This is the privacy policy of Penco whose registered office is at The Black Church, St Mary’s Place, Dublin 7 referred to as we, us or our in this Privacy Policy.
The privacy policy sets out how we collect and process your personal data. This privacy policy also provides certain information that is legally required and lists your rights in relation to your personal data.
This privacy policy relates to our personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside or organisation with whom we interact). We refer to this information throughout this privacy policy as personal data or personal information and further details of what this includes are set out in this privacy policy below.
The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times.
Please read this privacy policy carefully as it explains how we may collect and use your personal data.
This privacy policy may vary from time to time so please check it regularly. The privacy policy was last updated on 21st of May 2018.
Controller and contact details
For the purposes of relevant data protection legislation, we are a Controller of your personal data. As a controller we use the personal data we hold about you in accordance with this privacy policy.
If you need to contact us in connection with the use of your personal data then you may do so using our contact details as set out below.
Data protection representative
Our data protection representative is Mark Penco who you may contact on 00353 01 882 6100 or [email protected] codes offer protection to our clients and all of the Codes can be found on the Central Bank website www.centralbank.ie
The personal data that we collect about you may include the following information:
We collect your personal data from you as a controller when you enquire about our services and/or become a client of Penco . This may also involve the collection of data from or about others with whom you are associated such as your employees or representatives. By giving us information about someone else for the purpose of them utilising our services or becoming a client themselves you confirm that you have their permission to do so and that you have shared this privacy policy with them.
Where we are relying on a basis other than consent
We may rely on one or more of the following legal bases when processing your personal data for the following purposes:
The concept of fair analysis is derived from the Insurance Mediation Directive. It describes the extent of the choice of products and providers offered by an intermediary within a particular category of life assurance, general insurance, and/or a specialist area. The number of contracts and providers considered must be sufficiently large to enable an intermediary to recommend a product that would be adequate to meet the needs of a client. The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operating in the market for a particular product or service and their relative importance in and their share of that market. The extent of fair analysis must be such that could be reasonably expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search. In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair analysis of the market, we will consider the following criteria:
We will only store your data for as long as is necessary to comply with the requirements of our regulator The Central Bank of Ireland. Currently they require us to hold client records for at least 6 years after each transaction we undertake on your behalf. You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases even when you make a request concerning your personal information, we may not be required or able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations. If this is the case, we will let you know our reasons.
You may ask us to:
If you have any questions or concerns about this privacy policy or your data protection rights please contact us using our details set out at the beginning of this privacy policy.
If you are not satisfied with any response you receive in relation to the way we handle your personal information you may complain to the Data Commissioner’s Office Email : [email protected]