Empowered Money
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Privacy Policy

This policy explains how Empowered Money collects, uses, shares and protects your personal data when you use this website, book a consultation, request a quote, or become a client. We process personal data in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and the Data Protection Act 2018.

Who we are

Empowered Money Management Limited, trading as Empowered Money, is the data controller responsible for your personal data. Our office is at Unit 3, Dargle Centre, Castle Street, Bray, A98 A061, Co. Wicklow, Ireland. We are regulated by the Central Bank of Ireland.

You can contact us about this policy, or to exercise any of your rights, at info@empoweredmoney.ie or on 087 148 9171. We have not appointed a Data Protection Officer, as we are not required to do so under Article 37 of the GDPR.

What we collect

You can read most of this website without giving us anything. Where you contact us, use one of our tools, or become a client, we collect:

  • Identity and contact details — your name, email address, phone number and anything else you choose to tell us.
  • Financial information — the details we need in order to advise you, including your income, assets, liabilities, existing pensions and policies, family circumstances and goals.
  • Identity verification information — the documents and identifiers we are required to obtain before acting for you.
  • Health information — where you ask us to quote for protection cover. See below.
  • Website usage information — collected automatically, such as pages viewed, device and browser type, and an approximate location derived from your IP address.

Health information

Smoker status can reveal something about your health, so the GDPR treats it as a special category of personal data. We ask for it only because insurers price life, serious illness and income protection cover on that basis, and we cannot return an accurate quote without it. We rely on your explicit consent under Article 9(2)(a) of the GDPR, given when you submit the quote form, and we use it only to obtain and explain your quotes.

How we use your data, and our legal bases

  • Responding to enquiries, callbacks and quote requests — taking steps at your request before entering into a contract (Article 6(1)(b)), and our legitimate interests in running our practice (Article 6(1)(f)).
  • Providing financial advice and arranging products — performance of our contract with you (Article 6(1)(b)).
  • Meeting our regulatory obligations — compliance with a legal obligation (Article 6(1)(c)) under the Central Bank of Ireland’s Consumer Protection Code and the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended), which requires us to verify your identity and keep records of the advice we give.
  • Obtaining protection quotes — your explicit consent for the health element (Article 9(2)(a)), and Article 6(1)(b) for the rest.
  • Marketing — your consent (Article 6(1)(a)), which you can withdraw at any time.
  • Website analytics and error tracking — our legitimate interests (Article 6(1)(f)) in understanding how the site is used and fixing what is broken.

Who we share your data with

We do not sell your personal data, and we do not share it for anyone else’s marketing. We share it only with providers who help us run the practice. Each of them may use your personal data solely for the purpose we engaged them for and on our instructions, and each is required to keep it secure:

  • our booking and scheduling provider;
  • our financial planning and client-management systems;
  • the quotation service that prices protection cover;
  • our website hosting, analytics and error-tracking providers;
  • product providers, where you decide to take out a pension, investment or protection product.

We will name the specific providers behind any of these on request. We may also disclose personal data where required by law, by a court, or by the Central Bank of Ireland or another regulatory or law-enforcement body.

International transfers

Most of your personal data stays within the European Economic Area. Some of our providers operate from the United Kingdom, which the European Commission has found to offer an adequate level of protection, and some from the United States. Where personal data goes to a country without an adequacy decision, that transfer is protected by appropriate safeguards — the provider’s EU-US Data Privacy Framework certification and/or the European Commission’s Standard Contractual Clauses. Ask us if you would like details of the safeguards that apply to a particular transfer.

Cookies and analytics

We set no cookies on this website and run no advertising, remarketing or profiling tags. Our analytics are configured so that nothing is stored on your device and you cannot be recognised between visits. Our Cookie & Tracking Policy sets this out in full.

How long we keep your data

We keep personal data only for as long as we need it, including to meet legal, regulatory and tax requirements:

  • Enquiries that do not become client relationships — retained for up to 24 months.
  • Analytics data — retained for up to 12 months.
  • Client records — retained for at least six years after our relationship with you ends, as required by the Central Bank of Ireland’s Consumer Protection Code.
  • Anti-money-laundering records — retained for at least five years from the date we cease to provide services to you, as required by section 55 of the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended).

Security

We use appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction, and we limit access to those who need it to do their job. We will never sell your personal data.

Your rights

Under the GDPR and the Data Protection Act 2018 you have the right to:

  • be informed about how we use your data;
  • access a copy of the personal data we hold about you;
  • rectification of inaccurate or incomplete data;
  • erasure in certain circumstances;
  • restrict processing in certain circumstances;
  • data portability;
  • object to processing based on our legitimate interests, and to direct marketing at any time;
  • withdraw consent at any time where we rely on it, without affecting processing already carried out.

To exercise any of these, contact us using the details above. Some rights are subject to conditions and exceptions — in particular, we cannot erase records we are required by the Central Bank of Ireland or anti-money-laundering law to retain.

Complaints

If you are unhappy with how we handle your personal data you can lodge a complaint with the Data Protection Commission, 6 Pembroke Row, Dublin 2, D02 X963 — www.dataprotection.ie. We would appreciate the chance to put things right first, so please consider contacting us before you do.

Changes to this policy

We keep this policy under regular review and publish any updates on this page.

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