Privacy Policy

What Information We Collect

We only collect what's needed to provide our services properly. Nothing more. When you reach out to us or use our website, here's what we might gather:

• Your name and contact details when you fill out forms or email us
• Basic information about how you interact with our website—things like which pages you visit and how long you stay
• Technical data such as IP addresses and browser types (this helps us keep the site running smoothly)
• Any information you choose to share when discussing investment approaches or financial planning
• Communication history if we're working together on financial matters

We don't collect sensitive financial account numbers or passwords through our website. That sort of information only comes up in direct, secure conversations when absolutely necessary.

How We Use Your Information

Your data serves specific purposes. We're not in the business of hoarding information for no reason.

Legal Basis for Processing

Under GDPR, we need a lawful reason to process your data. Here's where we stand:

Contractual Necessity

When you become a client, we need certain information to fulfill our services. Can't really help you build a patient investment strategy without knowing who you are and what you're working toward.

Legitimate Interest

We have legitimate business reasons to process some data—like improving our services or preventing fraud. This doesn't override your rights, and you can object if you want.

Legal Obligation

Irish and EU financial regulations require us to maintain certain records. We don't have much choice here, but it's for everyone's protection.

Consent

Sometimes we'll ask for your explicit permission—for example, if you want to receive our occasional market insights or educational content. You can withdraw consent anytime.

Who Sees Your Information

We don't sell your data. Never have, never will. But running a financial services business means working with some trusted partners:

• Technology providers who help us maintain our website and secure communications
• Cloud storage services based in Ireland and the EU where we keep encrypted records
• Professional advisors (legal, accounting) when necessary for our business operations
• Regulatory bodies if legally required

Everyone who handles your data is contractually bound to protect it. We pick our partners carefully and make sure they meet the same standards we do.

Your Rights Under Irish and EU Law

GDPR gives you considerable control over your personal data. These aren't just theoretical rights—we actually honor them.

To exercise any of these rights, just send an email to [email protected] with your request. We'll need to verify your identity first, but then we'll handle it quickly.

How Long We Keep Your Data

We don't keep information longer than necessary. But "necessary" varies depending on what we're talking about:

Active Client Records

While working together, we maintain your information to provide continuous service. This makes sense—you wouldn't want us forgetting your investment approach halfway through.

After Relationship Ends

Irish financial regulations require us to keep certain records for seven years after a client relationship ends. After that period, we securely delete everything unless there's a specific legal reason to keep it longer.

Website Visitors

Analytics data gets anonymized or deleted after two years. Contact form submissions from people who don't become clients are removed after three years.

Marketing Communications

If you've opted in to receive updates but haven't engaged in over four years, we'll remove you from our list. Seems fair.

Security Measures

Protecting your information isn't optional. Here's what we do:

• All data transmission uses TLS encryption (that's the little padlock you see in your browser)
• Stored data is encrypted at rest using industry-standard methods
• Access to client information is strictly limited to staff who need it for their work
• Regular security audits and updates to our systems
• Secure, encrypted backups stored in EU data centers
• Staff training on data protection and privacy best practices

No system is 100% foolproof, but we take reasonable precautions seriously. If there's ever a data breach affecting your information, we'll notify you and the Data Protection Commission within 72 hours as required by law.

Cookies and Website Technology

Our website uses a few cookies—small files that help the site function properly. Nothing intrusive.

Essential Cookies

These keep the website working. Things like remembering you're logged in or maintaining security. You can't really turn these off without breaking the site.

Analytics Cookies

We use basic analytics to understand how people use our site. This helps us improve things. The data is anonymized and we don't track individuals across the web.

You can manage cookie preferences in your browser settings. Most browsers let you block or delete cookies, though some site features might not work as smoothly.

International Data Transfers

We primarily work with Irish and EU-based clients, and your data stays within the European Economic Area. If we ever need to transfer data outside the EEA, we'll use approved safeguards like Standard Contractual Clauses and only work with partners who provide adequate protection.

Changes to This Policy

We'll update this policy occasionally—usually when regulations change or we add new services. When we make significant changes, we'll let active clients know directly. The "Last updated" date at the top will always reflect the current version.

We're not in the habit of making major changes without good reason, and we'll never reduce your rights under GDPR without proper notice and justification.

Complaints and Concerns

If you're not happy with how we've handled your data, please tell us first. Most issues can be sorted out through direct conversation. Contact us at [email protected] and we'll do our best to resolve things quickly.

You also have the right to lodge a complaint with the Data Protection Commission in Ireland. Their details: