Privacy Statement – Martin & Garvan Insurance Ltd

Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Below you will find all you need to know about how we collect, use and protect your personal data.

We take the protection of your data very seriously. We want you to feel confident that we are keeping your data secure, and that we handle and process it in accordance with General Data Protection Regulations.

In our Statement, we explain what personal data we collect, how we collect it, what we use your data for and how we safeguard it.

For the purposes of the GDPR the data controller is:

Martin & Garvan Insurance Ltd  

96 Upper Drumcondra Road

Dublin 9

www.mgi.ie.ie

Phone +353 1 8379276

Martin & Garvan Insurance Ltd is registered in Ireland and regulated by the Central Bank of Ireland.

Company registration No: 70839. Registered office: 96 Upper Drumcondra Road, Dublin 9

Purpose for processing your data

Why does Martin & Garvan Insurance need to collect and store personal data?

In order for us to provide you with an insurance quotation and/or to complete the performance of an insurance contract we need to collect personal data to allow us and our Insurance partners to underwrite the insurance risk. We 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.

How will Martin & Garvan Insurance use the personal data it collects about me?

Martin & Garvan Insurance will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

Martin & Garvan Insurance is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.

Why we are processing your data? Our legal basis

Our reason and purpose for processing your personal data is:

• We need to process your data to complete the performance of a contract where you, the data subject, is a party.

• We use your Customer Data for the provision and administration of insurance products and related services. Examples of the actual or possible uses of your Customer Data are: processing your insurance application, processing claims, statistical analysis, underwriting purposes, fraud prevention, market research, risk management and the provision of advice.

Under what circumstances will Martin & Garvan Insurance contact me?

• We undertake not to ask irrelevant or unnecessary questions. The information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

Personal identification information

We may collect personal identification information from you in a variety of ways, including, but not limited to, when users visit our site, call into our offices, call on the phone, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers’ utilised and other similar information.

Web browser cookies

Our Site may use “cookies” to enhance User experience. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

How we use collected information

Martin & Garvan Insurance may collect and use Users personal information for the following purposes:

• To run a promotion
• To send periodic emails.
• To send Users information they agreed to receive about topics we think will be of interest to them.

We may use email address to respond to their requests, questions, and/or other enquiries. If a User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or the User may contact us.

Special Categories of personal data

If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethic origin – financial information not classified as special categories of personal data) – we will ensure the following:

• we will obtain your explicit consent directly from you.
• ensure the personal data is necessary for employment rights or obligations;
• protect the vital interests of the data subject, including the protection of rights and freedoms;
• necessary for any legitimate activities with appropriate safeguards;
• personal data made public by the data subject;
• legal claims;
• substantial public interest;
• preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, provision of health or social care treatment, or management of health and social care systems and services, under the basis that appropriate contracts with health professionals and safeguards are in place;
• public health, ensuring appropriate safeguards are in place for the protection of rights and freedoms of the data subject, or professional secrecy;
• National laws in terms of processing genetic, biometric or health data.

Who are we sharing your data with?

We may pass your personal data on to third-party service providers contracted to Martin & Garvan Insurance 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 our procedures. If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent from you, unless we are legally required to do otherwise.

If we transfer personal data to a third party or outside the EU we will ensure the recipient has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.

Data Subjects Rights:

Martin & Garvan Insurance will facilitate your (the data subject’s) rights in line with our data protection policy. You have the right of access to the personal data held about you by us by sending a signed written request to: Shane Garvan, Martin & Garvan Insurance Ltd, 96 Upper Drumcondra Road, Dublin 9n.

To ensure that Martin & Garvan Insurance satisfies itself about the identity of the person making the request, so it does not disclose your personal data to a party who is not entitled to it under the Data Protection Act, the person making the request will need to provide Martin & Garvan Insurance with their name, address(es), date of birth and any policy IDs/numbers that they have along with a copy of their photo identification.

You also have the right to require us to correct any inaccuracies in the information we hold about you by sending us a written request.

• 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 object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• Right to judicial review: in the event that Martin & Garvan Insurance refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in below.

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.

Retention of your personal data

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

In the event that you wish to make a complaint about how your personal data is being processed by Martin & Garvan Insurance (or third parties as described above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Shane Garvan in Martin & Garvan Insurance Ltd.

Failure to provide further information if needed

If we are collecting your data for a statutory requirement (payroll) or to fulfil a contract (life policy or motor insurance policy) and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

Profiling – automatic decision making

We use your Customer Data for the provision and administration of insurance products and related services. Examples of the actual or possible uses of your Customer Data are: processing your insurance application, processing claims, statistical analysis, underwriting purposes, fraud prevention, market research, risk management and the provision of advice. This gathering of information is consistent with our offline work practices.

Additional Processing

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.

If we have received your personal data from another source:

Martin & Garvan Insurance collects your personal data from your appointed agents and we are committed to protecting and respecting your privacy. It is the intention of this privacy statement to explain to you the information practices of Martin & Garvan Insurance in relation to the information we collect about you and other users.

Responsibilities

The GDPR Owner is responsible for ensuring that the privacy notice is correct and that mechanisms exist such as having the Privacy Notice on the Martin & Garvan Insurance website to make all data subjects aware of the contents of this notice prior to Martin & Garvan Insurance commencing collection of their data. All staff that need to collect personal data are required to follow this procedure.

Questions Regarding the Privacy Statement and Conditions of Use

If you have any questions about our Privacy Statement and Conditions of use, or any concern about privacy at Martin & Garvan Insurance or the use of this site in general, please contact us by e-mail at shane@mgi.ie

We reserve the right to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Website Privacy Policy and provided that the third party only uses your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.

Security

Your Personal Data is held on secure servers. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

On-line Dispute Resolution (ODR)

The European Commission provides an on-line dispute resolution (ODR) platform that allows consumers to submit their complaint through a central site, which will forward the complaint to the right Alternative Dispute Resolution (ADR) scheme. The ADR scheme for Martin & Garvan Insurance Ltd is the Financial Services Ombudsman, Lincoln House, Lincoln Place, Dublin 2.

Our GDPR Owner and data protection representative can be contacted directly here:

• Shane Garvan
• shane@mgi.ie
• Phone number – 01 8379276

Martin & Garvan Insurance Ltd – May 2018

You can also use our Privacy Tools page to request any data we store about you.