PRIVACY STATEMENT
Introduction
CMOR Financial Services are 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 CMOR Financial Services Ltd in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
CMOR Financial Services Ltd
Contact details:
CMOR Financial Services Ltd
Building G
West Cork Technology Park
Clonakilty
Co. Cork.
Tel: 023-8821957
Email: reception@cmorfinance.com
When we refer to ‘we’ it is CMOR Financial Services Ltd.
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?
CMOR Financial Service Ltd is a financial brokerage based in Clonakilty in West Cork. We service clients across Cork County for mortgages, protection, investment and pensions.
Our GDPR owner and data protection representatives can be contacted directly here:
The Principal, CMOR Financial Services Ltd, Building G, West Cork Technology Park, Clonakilty Cork. Tel. 023-8821957 or email reception@cmorfinance.com
How will CMOR Financial Services Ltd use the personal data it collects about me?
CMOR Financial Services Ltd 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 personal data safe.
Personal information you give to us:
Client
When you become a client of CMOR Financial Services Ltd, we collect information about you including (but not limited to) your name, your employer’s name, your work address and your email address. We may also collect your personal email address, a personal mailing address, and a mobile phone number. We will collect relevant information only to the product you wish us to provide for you.
We process your personal information for proposing application for the service you look for us to provide to you, to relevant information that may be of interest to you, to inform you of investor-related events we may hold from time to time, to keep you up-to-date with any relevant economic or tax changes that we feel may be important to you.
Website
CMOR Financial Service Ltd offers a great deal of content for our clients. In addition to producing original content, CMOR Financial Services Ltd provides links into some of our third party providers.
This means you may find yourself on the CMOR Financial Services Ltd website or reading an email from CMOR Financial Services Ltd and we will offer you a link to another organization’s website where you will find content information that we find relevant and useful to you.
At these times, you will be leaving the CMOR Financial Services Ltd website. CMOR Financial Services Ltd is not responsible or liable for content provided by these third-party websites or personal information they may happen to gather from you.
Your correspondence with CMOR Financial Services Ltd
If you correspond with us by email, the postal service, or other form of communication, we may retain such correspondence and the information contained in it and use it to respond to your inquiry; to notify you of our services; or to keep a record of your complaint. As always, if you wish to have CMOR Financial Services Ltd “erase” your personal information or otherwise refrain from communicating with you, please contact us at reception@cmorfinance.com.
Note: if you ask CMOR Financial Services Ltd not to contact you by email at a certain email address, CMOR Financial Services Ltd will note this on our records to comply with your no-contact request.
Purposes for processing your data
As explained above, CMOR Financial Services Ltd processes your data to provide you with the services you have requested or purchased from us, including arranging mortgages, protection, investments or pensions. We use this information to refine our services to better tailor them to your needs and to communicate with you about other services CMOR Financial Services Ltd offers that may assist you in your finances and the protection of you and your family.
What happens if you don’t give us your data
You can still avail of the services of CMOR Financial Services ltd without giving us your personal data.
Some personal information is necessary so that the CMOR Financial Services Ltd can supply you with the services you have purchased or requested, and to authenticate you so that we know it is you and not someone else.
You will not in this circumstance be given any advice in relation the product. You must be aware that the unit price can go down as well as up. You must wish to proceed with the product without taking any advice.
You may opt-out of receiving marketing communication at any time.
Our lawful reason for processing your applications is contractual.
Our lawful reason for direct marketing is legitimate interest. Legitimate interest means the interest of our organisation in conducting and managing our organisation to enable us to give you the best.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
In any event, CMOR Financial Service Ltd is committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.
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
- we will obtain your explicit consent
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to CMOR Financial Services Ltd 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 fulfil the service they provide on your behalf. When they no longer need your data to fill this service, they will dispose of the details in line with CMOR Financial Services Ltd 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:
- Product Providers
- IT providers
- Legal advisers
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:
CMOR Financial Services Ltd facilitates 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 - if CMOR Financial Services Ltd refuses your request under rights of access, we will provide you with a reason as to why.
All 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 it was obtained. CMOR Financial Services Ltd will process personal data in accordance with our retention schedule. This retention schedule has been governed by our internal governance.
Complaints
If you wish to make a complaint about how your personal data is being processed by CMOR Financial Services Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and CMOR Financial Services Ltd data protection representatives GDPR Owner.
Security of your data
To help protect the privacy of data and personally identifiable information you transmit through use of our site, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis.
We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We will take appropriate disciplinary measures to enforce our employees' privacy responsibilities.
Failure to provide further information
If we are collecting your personal data and the necessary contact details are not included this could exclude you from receiving valuable information from us.
Profiling – automatic decision making.
We do not carry out any profiling.
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
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us.
Privacy statement changes
CMOR Financial Services may change this Privacy Statement 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 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 May 2018