Introduction
This is the Data Privacy Notice of JC Mortgages Limited and provides information about the ways in which the firm collects and uses personal data as well as our privacy practices in connection with our website.
Please read this Data Privacy Notice to understand how we obtain and use your personal information. If you give us personal information about someone else, please make sure you have their permission and make them aware of this Data Privacy Notice, as it also applies to them.
Should you have any queries about your data, please contact John Coleman , JC Mortgages 24 Millrace rd, Phoenix Park Racecourse
For the purposes of data protection legislation, the data controller of your personal data is JC Mortgages Limited and we are registered with the Data Protection Commissioner as a data controller and data processor. JC Mortgages Limited complies with the Irish Data Protection Act 2018 and the General Data Protection Regulation (GDPR) 2018. The General Data Protection Regulation (GDPR) is a European Union regulation which came into force on 25 May 2018. GDPR gives you, the Data Subject, more rights and control over your personal data and places more obligations on us around how we use, process and store your data.
JC Mortgages Limited respects the rights of data subjects in all interactions including users of our website and is committed to protecting your privacy at all times in accordance with data protection legislation.
Security of data
JC Mortgages Limited takes seriously its security obligations in respect of your personal data under the Data Protection Act and the GDPR with regards to protection and keeping it secure, to prevent unauthorised access to, alteration, loss or destruction of all personal data in our possession.
How we obtain your personal information
You provide us with your personal information directly when you contact us, complete our forms, speak with us or visit our website, and social media accounts. We also get personal information from solicitors, employers, or regulators (where relevant). We also create new personal information about you based on information you have given us and through your interactions with us as well as noting your online preferences.
Please note that where you provide us with your personal information, either directly to us, through a facility provided on our website, you consent to us,
- Processing and administering your personal data to perform all necessary actions to give effect to your request or instruction; and
- Retaining a record of incoming and outgoing communications (e.g., Phone, email, post, or text message).
Information in the communications we receive and send will not be disclosed to any third party without the permission of the sender unless otherwise stated in this Data privacy Notice or in accordance with the Irish Data Protection Act and the GDPR. We inform all persons who submit their personal data to us of these conditions by this Data Privacy Notice.
For more detailed information on what personal information is collected and how it is used when using our website please see later in this document.
Collection and use of personal data
We collect and use personal information to arrange transactions on your behalf as agreed with you, to service our customers, assist with claims and the payment of plan benefits. We must have a lawful basis to collect and use personal information.
Your Consent
You need to give consent for us to collect and use personal information and your explicit consent in the case of your special category personal information (classed as sensitive). You are given the choice to provide consent, or not. When we collect your consent, we will explain what we need it for and how you can change your mind in the future.
- Consent for JC Mortgages Limited to collect and store your personal information to be able to provide you with advice, and in order to make recommendations for you. The information will be held for that purpose and should you purchase a plan, the information will be used to offer you an ongoing service of that plan. We also may contact you for follow up Financial Reviews even if you do not proceed with the
- Consent to Direct Marketing We would like to be able to contact you about offers and services, separately from your plan communications. We will only send you direct marketing content where we have your consent. When you use our website, you can consent to third party advertising. This shows you our ads where you have visited our website before or visited other websites offering similar products and services.
Consent and How to Withdraw Consent
Where processing is permitted because the data subject has given consent to the processing for one or more specific purposes. Such consent must be “opt-in”, freely given and clearly understood. If we process your personal information based on consent, you have the right to withdraw that consent at any time. The opt-out methods offered will depend on how the consent was collected and will be explained when you give us your consent, e.g., you can change your mind using the opt-out link in any direct marketing emails sent to you however, you will also be able to withdraw consent by contacting us directly.
Needed for your contract
We need to collect and use your personal information to provide your plan contract. This includes, but is not limited to, your name, date of birth, contact and bank account details. Depending on the plan type this can include health, employment, pension and salary information. We restrict access to, and use of, any sensitive personal information. We also create new personal information. In order to receive financial advice from us, you must give personal and financial information for your current and future needs to be assessed. This enables us to recommend the most suitable financial product for you. This also involves creating new and assumed personal information about you. We complete an analysis of you using your personal information to comply with regulations. When you give us your personal information we will check to see if we already have a record of you. This helps us to comply with your Data Protection Rights.
Personal information needed for plan contracts is held and used to (but not limited to)
- process your application
- set up and issue your plan
- provide you with information about your plan (we use your plan and contact details)
- to help the administration of your plan and assist with the payment of your plan benefits
- You must give us your tax residence information and tax identification number for tax reporting with product producers.
- provide customer care and service; and
- contact you to inform you of any relevant actions you may need to
Required By Law
We use your personal information to comply with law and regulations such as
- reporting to regulators
- keeping proper books and records; and
- we carry out internal reporting, quality checking, compliance controls and audits to help meet these obligations.
We must collect certain personal information to comply with anti-money laundering law. This depends on your plan type; to do this, we use personal information including your name, date of birth, address, nationality and occupation information.
- Up-to-date proof of identification and
- Screening of all customers against Financial Sanctions and Politically Exposed Persons (PEP) lists.
- Where needed, we carry out searches of publicly available information
Legitimate Interest
We use your personal information for our legitimate interests as shown below. This doesn’t affect your data protection and privacy rights. We believe these uses benefit our customers. You can contact us if you have any questions using the above contact details of this Data Privacy Notice.
Why we are processing your data? Our legal basis.
To use your information lawfully, we rely on one or more of the following legal bases:
- your consent;
- performance of a contract;
- legal obligation (e.g. “Minimum Competency Code”, “Fitness & Probity”, TCA 1997);
- protecting the vital interests of you or others;
- public interest; and
- our legitimate interests or the legitimate interests of a third party (e.g. your employer).
In order for us to provide you mortgages and associated insurance products such mortgage protection, life assurance, critical illness, income protection and pension and investment products JC Mortgages need to collect personal data. Our reason (lawful reason) for processing your data under the GDPR is:
- Contractual basis – JC Mortgages needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.
- When you become a client of ours, we would like to make you aware of products and services which may be of interest to you, we will send you direct marketing based on our legitimate interest and you can always opt- out of receiving marketing information from us.
In any event, JC Mortgages 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.
To Whom do we Pass your Personal Information
We pass personal information to:
Data processors: Companies that act as service providers under contract with us and only process your personal information as instructed by us. Your personal information is transferred securely and is not used by any other parties or for any other reason.
Our main Data Processors are <<
- Ptsb – credit Underwriting
- Bank of Ireland- credit underwriting
- Brokers Assist- Royal londan Zurich- Underwriting
- Brokers Ireland- Finance Ireland , Haven- credit underwriting
- Dilosk- ICS
- Irish life Insurance Underwriting
- Aviva – Insurance Underwriting
- com – Database
- Mailchimp- Marketing
- Vison net – Pep screening
Do we transfer your personal information outside of the EU?
- We sometimes need to share your information with organisations which are located or who undertake processing outside the European Economic Area (EEA) to help us provide you with our products and services. Some of our product providers, for example, are provided/located outside the We expect the same standard of data protection is applied outside of the EEA to these transfers and the use of the information, to ensure your rights are protected and will only transfer personal information to a country or territory outside of the EEA if that country provides an adequate level of protection for personal information as set down by the European Commission or where the transfer is made under a legally binding agreement which covers the EU requirements for the transfer of personal information to data processors outside of the EEA such as the model contractual clauses approved by the European Commission, the EU-US Privacy Shield Framework or such other approved mechanism or model approved by the European Commission.
How long do we keep your personal information for?
We keep and use your personal information for as long as you have a relationship with us. We also hold it after this, e.g., where we need to for complaints handling, for system back-ups needed for disaster recovery and for as long as we must for compliance with regulations and law. We will let you know how long we keep personal information for when you avail of a single or specific service such as (but not limited to) a quote or call-back. A copy of our Data Retention Policy is available on request.
What are your rights?
You have a number of rights over your personal information which you can exercise free of charge by contacting us using the details in this Data Privacy Notice. You will need to give us some personal information to help us identify you and we will respond to you within one month in line with current regulations. Any restrictions to your rights will be explained in our response.
• Right to Information
You have a right to the information set out in this Data Privacy Notice. We will inform you of our updated Data Privacy Notice, if we change the type of personal information we collect and / or how we use it. We have controls in place to protect your personal information and minimise the risk of security breaches. However, should any breaches result in a high risk for you, we will inform you without delay.
• Right to Restrict or Object
You can restrict or object to any unfair and unlawful collection or use of your personal information. You can object to any automated decision making that has a legal or similar significant impact for you and ask for the decision to be made by a person. You can withdraw consent and object to, for example direct marketing.
• Right to Correct and Update
You can ask us to correct and update personal information we hold about you. Your plans are long term contracts and to provide you with the best service it is important we have your up-to-date personal information, such as contact details. We are not required to rectify or erase your data where to do so would prevent you from meeting your contractual obligations to us or where we are required to process
(including retaining) your personal data for a lawful purpose in accordance with the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018
• Right to Delete and Be Forgotten
You can have your personal information deleted if it is incorrect or has been processed unfairly or unlawfully. If you have withdrawn consent, you can ask for your personal information to be deleted. We will keep a record of your request, so we know why your personal information was deleted. If we have provided a regulated product or service to you, we must keep your personal information for a minimum period by law. This does not affect the requirement to hold your information for the purposes of fulfilling a contract.
• Right to Portability
You can ask for a copy of all personal information that you gave us (including through your interactions with us), and which we hold in an automated format. You can receive this in a machine-readable format that allows you to keep it. You may also request us to send this personal information in a machine- readable format to another company. The format will depend on our ability to provide this in a secure way that protects your personal information. We will not likely be able to use a copy of your personal information sent to us in this way from another company. This is because we can only collect personal information that we need. We also need your most up to date personal information for underwriting and to comply with regulations.
• Right to Access
You have the right to know what personal information we hold about you and to receive a copy of your personal information. We must tell you,
- why we hold it,
- who we pass it to, including whether we transfer it outside the
- how long we keep it for,
- where we got it from; and
- if we carried out any automated decisions, the logic behind it and what it means for
This right does not allow you to access personal information about anyone else. To access your personal information please write to us using the contact details in this Data Privacy Notice. To help us respond as quickly as possible please let us know if you are only looking for copies of specific personal information or a complete copy of your client file.
Business
If JC Mortgages Limited is involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Data Privacy Notice.
Contact Us
If you have any questions about this Data Privacy Notice, please contact us at info@jcmortgages.ie
Collection and use of Personal Data
Except in relation to certain specific features of our website, you do not have to provide us with any personal information (or personal data) to use our website. However, where you elect to give us your personal data through our website via online feedback forms or web email then we will treat your personal information in accordance with this Data privacy Notice.
Cookies
We use cookies. We do not collect or store personal information without notifying you via a cookies pop up consent form when you visit our website. [Note: You can change the settings on your browser to
refuse all cookies. However, you should note that disabling cookies may result in some parts of the site not working efficiently / slower].
We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our services.
Web Browsing
Cookies are small text files, created by the website visited, that contain data. They are stored on the visitor’s computer to give the use the user access to various functions. Both session cookies and non-session cookies are used on this website (the “Site”). A session cookie is temporarily stored in the computer memory while the visitor is browsing the website. This cookie is erased when the user closes their web browser or after a certain time has passed (mean the session expires). A non-session cookie remains on the visitor’s computer until it is deleted.
Why do we use Cookies?
We use cookies to learn more about the way visitors interact with our content and help us to improve the experience when visiting our Site.
Site Functionality
The share function is used by visitors to recommend our Site and content on social networks such as Facebook or Linkedin. Cookies store information on how visitors use the share function – although not at an individual level – so that the Site can be improved. If you do not accept cookies, no information is stored.
For some of the functions within our Site we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third-party websites for information regarding their use of cookies.
Cookies we Use:
This Site uses Google Analytics which use cookies. At the aggregate level, cookies store information on how visitors use the Site, including the number of pages displayed, where the visitor comes from, and the number of visits, to improve the website and ensure a good user experience. If you do not accept cookies, no information is stored.
How to reject Cookies?
We will not use cookies to collect personally identifiable information about a visitor. However you can choose to reject or block the cookies set by info@jcmortgages.ie by
changing your browser settings – see the “Help function” within your browser for further details. Please note that most browsers automatically accept cookies so if you do not wish cookies to be used, you may need to actively delete or block the cookies.
Future Changes to this Data Privacy Notice
We may update our Data Privacy Notice from time to time. We will notify you of any changes by posting the new Data Privacy Notice on our webpage and by providing a copy at our next meeting.
Updated June 2024 (Version 1/2024)