Privacy Policy

Policy Review

Policy Prepared For: Linked Pensions & Investments Ltd

Approved by Board/Management On: 20/08/2020
Policy Became Operational On: 20/08/2020
Last Updated: 12/03/2021
Next Review Date: 20/08/2021

Introduction

Linked Pensions & Investments Ltd needs to gather and use certain information about individuals.

These can include customers, suppliers, business contacts, employees and other people the organisation has a relationship with or may need to contact.

This policy describes how this personal data must be collected, handled and stored to meet the company’s data protection standards thus complying with the legislation.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Linked Pensions & Investments Ltd with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Bank account information in order to pay for products and/or services within the Service
Usage Data
Other data that requires to produce an online quote

When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:

Date of birth
Passport or National ID card
Bank card statement
Other information linking You to an address

Purpose

This data protection policy ensures Linked Pensions & Investments Ltd:

Comply with Data Protection Legislation and follow Good Practice;
Protect the Rights of Employees, Customers and Partners;
Is Transparent in terms of How It Stores and Processes Individuals’ Data;
Protects itself from the Risks Associated with a Data Breach.

Policy Statement

The General Data Protection Regulation (GDPR) describes how organisations — including Linked Pensions & Investments Ltd, must collect, handle and store personal information.

These rules apply regardless of whether data is stored electronically, on paper or on other materials.

To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.

Data Subjects’ Rights

Data subjects have the following rights regarding data processing, and the data that is recorded about them:

To make subject access requests regarding the nature of information held and to whom it has been disclosed;
To prevent processing likely to cause damage or distress;
To prevent processing for purposes of direct marketing;
To be informed about the mechanics of automated decision-making process that will significantly affect them;
To not have significant decisions, that will affect them, taken solely by automated process;
To sue for compensation if they suffer damage by any contravention of the GDPR;
To act to rectify, block, erase, including the right to be forgotten, or destroy inaccurate data;
To request the Supervisory Authority to assess whether any provision of the GDPR has been contravened;
To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have that data transmitted to another controller;
To object to any automated profiling that is occurring without consent.

Subject Access Requests

All individuals who are the subject of personal data held by Linked Pensions & Investments Ltd are entitled to:

Ask what information the company holds about them and why;
Ask how to gain access to it;
Be informed about how to keep it up to date;
Be informed about how the company is meeting its data protection obligations.

Should an Individual contact the company requesting this information, this is called a Subject Access Request.

Subject Access Requests from individuals should be made by email, addressed to the data controller at (email address). The data controller can supply a standard request form, although individuals do not have to use this.

The data controller will aim to provide the relevant data within 30 days.

The data controller will always verify the identity of anyone making a subject access request before handing over any information.

Consent

Linked Pensions & Investments Ltd understands ‘consent’ to mean that it has been explicitly and freely given, and a specific, informed and unambiguous indication of the data subject’s wishes that, by statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her. The data subject can withdraw their consent at any time.

Linked Pensions & Investments Ltd understands ‘consent’ to mean that the data subject has been fully informed of the intended processing and has signified their agreement, while in a fit state of mind to do so and without pressure being exerted upon them. Consent obtained under duress or on the grounds of misleading information will not be a valid basis for processing.

There must be some active communication between the parties to demonstrate “active consent”. Consent cannot be inferred from non-responsive communications. The controller must be able to demonstrate that consent was obtained for the processing operation.

For sensitive data, explicit consent from data subjects must be obtained unless an alternative legitimate basis for processing exists.

Security of Data

All Employees/Staff are responsible for ensuring that any personal data that Linked Pensions & Investments Ltd holds and for which they are responsible, is kept securely and is not, under any conditions, disclosed to any third party unless that third party has been specifically authorised by Linked Pensions & Investments Ltd to receive that information and has entered into a confidentiality agreement.

All personal data should be accessible only to those who need to use it, and access may only be granted in line with the Access Control Policy.

All personal data should be treated with the highest security and must be kept:

in a lockable room with controlled access; and/or
in a locked drawer or filing cabinet; and/or
if computerised, password protected in line with corporate requirements in the Access Control Policy; and/or
stored on (removable) computer media which are encrypted in line with Secure Disposal of Storage Media.

Care must be taken to ensure that PC screens and terminals are not visible except to authorised Employees/Staff of Linked Pensions & Investments Ltd. All Employees/Staff are required to enter into an Acceptable Usage Agreement before they are given access to organisational information of any sort, which details rules on screen time-outs etc.

Manual records may not be left where they can be accessed by unauthorised personnel and may not be removed from business premises without explicit (written) authorisation. As soon as manual records are no longer required for day-to-day client support, they must be removed from secure archiving in line with your policies.

Personal data may only be deleted or disposed of in-line with the Retention of Records Procedure Manual.

Records that have reached their retention date are to be shredded and disposed of as ‘confidential waste’. Hard drives of redundant PCs are to be removed and immediately destroyed, as required before disposal.

Processing of personal data ‘off-site’ presents a potentially greater risk of loss, theft or damage to personal data. Staff must be specifically authorised to process data off-site.

Disclosure of Data

Linked Pensions & Investments Ltd must ensure that personal data is not disclosed to unauthorised third parties which includes family members, friends, government bodies, and in certain circumstances, the Gardaí/Police. All Employees/Staff should exercise caution when asked to disclose personal data held on another individual to a third party. It is important to consider whether disclosure of the information is relevant to, and necessary for, the conduct of Linked Pensions & Investments Ltd business.

All requests to provide data for one of these reasons must be supported by appropriate paperwork and all such disclosures, must be, specifically authorised by the GDPR owner.

Retention and Disposal of Data

Linked Pensions & Investments Ltd shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary, in relation to the purpose(s) for which the data was originally collected.

Linked Pensions & Investments Ltd may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.

The retention period for each category of personal data will be set out in the Retention of Records Procedure, along with the criteria used to determine this period, including any statutory obligations Linked Pensions & Investments Ltd has, to retain the data.

Linked Pensions & Investments Ltd Data Retention, Data Disposal and Storage Removal Procedures will apply in all cases.

Personal data must be disposed of securely, in accordance with the sixth principle of the GDPR. Thus, processed in, an appropriate manner, to maintain security, thereby, protecting the “rights and freedoms” of data subjects. Any disposal of data, will be done in accordance with the Secure Disposal Procedure.

Data Transfers

All exports of data from within the Non-European Economic Area (EEA) countries (referred to in the GDPR as ‘third countries’) are unlawful unless there is an appropriate “level of protection for the fundamental rights of the data subjects”.

The transfer of personal data outside of the EEA is prohibited unless one or more of the following specified safeguards, or exceptions, apply:

An Adequacy Decision

The European Commission can and does assess third countries, a territory and/or specific sectors within third countries to assess whether there is an appropriate level of protection for the rights and freedoms of natural persons. In these instances, no authorisation is required.

Countries that are members of the European Economic Area (EEA) but not of the EU are accepted as having met the conditions for an adequacy decision.

A list of countries that currently satisfy the adequacy requirements of the Commission are published in the Official Journal of the European Union. (Please see “Related Documentation” section below).

Privacy Shield

If Linked Pensions & Investments Ltd wishes to transfer personal data from the EU to an organisation in the United States it should check that the organisation is signed up with the Privacy Shield framework at the U.S. Department of Commerce (DOC). The obligation applying to companies under the Privacy Shield are contained in the “Privacy Principles”. The US DOC is responsible for managing and administering the Privacy Shield and ensuring that companies live up to their commitments. To certify, companies must have a privacy policy in line with the Privacy Principles e.g. use, store and further transfer the personal data according to a strong set of data protection rules and safeguards. The protection given to the personal data applies regardless of whether the personal data is related to an EU resident or not. Organisations must renew their “membership” with the Privacy Shield on an annual basis. If they do not, they can no longer receive and use personal data from the EU under that framework.

Binding Corporate Rules(BCRs)

Linked Pensions & Investments Ltd may adopt, approved binding corporate rules for the transfer of data outside the EU. This requires submission to the relevant supervisory authority for approval of the rules that Linked Pensions & Investments Ltd is seeking to rely upon.

Model Contract Clauses

Linked Pensions & Investments Ltd may adopt approved model contract clauses for the transfer of data outside of the EEA. If Linked Pensions & Investments Ltd adopts the (model contract clauses approved by the relevant supervisory authority), there is an automatic recognition of adequacy.

Exceptions

In the absence of an Adequacy Decision, Privacy Shield membership, Binding Corporate Rules and/or Model Contract Clauses, a transfer of personal data to a third country or international organisation shall only take place on one of the following conditions:

the data subject has explicitly consented to the proposed transfer, after being informed of the possible risks of such transfers, for the data subject, due to the absence of an adequacy decision and appropriate safeguards;
the transfer is necessary for the performance of a contract between the data subject and the controller, or the implementation of pre-contractual measures taken at the data subject's request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject, between the controller and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for the establishment, exercise or defence of legal claims; and/or
the transfer is necessary to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.

Data flow

Linked Pensions & Investments Ltd has established a data inventory and data flow process as part of its approach to address risks and opportunities throughout its GDPR compliance project namely;

business processes that use personal data;
source of personal data;
volume of data subjects;
description of each item of personal data;
processing activity;
maintains the inventory of data categories of personal data processed;
documents the purpose(s) for which each category of personal data is used;
recipients, and potential recipients, of the personal data;
the role of Linked Pensions & Investments Ltd throughout the data flow;
key systems and repositories;
any data transfers;
all retention and disposal requirements.

Linked Pensions & Investments Ltd is aware of all risks associated with the processing of, specific types of personal data.

Linked Pensions & Investments Ltd assesses the level of risk to individuals associated with the processing of their personal data. Data Protection Impact Assessments (DPIAs) are carried out in relation to the processing of personal data by Linked Pensions & Investments Ltd and in relation to processing undertaken by other organisations on behalf of Linked Pensions & Investments Ltd.

Linked Pensions & Investments Ltd shall manage any risks identified by the risk assessment, to reduce the likelihood of a non-conformance with this policy.

Where a type of processing, particularly using new technologies and considering the nature, scope, context and purposes of the processing is likely to result in a high risk to the rights and freedoms of natural persons, Linked Pensions & Investments Ltd shall, prior to the processing, carry out a Data Protection Impact Assessment (DPIA) of the impact of the envisaged processing operations on the protection of personal data. A single Data Protection Impact Assessment (DPIA) may address a set of similar processing operations that present similar high risks.

Following the result of a Data Protection Impact Assessment (DPIA), it is clear that Linked Pensions & Investments Ltd is about to commence processing of personal data that could cause damage and/or distress to the data subjects, the decision as to whether Linked Pensions & Investments Ltd may proceed must be escalated for review to the GDPR Owner.

The GDPR Owner shall, if there are significant concerns, either as to the potential damage or distress, or the quantity of data concerned, escalate the matter to the supervisory authority.

Data Protection Risks

This policy helps to protect Linked Pensions & Investments Ltd from potentially, serious data security risks, including:

Breaches of confidentiality: for instance, information processed inappropriately;
Reputational damage: for instance, the Company could suffer material or non-material damage if hackers successfully gained access to sensitive data.

General Staff Guidelines

The only people able to access data covered by this policy should be those who need it for their work;
Data should not be shared informally. When access to confidential information is required, employees can request it from their line managers;
Linked Pensions & Investments Ltd will provide training to all employees to help them understand their responsibilities when handling data;
Employees should keep all data secure, by taking sensible precautions and following the guidelines below;
Strong passwords are mandatory, and they should never be shared;
Personal data should not be disclosed to unauthorised people, either within the company or externally.
Data should be regularly reviewed and updated. If it is found to be out of date and/or no longer required, it should be deleted and disposed of appropriately.
Employees should request help from their line manager or the data protection officer if they are unsure about any aspect of data protection.

Data Storage

These rules describe how and where data should be safely stored. Questions about storing data safely can be directed to the GDPR Owner.

When data is stored in paper format, it should be kept in a secure place where unauthorised people cannot see it.

These guidelines also apply to data that is usually stored electronically but has been printed out for some reason:

When not required, the paper or files should be kept in a locked drawer or filing cabinet;
Employees should make sure paper and printouts are not left where unauthorised people could see them, like on a printer;
Data printouts should be shredded and disposed of securely when no longer required;
When data is stored electronically, it must be protected from unauthorised access, accidental deletion and malicious hacking attempts;
Data should be protected by strong passwords that are changed regularly and never shared between employees;
If data is stored on removable media (like a CD or DVD), these should be kept locked away securely when not being used;
Data should only be stored on designated drives and servers and should only be uploaded to an approved cloud computing service.
Servers containing personal data should be sited in a secure location, away from general office space.
Data should be backed-up frequently. Those back-ups should be tested regularly, in line with the company’s standard backup procedures.
Data should never be saved directly to laptops or other mobile devices like tablets or smart phones.
All servers and computers containing data should be protected by approved security software and a firewall.

Linked Pensions & Investments Ltd website protects data online by having a secure cloud server that’s protected by a secure Firewall system from preventing hacks and a has a secure SSL (Secure Socket Layer) which encrypts all the communication between Our online website www.digitaldestiny7.sg-host.com and You.

Data Usage

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Personal data is of no value to Linked Pensions & Investments Ltd unless the business can make use of it. However, it is when personal data is accessed and used, that it can be at the greatest risk of loss, corruption or theft. For example:

When working with personal data, employees should ensure the screens of their computers are always locked when left unattended.
Personal data should not be shared informally. It should never be sent by email, as this form of communication is not secure.
Data must be encrypted before being transferred electronically. The IT manager can explain how to send data to authorised external contacts.
Personal data should never be transferred outside of the European Economic Area (EEA).
Employees should not save copies of personal data to their own computers. Always access and update the central copy of any data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies Linked Pensions & Investments Ltd use may include:

Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser. You can learn more about cookies here: www.allaboutcookies.org.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary
Necessary cookies are absolutely essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.

Functional
Functional cookies help to perform certain functionalities like sharing the content of the website on social media platforms, collect feedbacks, and other third-party features.

Performance
Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for the visitors.

Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics the number of visitors, bounce rate, traffic source, etc.

Advertisement
Advertisement cookies are used to provide visitors with relevant ads and marketing campaigns. These cookies track visitors across websites and collect information to provide customized ads.

Others
Other uncategorized cookies are those that are being analyzed and have not been classified into a category as yet.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics
We may use third-party Service providers to monitor and analyze the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Google Search Console
Their Privacy Policy can be viewed at https://policies.google.com/privacy?hl=en_GB
Facebook Pixel
Their Privacy Policy can be viewed at https://www.facebook.com/about/privacy

Facebook Insights
We may use the Facebook Insights function in connection with the operation of the Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymised statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our Facebook Fan Page. Each Cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records and processes the information stored in the Cookie, especially when the user visits the Facebook services, services that are provided by other members of the Facebook Fan Page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook Privacy Policy here: https://www.facebook.com/full_data_use_policy

Email Marketing
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Linked Pensions & Investments Ltd by following the unsubscribe link or instructions provided in any email We send or by contacting Linked Pensions & Investments Ltd.

We may use Email Marketing Service Providers to manage and send emails to You.

Behavioral Remarketing
The Company uses remarketing services to advertise to You after You accessed or visited our Service. We and Our third-party vendors use cookies and non-cookie technologies to help Linked Pensions & Investments Ltd recognise Your Device and understand how You use our Service so that We can improve our Service to reflect Your interests and serve You advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies and to enable Linked Pensions & Investments Ltd to:

Measure and analyze traffic and browsing activity on Our Service
Show advertisements for our products and/or services to You on third-party websites or apps
Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit You to block such technologies. You can use the following third-party tools to decline the collection and use of information for the purpose of serving You interest-based advertising:

The NAI's opt-out platform: http://www.networkadvertising.org/choices/
The EDAA's opt-out platform http://www.youronlinechoices.com/
The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

You may opt-out of all personalized advertising by enabling privacy features on Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other online identifiers collected on Our Service with these third-party vendors. This allows Our third-party vendors to recognize and deliver You ads across devices and browsers. To read more about the technologies used by these third-party vendors and their cross-device capabilities please refer to the Privacy Policy of each vendor listed below.

The third-party vendors We use are:

Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Facebook
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/516147308587266
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation

Usage, Performance and Miscellaneous
We may use third-party Service Providers to provide better improvement of our Service.

Invisible reCAPTCHA
We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.
The reCAPTCHA service may collect information from You and from Your Device for security purposes.
The information gathered by reCAPTCHA is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/
Mouseflow
Mouseflow is a session replay and heatmap tool that shows how visitors click, move, scroll, browse, and pay attention on websites. The service is operated by ApS.
Mouseflow service may collect information from Your device.
The information gathered by Mouseflow is held in accordance with its Privacy Policy: https://mouseflow.com/privacy/

Data Accuracy

The law requires Linked Pensions & Investments Ltd to take reasonable steps to ensure data is kept accurately and up to date.

The higher the importance, that the personal data is accurate, the greater the effort Linked Pensions & Investments Ltd should put into ensuring its accuracy.

It is the responsibility of all employees who work with data to take reasonable steps, to ensure it is kept as accurate and up to date as possible.

Data will be held in as few places as necessary. Staff should not create any unnecessary additional data sets;
Staff should take every opportunity to ensure data is updated. For instance, by confirming a customer’s details when they call;
Linked Pensions & Investments Ltd will make it easy for data subjects to update the information Linked Pensions & Investments Ltd holds about them. For instance, via the company website;
Data should be updated as inaccuracies are discovered. For instance, if a customer can no longer be reached on their stored telephone number, it should be removed from the database.
It is the marketing manager’s responsibility to ensure marketing databases are checked against industry suppression files every six months.

Disclosing Data for Other Reasons

In certain circumstances, GDPR allows personal data to be disclosed to law enforcement agencies without the consent of the data subject. Under these circumstances, Linked Pensions & Investments Ltd will disclose requested data. However, the data controller will ensure the request is legitimate, seeking assistance from the board of directors and from the company’s legal advisers, where necessary.

Providing Information

Linked Pensions & Investments Ltd aims to ensure that individuals are aware that their data is being processed, and that they understand:

How their data is being used;
How to exercise their rights.

To this end, the company has a Privacy Statement, setting out how data relating to individuals is used by the company.

Roles and Responsibilities

Linked Pensions & Investments Ltd is a Data Controller under the GDPR.

Top Management and all those in managerial or supervisory roles throughout Linked Pensions & Investments Ltd are responsible for developing and encouraging good information handling practices within Linked Pensions & Investments Ltd; responsibilities are set out in individual job descriptions.

The GDPR Owner have specific responsibilities in respect of procedures such as the Subject Access Request Procedure and are the first point of call for Employees/Staff, seeking clarification on any aspect of data protection compliance.

Compliance with data protection legislation is the responsibility of all Employees/Staff of Linked Pensions & Investments Ltd who process personal data.

Linked Pensions & Investments Ltd Training Policy sets out specific training and awareness requirements in relation to specific roles and Employees/Staff of Linked Pensions & Investments Ltd generally.

Employees/Staff of Linked Pensions & Investments Ltd are responsible for ensuring that any personal data about them and supplied by them to Linked Pensions & Investments Ltd is accurate and up-to-date.

Everyone who works for or with Linked Pensions & Investments Ltd has some responsibility for ensuring data is collected, stored and handled appropriately.

However, these people have key areas of responsibility:

The board of directors is ultimately responsible for ensuring that Linked Pensions & Investments Ltd meets its legal obligations.
The GDPR Owner (Mike Mulrenan) is responsible for:
- Keeping the board updated about data protection responsibilities, risks and issues;
- Reviewing all data protection procedures and related policies, in line with an agreed schedule;
- Arranging data protection training and advice for the people covered by this policy;
- Handling data protection questions from staff and anyone else covered by this policy;
- Dealing with requests from individuals to see the data Linked Pensions & Investments Ltd, holds about them (also called ‘Subject Access Requests’).
- Checking and approving any contracts or agreements with third parties that may handle the company’s sensitive data.

Interpretation and Definitions

Material scope (Article 2.)

The GDPR applies to the processing of personal data wholly or partly by automated means (i.e. by computer) and to the processing other than by automated means of personal data (i.e. paper records) that form part of a filing system or are intended to form part of a filing system.

Territorial scope (Article 3.)

The GDPR will apply to all controllers that are established in the EU (European Union) who process the personal data of data subjects, in the context of that establishment. It will also apply to controllers outside of the EU that process personal data in order to offer goods and services, or monitor the behaviour of data subjects who are resident in the EU.

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions used by the company drawn from the General Data Protection Regulation (GDPR)

GDPR Article 4. Definitions

Account

Unique account created for You to access our Service or parts of our Service.

Company
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Linked Pensions & Investments Ltd, 6 Pearse Court, Pearse Street, Athlone, Co Westmeath..
For the purpose of the GDPR, the Company is the Data Controller.

Cookies
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

Device
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

Facebook Fan Page
Facebook Fan Page is a public profile named Linked Financial specifically created by the Company on the Facebook social network, accessible from https://facebook.com/linkedfinancial

Service
Service refers to the Website.

Third-Party Social Media Service
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Usage Data
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Website
Website refers to Linked Pensions & Investments Ltd, accessible from https://linkedfinancial.ie/

You
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Establishment

The main establishment of the controller in the EU will be the place in which the controller makes the main decisions as to the purpose and means of its data processing activities. The main establishment of a processor in the EU will be its administrative centre. If a controller is based outside the EU, it will have to appoint a representative in the jurisdiction in which the controller operates to act on behalf of the controller and deal with supervisory authorities.

Personal Data

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.

Special Categories of Personal Data

Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data, for the purpose of, uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Data Controller

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.

Data Subject

Any living individual who is the subject of personal data held by an organisation.

Processing

Any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Profiling

Is any form of automated processing of personal data intended to evaluate certain personal aspects relating to a natural person, or to analyse or predict that person’s performance at work, economic situation, location, health, personal preferences, reliability, or behaviour. This definition is linked to the right of the data subject to object to profiling and a right to be informed about the existence of profiling, of measures based on profiling and the envisaged effects of profiling on the individual.

Personal Data Breach

A breach of security leading to the accidental, or unlawful, destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed. There is an obligation on the controller to report personal data breaches to the supervisory authority and where the breach is likely to adversely affect the personal data or privacy of the data subject.

Data Subject Consent

Any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data.

The GDPR and Children

A child is defined currently, as being under the age of sixteen, but member states may consider lowering the legal age of consent to thirteen. The processing of personal data of a child is only lawful if parental or custodian consent has been obtained. The controller shall make reasonable efforts to verify in such cases that consent is given or authorised by the holder of parental responsibility over the child.

Third-Party

A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

Third Party Social Media Service
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

Filing System

Any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised or dispersed on a functional or geographical basis.

Related Documentation

An Adequacy Decision: Please see

http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Contacts

GDPR Owner – Mr Mike Mulrenan, Managing Partner

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 0906 417024 or email us at office@linkedfinancial.ie or write to us at Linked Pensions & Investments Ltd, 6 Pearse Court, Pearse Street, Athlone, Co Westmeath.

Privacy policy statement changes

Linked Pensions & Investments Ltd may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

Cookie	Duration	Description
__cfduid	1 month	The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.
ARRAffinity		This cookie is set by websites that run on Windows Azure cloud platform. The cookie is used to affinitize a client to an instance of an Azure Web App.
cookielawinfo-checbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-advertisement	1 year	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Advertisement".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
sxa_site		This cookie is used to identify the webiste visitor's session state across page requests on server.
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Cookie	Duration	Description
bcookie	2 years	This cookie is set by linkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page.
lang	session	This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.
lidc	1 day	This cookie is set by LinkedIn and used for routing.

Cookie	Duration	Description
_ga	2 years	This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site's analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
_gat_UA-194227010-1	1 minute	This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.
_gid	1 day	This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visted in an anonymous form.
_hjFirstSeen	30 minutes	This is set by Hotjar to identify a new user’s first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by Recording filters to identify new user sessions.

Cookie	Duration	Description
_fbp	3 months	This cookie is set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.
bscookie	2 years	This cookie is a browser ID cookie set by Linked share Buttons and ad tags.
fr	3 months	The cookie is set by Facebook to show relevant advertisments to the users and measure and improve the advertisements. The cookie also tracks the behavior of the user across the web on sites that have Facebook pixel or Facebook social plugin.
VISITOR_INFO1_LIVE	5 months 27 days	This cookie is set by Youtube. Used to track the information of the embedded YouTube videos on a website.

Cookie	Duration	Description
___utmvaKPuacYwB		No description
___utmvbKPuacYwB		No description
___utmvmKPuacYwB		No description
_hjAbsoluteSessionInProgress	30 minutes	No description
_hjid	1 year	This cookie is set by Hotjar. This cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the random user ID, unique to that site on the browser. This ensures that behavior in subsequent visits to the same site will be attributed to the same user ID.
_hjIncludedInPageviewSample	2 minutes	No description
_hjIncludedInSessionSample	2 minutes	No description
AnalyticsSyncHistory	1 month	No description
ARRAffinitySameSite		No description
CONSENT	16 years 7 months 25 days 15 hours	No description
incap_ses_340_1351791		No description
UserMatchHistory	1 month	Linkedin - Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor's preferences.
visid_incap_1351791	1 year	No description

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