Raglan Street Private Ltd. 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 Raglan Street Private in relation to the information we collect about you.For the purposes of the GDPR the data controller is: • Michael Keyes • Contact details of clientservice@raglanstreetprivate.ie • When we refer to ‘we’ it is Raglan Street Ltd.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?Raglan Street Private was set up with a very simple idea- to help clients plan financially for ideal outcomes. Our goal is to give a personal, technology-enhanced experience with total transparency into your finances. The result will transform the way you understand, manage and plan for the future. Combining our experience and knowledge along with our planning technology, we help you visualise your finances now and in the future resulting in smarter financial decisions.We provide advice and arrange transactions on behalf of clients in relation to life / pensions / investment and protection products / policies.Our GDPR Owner and data protection representatives can be contacted directly here:• Michael Keyes • michael@raglanstreetprivate.ie • +353 86 856 4520Purpose for processing your dataThe personal data we collect from you such as your name, address, financial details and potentially sensitive information are necessary to provide you with our financial planning services. These include but are not limited to negotiating, maintaining or renewing insurances and handling insurance claims and providing advice and arranging transactions on behalf of clients in relation to life/pensions/investments and protection products /policies.At times, the provision of our services may necessitate the transfer/disclosure of your personal data by Raglan Street Private Ltd to insurers, product providers, partners, regulators and professional advisers.We will hold the following information; Data to identify you, including your contact information Your financial details/ financial circumstances Your marital status Information which you have consented to give us Other personal information such as Anti Money Laundering information and information provided by you when exercising your rights under section 10 below.Why we are processing your data? Our legal basis.In order to provide you with our financial planning services it is necessary for us to collect and process your personal data. We are required, therefore, to inform you of the legal bases for processing your personal data. One such legal basis is that the processing is necessary for the performance of the advisory services contract (and any other contract) 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, Raglan Street Private 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 Raglan Street Private Ltd use the personal data it collects about me?Raglan Street Private Ltd. 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 If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below• we will obtain your explicit consentWho are we sharing your data with? Any information regarding the intention to disclose personal data to third parties and whether it is transferred outside the EU. In such circumstances, Organisation Name will provide information on the safeguards in place and how the data subject can also obtain a copy of these safeguards; If Organisation Name is based outside of the EU and the data subject resides within it (the EU), the Organisation Name provides the data subject with contact details of a data protection representative in the EU; Any information on website technologies used to collect personal data about the data subject; Any other information required to demonstrate that the processing is fair and transparent.We may pass your personal data on to third-party service providers contracted to Raglan Street Private Ltd. 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 Raglan Street Private Ltd. 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 product providers that we pass your personal data to are: xxx to provide list of who pass data onto • xxx • xxx.We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questionsIf 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: Raglan Street Private Ltd. facilitate 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 subjectAt 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.Additional information we are providing you with to ensure we are transparent and fair with our processingRetention of your personal data Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Raglan Street Private Ltd. will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (xxx) and our internal governance.Complaints In the event that you wish to make a complaint about how your personal data is being processed by Raglan Street Private Ltd. or how your complaint has been handled, you have the right to lodge a complaint with Raglan Street Private Ltd. GDPR Owner.You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:Data Protection Commission Canal House, Station Road, Portarlington, Co. Laois, R32 AP23 Phone: + 353 57 868 4800 / + 353 761 104 800 Fax: + 353 57 868 4757 Web: www.dataprotection.ie Email: info@dataprotection.ieFailure to provide further informationIf 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.Profiling – automatic decision making Profiling includes; 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) Profiling for marketing purposes - When we seek to contact you about other services, as outlined above * we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs. c) Establishing affordability and providing quotations for financial services d) Anti-Money laundering rules – Databases are used to ensure that AML legislation is being followed Contact Us Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on +353 86 856 4520 or email - clientservice@raglanstreetprivate.ie Privacy policy statement changes Raglan Street Private Ltd. 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 March 2019