Last Updated: 15/12/2021
PRIVACY POLICY
This privacy policy applies to the website of Shelbourne Financial trading as Financial Health of 95 Merrion Sq West, Dublin 2 ("Financial Health", "we", "our" or "us"). It does not apply to other Internet offers to which we merely refer by means of a link.
We are pleased that you have visited our website under the domain financialhealth.ie. In order to increase the attractiveness of our website, we are continuously improving the functions and services of the site. In doing so, security is our top priority. When using our website, you entrust us with your personal data. We appreciate this trust. That is why we handle your data with particular care.
Here you will find information on how we handle your personal data when you visit our website. In order to provide the functions and services of our website, it is necessary for us to collect personal data about you. Below we explain what data we collect about you, why this is necessary and what rights you have in relation to your data.
Responsible for the processing of personal data on this website is:
Shelbourne Financial Limited
95 Merrion Sq West,
Dublin 2
Telephone: 01518 0518
E-mail: info@financialhealth.ie
If you have any questions regarding the collection, processing or use of your personal data, we would be pleased to hear from you. We will also be happy to implement your suggestions. If you have any questions or suggestions regarding data protection, please contact us using the contact details above.
Our principles
Financial Health respects your right to privacy and is committed to the following key principles:
· We protect your privacy and aim to provide you with a service that is tailored to your needs.
· Personal data is collected for specific purposes based on your consent or a legitimate interest when you contact us.
· You have the right to information and access to your personal data at any time and may request its correction or deletion.
· We do not sell your personal data to third parties. However, if necessary and if explicitly mentioned afterwards or if you have consented, we may share your data with group companies, brand licensees, partners and other service providers. In this case, their own privacy policies may also apply.
· We take all reasonable measures to ensure the security and protection of your data from misuse.
· Personal data are processed by us only as necessary and for the purpose of providing a functional and user-friendly website, including its contents and the services offered there.
Rights of users and persons concerned
With regard to the data processing described in more detail below, users and data subjects have the right to
· to confirmation as to whether data relating to them is being processed,
· to information about the data processed, to further information about the data processing and to copies of the data;
· to correction or completion of incorrect or incomplete data;
· to immediate erasure of the data concerning them;
· to receive the data concerning them and provided by them and to transfer this data to other providers/controllers;
· to lodge a complaint with the supervisory authority if they are of the opinion that the data concerning them is being processed by the provider in breach of data protection provisions.
In addition, the provider is obliged to inform all recipients to whom data has been disclosed by the provider of any correction or deletion of data or restriction of processing that takes place. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Notwithstanding this, the user has a right to information about these recipients.
Likewise, users and data subjects have the right to object to the future processing of data concerning them, insofar as the data is processed by the provider. In particular, an objection to data processing for the purpose of direct advertising is permissible.
The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we are required to have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information.
We encourage you to get in touch if you have any concerns with how we collect or use your personal information.
Lawfulness of processing
The processing of personal data is only lawful if there is a legal basis for the processing. Pursuant to Article 6 (1) lit. a - f GDPR, the legal basis for processing may in particular be:
· The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes;
· The processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the data subject's request;
· Processing is necessary for compliance with a legal obligation to which the controller is subject;
· Processing is necessary in order to protect the vital interests of the data subject or of another natural person;
· Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
· Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child.
Access to the website and data on our website
Every time a user accesses a page from our Internet offering and every time a file is retrieved, our web server automatically stores and processes data about this process in a log file. In detail, the following data is stored for each access/retrieval:
· IP address of the requesting computer
· date and time of the request
· accessed page/name of the accessed file
· amount of data transferred
· message as to whether the access/retrieval was successful
· Internet address from which the page or file was accessed or the requested function was initiated.
The aforementioned data, including the IP address, are stored for the duration of the communication process in order to enable the use of our Internet services.
The provision of this data for the use of our website is not required by law but is technically necessary in order to be able to display our website to you. We also use the data to ensure the security and stability of our website; this is also our legitimate interest for processing. No personal evaluation of this data takes place. Only a statistical evaluation of the data records is reserved. The legal basis for the collection is Art. 6 para. 1 lit. f GDPR.
Collection, processing and use of personal data
We only collect and use personal data on an expressly voluntary basis, either in response to enquiries or in the context of the wealthpilot.de financial software in the protected area. Specifically, we collect, process and use the following personal data:
a) Contact: Contact options are provided on our website. If you contact us (e.g., by e-mail or telephone), we collect and store the data you send us (e.g., surname, first name, e-mail address). We use this data exclusively to process and answer your enquiry. It will not be passed on to third parties without your consent. In the case of consent, the legal basis for processing is Art. 6 Para. 1 lit. a GDPR. If your enquiry serves to prepare the conclusion of a contract, Art. 6 para. 1 lit. b GDPR is the additional legal basis. If you contact us by e-mail, our legitimate interest for data processing results from answering your enquiry, so that Art. 6 (1) lit f GDPR is the legal basis. If you send us an unencrypted e-mail, the e-mail is not protected against unauthorised access or modification by third parties during transmission.
b) Live Chat: We have integrated the Live chat service "Messages" from HubSpot (round chat icon at the bottom right edge of the screen). If you agree to and use this function, the following data will be transmitted to HubSpot's servers: Content of all chat messages sent and received, Context information (e.g., page on which the chat was used), Optional: e-mail address of the user (if provided by the user via the chat function). The legal basis for the use of Hubspot's services is Art. 6 I f GDPR - legitimate interest. Our legitimate interest in using this service is the optimisation of our marketing measures and the improvement of our service quality on the website.
Contractual Relationship
In order to establish or implement the contractual relationship with our customers, it is regularly necessary to process the personal master, contract, and payment data provided to us. We also process customer and prospect data for evaluation and marketing purposes. This processing is carried out on the legal basis of our legitimate interest and serves our interest in further developing our offer and informing you specifically about our offers. Further data processing may take place if you have consented or if this serves the fulfilment of a legal obligation.
Commercial and business services
We process data of our contractual and business partners, e.g., customers and interested parties in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g., to answer enquiries.
We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation. We only disclose the data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g., to participating telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities).
Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and organisational procedures, administration, and response to requests, visit action evaluation, interest-based and behavioural marketing. And, the Legal bases are Contractual performance and pre-contractual enquiries, Legal obligation, and our Legitimate interests.
When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of t data subject access request is both our legitimate interest and our legal obligation.
The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfil the legally required accountability.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process.
You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future. In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.
Legal defence and enforcement of our rights
The legal basis for the processing of your personal data in the context of legal defence and enforcement of our rights is our legitimate interest.
The purpose of processing your personal data in the context of legal defence and enforcement of our rights is the defence against unjustified claims and the legal enforcement and assertion of claims and rights. Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected.
The processing of your personal data in the context of legal defence and enforcement is mandatory for legal defence and enforcement of our rights. Consequently, there is no possibility for you to object.
Use of cookies
We use cookies to facilitate and improve the use of our website. Cookies are text information that is stored on a computer via the web browser when you visit a website. Our cookies are either deleted when the browser session is ended ("session cookies") or they have a specific lifetime. The legal basis for data processing is Art. 6 para. 1 lit. f GDPR. You can find more general information about cookies on www.allaboutcookies.org and more specific information on the cookies we use in our Cookie Policy.
Google Analytics
This website uses Google Analytics, a web analytics service provided by Google LLC ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.
IP anonymisation has been activated on this web site so that the user's IP address is truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area.
Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website.
The legal basis for the collection and processing of the data is Art. 6 (1) f GDPR. The legitimate interest in collecting and processing the data is to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services related to website and internet use.
Squarespace Metrics
Our website uses Squarespace Metrics, a web analytics service provided by Squarespace, Inc, 225 Varick Street, New York, NY 10014, USA ("Squarespace").
Squarespace Analytics uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. The data generated by cookies about the use of our website is transmitted to a Squarespace server in the USA and stored there.
Squarespace uses the data to evaluate the use of the website by the visitor, to compile reports on the visitors' activities on the website and to provide other services related to the use of the website. Where Squarespace is required to do so by law, or where third parties process the data on its behalf, the data will be transferred to those third parties. Squarespace will never associate your IP address with any other data held by Squarespace. You have the option to prevent cookies from being stored on your computer by making the appropriate browser settings. However, by deactivating cookies you may not be able to use all the functions of our web site to their full extent. By using the website, you consent to the processing of data about you by Squarespace in the manner described above and for the purposes of compiling visitor statistics on the use of the website and improving the website.
The legal basis for the collection and processing of the data is Art. 6 (1) f GDPR. The legitimate interest in collecting and processing the data is to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services related to website and internet use.
Hotjar
We use Hotjar, a web analytics service provided by Hotjar Ltd, Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta ("Hotjar"), to better understand usage patterns, to better understand the needs of our users and to optimize our services and user experience. Hotjar enables us to better understand the user experience on our sites (i.e., how long users spend on which of our sites, which links they click, what they like and dislike, etc.) so that we can tailor our offerings based on user feedback.
Hotjar uses cookies and other technologies to collect information about user behavior and user devices (in particular, a device's IP address (which is collected and stored in anonymized form), screen size, device type (unique device identifiers), browser information, geographic information (on a country-by-country basis only), preferred language for viewing our web site). Hotjar stores this data in a pseudonymized user profile. Neither Hotjar nor we will use this information to identify individual users, nor will the data be merged with other data about individual users. You can object to the creation of user profiles, the storage of data about your use of our site by Hotjar, and the use of tracking cookies by Hotjar on other sites at any time by following this link https://www.hotjar.com/opt-out.We have entered into an order processing agreement with Hotjar. The use of Hotjar is based on your consent according to Art. 6 (1) (a) GDPR.
Hubspot
When you visit certain business sections of our website, our partner HubSpot uses the cookie listed below for functionality, performance and to track visitors. This cookie is used to keep track of a visitor's identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts. Please refer to HubSpot`s usage policy for more information. The legal basis for the collection and processing of the data is Art. 6 (1) f GDPR. The legitimate interest in collecting and processing the data is to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services related to website and internet use.
Security
We use technical and organisational security measures to protect your data against accidental or intentional manipulation, loss, destruction or access by unauthorised persons, e.g., by means of an encrypted connection. Our security measures are continuously improved in line with technological developments.
Storage period
a) Your personal data will be deleted or blocked as soon as it is no longer required for processing in order to comply with legal obligations and the purpose for which it was stored has also ceased to apply.
b) Please note that even after the termination of a contract it may be necessary to store personal data in order to comply with contractual or legal obligations, e.g.
c) to comply with commercial or tax retention obligations with retention periods of up to ten years, calculated from the end of the calendar year, or
d) for the assertion or exercise of claims or rights or for the defence against rights or claims, this within the framework of the statutory provisions on the statute of limitations, which may be up to 30 years from the respective statutory commencement of the limitation period.
Transfer to third parties
In principle, your data will only be passed on to third parties if you have given us your consent to do so or if this is permitted by law. This is the case external service providers of ours who we have carefully selected and commissioned and who are bound by our instructions and regularly monitored (e.g., web hosting providers) or if this is necessary to fulfil a legal obligation to which we are subject.
No automated processing of your data, including profiling
You will not be subject to any processing of your data based exclusively on automated processing including profiling (Art. 13 para. 2 lit. f) GDPR, Art. 22 para. 1 to 4 GDPR, Art. 4 No. 4 GDPR in which would have legal effect vis-à-vis you or would significantly affect you in a similar way.
SSL encryption
To protect the security of your data during transmission, we use state-of-the-art encryption procedures (e.g. SSL) via HTTPS.
Social Media
The data you enter on our social media pages, such as comments, videos, pictures, likes, public messages, etc. are published by the social media platform and are not used or processed by us for any other purpose at any time. We only reserve the right to delete content if this should be necessary. Where applicable, we share your content on our site if this is a function of the social media platform and communicate with you via the social media platform. The legal basis is our legitimate interest. The data processing is carried out in the interest of our public relations and communication.
If you wish to object to certain data processing over which we have an influence, please contact us. We will then examine your objection. If you send us a request on the social media platform, we may also refer you to other secure communication channels that guarantee confidentiality, depending on the response required. You always have the option of sending us confidential enquiries to our address stated in the imprint.
As already stated, where the social media platform provider gives us the opportunity, we take care to design our social media pages to be as data protection compliant as possible. With regard to statistics that the provider of the social media platform makes available to us, we can only influence these to a limited extent and cannot switch them off. However, we make sure that no additional optional statistics are made available to us.
Data processing by the operator of the social media platform
The operator of the social media platform uses web tracking methods. The web tracking can also take place regardless of whether you are logged in or registered with the social media platform. As already explained, we can unfortunately hardly influence the web tracking methods of the social media platform. We cannot, for example, switch this off.
Please be aware: It cannot be ruled out that the provider of the social media platform uses your profile and behavioural data, for example to evaluate your habits, personal relationships, preferences, etc. We have no influence on this. In this respect, we have no influence on the processing of your data by the provider of the social media platform.
International transfers
We do not directly and for the purpose of processing transfer your personal data outside the European Economic Area (EEA) and Ireland.
Changes to our privacy policy
We reserve the right to adapt this privacy policy so that it always complies with the current legal requirements or in order to implement changes to our services in the privacy policy, e.g., when introducing new services. The new privacy policy will then apply to your next visit.
Questions
If you have any questions about data protection, please write us an e-mail or contact us using the details provided on the website.