Privacy and Cookie Policy

PRIVACY POLICY

Data Privacy policy of Fitzgerald Brennan Asset Management DAC

Fitzgerald Brennan Asset Management DAC takes privacy and the protection of personal data extremely seriously. This policy document explains how this firm collects your personal information, how it is used and how you can communicate with us about it. We have kept the information in this policy as clear as possible, however, if you require clarification or further information, please contact the firm at investor@fbam.ie

1. Who Are We
In this policy document “FBAM” “firm” “we” “our” “ours” “us” refers to Fitzgerald Brennan Asset Management DAC

2. The Information we may collect about you
FBAM may collect the following information:

  • Names
  •  Contact information including home address
  • Phone number
  • E-mail address
  • Marital status
  • Gender
  • Date of birth
  • Educational and employment details
  • Financial information
  • Copy of PPS number
  • Copy of passport and/or driving licence
  • Proof of address
  • Bank account details
  • Health information
  • Information on investment and lifestyle risk preferences
  • Health information and any vulnerabilities relating to the ability to understand and make informed investment and/or contractual decisions, with or without assistance. This has a bearing on investment suitability advice provided by the firm

 

3. How FBAM collects information about you
FBAM garners personal information and data directly from clients under the following circumstances:

  • Opening an account with us
  • Dealing with us by e-mail, phone, letter, or the website
  • Visiting and interacting with the FBAM website. Please note our website uses Cookies, for further information on this please see our Cookie policy at the end of this document.
  • Subscribe to marketing documents
  • Updating and confirming data with clients
  • Meeting directly with FBAM staff for review meetings

4. How FBAM ensures the safety of your information
FBAM is committed to ensuring that all personal information is secure. In order to prevent unauthorised disclosure or access, we have in place appropriate electronic, physical and managerial procedures, to secure and safeguard the information we collect.

5. How long do we keep your information
How long we keep your information is dependant on the nature of the information and the purpose for which it is processed. FBAM sets appropriate retention periods which meet legal and regulatory obligations. The firm holds your information whilst you are a client and for a period of time after that. We do not hold information for longer than is necessary. If the purpose for which the information was obtained has ceased and the personal information is no longer required, it will be deleted or anonymised.

6. Data Analytics
We use Google analytics to collect information about visitor behaviours on our website. Google analytics stores information about what pages you visit, how long you are on the site, how you got there and what you click on. This analytic data is collected via JavaScript tag in the pages of our site and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.

7. How FBAM utilises your information and the legal basis
We use your information to:

  • Manage your funds
  • Improve services to you
  • Understand your needs
  • Market products and services to you
  • Provide information on our services and products to you
  • Comply with the applicable laws and regulations

To lawfully use your information, we rely on one or more of the following legal bases:

  • Your consent, which you may withdraw at any time
  • Legal obligation e.g., Anti-Money Laundering, Counter Financing of Terrorism
  • Protecting the vital interests or you and/or others, in exceptional circumstances
  • FBAM’s legitimate interests

8. Providing your information to third parties
When FBAM provides services to you, we may share information with:

  • Your appointed representatives
  • Service providers who provide us with support services
  • Regulatory and statutory bodies and law enforcement authorities

9. Potentially using companies to process your information outside of the European Economic Area (EEA)
In some circumstances the firm might transfer information relating to you to a service provider outside of the EEA. If such an event were to occur, we would ensure that any transfer of information outside of the EEA is managed carefully to protect your privacy rights.

10. Personal information rights
If FBAM holds your personal information with respect to a service or product, you are entitled to certain rights. These rights allow you to exert control over the way in which your personal information is processed. For example:

UPDATING AND CORRECTING YOUR PERSONAL INFORMATION
If you believe that personal information we hold about you is out of date or inaccurate, you can seek for us to correct this information at any time.

ACCESSING YOUR PERESONAL INFORMATION
You may request from us a copy of the personal information that we hold about you.

WITHDRAWAL OF CONSENT
It is your right to with draw consent, where previously it was given. Your right to
restrict processing.

DELETION OF YOUR INFORMATION
You may request the firm to delete your personal information.

RIGHT TO DATA PORTABILITY
You may request in some cases that your personal information be transferred to
you or another entity in digital form.

RIGHT TO OBJECT.

11. How to exercise your rights
Free of charge, you may exercise any of your rights, by contacting FBAM on:

Phone (00353 1) 6788040.
E-mail: investor@fbam.ie

If you contact the firm asking about your information, we may ask that you identify yourself. This is to assist in the protection of your information. Once we have effectively verified your identity, we will respond to requests without inappropriate delay and within one month/30 calendar days or receiving the request. This time period may be extended in exceptional circumstances, however, we will inform you if this applies and the reason for the time extension.

12. Complaints about data processing
If you are concerned about how personal data is processed by us, please bring such concerns to the attention of the FBAM Compliance Department using the contact details listed in section 10 above. You have the right to complain to the Data Protection Commissioner. This can be done using the following contact details:

E-mail: info@dataprotection.ie
Phone: 057 8684800
Post: Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23, County Laois.

COOKIES POLICY

A cookie is a small piece of data sent from a website and placed on a user’s computer, while the user browses a website. Cookies can be read by the website on any future visits by a user. Cookies are useful as they allow the website to remember you on any return visit and increase the efficiency of the website. In general, cookies do not contain personal information from which you can be identified, unless you have provided such information to the website yourself.

FBAM will not attempt to personally identify visitors from their IP addresses. Cookies do not compromise the security of your computer. Visitors can use most of FBAM’s website without any loss of functionality if cookies are disabled from their web browser.

How to Disable or Manage Cookies
If you require additional information regarding the management of cookies, including disabling different types of cookies please visit http://www.aboutcookies.org

Policy last updated 06/07/2021