Introduction

We are fully committed to protecting and respecting your privacy. We wish to be transparent on how we process your personal data and demonstrate that we comply with the EU General Data Protection Regulation (GDPR) in relation to collection, use and retention of your personal data and ensuring you understand your rights as a client.  

It is the intention of this privacy statement to explain our information handling practices in relation to the information we collect about you and how it is used.

For the purposes of the GDPR the data controller is:

• IPM (Insurances) Ltd. t/a IPM Draper and IPM (Financial Services) Ltd. t/a IPM Draper Financial Brokers
• Ph +353 (0) 71 9143742 email enquiries@ipminsurances.com
• When we refer to ‘we’ it is IPM (Insurances) Ltd. and IPM (Financial Services) Ltd.

Please take time to read this Statement carefully as it sets out the basis on which any personal data, we collect from you, or that you provide to us, will be processed by us.

1. Who We Are

IPM Draper Insurance and Financial Brokers comprise of the following two entities dealing with general insurance and life, pensions, savings and investments.

IPM (Insurances) Ltd. t/an IPM Draper is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Union (Insurance Distribution) Regulations 2018; and as an Investment Intermediary authorised under the Investment Intermediaries Act 1995.

IPM (Financial Services) Ltd t/a IPM Draper Financial Brokers is regulated by the Central Bank of Ireland as an investment intermediary under the Investment Intermediaries Act, 1995 (as amended) (IIA) and as an insurance intermediary under the European Union (Insurance Distribution) Regulations 2018 (IDR).

IPM (Financial Services) Ltd is also regulated by the Central Bank of Ireland as a Mortgage Credit Intermediary/Mortgage Intermediary  under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016 (CMCAR) and under the Consumer Credit Act, 1995 (as amended) (CCA)         

We are Members of Brokers Ireland

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to general insurance, life, pensions, savings and investments.

We operate on the basis of fair analysis of the market and we pay particular attention to identifying and recommending the product/s that best fulfil the specific needs of our customers.

Accordingly, the number of contracts and providers we share your data with must be sufficiently large to enable us as an intermediary acting on the customer’s behalf, to recommend a product that would be adequate to meet a client’s needs having regard to the client’s fact-find and product suitability assessment.

The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operating in the market for a particular product or service and their relative importance in and share of that market.  The extent of fair analysis must be such that could reasonably be expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search.  

Our Data Protection representative can be contacted directly here 

• Adrian McHale
• Email address adrian@drapergroup.ie
• Phone number +353 (0) 71 9143742

2. How we collect your data

Through client fact-finds and general consultation we collect personal data in relation to our clients. In line with our terms of business we provide intermediary services on a number of products which include, general insurance, life cover, serious illness cover, savings, investments and pensions. Personal data including Name, Address, Date of birth, Contact Details, Marital Status, Occupation, Employment Details, Income, Expenditure, Existing Financial Provisions, Medical Condition and Health Status, knowledge of Investments and Financial Objectives and Priorities are collected.

3. Purpose and legal Basis for processing your data

The primary reason for collecting your personal data is to provide you with relevant information, respond to your requests and to assist us to advise you on the most suitable product to best meet your requirements in the areas of service where we act as intermediary.

Your data is used for risk evaluation and product suitability purely for the purpose of fulfilling our service to you. We will not use your data for automatic profiling or for any reason that has not been made clear, other than to comply with legal requirements and to protect our legitimate interests in so far as the law demands.

Our legal basis for collecting and processing your data is because it is necessary for the performance of the advisory services that we commit to delivering to you. Also it is necessary for the purposes of the legitimate interest that we have, as a firm that is authorised and regulated by the Central Bank of Ireland, in the proper administration and correct operation of our firm.
There may also be circumstances where the legal basis for processing your personal data is consent (where we have sought it and it has been provided to us), in which case that consent may be withdrawn at any time.

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.

We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.

4. Sharing your information with third parties

In so far as it is necessary to provide our service to you we will provide your personal information to our service providers. Any third parties that we share your data with are obliged to keep your details securely, and to use it only to fulfil the service they provide on your behalf.

In certain instances, we may make your information available to third parties with whom we have a relationship where that third party is providing services on our behalf. We will only provide those third parties with information that is necessary for them to perform the services and we take measures to protect your information. We may disclose information collected about you if required to do so by law or when necessary to protect the rights of IPM Draper Insurance and Financial Brokers or its employees.

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:

Service Providers, Insurance companies, Banks, and any other providers you agree to do business with, including statutory and regulatory bodies including, but not limited to, Financial Service and Pension Ombudsman, Data Protection Commission, Revenue Commissioners and the Law Enforcement Agencies and our Insurers.

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.

5. Retention of your Personal Data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. IPM Insurance and Financial Brokers will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body, The Central Bank of Ireland and our internal governance.

6. Data Subjects Rights

We will facilitate your rights in line with our data protection policy and the subject access request procedure. This is available on request.  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 we refuse 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.

To exercise your Right of Access or to update your details under your Right of Rectification or Erasure please email your request to us together with proof of your identity.

Cookies

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

For further information, visit allaboutcookies.org.

How do we use cookies?

IPM Draper Insurance and Financial Brokers uses cookies in a range of ways to improve your experience on our website, including:

Session Cookie:
This session cookie allows us to know you are the same person when you move from one page to the next, for both users who are logged in and also for some users who have not logged-in.

Third-Party Cookies:
We use suppliers who also set cookies on behalf of our website to provide certain features on the website and help us to review how our customers usage of the website, details of which we have included below along with links to their respective privacy policies which will detail how these suppliers use data they collect in more detail.

Google Analytics:
We use Google Analytics to determine how popular parts of our website are, to determine if you have been to the website before, and to securely and anonymously record the value of any purchases you make on our website. Google analytics sets cookies which will stay active for a number of years and identify on your computer that you have visited our website.

These cookies can be identified by their prefix of __u…. You can opt out of being tracked by Google Analytics across all websites you visit by installing a browser plugin like this one http://tools.google.com/dlpage/gaoptout?hl=en .

If you just want to find out more information about Google’s privacy policy, then please click here http://www.google.com/intl/en/analytics/privacyoverview.html.

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality – IPM Draper Insurance and Financial Brokers uses these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – IPM Draper Insurance and Financial Brokers uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. IPM Draper Insurance and Financial Brokers sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

7. Complaints

In the event that you wish to make a complaint about how your personal data is being processed, you have the right to lodge a complaint directly with the Supervisory Authority and our named data protection representatives at the contact details given in this privacy statement.

You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:

Data Protection Commission
Canal House,
Station Road,
Portarlington,
Co. Laois, R32 AP23

Phone: + 353 57 868 4800 / + 353 761 104 800

Fax: + 353 57 868 4757

Web: www.dataprotection.ie

Email: info@dataprotection.ie

8. Security of Your Personal Data

Our intent is to strictly protect the security of your personal information; honour your choice for its intended use; and carefully protect your data from loss, misuse, unauthorised access or disclosure, alteration or destruction. We have taken appropriate steps to safeguard and secure information we collect such as credit card information.

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

T: +353 (0) 71 9143742

E: enquiries@ipminsurances.com 

9. Failure to Provide Further Information

If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.

10. Privacy Statement Changes

IPM Draper Insurance and Financial Brokers may change this privacy statement from time to time. When such a change is made, we will post a revised version on our website.
Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy statement periodically so you’re aware of any changes. By using our services, you agree to this privacy statement.

This privacy statement was last reviewed in February 2021