privacy policy

Privacy Notice

Privacy Notice

Fusion Financial Services Limited t/a Fusion Insurance is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights.

For the purposes of the GDPR, the data controller is:

Fusion Financial Services Limited t/a Fusion Insurance.

27 Swords Plaza, The Mall, Swords, Co. Dublin K67PX53

015331820

info@fusioninsurance.ie

When we refer to we/us, we mean Fusion Financial Services Limited t/a Fusion Insurance

Please read this Privacy Notice carefully as this sets out the basis on which any personal data, we collect from you, or that you provide to us, will be processed by us.

Who are we?

Fusion Financial Services Limited t/a Fusion Insurance is a family run insurance broker in Swords, Co. Dublin. Founded in 2013, we have established relationships with insurers and clients alike and strive to provide top quality service and value for money. We hold a range of agencies with insurers for all manner of insurance products and aim to get the best coverage possible for the most competitive rate available in a timely manner. Our expertly skilled staff are dedicated to providing quality advice and service to our clients.

Our GDPR Owner can be contacted directly here:

Laura Martin

laura@fusioninsurance.ie

015331820

How do we collect your information and what information do we collect?

The personal information we collect varies depending upon the nature of our services. We will endeavour to provide you with an overview of those categories of personal data our organisation collects and our purpose for using that data.

Our organisation collects personal data in the following ways, if you:

request a service from us; any form of insurance quote or advice
register with or use any of our websites or online applications; collect contact info including name/telephone/email and insurance query
use our website/apps and it installs cookies or other tracking technologies onto your device.
engage with us on social media; Facebook, Instagram, Linkedin, Twitter
contact us with a complaint or query;
apply for a position with us;

What information do we collect?

The information we collect about you includes the following:

Data subject details – name, address and eircode (proof of address and ID in some cases), other contact details (e.g. email and telephone details), gender, marital status, family details, date and place of birth, employment role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history, relationship to the policyholder, insured, beneficiary or claimant.
Identification details – identification numbers issued by government bodies or agencies (e.g. PPSN, passport number, tax identification number, driver’s license number and proof of same in some cases).
Financial details – payment card number, bank account number and account details, details of your credit history and bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details
Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office.
Insured risk – information about the insured risk, which contains personal data and may include, only to the extent relevant to the risk being insured:
Health – current or former physical or mental medical conditions, health status, injury or disability information, medical procedures performed, relevant personal habits (e.g. smoking or consumption of alcohol), prescription information, medical history including special categories of information, for example information about your personal characteristics (biometric information) or disability information ;
Criminal records – criminal convictions, including driving offences; and
Personal sensitive data – trade union membership.
Policy details – details about quotes and policies obtained by data subjects.
Credit and anti-fraud data – credit history, information about fraud convictions, and allegations of crimes and sanctions details received from various anti-fraud and sanctions databases, or regulators or law enforcement agencies.
Claims – information about current and previous claims, which may include health data, criminal records data and personal sensitive data.
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, PAO

Marketing data – where legitimate interest has been identified or if the individual has consented to receive marketing of our products and services and other companies’ products and services that may interest you.

Social media information (e.g., likes and posts) with our social media presence; this includes; LinkedIn, Twitter, Facebook, Instagram

Website usage – details of your visits to our websites and information collected through cookies and other tracking technologies, including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.

Fusion Insurance collect and receive personal data from various sources, including (depending on the service provided):

Data subjects and their family members, online or by telephone, or in written correspondence

Data subjects’ employers or trade or professional associations of which they are a member

In the event of a claim, third parties including the other party to the claim (claimant/defendant), witnesses, experts (including medical experts), loss adjusters, lawyers and claims handlers

Other insurance market participants, such as insurers, reinsurers and other intermediaries

Credit reference agencies

Anti-fraud databases and other third party databases, including sanctions lists

Government agencies, such as vehicle registration authorities and tax authorities

Claim forms

Open electoral registers and other publicly available information

Business information and research tools

Third parties who introduce business to us and;

Other people’s data: As well as collecting personal information about you, Fusion Insurance may also use personal information about other people, for example, family members you wish to insure on a policy including name, address, date of birth, employment information, driving history, criminal/medical history and their relationship to the policyholder.

Note: If you are providing information about another person Fusion Insurance expect you to show them this Privacy Notice and ensure that they have given you permission to provide this information to us so that a quote can be provided. If they have any concerns please ask them to contact ‘The GDPR Owner’ as per contact details above.

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.

Information we automatically collect.

We sometimes automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, "cookies" and web beacons. Other cookies such as functional cookies, marketing cookies and analytical cookies will only be used with your expressed consent. Further information about our use of cookies can be found in our Cookie Notice at the footer of our web page.

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 quotes/advice

Performing services for our clients and prospective clients – obtaining quotes/policies
Statutory and other regulatory requirements – we are required to carry out various obligations which can include:

AML/Sanction checking

Knowing your customer “Fact Find”

Adherence to the Consumer Protection Code

Communicate and marketing to you – written letter/email/phone/text/WhatsApp/social media messenger
Process claims – we will take details on any incidents from you or a Third Party and send to your insurance company to process.
To contact you if required or to respond to any communications that you might send to us.
To administer our site including data analysis, testing, research, statistical and survey purposes.
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.
Arranging premium finance agreements – Close Brothers Premium Finance or Premium Credit
Provide professional services and notify you of any changes to our service.
10 Handling complaints

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.

How we share your data

When required, 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 (data processors) with information that is necessary for them to perform the services. We will take measures to protect your information, such as putting in place Standard Contractual Clauses and confidentiality agreements.

Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters, reinsurers, and loss adjuster.. You can refer to their privacy statements on their website for more information about their privacy practices.
Vetting and risk management agencies such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies, where necessary to prevent and detect fraud in the insurance industry and take steps to assess the risk in relation to prospective or existing insurance policies and/or the services.
Legal advisers, loss adjusters, and claims investigators, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature;
Medical professionals, e.g., where you provide health information in connection with a claim against your insurance policy; or when we are providing a quote for insurance.
EU Law enforcement bodies, when required to do so by law and/or regulation, or another legal request.
Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity;
Third-party processors: We outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT service providers who manage our IT and back-office systems and telecommunications networks, and accounting and payroll providers, CRM providers. These processing operations remain under our control and we have data processing agreements in place with all our third party processors to ensure all processing is carried out in accordance with our security standards and the GDPR.
Internal and external auditors where necessary for the conduct of company audits or to investigate a complaint or security threat.

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 insurers 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.

We do not sell, rent or trade our mailing lists, phone numbers or email addresses.

Security

Fusion Financial Services Limited intends 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. The personal data you share with us on our website is protected by an SSL certificate. We use Worldnet’s secure online payment services. Worldnet’s SSL certificate and Payment Card Industry Data Security Standards (PCI DSS) ensure the highest level of security. We used a cloud based computer system with numerous layers of security including Multi Factor Authentication.

Retention

Fusion Financial Services Limited t/a Fusion Insurance shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary. The retention period for each category of personal data will be set out in our Retention Schedule. The Retention Schedule has been governed by our regulatory body The Central Bank of Ireland and our internal governance. Once we no longer need your personal data, we will dispose of it securely.

For general brokers only; liability insurance

If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person, who is able to provide it concerning:

the existence of the insurance contract,
who the insurer is,
the terms of the contract, and
whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.

Data Subjects Rights:

Fusion Insurance will facilitate your rights in line with our data protection policy and the Subject Access

Request Procedure. This is available on request.

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. (The erasure of such data will be dependent on our other legal obligations, and whether the data is subject of legal privilege).
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.
Right to make a complaint: if we refuse your request under rights of access, we will provide you with a reason as to why.

All 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.

Complaints

If you wish to make a complaint about how Fusion Financial Services Limited t /a Fusion Insurance are processing your personal data or how your complaint has been handled, you have the right to lodge a complaint with our GDPR Owner

You may also lodge a complaint with the Data Protection Commission (DPC) in Ireland, whose details are:

Data Protection Commission
21 Fitzwilliam Square South,
Dublin 2.
D02RD28
Web: www.dataprotection.ie
Email: info@dataprotection.ie

See website for updated contact details to reach the appropriate section within the DPC.

Failure to provide further information.

If we are collecting your data for a contract and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.

When you fail to provide us with information we require to fulfil our obligations to you, we may be unable to offer our services to you.

Profiling – automatic decision making.

An automated decision is when we input your personal data into a computer programme and this programme analyses your personal data to provide us with a result. There is no human involvement in the decision-making. An example of this is where we input your details into an insurers rating engine that calculates their premium based on the information provided. If a decision is taken by automated means, you have the right to object to this and ask us to reconsider the service you have asked us to provide.

Special Categories of personal data

Special categories of 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, either we will 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,
a policy of health insurance or health related insurance
an occupational pension, a retirement annuity contract or any other pension arrangement
the mortgaging of a property

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 015331820 or email info@fusioninsurance.ie

Privacy notice/ statement changes

When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be effective from the point at which they are posted. We would encourage you to review our Privacy Notice so that you are aware of updates.

This privacy policy was last reviewed in October 2022