Privacy Policy

Data Privacy Notice
This is the data privacy notice of Tynan Dillon Advisors Limited, Tynan Dillon Limited and TD Financial Systems Limited. In this document, “we”, “our”, or “us” refer to the above companies, all of which have registered offices at 74 Northumberland Road, Ballsbridge, Dublin 4

Introduction
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
In order to provide our services, we are obliged to collect data from our clients. We operate our business subject to regulations of the professional regulatory bodies that we are members of, (including Chartered Accountants Ireland and the Irish Tax Institute), and also subject to taxation and other legislation. This regulation and legislation imposes considerable data retention obligations on us.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website and terminate your engagement with us immediately.
We take seriously the protection of your privacy and confidentiality. We understand that all of our clients and all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
The relevant legislation requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1.Information we process because we have a contractual obligation with you
When you engage our services, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

We may use it in order to:

verify your identity for security purposes

sell products to you

provide you with our services

provide you with suggestions and advice

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

2.Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including general enquiries regarding our services, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us in writing. However, if you do so, you may not be able to use our services further.

3.Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:

record-keeping for the proper and necessary administration of our business
responding to unsolicited communication from you to which we believe you would expect a response
protecting and asserting the legal rights of any party
insuring against or obtaining professional advice that is required to manage business risk
protecting your interests where we believe we have a duty to do so.

4.Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal information.

Specific uses of information you provide to us
5.Information provided on the understanding that it will be shared with a third party
In the course of our work with clients, they are required to provide personal information on the understanding that it will be shared with third parties, (e.g. financial information provided to us in order to allow us assist with tax filings submitted to the Revenue Commissioners, or accounts filings submitted to the Companies Registration Office). If you have any concerns regarding the sharing of information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

We store personal information, as we are required to do so as part of our work, and we reserve a right to use it in the future if this is in our clients’ best interests. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal or regulatory basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have provided. You can make a request by contacting us in writing.

6.Complaints regarding content on our website
If you complain about our use of personal data, or about any of the content on our website, we shall investigate your complaint.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

7.Information about your direct debit
If you agree to set up a direct debit arrangement with us, the information you give to us is passed to our own bank for processing according to our instructions.

We are registered as an approved originator/beneficiary under the direct debit guarantee scheme. This provides for the customer’s bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.

8.Job application and employment
If you send us information in connection with a job application, we may keep it on file in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment.

9.Sending a message to us
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

10.Complaining
When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

Access to your own information
11.Access to your personal information
At any time you may review or update personally identifiable information that we hold about you.

To obtain a copy of any information that is not provided on our website you may send us a request in writing.

After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

12.Removal/deletion of your information
If you wish us to remove or delete your personal data from our records, you may contact us in writing and request that we do so. This may limit the service we can provide to you.

13.Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters
14.Use of site by children
We do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may engage our services only with consent from a parent or guardian

15.How you can complain
If you are not happy with our privacy policy or if have any complaint then you should inform us in writing.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Data Protection Commissioner. This can be done at https://www.dataprotection.ie/docs/complaints/1592.htm

16.Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

to provide you with the services you have requested;

to comply with other laws and regulations, including for the period demanded by our tax authorities;

to support a claim or defence in court.

17.Compliance with the law
Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our website.

18.Review of this privacy notice
We may update this privacy notice from time to time as necessary.

If you have any question regarding our privacy policy, please contact us.