Northstar Financial Planning Privacy Notice.

Introduction

This Privacy Notice applies to all personal information processing activities carried out by Northstar Financial Planning.

Northstar Financial Planning is a data controller in respect of personal information that we process in connection with our business and that includes the products and services that we provide to you. In this notice, references to “we”, “us” or “our” are references to Northstar Financial Planning.

Northstar Financial Planning 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 as a client.

It is the intention of this privacy statement to explain to you the information practices of Northstar Financial Planning in relation to the information we collect about you.

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.

How to contact us

For the purposes of the GDPR the data controller / Data Protection Officer / GDPR Owner:

• Address | Northstar Financial Planning, 19 Chapel Street, Carndonagh, Co. Donegal, F93 ET78.
• Email | ken@northstarfp.ie
• Phone number | 01 539 44 50

Who are we?

Our principal address is Northstar Financial Planning, 19 Chapel Street, Carndonagh, Co. Donegal, F93 ET78, Ireland.

For more information on Northstar Financial Planning Limited t/a, please visit our ‘About Us’ page at www.northstarfp.ie.

Purpose for processing your data

As a client of Northstar Financial Planning Limited we process personal information about you and we do this for a number of specific reasons, primarily:

• For the purpose of providing the agreed level of service to you under your contract with an employee of Northstar Financial Planning Limited
• In order to comply with statutory obligations and other tax and regulatory requirements which we are subject to (for example anti-money laundering requirements); and
• In order to provide you with information in relation to Northstar Financial Planning Limited

Please be aware that we will never disclose your personal information to any third party unless you have consented to it, where it is necessary to enable us to carry out our contractual obligations to you or where we are obliged to in order to comply with legal, statutory and/or regulatory requirements. You should know that we will not sell your personal information to any third party to be used for marketing purposes.

We collect information from you when you access our website when you request a quote online or over the phone or when you speak to members of our staff. We will only collect information that is adequate, relevant, and limited to what is necessary in relation to the purposes identified within the policy basis requested.

The table below outlines the categories and types of data we collect along with the source of the data. The type of data we collect will depend on the product or service you are availing of. The types of data we collect may change over time; the following table is an indicative list to help you understand the types of data we collect.

Information collected by Northstar Financial Planning Limited may include the following

1. Individual details e.g., name, address, age, gender, date of birth, email, mobile, family and Beneficiary Data.
2. Unique identifiers such as PPS number – where tax is payable, or tax relief is applicable. Photo ID and Proof of Address – as part of Anti-Money Laundering compliance.
3. Employment information e.g., role, employment status, salary information, and employment benefits.
4. Health information – The collection of which is necessary for any insurance protection product and may include specific health questionnaires.
5. Existing Pensions, Investment and Insurance Benefits information such as existing private insurance, pension and investment plans, including employer-sponsored plans.
6. Financial details e.g., bank account details and salary details which may include copy payslips in the case of pension plan applications.
7. Health Ratings Data (From you and any relevant third parties). Information on any previous health-related premium ratings.
8. Calculators on our website. We use this data to perform calculations to prepare quotations for you including Mortgage Protection, Life Insurance, Serious Illness Cover and Income Protection Insurance.

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.

Why are we processing your data? Our legal basis

In order for us to provide you with the products and services outlined in our Terms of Business, Northstar Financial Planning Limited need to collect personal data. Our reason (lawful reason) for processing your data under the GDPR is:

Legal basis – Northstar Financial Planning Limited needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.

In any event, Northstar Financial Planning Limited 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.

How will Northstar Financial Planning Limited use the personal data it collects about me?

Northstar Financial Planning Limited will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date and not keep it for longer than is necessary.

Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your request for investment, protection, pension products, independent financial advice, and quotes.

Your Personal Data will allow us to:

1. Perform services for existing and prospective clients – We use your data to enable us provide the required advise and product information.
2. Complete statutory and other regulatory requirements including AML/Sanction checking, Product Specific “Fact Find” and Knowing your client – Product Specific “Full Financial Review”
3. Communicate and market to you – We may from time to time with your express permission, email, write or telephone you with respect to special offers or regarding additional product areas in which you have already expressed an interest. For all existing clients, we also receive an annual review where applicable.
4. Process claims – insurance protection claims, which relate to life insurance, serious illness, accident, or disability should be notified to us in the first instance via telephone after which they will be passed on to the relevant users’ claim team.
5. Contact you if required or to respond to any communications that you might send to us. Our first point of contact will be by telephone, followed up via email.
6. Administer our site including data analysis, testing, research, statistical, and survey purposes.
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. Handling complaints.
9. To notify you about changes to our service.

Special Categories of personal data

Subject to suitable and specific measures being taken to safeguard the fundamental rights and freedoms of data subjects, the processing of data concerning health shall be lawful where the processing is necessary and proportionate for the purposes of the following:

• (a) a policy of insurance or life assurance,
• (b) a policy of health insurance or health-related insurance,
• (c) an occupational pension, a retirement annuity contract or any other pension arrangement, or
• (d) the mortgaging of property

Service Providers

We make your information available to third-party life insurance partners (Life Insurance Companies) 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.

These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose in accordance with the General Data Protection Regulation.

The below is a list of companies we may share your information with:

1. Insurance and Assurance companies we have agencies with including:
   • Aviva
   • Irish Life
   • New Ireland
   • Royal London
   • Zurich
2. Pension Trustees, & beneficiaries of Pensions & other Financial Products, Relatives & guardians, (in certain circumstances and within the law)
3. Legal, financial, investment, medical, & other professional advisors in the process of
4. Any business which we are required by law to share the information with, i.e. compliance resource companies.
5. CRM Provider – BIS – Platform a Database provider
6. Digital Signature Provider
7. The Pensions Authority
8. Cashcalc – a financial planning and cashflow modeling software program
9. Central Bank of Ireland. We are authorised by Central Bank and they have the right to inspect our files.
10. The Financial Services Ombudsman. In the event of a complaint.
11. Data Protection Commissioner

If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards, including adherence to GDPR and on condition that enforceable data subject rights and effective legal remedies for you the data subject are available.

Data Subjects Rights

Northstar Financial Planning Limited facilitates 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 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 Northstar Financial Planning Limited refuses your request under rights of access, we will provide you with a reason as to why.
• 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.

Additional information we are providing you with to ensure we are transparent and fair with our processing.

Retention of your personal data

Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. Northstar Financial Planning Limited 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.

In the event that you wish to make a complaint about how your personal data is being processed by Northstar Financial Planning Limited or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Northstar Financial Planning Limited data protection representatives/Data Protection Officer / GDPR Owner to email address ken@northstarfp.ie

Failure to provide further information

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

Profiling – automatic decision making

Financial and mortgage advisors using profiling in their business. The main categories are:

• Risk profiling. To establish a customer’s attitude to investment risk (relates to pensions and investments) advisors have automated calculators which calculate the customers attitude to various levels of risk having answered a series of questions.
• Profiling for marketing purposes. When we seek to contact you about other services, as outlined above we run automated queries on our computerised data base to establish the suitability of proposed products or services to your needs.

Additional Processing

If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.

Privacy policy statement changes

Northstar Financial Planning Limited may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

This privacy policy was last reviewed 22 January 2026