Rose Private Privacy Statement

Here at Rose Private we take your privacy seriously and will only use your personal information to administer your account and to provide the products and services you have requested from us.

This document is being provided to you in line with our obligations under the General Data Protection Regulation (GDPR) which came into force on the 25 May 2018. Please take time to read this notice carefully. If you are under 16 years of age, please read this summary with a parent or guardian and ensure you understand it. If you have any questions about how we use your information, please contact us at the details given at the end of this document.

1. Who we are

Rose Private is a boutique 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/tax and estate planning.

Our GDPR owner and data protection representative can be contacted here:

Dataprotection@roseprivate.ie

Phone number 015310220

2. The Information we hold about you

The 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 and tax and estate planning.

At times, the provision of our services may necessitate the transfer/disclosure of your personal data by Rose Private to insurers, product providers, partners, agents, regulators and professional advisers.

We will hold

• 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, telephone recordings, CCTV images and information provided by you when exercising your rights under section 11 below.

3. When we collect your information

We collect 

• Information you give us
• Information from your use of our products and services
• Information provided to us by third parties

4. 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).
• 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 regulatory authorities.

5. How we use automated processing

We may analyse your information using automated means to

• Profile your risk - To establish your attitude to investment risk (relates to pensions and investments) Rose Private uses certain software tools which calculate your attitude to risk having answered a series of questions.
• Anti-Money laundering rules – Databases are used to ensure that AML legislation is being followed
• Profiling for marketing purposes - When we seek to contact you about other services, as outlined above we run automated queries on our database to establish the suitability of proposed products or services to your needs.
• Establishing affordability and providing quotations for financial services products.

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.

6. Who we are sharing your information with

We may pass your personal data on to third-party service providers contracted to Rose Private 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 fulfil 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 Rose Private's 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 party insurers/product providers that we may pass your personal data to are in Appendix 1.

We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions

7. How long we hold your data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Rose Private will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance.

8. Implications of not providing your data

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.

9. Using companies to process your information outside the European Economic Area (EEA)

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.

10. 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.

11. How to exercise your information rights including the right to object

Rose Private facilitates your rights as a client in line with our data protection policy and the subject access request procedure. 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.
• 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: in the event that Rose Private 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: in the event that processing is based on consent you may withdraw consent at any time.

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.

In the event that you wish to exercise your data rights or make a complaint about how your personal data is being processed by Rose Private or how your complaint has been handled, you have the right to lodge a complaint with the Rose Private Data Protection Owner at the contact details given above or directly with the Data Protection Commission (21 Fitzwilliam Square South, Dublin 2, D02 RD28).

If we are unable to deal with your request fully within a calendar month, we may extend this period by a further two calendar months and explain the reason why. If you make your request electronically, we will try to provide you with the relevant information electronically. 

12. How to contact us with data protection issues

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on (01)5310220 or email Dataprotection@roseprivate.ie

13. Privacy Policies of other websites

Please note that this Privacy Notice applies to Rose Private & the Rose Private Website. This privacy notice does not apply to any other websites or links which may be referred to on our website & or Terms of Business, therefore please refer to the privacy notice of any website which you visit.

14. Updates

Rose Private 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.

What are cookies and how are they used? 

A cookie is a small text file which is placed on your computer or internet enabled device by websites in order to add functionality. A cookie can be used to identify a user’s computer or internet enabled device to the website, or to other third party websites. This allows websites to improve the way they work, such as remembering preferences expressed by a user or tracking a user’s use of a website for statistical analysis.

We use different types of cookies. Some are persistent cookies (cookies that remain on your hard drive for an extended period of time) and some are session ID cookies (cookies that expire when you close your browser).

Why do we use cookies and tracking technologies?

Cookies help us to operate our website and to enhance and customise your experience on our website: 

How can you control cookies?

You can accept or reject cookies by amending your web browser controls or by accepting or rejecting cookies when presented with that choice when you access our websites.

Please note that disabling cookie support may prevent our websites from functioning properly and you may not be able to fully utilise all of their features and services.

Most advertising networks also offer you the option to opt out of targeted advertising. For more info, visit https://www.youronlinechoices.com/.

You can manage your cookie settings by following your browser's instructions. Here are some links that might be of assistance:

• Google Chrome - https://support.google.com/chrome/answer/95647?co=GENIE.Platf orm%3DDesktop&hl=en

• Microsoft Internet Explorer - https://support.microsoft.com/en-nz/help/17442/windows-internet-explorer-delete-manage-cookies

• Mozilla Firefox - https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

• Apple Safari - https://support.apple.com/en-nz/guide/safari/manage-cookies-and-website-data-sfri11471/mac

This Privacy and Cookie Policy was last reviewed in January 2024

Appendix 1

List of Financial Institutions that may receive your personal data from Rose Private.

Aviva Life & Pensions Ireland and Friends First

Standard Life International DAC

New Ireland Assurance Company plc

Zurich Life Assurance plc

Irish Life

Royal London Insurance DAC

Goodbody

Quilter Cheviot Europe Limited

Davy

Independent Trustee Company Ltd

Harvest Financial Services Ltd

BCP

Permanent TSB

Conexim

Cantor Fitzgerald Ireland Limited

Quest Retirement Solutions Limited

Quintas Wealth Management Limited