Data Protection Notice
Effective 25thMay 2018
We respect your trust in us to use, store and share your information. In this notice, we explain how we collect personal information about you, how we use it and how you can interact with us about it.
We try to keep this notice as simple as possible but if you are unfamiliar with our terms, or want more details on any of the information here, please contact us. You can also ask for more details at 01 6344850.
Data Protection Officer
Our Data Protection Officer oversees how we collect, use, share and protect your information to ensure your rights are fulfilled. You can contact our Data Protection Officer at firstname.lastname@example.org or by writing to them at: Data Protection Officer, Cogent Associates, Hyde House, 65 Adelaide Road, Dublin 2
How we collect information about you
We collect personal information from you when apply for services or look for advice. We also collect information through our website, apps, social media, discussion forums, market research and our CCTV footage. We will sometimes record phone conversations and we will always let you know when we do this.
Our website uses ‘cookie’ technology. A cookie is a little piece of text that our server places on your device when you visit any of our websites or apps. They help us make the sites work better for you.
When you apply to us for our services, and during the time you use these, we carry out information searches and verify your identity. We do this by sending and receiving information about you to and from third parties including CRO.
How we keep your information safe
We protect your information with security measures under the laws that apply and we meet international standards. We keep our computers, files and buildings secure. When you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.
How long we keep your information
To meet our legal and regulatory obligations, we hold your information while you are a customer and for a period of time after that. We do not hold it for longer than necessary.
Meeting our legal and regulatory obligations
To use your information lawfully, we rely on one or more of the following legal basis
- Performance of a contract
- Legal obligation
- Protecting the vital interests of you or others
- Public interest
- Our legitimate interests
- Your consent
To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. We may also gather information about you from third parties to help us meet our obligations. If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our products and services.
Sometimes we need your consent to use your personal information. With direct marketing for example, we need your consent to make you aware of products and services which may be of interest to you. We may do this by phone, post, email, text or through other digital media.
You can decide how much direct marketing you want to accept.
How we use your information
We use information about you to:
- Provide relevant services
- Identify ways we can improve our services
- Maintain and monitor services
- Protect both our interests
- Meet our legal and regulatory obligations and
- Decide and recommend how our services might be suitable for you.
To provide our services under the terms and conditions we agree between us, we need to collect and use personal information about you. If you do not provide this personal information, we may not be able to provide you with our products and services.
We analyse the information that we collect on you through your use of our products and services and on our social media, apps and websites. This helps us understand your financial behaviour, how we interact with you and our position in a market place. Examples of how we use this information includes helping protect you and others from financial crime, offering you products and services and personalising your experience.
We may report trends we see to third parties. These trend reports may include information about activity on industries. When we prepare these reports, we group customers’ names. We do not share information in these reports that can identify you, such as your name and company.
Your information and third parties
Sometimes we share your information with third parties.
For example to:
- Provide services and information
- Analyse information
- Research your experience dealing with us
- Sell whole experience dealing with us
- Sell whole or part of our business
- Prevent financial crime
- Help trace, investigate and recover
- Trace information; and
- Protect both our interests
We expect these third parties to have the same levels of information protection that we have.
Your personal information rights
Accessing your personal information:
- You can ask us for a copy of the personal information we hold. You can ask us about how we collect, share and use your information.
- Updating and correcting your personal details
- Removing Consent: You can change your mind whenever you give us your consent, such as for direct marketing, using your sensitive information,
- Restricting and objecting
- You may have the right to restrict or object to us using your personal information or using automated decision making.
- Deleting your information (your right to be portability). Where possible we can share a digital copy of your information directly with you or another organisation.
When you contact us to ask about your information, we may ask you to identify yourself. This is to protect your information.
Making a Complaint
If you have a complaint about the use of your personal information, please let our Data Protection Officer know, giving them the opportunity to put things right as quickly as possible.
If you wish to make a complaint you may do so in person, by telephone in writing and by email. Please be assured that all complaints received will be fully investigated.
You can also contact the Data Protection Commission in Ireland at www.dataprotection.ie.
Updates to this notice
We will make changes to this notice from time to time, particularly when we change how we use your information, and change our technology and Services.
You can always find an up-to-date version of this notice here, on our website at www.cogentassociates.ie.