Privacy Policy

Moore Wealth Management is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client. It is the intention of this privacy statement to explain to you the information practices of Moore Wealth Management in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:

• Moore Wealth Management
• Contact details of Moore Wealth Management
• When we refer to ‘we’ it is Moore Wealth Management

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?

Our goal is to provide superior personalized wealth management services to our clients by partnering with them to build long term advice based relationships to help them achieve their financial goals. We accomplish this by cultivating a business that is attentive to the needs of our clients and ensuring that all of our clients receive our full focused attention in establishing the goals and objectives that we agree with them. By maintaining a forward looking investment process which is focused on realising those goals within an agreed level of risk, we are able to deliver complete wealth management solutions individually tailored for every client.

Our Data Protection Officer / GDPR Owner and data protection representatives can be contacted directly
here:

• Name; Colm Moore
• Email address; colm@mwm.ie
• Phone number; 086 8603953

Why we are processing your data? Our legal basis.

In order for us to provide you with financial and wealth management advice Moore Wealth Management need to collect personal data for report writing, analysis and entering into of contracts. Our reason (lawful reason) for processing you data under the GDPR is:

• Contractual – Moore Wealth Management needs to process your data to complete a contract, we will need your data to complete a full financial analysis and to arrange or renew insurance and or pension.

In any event, Moore Wealth Management 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 Moore Wealth Management use the personal data it collects about me?

Moore 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 endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary.

Special Categories of personal data

If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) we will ensure the below.
Subject to suitable and specific measures being taken to safeguard the fundamental rights and freedoms of data subjects, the processing of data concerning health shall be lawful where the processing is necessary and proportionate for the purposes of the following:

1. a policy of insurance or life assurance,
2. a policy of health insurance or health-related insurance,
3. an occupational pension, a retirement annuity contract or any other pension arrangement, or
4. the mortgaging of property

Who are we sharing your data with?

We may pass your personal data on to third-party service providers contracted to Moore 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 Moore 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 explicit consent, unless we are legally required to do otherwise.

The third parties that we pass your personal data to are:

• our CRM providers – Best Advice
• Friends First
• Zurich Life
• Aviva
• Irish Life
• New Court
• ITC
• New Ireland
• Royal London
• Merrion Stockbrokers
• Broker Solutions
• BlackBee Investments
• BCP
• Cantor Fitzgerald
• Wealth Options
• Quilter Cheviot Ireland

We have issued all our third party processors with a Data Processor checklist asking them GDPR specific questions

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: Your rights as a data subject

Moore Wealth Management facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• 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 Organisation Name refuses your request under rights of access, we will provide you with a reason as to why.

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.

Additional information we are providing you with to ensure we are transparent and fair with our processing

Retention of your personal data

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

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Moore Wealth Management or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Moore Wealth Management’s data protection representatives Data Protection Officer / GDPR Owner

Failure to provide further information

If we are collecting your data for a contract (e.g. Life 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 may from time to time use automated decision making that can benefit you – however, we will always tell you when this is the case and will explain the reasoning – should you wish to have human intervention in an automated decision we will ensure this happens.

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.

Contact Us

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. Your privacy is important to us. If you have any comments or questions regarding this Statement, please contact us.