Biz Broker Ltd t/a Clarke & Conlon Insurance Brokers 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 General Data Protection Regulation in relation to not only processing your data
but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of Biz Broker
Ltd trading as Clarke & Conlon Insurance Brokers in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
Biz Broker Ltd t/a Clarke & Conlon Insurance Brokers.
Pearse Street, Ballina, Mayo, Ireland.
Owner contact email: email@example.com
Owner Name: Harry Clarke
Phone Number: 096-79626
When we refer to ‘we’ it is Biz Broker Ltd t/a Clarke & Conlon Insurance Brokers
Please read this Statement 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?
We are an independent Insurance Broker with over 30 years’ experience specialising in Business
Insurance, but in a unique way compared to others. We specialise in the construction,
manufacturing, retail, and leisure industries for business owners. We also offer personal lines
insurance i.e.: home & motor.
Types of Data Collected
Among the types of Personal Data that this Application collects, by itself or through third parties,
there are: first name; last name; date of birth; phone number; company name; profession; address;
country; email address; various types of Data; city; field of activity; Cookies; Usage Data; driving
licence number; financial information or insurance policy numbers.
There are times where we will also need to collect special categories of information, due to their
more sensitive nature. This will only be asked where it is relevant to the policy or claim in order to
fulfil our services to you.
Complete details on each type of Personal Data collected are provided in the dedicated sections of
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically
when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to
provide this Data may make it impossible for this Application to provide its services. In cases where
this Application specifically states that some Data is not mandatory, Users are free not to
communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the
services used by this Application serves the purpose of providing the Service required by the User, in
Users are responsible for any third-party Personal Data obtained, published or shared through this
Application and confirm that they have the third party's consent to provide the Data to the Owner.
Purpose for processing your data
Why are we processing your data? Our legal basis.
For us to provide you with our general insurance broking services, it is necessary for us to collect and
process your personal data. We are required, therefore, to inform you of the legal bases for
processing your personal data. One such legal basis is that the processing is necessary for the
performance of the advisory services contract (and any other contract) that we commit to delivering
to you. We may need your personal data in order to advise you, provide you with insurance
quotations and arrange any contracts of insurance or related payment arrange any contracts of
insurance or related payment transactions on your behalf with Insurers / Insurance Providers.
Another legal basis is that some processing is necessary for the purposes of the legitimate interest
that we have, as a firm that is authorised and regulated by the Central Bank of Ireland, in the proper
administration and correct operation of our firm. There may also be circumstances where the legal
basis for processing your personal data is consent (where we have sought it and it has been provided
to us), in which case that consent may be withdrawn at any time.
In any event, we are committed to ensuring that the information we collect, and use is appropriate
for this purpose and does not constitute and invasion of your privacy.
We will process (collect and use) the information you provide in a manner compatible with the
GDPR. We will endeavour to keep your information accurate and up to date, and not keep it for
longer than is necessary.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its
legal obligations, respond to enforcement requests, protect its rights and interests (or those of its
Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Contacting the User, Analyics, Interaction with external social networks and platforms, Content
commenting, verify your identity, process your information for audit, compliance with regulatory or
legal requirements and Remarketing and behavioural targeting for internal record keeping and to
protect your vital interests.
The personal data we will collect from you and process, where relevant, is dependent on the type of
product you are seeking, this is not a limited list and may include:
Personal, such as title, full name, address, landline telephone number, mobile number, work
number, email address
Your date of birth, gender and/or age, PRSI number
Your nationality, residency and/or citizenship status, if needed for the product or service
Details of beneficiaries, such as joint policy holders, named drivers, beneficiaries of our
products or services
Family members (if relevant to the product or service)
Your marital status, family, lifestyle or social circumstances, if relevant to the product (for
example, the number of dependents you have or if you are a widow or widower)
Employment information: Your job title and the nature of the industry you work in
Records of your contact with us such as via phone, if you get in touch with us online using
our online ‘contact us’ services or details such as your mobile phone location data, IP
address, records of landline telephone recordings
Products and services, you hold with us, as well as have been interested in and have held
and the associated payment methods used, including existing policy number, client
identification number, renewal dates of policies with us and other insurers, premium details,
details of excesses, images/surveys
The usage of our services, any claims and whether those claims were paid out or not (and
details related to this)
Bank and payment card details, to reimburse any premium owed to you, records of
payments and arrears
Marketing to you and analysing data, including history of those communications, whether
you open them or click on links, and information about products or services we think you
may be interested in, and analysing data to help target offers to you that we think are of
interest or relevance to you. Offers may include our car, insurance, financial services,
connected car, travel and any of our other products and services
Vehicle & Driver(s) information, such as make and model, registration number, year of
manufacture, value, purchase date, fuel type, engine size, vehicle licensing cert, who uses
the vehicle, carrying capacity, weight, distance travelled per year, type of use of vehicle ie,
business use or social/domestic use, right/left-hand drive, details of insurance cover, change
in insurance cover and modifications if any, connected vehicles insured. Driving history, no
claims bonus, gap in cover, claims history, disqualifications and penalty points incurred
Information about your use of products or services held with the firm, such as other
insurance policies, mortgage, savings or financial services and products
Information we obtained from third parties, including information about insurance risk,
pricing, claims history, instances of suspect fraud and usage history
Financial information: Bank and payment information
Fraud, debt and theft information, including details of money you owe, suspected instances
of fraud or theft, and details of any devices used for fraud
Criminal records information, including alleged offences, for example if you apply for car
Information about your health or if you are a vulnerable customer. Injuries/illnesses suffered
by you or anyone insured on the policy either prior to taking out an insurance or during
Information about your property, such as location, value, number of rooms, property type
and building work you have had done
Financial details about you, source of income, source of wealth, details of your expenditure,
and payment method(s), if relevant
Details about all your existing borrowings and loans, if relevant
Information about your employment status, if relevant
Information about your property occupier status, such as whether you are a tenant, live with
parents or are an owner occupier of the property where you live at the time of your
Information we obtain from third parties, including vehicle details, details of outstanding
finance, vehicle claims/history, publicly available information, and information to help
improve the relevance of our products and services
Where relevant, information about any guarantor which you provide in any application
Tax information, if relevant (for example, for tax planning purposes)
Images, in connection with the risk being insured or for other business use including claims
Note: Some personal data is mandatory in order for the performance of the contract. In the event
you decide not to provide the mandatory personal data we will be unable to provide you with a
certain service or product. We will indicate to you were any personal data required is mandatory or
Special Categories of personal data & data on criminal convictions and offences
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin,
etc) we will ensure to obtain your explicit consent as part of your request for an insurance quotation.
We only process special categories of personal data, and data on criminal convictions and offences
including penalty points. Where it is necessary to enable us to provide you with an insurance
quotation as requested by you and, if instructed by you, for us to arrange a contract of insurance on
your behalf with the Insurer / Insurance Provider whom you have chosen.
Who are we sharing your data with?
We only share your information with a select number of individuals and companies, and only as
necessary. Sharing can occur in the following circumstances and/or with the following persons:
When you request an insurance quotation from us, we will need to share your personal data with
the Insurers / Insurance Providers with whom we hold agency appointments. When you enter a
contract of insurance or related finance transaction with that Insurer / Insurance Provider they also
websites and/or with their policy documentation for your contract of insurance. We may also
continue to share your personal data with the Insurer / Insurance Provider to enable them to
manage and administer your contact of insurance and / or related finance transaction, and for the
prevention and detection of fraud.
Your authorised representatives: these include your attorney (under a Power or Attorney)
and any other party authorised by you to receive your personal data.
Third parties we need to share your information with, to facilitate payments, you have
requested (for example, SWIFT, credit card issuers and merchant banks, insurers) and those
you ask us to share your information with.
We may need to pass and / or allow access to our system containing your personal data to
third-party service providers contracted by us to provide us with our Insurance Broker
Software and Quotation System, our IT System Support & Maintenance, our Offsite Data
Backup, our Telephone Communications and Offsite Recording & Backup, our Confidential
Documentation Destruction, Compliance / Business Development / Systems & Marketing
advice, and Statutory Audit Services. Any such third parties are obliging to keep your details
securely, and to use them only to fulfil the service that they provide to us. When they no
longer need your data to fulfil this service, they will dispose of the details in line with our
data protection policy.
When you apply to us for insurance. We will pass your details to the insurer and reinsurer.
We may request information relating to your health for underwriting and claims
administration purposes. If you make a claim, any information you give us, or to the insurer,
may be put onto a register of claims and shared with other parties to prevent fraudulent
claims. A list of the participants is available from the insurer.
We may disclose your information within our Group of companies, to our agents and other
insurers and third parties for administration, regulatory, customer care and service
purposes, and to investigate or prevent fraud.
Companies that provide support services for the purposes of protecting our legitimate
Your personal information remains protected when our service providers use it. We only
permit service providers to use your information in accordance with our instructions, and we
ensure that they have appropriate measures in place to protect your information.
Our service providers include marketing and market research companies, analytics
companies, IT and telecommunication service providers, software development contractors,
data processors, debit/credit card producers, computer maintenance contractors, printing
companies, property contractors, document storage and destruction companies, custodians
and providers of administration services, archiving services suppliers, debt collection
agencies, budgeting and advice agencies, tracing agencies, receivers, liquidators, examiners,
auditors and consultants, including legal advisors.
We may also share information with the following third parties to help us manage our
business for our legitimate interests:
Insurers/re-insurers and insurance bureaus
Our files are backed up on the cloud and stored within the European Union
Our IT systems parent company is based in the UK
Trade associations and professional bodies, non-statutory bodies, and members of trade
Persons making an enquiry or complaint
Statutory and regulatory bodies and law enforcement authorities.
These include State Regulators and authorities such as; statutory and regulatory bodies;
including the Central Bank of Ireland, the Data Protection Commission, the Financial Services
and Pensions Ombudsman, An Garda Síochána/police authorities/enforcement agencies,
Revenue Commissioners, Criminal Assets Bureau, EU and other designated authorities in
connection with combating financial and other serious crime, organisations, ombudsmen
and regulatory authorities, as well as fraud prevention agencies. As well as Industry bodies
such as the Motor Insurers Bureau of Ireland and the Personal Injuries Assessment Board.
If we wish to pass your sensitive personal data onto a third party, we will only do so once we
have obtained your explicit consent unless we are legally required to do otherwise.
If we transfer your personal data to a third party outside the EU, we as the data controller
will ensure the recipient (processor or another controller) has provided the appropriate
safeguards and on condition that enforceable data subject rights and effective legal
remedies for you the data subject are available.
In certain contracts of insurance 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 may be transferred to and vested 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 may be entitled to seek and
obtain information from the insurer or from any other person who is able to provide it
The existence of the insurance contract;
Who the insurer is;
The terms of the contacts; and
Whether the insurer has informed the insured person that the insurer intends to refuse
liability under the contract.
Special Categories of Personal Data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin,
criminal convictions (penalty points) – financial information is not classified as special categories of
personal data) – this will only be requested and processed where it is necessary for the performance
of an insurance contract and will only be processed by way of
Assessment of risk
For the prevention of fraud
For the establishment, exercise, enforcement or defence of legal claims or
To protect the vital interests of a person
Data Subject Rights
Biz Broker Ltd t/a Clarke & Conlon Insurance Brokers facilitate you, our clients, 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
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, this will be subject to our requirement to legislation to
keep data on file for periods of time.
Right to restriction of processing – where certain conditions apply to have a right to
restrict the processing of data.
Right of portability – you have the right to have the data we hold about you transferred to
Right to object – you have the right to object to certain types of processing such as direct
Right to object to automated processing, including profiling
Right to judicial review: if Clarke and Conlon Insurance Brokers refuses 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. There may be some circumstances where we
cannot comply with your request. For example, we would not be able to agree to your request if it
would mean we couldn’t comply with our own legal or regulatory requirements. In these instances,
we will let you know why we cannot agree to your request.
Additional information we are providing you with to ensure we are transparent and fair with our
Our approach to sending your personal data abroad
Sometimes we will transfer the personal information we collect about you to countries outside of
the European Economic Area (‘EEA’)
When a transfer happens, we will take steps to make sure your personal information is protected.
We will do this using a number of different methods including:
Only transferring data to countries that have been deemed by the EU as having adequate
privacy legislation, so transferring data to them is considered equivalent to processing within
the EU. You can find out more about adequacy status at:
Establishing appropriate contracts. We’ll use a set of contract wording known as the
‘standard contractual clauses’ which has been approved by the data protection
Transferring personal data only to those companies in the United States who are
certified under the ‘Privacy Shield’. The Privacy Shield is a scheme under which
companies certify they provide an adequate level of data protection. You can find
out more about the Privacy Shield at: https://www.privacyshield.gov/Individuals-in-
We take your privacy very seriously and will only use your personal information for the
do this without your permission first. We will then contact you for marketing purposes,
which may include for example, for offering other services that we think may be of interest
to you or to ask if you want to take part in a competition we might run.
If at any time you wish to ‘opt out’ of receiving any more marketing, you can do so simply by
emailing firstname.lastname@example.org or call 09679626.
How long do we keep your personal information for?
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained.
Biz Broker Ltd t/a Clarke & Conlon Insurance Brokers will process personal data in accordance with
our retention schedule. This retention schedule has been governed by our regulatory body (the
central bank of Ireland) and our internal governance.
Policies: Seven years after the policy expires and no further action on the policy is required.
Claims: Seven years after a claim has been closed unless there are extenuating circumstances
requiring the claim to be held for longer.
Complaints: Seven years.
There are situations, depending on the nature of the policy and any claims made under it,
where data may need to be kept for a further period than outlined above. Includes:
Where children are involved in a claim.
Where there is a claim on your policy over a set amount – we use such personal data
to inform our pricing models after the claim is finally determined.
In the circumstances of the prevention or detection of crime and the apprehension or
prosecution of offenders, Clarke and Conlon Insurance Brokers can hold your personal data
for different periods of time and, if you are considered to pose a fraud or money laundering
risk, your data can be held for up to six years.
If you wish to make a complaint about how your personal data is being processed by Biz Broker Ltd
t/a Clarke & Conlon Insurance Brokers or how your complaint has been handled, you have the right
to lodge a complaint within the Organisation Name’s data protection representatives GDPR Owner.
You may also lodge a complaint with the Data Protection Commission in Ireland, whose details are:
Data Protection Commission
Co. Laois, R32 AP23
Phone: +353 57 868 4800 / + 353 761 104 800
Fax: 353 57 868 4757
Failure to provide further information
If we are collecting your data for a contract to provide you with insurance and you cannot provide
this data, the consequences of this could mean the contract cannot be completed or details are
Your privacy is important to us. If you have any comments or questions regarding this statement,
please contact us on (096) 79626 or email@example.com
time. When such a change is made, we will post a revised version online. Changes will be effective
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