1. Introduction
1.1 Protecting the privacy of those who visit our website and use our services is important to us.
1.2 This policy applies whenever we act as the data controller for personal data relating to website visitors and service users. This means that we decide why and how that personal data is processed.
2. How Your Personal Data Is Used
2.1 This section explains:
- the broad categories of personal data we may process;
- the kinds of personal data we collect;
- the reasons for which personal data may be processed;
- the legal grounds on which processing is based; and
- the parties with whom personal data may be shared.
Personal Information
2.2 The personal data collected by us includes your name, address, email address, telephone number, date of birth, marital status and employment status.
Website Usage Data
2.3 We may process information concerning how you use our website (“usage data”). Usage data may include your IP address, geographical location, browser type and version, operating system, referral source, visit duration, pages viewed, navigation paths through the website, and details of the timing, frequency and pattern of your use of the service. This information is obtained from our analytics tracking system.
Usage data may be processed so that we can assess how our website and services are used. This processing is based on our legitimate interests in monitoring and improving our website and services.
Enquiry Data
2.4 We may process the information included in an enquiry you send us about goods and/or services (“enquiry data”). Enquiry data may be used to offer, market and sell goods and/or services that are relevant to you. Consent is the legal basis for this processing.
Notification Data
2.5 We may process information that you give us when signing up for email notifications and/or newsletters (“notification data”). Notification data may be used to provide the notifications and/or newsletters to which you have subscribed. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, before entering into such a contract.
Correspondence Data
2.6 We may process information contained in, or connected with, communications you send to us (“correspondence data”). This may include the content of the communication and its associated metadata. Metadata relating to communications submitted through our website contact forms will be generated by the website. Correspondence data may be processed so that we can communicate with you and maintain appropriate records. The legal basis is our legitimate interests in properly administering our website and business and managing communications with users.
Sharing Personal Data
2.7 Where required to deliver services to you or improve your customer experience, we may provide your personal data to trusted partners.
Where appropriate, your data may be shared with the companies with which we hold agencies, namely Zurich Life, Davy Select, Irish Life, Royal London, Aviva, New Ireland, Standard Life, BCP, Cantor FitzGerald, Bank of Ireland, Dilosk and Nua Money.
We engage only with trusted partners that are able to provide an adequate level of protection for your personal data. Personal data will be disclosed to third parties or public officials when we are legally required to do so. We may also disclose it to third parties where you have given consent or another lawful basis applies.
Meeting Recordings and Transcription
2.8 Meetings held on Microsoft Teams or Zoom may be recorded so that discussions and decisions are captured accurately. We also use an artificial intelligence tool to transcribe those meetings and prepare minutes. Consent is the legal basis for this processing.
Personal Data Relating to Others
2.9 You should not provide us with another person’s personal data unless we ask you to do so.
3. Retention and Deletion of Personal Data
3.1 Our policies and procedures for retaining and deleting personal data are set out in this section. They are intended to support compliance with our legal obligations in relation to data retention and deletion.
3.2 We will not keep personal data processed for any purpose for longer than is necessary for that purpose.
3.3 It may not always be possible to state the relevant retention period in advance.
Where this is the case, the period will be determined by reference to our legitimate need to retain the data.
3.4 Regardless of the other provisions in this section, we may retain your personal data where this is required to meet a legal obligation that applies to us, or to protect your vital interests or those of another natural person.
4. Changes to This Policy
4.1 We may revise this policy periodically by placing an updated version on our website.
4.2 We recommend that you review this page from time to time so that you remain satisfied with any amendments to the policy.
4.3 We may advise you of policy changes by email or through our website’s private messaging system.
5. Your Rights Under Data Protection Law
5.1 This section provides an overview of the rights you have under data protection law. As some of these rights are complex, the summary does not cover every aspect. For a complete explanation, you should refer to the applicable legislation and guidance published by the relevant regulatory authorities.
5.2 Your main rights under data protection law include:
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
Right of Access
5.3 You are entitled to ask whether we process your personal data and, if we do, to obtain access to that data and certain related information. That information includes the purposes of the processing, the categories of personal data involved and the recipients of the data. As long as the rights and freedoms of other people are not adversely affected, we will provide you with a copy of your personal data.
Right to Rectification
5.4 You are entitled to have personal data that is inaccurate corrected and, having regard to the purposes of the processing, to have incomplete personal data completed.
Right to Erasure
5.5 In certain circumstances, you may require your personal data to be erased without undue delay. Those circumstances include where:
- the personal data is no longer required for the purposes for which it was collected or otherwise processed;
- you withdraw the consent on which the processing depends;
- you object to processing under certain provisions of applicable data protection law;
- the processing is carried out for direct marketing; or
- the personal data has been processed unlawfully.
The right to erasure is not absolute and is subject to exceptions. Broadly, these include circumstances in which processing is required to exercise the right to freedom of expression and information, comply with a legal obligation, or establish, exercise or defend legal claims.
Right to Restrict Processing
5.6 In certain circumstances, you may require us to limit the processing of your personal data. These circumstances include where:
- you contest the accuracy of the personal data;
- processing is unlawful, but you oppose erasure;
- we no longer need the personal data for our processing purposes, but you require it for the establishment, exercise or defence of legal claims; or
- you have objected to processing, pending verification of that objection.
When processing is restricted on this basis, we may continue to retain your personal data. Apart from storage, we will process it only with your consent; to establish, exercise or defend legal claims; to protect the rights of another natural or legal person; or for reasons of important public interest.
Right to Object
5.7 You may object to our processing of your personal data for reasons connected with your particular situation, but only where the processing is based on the need to perform a task in the public interest or in the exercise of official authority vested in us, or on legitimate interests pursued by us or a third party.
If you raise an objection, we will stop processing the personal information unless we can show compelling legitimate grounds that take precedence over your interests, rights and freedoms, or the processing is required to establish, exercise or defend legal claims.
5.8 You may object to the use of your personal data for direct marketing, including profiling undertaken for direct marketing. If you object, we will no longer process your personal data for that purpose.
5.9 You may object, on grounds relating to your particular situation, to our processing of your personal data for scientific or historical research or statistical purposes, unless the processing is necessary to carry out a task for reasons of public interest.
Right to Data Portability
5.10 Where your personal data is processed by automated means on the basis of consent, or because processing is necessary to perform a contract to which you are a party or to take steps at your request before entering into a contract, you are entitled to receive that data from us in a structured, commonly used and machine-readable format. This right does not apply if exercising it would adversely affect the rights and freedoms of others.
Right to Complain
5.11 If you believe that the way we process your personal information breaches data protection law, you have the legal right to complain to a supervisory authority responsible for data protection. A complaint may be made in the EU member state where you habitually reside, where you work, or where the alleged infringement occurred.
Right to Withdraw Consent
5.12 Where consent is the legal basis on which we process your personal information, you may withdraw that consent at any time. Doing so will not affect the lawfulness of any processing completed before the withdrawal.
Who We Are
Libertas Wealth Advisory Limited, trading as IIG, Indigo Investment Group, Indigo Investments, Indigo Mortgages, Indigo Wealth, Indigo Private Clients, Indigo Financial Planning, Indigo Mortgage Protection, WLTH and iNVST are regulated by the Central Bank of Ireland.
Registered office: The Greenway,112–114 St Stephen’s Green, Dublin 2, D02 TD28.
Director: Eoin Macken.
Registered in Ireland, No. 808671.
Libertas Wealth Advisory Limited, trading as IIG, Indigo Investment Group, Indigo Investments, Indigo Mortgages, Indigo Wealth, Indigo Private Clients, Indigo Financial Planning, Indigo Mortgage Protection and iNVST are regulated by the Central Bank of Ireland.