Nelson Life Privacy Notice.

Introduction

Nelson Life is committed to protecting and respecting your personal data and privacy rights. We wish to be transparent on how we process your personal data and are committed to ensuring you understand your rights as our client under the General Data Protection Regulations (GDPR) and Data Protection Acts 1988-2018.

This Privacy Notice sets out what we do with your personal information, why we gather it and what this means to you.

Nelson Life is a data controller in respect of personal information that we process in connection with our business and that includes the products and services that we provide to you. This means that we are accountable under legislation on data protection matters as it affects you, our client.

Please take time to read this Privacy Notice carefully.

Who we are and how to contact us:

In this notice, references to “we”, “us” or “our” are references to Nelson Life.

For more information about us, please visit www.nelsonlife.ie

If you have any queries about your personal data, please contact the Data Protection Manager:

  • Address: Data Protection Manager, Nelson Life, Dockgate, Dock Road, Galway, Ireland.
  • Email | dataprotection@nelsonlife.ie
  • Phone number | 091 44 11 88.

Information we collect about you and how we obtain it

We will hold:

  • Data to identify you and verify your address, including joint policy holders and beneficiairies.
  • Financial information.
  • Telephone records.
  • Health related data, where applicable

We collect, store and use personal data you willingly give us from the first use of our products or services, use of our website and provided to us by third parties.

Why we collect your personal information and our lawful basis

We process personal information about you and we do this for a number of specific reasons:

  • For the purpose of providing the agreed level of service to you under your contract with Nelson Life or because you have asked for something to be done to enter into that contract (loan offer or quote);
  • In order to comply with legal obligations and other tax and regulatory requirements which we are subject to (for example anti-money laundering requirements & know your client obligations);
  • Where you have agreed or explicitly consented to the use of your data in order to provide you with information in relation to our products and services (you may withdraw your consent at any time); and
  • For our legitimate interests, which you may object to, such as managing our business including credit risk management, training and quality assurance and testing.

Who are we sharing your data with?

Your personal data may be shared with third party product and service providers with whom we are contracted in the course of providing you with advice and related services, for example our specified CRM (Computer Database) provider and product providers (outlined in our Terms of Business document).

We believe processing is necessary in the performance of the contract to you (as outlined in our Terms of Business document).

These systems are used to enhance and improve the services we provide to you i.e. update policy values, policy benefits and automate policy update notifications to you, streamline our document management, manage and track our communications, tasks, activities and time spent, accurate fact finding, document management, policy values and benefits (provided in our portfolio reports), compliance tracking and meeting our regulatory requirements. Our current CRM provider is; ASE Software Ireland Limited, trading as Applied Systems Ireland, registered in Ireland CRO 350292, registered office; Strauss House, First Floor, No1 College Business & technology Park, Blanchardstown, Dublin D15 PEC4.

When providing services to you, we may share your personal information with our

  • Product providers (outlined in our Terms of Business) – also available at www.nelsonlife.ie
  • Statutory and regulatory bodies.
  • Credit Rating Agencies.
  • Financial modelling provider (Voyant is a privately held company headquartered in Austin, Texas. Voyant UK is a wholly owned subsidiary based in London, providing innovative financial products and services to customers across the United Kingdom and Europe. Address; Unit 12, Block 42 Rosemount Business Park, Dublin 11

Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to carry out the service they provide on your behalf.

Sharing your data with a company outside the EEA

If we transfer personal data to a third party or outside the EEA, we will ensure that the appropriate safeguards are in place and that your rights are enforceable.

Implications of not providing your data

If you do not provide information to Nelson Life, we may not be able to :

  • Provide or continue to provide products or services to you
  • Assess your suitability to a product or service
  • Recommend a financial product or service

How long we store your personal data

We will keep and store your personal data in accordance with our retention schedule, which is in line with legislation and regulatory rules, which we must follow. In most cases, we are obliged to keep data for up to 6 years from the date on which we cease to provide any product or service to you.

Profiling – automatic decision making.

Financial and mortgage advisors use profiling in their business.  The main categories are:

  • 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.
  • Profiling for marketing purposes. When we seek to contact you about other services, as outlined above we run automated queries on our computerised database to establish the suitability of proposed products or services to your needs.
  • Profiling for marketing purposes. Establishing affordability and providing quotations for financial services products.

Additional 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.

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 within one month of Nelson Life receiving your request. This may be extended to three months and we will explain why. This service is free.
  • Right of rectification – have incomplete or incorrect data about you corrected.
  • 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, you have a right for your personal data not to be processed.
  • 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 or for our legitimate business interests.
  • Right to object to automated processing, including profiling –you have a right not to be subject to a decision based solely on automated processing or profiling, if such a decision could have a significant effect.
  • Right to lodge a complaint with the Data Protection Commission

If you wish to exercise any of these rights, please contact us at dataprotection@nelsonlife.ieand we will service your request within one month of receipt unless there is a delay, in which case we will explain why and service your request within 3 months. The service is free of charge.

How to lodge a complaint to the Data Protection Commission

In the event that you wish to make a complaint about how your personal data is being processed by Nelson Life or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority, the Data Protection Commission or another Supervisory Authority at info@dataprotection.ie Tel: 1890252231

 We will update our data privacy notice from time to time. Any updates  will be made available on our website www.nelsonlife.ie.

This Privacy notice was last reviewed 20 October 2019.