123.ie Data Protection Notice,At 123.ie, we’re committed to ensuring your personal data is protected.
This Notice explains how we use the information ,we collect about you and tells you about your data protection rights.,1.Who are we?,Where we refer to “we” “us” “our” we mean 123 Money Limited, trading as 123.ie,a wholly owned subsidiary of RSA ,Insurance Ireland DAC (‘RSA’)and part of the Intact Financial Corporation (‘Intact’) group of companies.We provide ,personalinsurance products and services,and we also provide insurance services in partnership with other companies.,We are a Data Controller in relation to the personal information we collect and hold about you.Contact information for us ,is in Section10below.,2.What information do we collect about you and for what purposes? ,We will use your personal information to provide insurance services such as giving aquoteor servicing your policy.
We will ,also use your personal data for related matters such as complaints handling, prevention or detection of fraud and statistical,analysis.
If you have given us separate marketing consent, we will use your personal data(e.g.
your name, address, phone ,number and email address)to send you news and offers related to our, and our partners, products and services.,The following (non-exhaustive) types or categories of personal information that we may collect and use about you(or other ,people to be insured)includes: name, address, Eircode, date of birth, occupation, policy numbers, contact details, gender, ,drivinglicence detailsand penalty points information, vehicle registration number, marketing preferences and renewal dates ,of policies with other insurers, bank andpayment card details,claims data, medical / health information,vulnerability data ,(see below),geo-location and driving behaviour dataandon-line identifiers such as IP addresses.
,Note:You don’t have to provide us with any personal information, but if you don’t provide information that we need,then ,we may not be able to proceed with your applicationfor insurance.
We will let you know what information is required to ,proceed with your application.,When looking for a quote for an insurance product from us, you will need to provide us with information relating to what you ,wish to be insured(e.g.
car make/model, your home, details about youor other people to be insured).
When buying certain ,products, we mayneed to collect special categories of data (e.g.
medicalor healthinformation) and driving offences or ,convictions history.
If you become vulnerable, due to a life event, health issue orother matter, we will seek to identify this ,and decide what additional support we can provide, so we can meet your needs and fulfil our obligations to you.Toprovide ,our products, we will also need to process your payment information (e.g.bank account details, credit and debit card details) ,to collect payments from you and to issue any refunds to you.,We may need to contact you if you request a quote from us and/or to service your policy.
This maybe donevia our website,(including digital chat media), by email, SMS, mobile Apps, telephone calls and/or by post.
Telephone callsand the other ,ways we contact you or you contact us may be recorded for quality assurance, training,verification and security purposes.
,Where you have optedforcertain motor productswhichinvolves GPS vehicle tracking,we will collectand process ,information from the smart sensorinstalled in your car including geo-location, driving behaviourand/or kilometer usage,data(‘telematics’ data).,When applyingto us for an insurancepolicy, you may need to provide us with information relating to other persons insured,under the policy.
You agree that you will bring this Noticeto the attention of each person named on the policyat the earliest ,possible opportunity.
Please also ensure that anyone who is insured under your policy hasagreed to provide their personal ,information to us.
Ifyouhave taken out a telematics-basedmotorproduct, you should let all drivers of your car know about ,the black box orsmart sensorfitted to your carthat collects information about where and how your car is driven.,Secondary processing of your personal information (i.e.
for a purpose other than for which it was collected)may be ,undertaken but only in accordance with data protection laws, e.g.
where necessary and proportionate for the purposes of ,preventing, detecting, investigating or prosecuting criminal offences, or for the purposes of legal advice and legal ,proceedings.
,We collect information through website cookies and other similar technologies (e.g.
pixel trackers or ‘like’buttons) when ,youvisit our website or use one of our mobile Apps.
These tools are used by usand ourthird-partyservice providers to ,help improve our and their products and services, the functionality andperformance of our websites and Apps,and to ,support more effective advertising.For more information about how and why we use cookies,please visit ourCookie Policy,on our website(www.123.ie).,The below table describes the purposes for which we use your personal data and the legal basis for doing so.
,PurposeLegal Basis ,To provide you with a quote for an insurance product and to ,provide you with insurance cover if you decide to buy a ,product.
,Processing is necessary for the performance of a contract or ,to take steps at your request prior to entering into a contract.,To assess the information you have provided and decide ,whether we can provide you with cover and at what price.
,To verify your identity and to verify the accuracy of the ,information we receive.
,Processing is necessary for the performance of a contract or ,to take steps at your request prior to entering into a contract.,Processing is necessary for the purposes of ourlegitimate ,interests to investigate and prevent potential fraud.
,Processing is necessary to comply with legal obligations ,Criminal Justice (Money Laundering and Terrorist Financing) ,Acts 2010 to 2021.,To administer your insurance contract and make any ,changes during its term, answer queries, provide updates ,and process a cancellation.
,Processing is necessary for the performance of a contract or ,to take steps at your request prior to entering into a contract.
,Processing is based on your specific consent (to store your ,credit card data for future purchases only).
,To arrange any payments in relation to your policy.,If you have opted for a telematicsmotor insurance product,,data collected via the smart sensor installed in your car may ,be used to determinethe circumstances surrounding any Processing is based on your specific consent (to access and ,claim under your policy, your car’s location, kilometres store data on the smart sensor only).,travelled, driving behaviour (such as your car’s speed) and ,also to identify any potential unacceptable driving.,Processing is necessary for the performance of a contract or ,to take steps at your request prior to entering into a contract.,Processing is necessary for the purposes of our legitimate ,interests.The interest is to manage our business.,To detect and prevent fraud, money laundering and other ,offences.To assist An Garda Siochána or any other ,authorised law enforcement body withtheirinvestigations.
,Processing is necessary for the purposes of our legitimate ,interests to investigate and prevent potential fraud and other ,illegal activity.
,Processing is necessary to comply with legal obligationse.g.
,Criminal Justice Act 2011, Section19.,To manage and investigate any complaints.,Processing is necessary for the performance of a contract or ,to take steps at your request prior to entering into a contract.,Processing is necessary to comply with legal obligationse.g.
,Central Bank Codes of Conduct such as the Consumer ,Protection Code.,To comply with laws and regulations.Processing is necessary to comply with legal obligations.,For statistical analysis including internal risk assessment, Processing is necessary for the purposes of our legitimate ,portfolio performance reporting or market-level research interests.
This interest is to improve our processes, products ,exercisesor forcustomer satisfaction surveys.and servicesand manage our business.,For quality assurance, training, records maintenance, Processing is necessary for compliance with our legal ,verification and security purposes, for example the recording obligations e.g.
the Central Bank Minimum Competency ,or live monitoring of telephone calls.
Code and Minimum Competency Regulations 2017.,Processing is necessary for the purposes of our legitimate ,interests.
This interest is to improve our processes, products, ,and services.,For staff training, performance reviews and internal ,disciplinary purposes.,For the ongoing development, testing and security of our IT ,systems.
to make back-ups of data in case of emergencies ,and for disaster recovery purposes.,Processing is necessary for the performance of a contract or ,to take steps at your request prior to entering into a contract.
,Processing is necessary to comply with legal obligationse.g.
,Central Bank Guidance and Requirements.,Processing is necessary for the purposes of our legitimate ,interests.The interest is to protect and to ensure the ,continuity of our business.,For marketing purposes.Please see Section5 below for ,more information on our marketing.,Processing is based on your specific consent.
,To issue service-related communications to you such as,policyrenewal reminders, new website and customer ,service featuresor adverse weather alerts.,Processing is necessary for our legitimate interests.This ,interest is to communicate important information to you to ,ensure continuity of cover, awareness of new service ,features and to help safeguard your property.,To administer and improve our website.
To make ,suggestions and recommendations to you as a user of our ,website about services that may be of interest to you.For ,further information please see our Cookie Policy.
,Processing is necessary for the performance of a contract or ,to take steps at your request prior to entering into a contract ,(i.e.,use of cookies which are essential or strictly necessary ,toprovide you with the service which you have requested).,Processingisbased on your specific consent.
,3.How else do we collect information about you?,Where possible, we will collect your personal information directly from you.
However, we may receive information about ,you from other people or sources.
For example: ,•It was given to us by someone who is applying for an insurance product on your behalf (e.g.
a spouseor partner).
,•The Underwriter of your policy i.e.
yourinsurance company.,•Other companies within the Intact Group.
,•It was supplied to us when you purchased, or sought to purchase,an insurance product or service that is provided ,by us in partnership with other companies.,•It was lawfully collected from other sourcessuch as the Integrated Information Data Service(‘IIDS’) which is a ,shared industry members database that, by arrangement with the Department of Transport, allows its users to ,confirm the accuracy of penalty pointsand no-claims discount informationprovided by customers.
,•From vehicle history check suppliers/databases.
,•By using GPSvehicle trackingsmart sensor technologies to collect driving behaviour,geo-location and/or kilometre ,usage data(‘telematics’) where you have opted for a telematics motor insurance product.,•Through geocodingdatabases usedto determine location-based risk factors.,•Law enforcement agencies and government departmentssuch as An GardaSiochána.,•From searches of publicly available information (e.g.social media platforms, on-line content, court judgementsetc).
,•From the Insurance Linkclaimsanti-fraud database(for more information see www.inslink.ie),from insurance ,companiesand fromother fraud prevention databases and data enrichment services available in the insurance ,industry.
The aim of thisis to help us to check information for fraud and to protectagainst misrepresentation.,•Personal data collected through website cookies processing e.g.IP address.
,4.Will weshare your personal information with anyone else?,We may share your details with other third parties (e.g.,service providers, data processors, other data controllers)to ,administer your policy, prevent and detect fraud, provide marketing and advertising services, comply with laws and ,regulations and to conduct internal or market level research analysis.
For example: ,•Anyone authorised by you to act on your behalf.
,•The Underwriter of your policyi.e.
your insurance company.,•Our third-partyservice providers such as our information technologysuppliers, cloud service providers, data ,storage providers, payment services providers, documentation fulfilment providers, digital platform providers, social ,mediaproviders and marketing agencies.,•Other companies within the Intact Group.
,•Property and Risk Surveyors.
,•The Insurance Link claims anti-fraud database(for more info see www.inslink.ie), with other insurance companies,and with industry bodies such as Insurance Ireland.
,•Other fraud prevention databases and data enrichment serviceprovidersavailabletothe insurance industry.
,•In the event that we may be taken over, or sell any business or assets, in which case we will disclose your personal ,information to the prospective buyer of such business or assets.,•Law enforcement agenciesand government departments includingtheCentral Bank ofIreland, the Financial ,Services and Pensions Ombudsman, the Revenue Commissioners/Inspector of Taxes, An GardaSiochána, the ,Criminal Assets Bureau, the Data Protection Commission-as a result of our legal and regulatory obligations or on ,footof a Court Order or Subpoena.,•We add details of yourmotor policy to the Motor Third Party Liability Database (‘MTPLD’) and National Fleet ,Database (‘NFD’) maintained by the Motor Insurers Bureau of Ireland (‘MIBI’), to comply with our legal obligations ,under section78A of the Road Traffic Act 1961 (as amended).
This information can be used by government bodies ,such as An Garda Síochánaand the MIBI for purposes permitted by law, including electronic licensing and law ,enforcement.
For more information see www.mibi.ie.,•Our trusted partners and with third parties where personal data is processed viathe use of website cookiesor other ,similar technologies for specific purposes.
For further information please see our Cookie Policy.,Sometimes the partieswe share information with (including transfers within the Intact Group) may be located outside of the ,European Economic Area.
We will only do this by reliance on an approved ‘transfer mechanism’such as European ,Commission adopted Standard Contractual Clauses, use of Binding Corporate Rules or as a result of an Adequacy decision ,of the European Commission.If you want more information on transfers or the safeguards we apply, please get in touch ,using the contact information below.,5.Marketing,If you have provided us with marketing consent, wewill use your personal information for the purpose of offering you other ,products and services including customer discounts and rewards, which may be of interest to you.
This information may be ,provided and communicated to you by post, SMS, telephone, emailand/orsocial media and digital channels(e.g.
using ,platforms such asFacebook Custom Audiences, Google Customer Match, TV on demand).,To personalise the marketing messages we send to you, we may share some of your data with social media and digital ,platforms (in a secure way) so that where you hold an account with them,they can display messages from us to you, or to ,try to make sure you don’t get irrelevant messages(for example, messages about products / services you already have).,You can withdraw your consent for marketing at any time by emailing 123dataprotection@123.ie, phoning us,or by using ,the ‘unsubscribe’option facility provided on our marketing SMS and email communications.
,6.Profiling and automateddecision making,We may conduct the following activities, some of which involve automated (computer based) decision-making:,•With our third-partypartners, and with your consent, profiling exercises are performed usingcookies that allows us ,to measure the effectiveness of our advertisingby understanding the actions people take on our website and target ,ouradvertisingacross other websites or display networks to anonymised audiences based on their actions.,•We may place you in groups or segments with similar customersbased on your profile.
This helps us to design ,products, services and offers for different customer segmentsand toprovide you withrelevant marketing ,advertisements via digital channels and social media.,•The use ofPricing and Underwritingenginesand algorithms –theseprocessescalculate the insurance risks based ,on the information that you have supplied or that we have collected about you.
,•The use of Telematics/ Smart Sensor data analytics –where you have opted for an insurance product that collects ,information using smart sensors (e.g., in-car “black box”) and this is used to calculate your insurance risk.
,The results of these Pricing and Telematics processes will be used to assess your individual risk and to determine if we ,can provide, or continue to provide, you with a policy, to determine its terms and to calculate the premium you have to pay.
,If you do not agree with the result, you have the right to request human intervention to allow you to express your point of ,view, to obtain an explanation of the decision reached and contest the decision.,7.How long will we keep your personal information?,The Underwriter of your policy(insurance company)isalso a Data Controller in relation to your personal information.
You ,should also read their Data Protection Noticeto determine how long they will keep your personal information.
In general, ,we will retain your personal information for a period of 7 years from the date of cancellation of your policy.
Quote information ,is retained for 15 months.We generally retain call recordings for 7 years from the date of the recording to comply with our ,regulatory obligations.
There may be reasons why we need to retain your personal information for longer periods, for ,example to comply with our legal and regulatory obligations.
,8.What are your Rights over the personal information that is held by us?,You have legal rights under data protection law in relation to your personal information:,1)Right to Rectification: Correct any information we hold about you if you think it’s incorrect or incomplete.
,2)Right to Erasure: Request your personal information be deleted where you believe it’s no longer required.
We ,may not always be able to do this, for example, while you’re still insured with us or where we need to keep your ,personal data to meet legal or regulatory obligations.
,3)Right of Access: Provide you with a copy of the personal information we hold about you.
,4)Right to Portability: Request that we transfer a copy of the personal information you have given us, to another ,company.
We would provide the information in a machine-readable format.
,5)Right to Restriction: Request that we restrict the use of your personal information by us in certain circumstances.
,6)Right to Object: Object to the processing of your personal data for marketing purposes or for any purpose where ,processing (including profiling) is necessary for the purposes of our legitimate interests (see table above).
,7)Right to Withdraw Consent: To withdraw consent, where your consent is our basis for using your personal data,(see table above).,8)Right to Contest Decisions: To contest decisions based solely on automated decision making, obtain an ,explanation of the decision reached, express your point of view, and ask forhuman intervention.
,Please note that requests to object to or restrict the use of your personal information may lead to us being unable to continue ,to service your policy and lead to cancellation of your policy.
,If you would like to request any of theseRights, please email us at 123dataprotection@123.ieor write to us at the address ,at the bottom of this Notice.
When you’re making the request please provide us with your name, address, date of birth and ,anypolicy numbers that you have.
You may need to provide us with a copy of your photo identification to ensure we do not ,provide your personal information to anyone that is not entitled to it.
,All requests are free, unless we think your request is manifestly unfounded or excessive in nature.
We aim to respond within ,one month from receipt of your request.
If we cannot meet this time framedue to the complexity or repeated nature of a ,request, we will let you know as soon as possible and explain the reason for this.,Submitting a request does not mean we will be able to complete it or complete it fully.
We are often bound by legal and ,regulatory obligations or may rely on a lawful exemption which restricts the scope of our obligations as a Data Controller.
,When this is the case, we will explain this to you in our response, and that you can lodge a complaint with the Data Protection ,Commission or bring the matter to Court.,9.Changes to our Data Protection Notice,This Notice will be updated from time to time so please check it each time you submit information to us or renew your policy.,10.How do you ask a question about this Data Protection Notice?,If you any questions or comments about this Noticeplease contact:The Data Protection Officer, 123.ie, RSA House, ,Dundrum Town Centre, Sandyford Road, Dundrum, Dublin 16, D16 FC92.
You may also email us at ,123dataprotection@123.ieor visit www.123.ie.
,11.How doyou Complain?,If you’re unhappy with how we have handled your personal information and wish to complain about this, please contact us ,at 123dataprotection@123.ieor write to us using the address above.
Our Data Protection Officer will investigate your ,complaint and will give you additional information about how it will be handled.
We aim to respond in a reasonable ,timeframe, normally within one month.,If you’re not satisfied with our response you can contact the Data Protection Commission:,Post:Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28,Phone:01 7650100 / 1800437 737,Email:info@dataprotection.ie,Web: www.dataprotection.ie,12.Representatives,The General Data Protection Regulation (‘GDPR’) requires organisations not established in the European Union (‘EU’) to ,designate an EU representative if they’re subject to the GDPR, for example offering products/services to EU citizens.
,Intact may undertake processing activities to which the GDPR applies and as they do not have an establishment in the EU ,they have appointed an EU Representative, RSA Luxembourg S.A, to act on their behalf.
The EU representative can be ,contacted at the following address rsa.dp@eu.rsagroup.com.
The EU Representative will address any issues and/or ,queries you may have relatedto Intact’s processing of your personal data.
The EU representative will also deal with data ,subject rights requests for EU citizens and enquiries by EU supervisory authorities on Intact’s behalf.,Important Note ,The Underwriter of your insurancepolicy (your insurance company)is also a Data Controller in relation to your personal ,information.
You should also read their Data Protection Notice (sometimes referred to as a ‘Data Privacy Notice’ or a ,‘Privacy Notice’).
Detail of who the Underwriter of your insurance is, is in your insurance documentation orwithin our ‘Terms ,of Business’ on our website.
Our insurance partner for home and motor products, is RSA Insurance Ireland DAC and their ,Data Protection Notice is available on: www.rsagroup.ie(on the bottom of each webpage).We can post RSA’s Notice to ,you also.RSA’sNoticeincludesfurther information on how RSAusesyour personal information, for example, for claim ,handling or reinsurance purposes, your rights over this informationand how to exercise these rights.,This Notice is effective from June 2023.,123 Money Ltd.
trading as123.ie is regulated by the Central Bank of Ireland.
Registered Office: RSA House, Dundrum Town Centre, ,Sandyford Road, Dundrum, Dublin 16, D16 FC92.
Registered in Ireland Number 323099.