Privacy Statement

Privacy Statement

Melalex Financial Ltd Trading As Kavanagh International Wealth Managementis committed to protecting and respecting your privacy.

It is the intention of this privacy statement to explain to you the information practices of Kavanagh International Wealth Management in relation to the information we collect about you and other users.

For the purposes of the GDPR the data controller is:

  • Michael Kavanagh of Kavanagh International Wealth Management
  • Tel: 021 487 5497 – email: michael@kwm.ie

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.

Who are we?

Melalex Financial T/A Kavanagh International Wealth Management is regulated by the Central Bank of Ireland. Our Central Bank of Ireland number is C32483. You can verify our regulatory status by visiting the Central Bank of Ireland website.
Our firm is authorised in Ireland as an investment intermediary to provide the investment instruments collective investments, listed bonds and shares, tracker bonds, PRSA’s and insurance policies under Section 10 of the Investments Intermediaries Act, 1995, as amended.  Our firm is also registered as an insurance/reinsurance intermediary under the European Communities (Insurance Mediation) Regulations, 2005 (as amended).  We are an authorised mortgage intermediary under the Consumer Credit Act, 1995 as amended.  Our firm is also authorised as a deposit broker.
Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly here:

  • Michael Kavanagh QFA APA
  • michael@kwm.ie
  • 021 487 5497

 

Purpose for processing your data

Kavanagh International Wealth Management are an Insurance Broker Therefore we can generally give consumers greater choice than agents and tied agents.  We hold written appointments from the product producers set out in Appendix 1 of our Terms Of Business.  We provide advice on all protection products, investments, pensions, deposits and mortgages.
Why do Kavanagh International Wealth Management need to collect and store personal data?

In any event, 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.

In terms of being contacted for marketing purposes Kavanagh International Wealth Management would contact you for additional consent. On our initial meeting, we complete a financial review form (Fact-Find) This document contains a section which you complete to give us permission and confirms the method you wish us to contact you.

 

How will Kavanagh International Wealth Management use the personal data it collects about me?

Kavanagh International Wealth Management 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.

Kavanagh International Wealth Management 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.
Under what circumstances will Kavanagh International Wealth Management contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure.

 

Why we are processing your data? Our legal basis.

Our reason and purpose for processing your personal data is:

  • We have your consent
  • We need to process your data to complete the performance of a contract

where you, the data subject is a party Kavanagh International Wealth Management processes data without consent in order to fulfil contractual obligations [such as bank details to process salaries, postal address in order to supply products and services, etc.].

  • legal obligation that needs to meet
  • protect the vital interests of the data subject, including the protection of rights and freedoms
  • processing that is in the public interest
  • necessary for the legitimate interests of the data controller or third party, unless the processing is overridden by the vital interests, including rights and freedoms
  • national law

 

Special Categories of personal data

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

  • we will obtain your explicit consent
  • 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 the 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 Kavanagh International Wealth Management 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 fulfill 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 Kavanagh International Wealth Management 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, unless we are legally required to do otherwise.
If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) 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:

Kavanagh International Wealth Management facilitate the data subject’s rights in line with the data protection policy and the subject access request procedure. This is available on 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 Kavanagh International Wealth Management 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 clause 3.6 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. Kavanagh International Wealth Management will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body  (Central Bank, Revenue ) and our internal governance.

Michael Kavanagh / GDPR Owner

If we are collecting your data for a statutory requirement (payroll) or to fulfill 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.

 

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:

Kavanagh International Wealth Management have collected your personal data from for example your Tax Advisor or Accountant, Kavanagh International Wealth Management is committed to protecting and respecting your privacy.

It is the intention of this privacy statement (“Privacy Statement”) to explain to you the information practices of Kavanagh International Wealth Management in relation to the information we collect about you and other users.

We want to share any other information required to demonstrate that the processing is fair and transparent.
The Categories of personal data we have collected are:

Who we are sharing this data with

If we have received your personal data from another source we will endeavour to share with you:

  • one month of obtaining the personal data, in accordance with the specific circumstances of the processing;
  • at the first instance of communicating in circumstances where the personal data is used to communicate with the data subject;
  • when personal data is first disclosed in circumstances where the personal data is disclosed to another recipient.

 

The above will not apply when:

  • If you already has the information;
  • If the provision of the above information proves impossible or would involve an excessive effort
  • If obtaining or disclosure of personal data is expressly identified by Member State law; or
  • If personal data must remain confidential subject to an obligation of professional secrecy regulated by Member State law, including a statutory obligation of secrecy.

 

Responsibilities

The Data Protection Officer/GDPR Owner is responsible for ensuring that the privacy notice(s) is correct and that mechanisms exist such as having the Privacy Notice(s) on Kavanagh International Wealth Management website to make all data subjects aware of the contents of this notice prior Kavanagh International Wealth Management 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 the IAPP or the use of this Site in general, please contact us by e-mail at michael@kwm.ie
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”.

CONTACT DETAILS

Phone: +353 21 4873595
Email: info@kwm.ie
Address: 3 Station Road,
Ballincollig, Co Cork. Ireland

Melalex Financial Ltd T/A Kavanagh International Wealth Management is regulated by the Central Bank of Ireland.

© 2018 KAVANAGH INTERNATIONAL WEALTH MANAGEMENT. ALL RIGHTS RESERVED. | PRIVACY STATEMENT