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 below.

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 and tax and estate planning.

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

Email: 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, office service providers, regulators and professional advisers.

We will process:

Data to identify you, including your contact information, name, address, date of birth, email address etc.
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 (are not held by Rose Private but are held by our Office Service providers in line with their own GDPR retention policy) 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
Use is necessary to protect your “vital interests” in exceptional circumstances
Use for our legitimate interests such as managing our business and fraud or crime prevention. This may include things like training and quality assurance, strategic planning, statistical analysis of our service provision. You may object to your personal information being used for these purposes.

5. How we use automated processing

We may analyse your information using automated means to:

Help us understand your needs and develop our relationship with you
To assist in compliance with our legal obligations
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

In the course of providing our services to you, complying with legal obligations or pursuing our legitimate interests, we may share your personal data with the following categories of recipients:

Third parties with whom: (i) we need to share your information to facilitate transactions you have requested, and (ii) you ask us to share your information
Service providers who provide us with support services to enable delivery of our services
Statutory and regulatory bodies and law enforcement authorities.

The third party insurers/product providers that we may pass your personal data to are in appendix 1.

All of our Data Processors are obliged to have the appropriate safeguards in place to comply with GDPR.

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. Rose Private Data Retention period is 9 years in most circumstances (full data retention details available on request).

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:

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 you 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.
Right to lodge a complaint with a supervisory authority.

If you wish to exercise any of your data rights, you can contact us by writing to the address above or emailing us.

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

If you are not happy with any aspect of how your data is used, you also have the right to complain to the Data Protection Commission in Ireland. You can contact the Office of the Data Protection Commission at:

Telephone: +353 (1) 765 01 00 or Lo Call Number 1800 437 737

Online Contact Form: https://forms.dataprotection.ie/contact

Postal Address: Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963, Ireland

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) 5310 220 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.

15. Cookie 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:

Name	Description	Expiration	Type
exp_csrf_token	This cookie is used by our website to protect against a common cybersecurity threat. It prevents submissions to forms.	2 hours	Strictly Necessary
exp_last_visit	This cookie is used by our website. It sets the datetime that the user last visited the site.	1 year	Performance
exp_last_activity	This cookie is used by our website. Every time the state is updated (the page reloaded) the last activity is set to the current datetime.	1 year	Performance
exp_tracker	This cookie is used by our website. It is a temporary cookie that stores last 5 visited pages for error reporting and debugging.	Session	Performance
exp_stashid	This cookie is used by our website to successfully redirect users after form submissions.	Session	Functional
CookieScriptConsent	The Key together with Consent state are saved in End User’s browser as first-party cookie called “CookieScriptConsent” in JSON encrypted form. This information is later used by the Service to remember End User’s choice. The Key can also be used as a proof of End User’s consent.	30 days	Functional

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:

This privacy policy was last reviewed in June 2025

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
Unio Financial Services Limited
BCP
Permanent TSB
Conexim
Cantor Fitzgerald Ireland Limited
Quest Retirement Solutions Limited
Quintas Capital Regulated Limited