol Capital must comply with the General Data Protection Regulations. When they no longer need your data to fulfil this service, the third parties will dispose of your personal data in line with Saol Capital’s procedures.

Where will my personal data be held?

Saol Capital holds personal data about its clients on servers in the EEA. In limited and necessary circumstances, your information may be transferred outside of the EEA or to an international organisation to comply with our legal or contractual requirements. Saol Capital has safeguards in place to ensure the security of your data if such a transfer takes place.

How long will we retain your data for?

Data will not be held for longer than is necessary for the purpose(s) for which it was obtained. Once the retention period for a record has passed, that record is deleted from our systems. In order to comply with regulatory obligations, Saol Capital is obliged to retain personal data about clients for a minimum period of 6 years or such longer period as we are directed to by law, for example we are required to hold certain information for 6 years after a client relationship has ended

Sensitive Personal Data

Sensitive personal data is “special categories of personal data” and specifically includes medical data which may be required to arrange life assurance policies on your behalf. We will only pass sensitive personal data to third parties (typically life insurance companies) with your explicit consent.

What rights do I have if I provide Saol Capital with my personal information?

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 judicial review: if Saol Capital refuses your request under rights of access, we will provide you with a reason as to why.
• Right to object to automated processing, including profiling.
• Right to withdraw consent: if processing is based on consent, you may withdraw consent at any time.

How can I find out the personal data Saol Capital holds about me?

At your request, we can provide details of the personal data we hold about you and how it is processed. If Saol Capital does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of Saol Capital or a third party, information about those interests.
• The categories of personal data collected, stored, and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide to prove that I am the data subject?

Saol Capital accepts the following forms of ID when information on your personal data is requested:

• Passport, Driving licence, Utility bill (not older than 3 months),
• Bank statement (not older than 3 months),
• Revenue / Social Welfare documentation (not older than 3 months).

How do I make a complaint?

If you wish to make a complaint about how your personal data is being processed by Saol Capital, by third parties engaged by Saol Capital, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Saol Capital’s GDPR Officer.

Saol Capital GDPR Officer

If you have any queries or concerns about your personal data or wish to exercise and of your rights as a data subject, our GDPR Officer can be contacted in the following ways:

By Post: Saol Capital, 3^rd Floor, City Quarter, Lapps Quay, Cork T12 Y3ET

Telephone: 021 424 4100

Email: dataprotection@saolcapital.ie

Supervisory Authority

Data Protection Commissioner of Ireland Office of the Data Protection Commissioner.

Canal House,                 

Station Road,

Portarlington,

Co. Laois, R32 AP2

Ireland.

Telephone 0761 104 800 or 057 868 4800

10:00 - 12:00hrs (Monday - Friday)  

14:00 - 16:00hrs (Monday - Friday)

Email info@dataprotection.ie