Privacy
Spartan Financial Solutions
56 Cathedral Court, Ennis, Co Clare
DPO contact details; Geoff O’Sullivan geoff@spartanwealth.ie 065-6797988
What We Do
Spartan Financial Solutions Ltd is a wholly owned Irish Company, established in October 2007. We specialise in the provision of all classes of life insurance, investments, pensions, savings and financial planning.
Privacy Notice
Spartan Financial Solutions 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. Spartan Financial Solutions will identify itself on Web pages and in correspondence.
This Privacy Notice will inform you of the information we gather and how it is used. Spartan Financial Solutions 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. Spartan Financial Solutions 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 authorised to advise you in relation to a wide range of Insurance, Protection, Pension and Investment Products.
We research the products on your behalf with the Product Producers with whom we hold appointments.
We will identify and select suitable products from the Product Producers and on receipt of your instructions we will transmit orders on your behalf to one or more Product Producers, a list of which is available on request. This process applies to all classes of life insurance, investments, pensions, savings and financial planning.
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 consent.
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
- use our website/apps and it installs cookies or other tracking technologies onto your device.
- contact us with a complaint or query;
- apply for a position with us;
- protect the vital interests of the data subject, including the protection of rights and freedoms
- 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
What information do we collect?
The information we collect about you includes the following:
| 1. | Contact and Identifying information, e.g., name, address, contact details; email, mobile, landline |
| 2. | Unique identifiers e.g.
· PPS number – the reason why we collect your PPS number is to comply with anti money laundering customer due diligence requirements. · pension scheme reference number- the reason why we collect this is to allocate contributions and manage your pension records. · insurance policy numbers, the reason why we collect this is to manage your insurance policy records on your behalf. |
| 3. | Demographic details, age, gender, marital status, lifestyle, and insurance requirements; date of birth, dependents, photo ID, as well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy. E.g., your children/spouse. This information will be noted in our factfind and information gathering notes. |
| 4. | Family and Beneficiary Data, e.g., dependants, next of kin or nominated beneficiaries, Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax Advisor/Accountant. |
| 5. | Employment information e.g., role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history;
This information is necessary for our Fact Find with our clients. |
| 6. | Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office. |
| 7. | Health information such as information about your health status, medical records and medical assessment outcomes; We collect medical information relating to personal habits (e.g., smoking and consumption of alcohol), medical history. We may also process certain special categories of information, for example information about your personal characteristics (biometric information) or disability information.This information is gathered in respect of Life cover effected on your behalf |
| 8. | Pensions and Insurance Benefits information such as current benefits, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions. |
| 9. | Financial details e.g., bank account details, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details. |
| 10. | Claims Data (From you and any relevant third parties). |
| 11. | Marketing preferences: we will only send you direct marketing if you explicitly consent. We will gather your explicit consent for the method of communication for marketing purposes. |
| 12. | Online information: e.g., information about your visits to our websites and we would refer you to our cookies policy on our website. |
| 13. | Special Categories of personal data are sensitive in relation to your fundamental rights and freedoms and therefore require specific protection when processed as these could create significant risks to the rights and freedoms of individuals.
If we collect any special categories of personal data, such as health add any further special category here if needed data, we will either obtain your explicit consent or we will adhere to the Data Protection Act 2018. This Act allows us to process special categories of personal data for insurance and pension purposes. We will ensure we have suitable and specific measures in place to safeguard the rights and freedoms of you and the processing of your data. These measures relate to the below: – a policy of insurance or life assurance, – an occupational pension, a retirement annuity contract or any other pension arrangement |
| 14. | Searches that we undertake in relation to sanctions, money laundering and credit checks. We are obliged to conduct PEP/AML/Sanctions search and the firm is using Wealthtrack to conduct PEP checks at the onboarding of new customers in accordance with AML requirements under the CJA 2010. Financial Sanction screening is available as part of the Wealthtrack system functionality. A record of searches for Politically Exposed Persons and Financial Sanctions checks are recorded on the client checklists. |
| 15. | Calculators on our website. We use this data to perform calculations to prepare quotations for life insurance based on the information that we gather on application forms and factfinds. |
When our organisation collects sensitive personal data as defined within the GDPR we will ensure that we require this information, and we have your explicit consent and/or authorisation prior to our collection. Please see the further information contained in this Privacy Notice that outlines special categories of personal data.
How do we use your personal data?
Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your request for insurance, investment, protection, pension products, financial advice, quotes.
| 1. | Performing services for our clients and prospective clients – when you require insurance/investment products, we use your data to enable us to provide the required product |
| 2. | Statutory and other regulatory requirements – we are required to carry out various obligations which include:
· AML/Sanction checking · Knowing your customer “Fact Find” · Adherence to the requirements and obligations under the Consumer Protection Code 2025 |
| 3. | Communicate and marketing to you – updates on performance of products that you have with us etc. |
| 4. | Process claims – where relevant |
| 5. | To contact you if required or to respond to any communications that you might send to us. |
| 7. | Carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request. |
| 8. | Arranging premium finance agreements with the providers that we use to place business. |
| 10 | Handling complaints |
| 11 | To notify you about changes to our service |
Legal Basis
We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to collect and use your personal data.
| Performance of a contract | When we enter a contract with you, we will collect and use your personal data to enable us to fulfil that service. |
| Legal obligation | The use of some of your personal data is necessary for us to meet our legal obligations e.g., pension contributions for Revenue Certificates, Regulatory purposes to the Central Bank. |
| Consent | Sometimes we may rely on consent as a legal basis for processing your information. For example, we rely on consent to collect and use personal data for any criminal convictions or alleged offences. This is used when we need to assess risk relating to an insurance policy for you. We share this information with other third parties where it is necessary to manage these services provided to you – these services include insurance underwriters, reinsurer and other insurance providers.
We may also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely. We will also ensure that we use clear and plain language and if you give us your consent you can withdraw this easily at any time. Sometimes if you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect. |
| Legitimate interests | Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws. |
If you require further information on any of the above basis for processing your data, we can provide you with further details.
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 performance.
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 policy.
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 an product or service that you are using or that we believe may be of interest to you after you have chosen to ‘Opt in’.
Transferring personal data outside of Ireland
Where we transfer personal data to a country outside of the EEA (referred to in the GDPR as ‘third country,’) we will ensure it is done lawfully, i.e. there is an appropriate “level of protection for the fundamental rights of the data subjects”. We will therefore ensure that either the EU Commission has granted an adequacy decision in respect of the third country, or appropriate specified safeguards have been put in place, (e.g., Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs)).
We share data with providers located in the UK. The EU Commission adopted adequacy decisions for transfers of personal data to the UK. This means that the EU accepts that the UK data protection regime is substantially equivalent to the EU regime and allows personal data to be transferred freely from the EEA to the UK. Therefore, the UK is not deemed a third country.
Data security
Spartan Financial Solutions 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 all information that we collect, 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 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 Organisation Name 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. Spartan Financial Solutions will process personal data in accordance with our retention schedule. This retention schedule is governed by regulatory & legislative requirements.
Withdraw consent
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 withdrawal.
Complaints
Contacting Us
If you have any questions or comments about our privacy notice or practices, please contact us. Spartan Financial Solutions 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: Geoff O’Sullivan
Email: geoff@spartanwealth.ie
Version: June 2026
