DATA PRIVACY NOTICE
JC Mortgages Limited is regulated by the Central Bank of Ireland. JC Motgges is committed to protecting the privacy and security of your personal information. This Data Privacy Notice is provided to fulfil our obligations under the General Data Protection Regulation (GDPR), effective from 25 May 2018. GDPR requires greater accountability and transparency from organisations such as ours with regard to the treatment of your personal information, and provides data subjects with enhanced rights and greater control over how we process it.
JC Mortgages Limited provides advice and arrange transactions on behalf of clients in relation to Insuranceand Mortgages. We provide our services from the selection of products provided by the companies we have agencies with. We recommend the product that, in our professional opinion, is best suited to you. In providing this service to you we will need to obtain personal information from you. The following outlines how we deal with this information and how it is used. Any questions or concerns you have can be addressed to us directly.
Data Controller contact details:
Registered address: JC Mortgages Limited, 24 Millrace Road Apartments, Phoenix Park Racecourse, Castleknock, Dublin 15. Ireland.
Data Protection Officer:
JC Mortgages Limited has appointed a Data Protection Officer to enhance and maintain the protection and privacy of all personal data it processes. If you have any queries regarding the use of your personal data you can contact the DPO at any time.
Data Protection Officer contact details:
Data Protection Officer, JC Mortgages Limited, 24 Millrace Road Apartments, Phoenix Park Racecourse, Castleknock, Dublin 15. Ireland.
This Privacy Notice sets out the bases on which we gather, use, process and disclose any personal data we collect about you, or that you provide to us.
This Privacy Notice applies to you, whether you are a current, past or prospective customer. It also applies to third parties whose data you provide to us in connection with our relationship with you (for example, the names of relatives). Please ensure that you provide a copy of this Privacy Notice to any third parties whose personal data you provide to us.
JC Mortgages Limited uses your personal information to make you aware of products and services which may be of interest to you. JC Mortgages Limited will only communicate from a marketing perspective where you have expressed explicit consent for JC Mortgages Limited to do so and the manner of this communication will be in accordance with your preferences. Documented consent will be retained for 6 years. You can at any time withdraw that consent. Where consent is required for a process JC Mortgages Limited will outline what the effect of refusal of consent will imply with respect to the particular product or service being offered.
Who controls your Personal Data and how can you contact them.
We control your Personal Data to allow us to give you advice and recommendations on your financial affairs. Your data is then passed on to the relevant company/companies we have agencies with by way of application forms, by post email or through their secure websites online.
Data we may collect about You
In order for us to give you a recommendation and information on financial products, we need to collect and process personal information about you. If you do not provide the information we need, we may not be able to offer you advice or provide our services to you. The types of personal data that are processed may include:
● Individual details – Name, address (including proof of address), other contact details (e.g. email and telephone numbers), gender, marital status, date and place of birth, signatures nationality, employer, job title and employment history, and family details, including their relationship to you, source of wealth, source of funds, politically exposed person status,
● Financial detail – full details on any debts, loans assets you may own, salary
● Identification details – Identification numbers issued by government bodies or agencies, including your PPS Number, passport number, tax identification number
Special Categories of Personal Data
● Health information which has additional protection under Data Protection Law. We do not process health information other than hold the information on application forms you have filled in. The Life Insurers process and control your health data to allow them to underwrite your policy or decide decline cover, they may have further information they have obtained with your approval from your doctor, but we are not privy to this information.
● Claims information – information you give us with regards claims you notify us about or ask for help on.
● Policy Information – Information about the quotes you receive and policies you take out
● “Special categories” of particularly sensitive personal data require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal data.
● We may process special categories of personal data in the following circumstances:
● 1. In limited circumstances, with your explicit consent.
● 2. Where we need to carry out our legal obligations and in line with our data protection policy.
● 3. Where it is needed in the public interest, and in line with our data protection policy. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
Where We May Collect Your Personal Data From
We may collect your personal data from various sources, including;
You, Your employer or representative, Life Companies we have agencies with, any other records you have or had any other contracts of insurance with or sought a quote from a us on that is under our agencies, otherwise we will need a letter of authorisation from you to allow us contact other companies on your behalf. When you visit our website and input a request for us to contact you. Which of the above sources apply will depend on your particular circumstances and the product or service you are interested in or your enquiry relates to.
Legal Bases for Processing Your Information
We will only use your Personal Data for lawful reasons. These are:-
a) The use is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering a contract (such as providing a recommendation).
b) The use is necessary to comply with our legal obligations.
c) You have consented to us using your information in such a way.
d) The use is necessary for the purpose of our legitimate interests.
e) The use is necessary for the performance of a task carried out in the public interest, such as assisting a regulatory authority’s investigation of a criminal offence
The Purpose of Processing Your Information.
● To give you information on and provide you with recommended financial products.
● Disclose data to policyholder, life assured, beneficiary, trustee, assignee, successors, group company or to other parties.
● To comply with legal and regulatory requirements including Anti-Money Laundering and Sanctions compliance.
● To understand how people interact with our websites (if applicable).
● To carry out and determine the effectiveness of advertising, and of marketing campaigns.
Who we share Your Information with
In order to provide our services and to comply with legal obligations imposed on us, we may share your information with:-
How long do we keep Your Information
When providing products to you it may be necessary to retain your information for an extended period of time. We keep your information for as long as required by law for the purpose that you gave it to us for. As a general rule for legal and best practice reasons we are required to keep your information for 6 years after the date on which the our relationship with you ends.
If your personal data is processed by JC Mortgages Limited, you have certain rights in relation to that data, which are outlined in summary form below. JC Mortgages Limited may require further information from you before we can respond to your request. The scope of certain rights may be subject to certain restrictions or exceptions provided for under data protection legislation.
Accessing your Personal Data
You have the right to access a copy of your personal data which we hold on you. In the case of personal data you provided to us to process on the basis of your consent or for automated processing, you have the right to have it provided in a commonly used electronic format to you or to another Data Controller (subject to applicable Data Protection Law). If you would like a copy of your personal data, please contact us. Your request will be dealt with as quickly as possible and in any event within a month for us to respond. If at that stage we are unable to provide the data you require (due to the complexity or number of requests) we may extend the period to provide the data by a further two months but shall explain the reason why. There is no charge for the request for your data but it must be in writing, fax, email or text message.
Correcting Your Personal Data
You have the right to have your personal data corrected if you feel we have incorrect or incomplete data held on you. This is also know as your right to rectification.
Deleting Your Personal Data
Subject to any overriding legal obligation requiring us to retain it, you have the right to have your personal data deleted, however erasing your information may make it difficult or impossible for us to give you information on, provide you with, or administer our financial products. If you want your information deleted please contact us. This is also know as your right to erasure.
Restricting our use of your Personal Data
You have the right to restrict our use of your ersonal data in certain circumstances. If you wish to exercise your rights in this regard please contact us.
You can exercise this right if one of the following applies:
• You contest the accuracy of the personal data held about you and JC Mortgages Limited is verifying the accuracy of the data
• The personal data has been processed unlawfully and you oppose erasure and request restriction instead
• JC Mortgages Limited no longer needs the personal data but you need the data in connection with a legal claim
• You have objected to processing and JC Mortgages Limited is considering whether its legitimate grounds override your rights and interests.
Automated/Profiling Decision Making
Where we use automated decision-making you will always be informed & you will be entitled to have a person review the decision so that you can contest it and put your point of view and circumstances forward. Eg. When we produce quotes for the business you are contacting us about. When we want to market to you we may run a program which allows us identify certain criteria of clients (all those with that fit within a certain criteria for example).
Your Right to Object and Withdraw your Consent to Data Processing
Where our lawful basis for processing your personal data is based on our legitimate interests, you have the right to object. You also have the right to withdraw your consent to any processing at any time. However if we cannot process your data it may make it difficult, impossible or unlawful for us to give you information on, provide you with, advice on financial products. If you want to object or withdraw your Consent to processing please contact us.
Your Right to Data Portability
This right allows you to obtain your personal data in a format that enables you to transfer that personal data to another organisation where JC Mortgages Limited is processing your personal data on the basis of consent or on the fulfilment of a contract and if processing is carried out by automated means. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.
Your Right to Make a Complaint
If you are dissatisfied about the way we handle your Personal Data please contact us. We will do our best to address your concerns swiftly and resolve any issues you have. You have the right to complain to the Office of The Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. www.dataprotection.ie Tel.: +353 (0)761 104 800. Fax: +353 57 868 4757. E-Mail: email@example.com
This Privacy Notice may be updated from time to time and the current version of this Privacy Notice shall be displayed on our website.