ARF Ireland is committed to respecting and protecting your privacy and would
like you to feel safe when giving us your details. To provide you with relevant information,
respond to your requests we sometimes request that you provide us with information
about yourself. Guardian Wealth Ltd will identify itself on Web pages and in
This Privacy Notice will inform you of the information we gather and how it is used.
Guardian Wealth Ltd t/a Guardian Wealth Ltd, t/a RDA Accountants, t/a ARF Ireland
maintains the same privacy practices with respect to data that is collected off-line and this
notice also covers those methods of data collection and use. Guardian Wealth Ltd complies
with EU General Data Protection Directive – GDPR for the collection, use, and retention of
personal information from European Union member countries.
Why do we need to collect and store personal data?
In order for us to provide you with the services that we are authorized to advise you in
relation to a wide range of Protection, Pension and Investment Products.
We research the products on your behalf with the Product Producers (Insurers) with
whom we hold agency appointments.
We will identify and select suitable products from the Product Producers (Insurers) and
on receipt of your instructions we will transmit orders on your behalf to one or more
Product Producers Insurers), a list of which is available on request. This process applies
to all classes of insurance policies.
We need to collect personal data to provide the service requested. In any event, 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.
In terms of being contacted for marketing purposes we would contact you for additional
Why we are processing your data? Our legal basis
Our reason and purpose for processing your personal data is:
• We have your consent
• We need to process your data to complete the performance of a contract
• Where you, the data subject is a party. The firm processes data without consent
in order to fulfil contractual obligations [such as arranging cover with product
providers/insurers with whom we hold letters of appointment].
• Legal obligation that needs to meet
• Protect the vital interests of the data subject, including the protection of rights
• Processing that is in the public interest
• Necessary for the legitimate interests of the data controller or third party, unless
the processing is overridden by the vital interests, including rights and freedoms
• National law
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
• protect the vital interests of the data subject, including the protection of rights
• necessary for the legitimate activities with appropriate safeguards;
What other information we gather
In general, you may visit this website without identifying yourself or revealing any personal
information from your visit to customise and improve your experience on our website.
This website may collect certain information from your visit, including the date and time
of your access, the pages you have accessed, the name of the Internet Service Provider
and the Internet Protocol (IP) address by which you are accessing the Internet, and the
Internet address from which you linked to our site, if applicable. We use this information
to better understand how our website is being used so that we can improve its
Some portions of this website may request that you give us information about yourself,
from which we are able to identify you, such as your name, email or other address. Some
of the ways in which we may collect information from you are: Please refer to our cookies
Use of the information we gather
When we collect information about you, we intend to tell you why we are asking for the
information and what we intend to do with it. You will have the option of not providing the
information, in which case you may still be able to access other parts of this website,
although you may not be able to access certain services. In certain areas of our website,
we may, where appropriate, enable you to ‘opt-in’ to certain uses of your information e.g.
personal data and direct marketing. Data will not be held for longer than is necessary,
credit card transactions will be held for the duration of the transaction and general client
details will be held while you are a customer.
The information we collect about you or your computer is used to run the website, respond
to your requests or process any transactions you have requested. It may also be used to
verify your identity, send you information or contact you in relation to a product or service
that you are using or that we believe may be of interest to you after you have chosen to
Sharing information with third parties
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.
The information we collect may be used, store and processed in the EU, EEA, UK, United
States, Switzerland or in any other country in which Guardian Wealth Ltd does business.
By providing the information via the website, you are consenting to the transfer of the
information outside of your country to any country (including countries which may not
have adequate levels of protection).
Guardian Wealth Ltd t/a Guardian Wealth Ltd, t/a RDA Accountants, t/a ARF Ireland may
disclose information it has collected about you on the website if required to do so by law
or when necessary to protect the rights of Guardian Wealth Ltd or its employees.
Guardian Wealth Ltd t/a Guardian Wealth, t/a RDA Accountants, t/a ARF Ireland 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 online, including the use of encryption when collecting or
transferring sensitive data such as credit card information.
However, you should always take into consideration that the internet is an open forum
and that data may flow across networks with little or no security measures, and therefore
such information may be accessed by people other than those you intended to access it.
How to update and/or amend the personal information you have provided
You are entitled to know whether we hold information about you and, if we do (subject to
certain limitations), to have access to that information and have it corrected if it is
inaccurate or out of date. To exercise your Right of Access or to update your details under
your Right of Rectification or Erasure please email your request to the contact address
below with proof of identity.
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 organization.
• 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
• Right to judicial review: in the event that Guardian Wealth Ltd refuses your
request under rights of access, we will provide you with a reason as to why.
You have the right to complain as outlined in clause 3.6 below.
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.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were
obtained. Guardian Wealth Ltd t/a Guardian Wealth Ltd, t/a RDA Accountants, t/a ARF
Ireland will process personal data in accordance with our retention schedule. This retention
schedule is governed by regulatory & legislative requirements.
If we are relying on your consent to process your data, you can withdraw this at any time
– this does not affect the lawfulness of processing based on your consent before its
In the event that you wish to make a complaint about how your personal data is being
processed by Guardian Wealth Ltd, or how your complaint has been handled, you have
the right to lodge a complaint directly with the Michael Coburn and the Office of the Data
If you have any questions or comments about our privacy notice or practices, please
contact us. Guardian Wealth Ltd may modify or update this privacy notice from time to
time at any time without prior notice. You can check the “Version” date below to see when
the notice was last changed. We encourage you to check this notice often so that you can
continue to be aware of how we are protecting your personal information. Your continued
use of the website constitutes your consent to the contents of this privacy notice, as it
may be modified from time to time.
Contact: Michael Coburn
Version: May 2018