Raglan Street Private Privacy Statement

Raglan Street Private 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.

For the purposes of the GDPR the data controller is Raglan Street Private.

When we refer to we/us, we mean Raglan Street Private

Please read this Privacy 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?

Raglan Street Private is a financial advisory firm that provides professional financial planning services to

clients and their families. We provide advice and arrange transactions on behalf of clients in relation to

life/pension/investment and protection products/policies.

Our GDPR Owner can be contacted directly here:

 Michael Keyes

 Email address: michael@raglanstreetprivate.ie

 Phone number: 0868564520

How do we collect your information and what information do we collect?

The personal information we collect varies depending upon the nature of our services. We will

endeavour to provide you with an overview of those categories of personal data our organisation

collects and our purpose for using that data.

Our organisation collects personal data in the following ways, if you:

 request a service from us such as, Investment advice, pension planning or protection advice.

 register with or use our website

 use our website and it installs cookies or other tracking technologies onto your device.

 contact us with a complaint or query;

 apply for a position with us

What information do we collect?

The information we collect about you includes the following:

1. Contact and Identifying information, e.g., name, address, contact details; email, mobile,

landline

2. Unique identifiers e.g.

 PPS number – the reason why we collect your PPS number, where relevant, is for

the purposes of pension applications

 Pension scheme reference number- the reason why we collect this is pension

planning advice/applications

 Insurance policy numbers -the reason why we collect this is to obtain full

information where required

3. Demographic details, age, gender, marital status, lifestyle, and insurance requirements;

date of birth, dependents, photo ID, as well as collecting personal information about you,

we may also use personal information about other people, for example family members

you wish to insure on a policy. E.g., your children/spouse

4. Family and Beneficiary Data, e.g., dependants, next of kin or nominated beneficiaries,

Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax

Advisor/Accountant.

5. Employment information e.g., role, employment status (such as full/part time, contract),

salary information, employment benefits, and employment history.

This information is necessary for our Fact Find with our clients.

6. Publicly available sources: e.g., Information about you in the public domain such as

Director information from the Companies Registration Office.

7. Health information such as information about your health status, medical records and

medical assessment outcomes; We collect medical information relating to personal habits

(e.g., smoking and consumption of alcohol), medical history. We may also process certain

special categories of information, for example disability information. – This information is

required for protection advice and applications e.g., life cover, health insurance.

8. Pensions and Insurance Benefits information such as current benefits, pension entitlement

information, date of retirement and any relevant matters impacting your benefits such as

voluntary contributions & Pension Adjustment Orders.

9. Financial details e.g., bank account details, details of your credit history and bankruptcy

status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement

data and national insurance contributions details.

10. Marketing preferences: we will only send you direct marketing if you explicitly consent &

this will be via email.

11. Online information: e.g., information about your visits to our websites; see cookie policy

www.raglanstreet.ie

12. Criminal records information e.g via adverse media internet searches

13. Searches that we undertake in relation to sanctions, money laundering and credit checks

(where required) via Vision Net & BIS Platform

When our organisation collects sensitive personal data as defined within the GDPR we will ensure that

we require this information, and we have your explicit consent and/or authorisation prior to our

collection. Please see the further information contained in this Privacy Notice that outlines special

categories of personal data.

Information we automatically collect.

We sometimes automatically collect certain types of information when you visit our website and

through e-mails when we communicate with you. Automated technologies may include the use of web

server logs to collect IP addresses, "cookies" and web beacons. Other cookies such as functional cookies,

marketing cookies and analytical cookies will only be used with your expressed consent. Further

information about our use of cookies can be found in our Cookie Notice at the footer of our web page.

www.raglanstreetprivate.ie

How do we use your personal data?

Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your

request for insurance, investment, protection, pension products, financial advice, quotes.

1. Performing services for our clients and prospective clients – when you require

insurance/investment products, we use your data to enable us to provide the required product

Statutory and other regulatory requirements – we are required to carry out various obligations

which include:

 AML/Sanction checking

 Knowing your customer “Fact Find”

 Adherence to the Consumer Protection Code

3. Communicate and marketing to you – via email & telephone where this complies with the

Consumer Protection Code

4. Process claims – this may include requesting medical information on behalf of protection

provider

5. To contact you if required or to respond to any communications that you might send to us.

6. To administer our site including data analysis, testing, research, statistical and survey purposes.

7. Carry out our obligations arising from any contracts entered between you and us and to provide

you with the information, products and services that you request.

9. Provide professional services – this includes financial planning through the use of cashflow

modelling software.

10 Handling complaints

11 To notify you about changes to our service

Legal Basis

We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to

collect and use your personal data.

Performance of a

contract

When we enter a contract with you, we will collect and use your personal data to

enable us to fulfil that service.

Legal obligation The use of some of your personal data is necessary for us to meet our legal

obligations e.g., pension contributions for Revenue Certificates, Regulatory

purposes to the Central Bank.

Consent Sometimes we may rely on consent as a legal basis for processing your information.

For example, we rely on consent to collect and use personal data for any criminal

convictions or alleged offences. This is used when we need to assess risk relating to

an insurance policy for you. We share this information with other third parties

where it is necessary to manage these services provided to you – these services

include insurance underwriters, reinsurer and other insurance providers.

We may also rely on your consent to send direct marketing to you. We will ensure

that we present this to you concisely. We will also ensure that we use clear and

plain language and if you give us your consent you can withdraw this easily at any

time.

Sometimes if you refuse to provide information that we reasonably require to

provide the services, we may be unable to offer you the services and/or we may

terminate the services provided with immediate effect.

Legitimate

interests

Where we rely on this legal basis to collect and use your personal information, we

shall take appropriate steps to ensure the processing does not infringe the rights

and freedoms conferred to you under the applicable data privacy laws.

If you require further information on any of the above basis for processing your data, we can provide

you with further details.

How we share your data

When required, we may make your information available to third parties with whom we have a

relationship, where that third party is providing services on our behalf. We will only provide those third

parties (data processors) with information that is necessary for them to perform the services. We will

take measures to protect your information, such as putting in place Standard Contractual Clauses and

confidentiality agreements.

1. Insurance Partners where we need to manage the services provided to you such as Product

Providers and insurance underwriters & reinsurers. update as required. You can refer to

their privacy statements on their website for more information about their privacy

practices.

Medical professionals, e.g., where you provide health information in connection with a

claim against your insurance policy; or when we are providing a quote for insurance.

3. EU Law enforcement bodies, when required to do so by law and/or regulation, or another

legal request.

4. Public authorities, regulators and government bodies, where necessary for us to comply

with our legal and regulatory obligations, or in connection with an investigation of

suspected or actual illegal activity;

5. Third-party processors: We outsource our processing operations to suppliers that process

personal information on our behalf. Examples include accounting and payroll providers,

CRM providers.

These processing operations remain under our control and we have data processing

agreements in place with all our third party processors to ensure all processing is carried out

in accordance with our security standards and the GDPR.

6. External auditors where necessary for the conduct of company audits or to investigate a

complaint or security threat.

Transferring personal data outside of Ireland

Where we transfer personal data to a country outside of the EEA (referred to in the GDPR as ‘third

country,’) we will ensure it is done lawfully, i.e. there is an appropriate “level of protection for the

fundamental rights of the data subjects”. We will therefore ensure that either the EU Commission has

granted an adequacy decision in respect of the third country, or appropriate specified safeguards have

been put in place, (e.g., Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs)).

We may share data with some providers located in the UK. The EU Commission adopted adequacy

decisions for transfers of personal data to the UK. This means that the EU accepts that the UK data

protection regime is substantially equivalent to the EU regime and allows personal data to be

transferred freely from the EEA to the UK. Therefore, the UK is not deemed a third country.

We may share your data with acountry outside of the EEA and wherethere is no finding of adequacy of

the transfer of data from Ireland to the country outside of the EEA. In the absence of an adequacy

decision the GDPR allows the transfer if the controller or processor has provided appropriate

safeguards. These safeguards include Standard Contractual Clauses (SCCs). We, the data controller must

abide by the SCCs as well as the Recommendations adopted by the European Data Protection Board on

measures that supplement the SCCs which will ensure the level of protection provided for within the

GDPR.

Security

The security of your personal data is important to us, we have implemented appropriate technical and

organisational measures to ensure a level of security appropriate to the risk. We have processes in

place to protect your personal data from loss, unauthorised access, misuse, alteration and destruction.

Retention

Raglan Street Privateshall not keep personal data in a form that permits identification of data subjects

for a longer period than is necessary.

Raglan Street Private may store data for longer periods if the personal data will be processed solely for

archiving purposes in the public interest, scientific or historical research purposes or statistical purposes,

subject to the implementation of appropriate technical and organisational measures to safeguard the

rights and freedoms of the data subject.

The retention period for each category of personal data will be set out in our Retention Policy along

with the criteria used to determine this period, including any statutory obligations we have. Should you

require further information we would be happy to provide.

Personal data will be disposed of securely.

Data Subjects Rights:

Raglan Street Private will facilitate your rights in line with our data protection policy & subject access

request policy. 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. (The erasure of such data will be dependent on our other legal

obligations, and whether the data is subject of legal privilege).

 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 make a complaint: if we refuse your request under rights of access, we will provide you

with a reason as to why.

All 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.

Complaints

If you wish to make a complaint about how your personal data is being processed by Raglan Street

Private or how your complaint has been handled, you have the right to lodge a complaint with our GDPR

Owner – Michael Keyes.

You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details

are:

Data Protection Commission

21 Fitzwilliam Square South,

Dublin 2.

D02RD28

Web: www.dataprotection.ie

Email: info@dataprotection.ie

See website for updated contact details to reach the appropriate section within the DPC.

Failure to provide further information.

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.

When you fail to provide us with information we require to fulfil our obligations to you, we may be

unable to offer our services to you.

Profiling – automatic decision making.

An automated decision is when we input your personal data into a computer programme and this

programme analyses your personal data to provide us with a result. There is no human involvement in

the decision making these are listed below. If a decision is taken by automated means, you have the

right to object to this and ask us to reconsider the service you have asked us to provide. Some further

examples of automated decisions that we undertake are listed below.

The main categories are

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) Establishing affordability and providing quotations for financial services products.

c) PEP & Sanction Checks

Special Categories of personal data

Special categories of data are sensitive in relation to your fundamental rights and freedoms and

therefore require specific protection when processed as these could create significant risks to the rights

and freedoms of individuals.

If we collect any special categories of personal data, such as health data, we will either obtain your

explicit consent or we will adhere to the Data Protection Act 2018. This Act allows us to process special

categories of personal data for insurance and pension purposes. We will ensure we have suitable and

specific measures in place to safeguard the rights and freedoms of you and the processing of your data.

These measures relate to the below:

 a policy of insurance or life assurance,

 a policy of health insurance or health related insurance

 an occupational pension, a retirement annuity contract or any other pension arrangement

Contact Us

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

Privacy notice/ statement changes

When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be

effective from the point at which they are posted. We would encourage you to review our Privacy

Notice so that you are aware of updates.

This privacy policy was last reviewed in December 2025. V1.3