Last Updated: 4 March 2026

Clarity Financial Planning Ltd 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 Clarity Financial Planning Ltd. Our contact details are

Clarity Financial Planning Limited
Registered Office Address: 51 Bracken Road, Dublin, D18 CV48. Ireland
Email: Paul@clarityfinancial.ie
Mobile: 086 040 3548
Website: www.clarityfinancial.ie

When we refer to we/us, we mean Clarity Financial Planning Ltd.

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?
Clarity Financial Planning Limited is a member of Brokers Ireland.

We provide advice and guidance in the areas of cashflow modelling regarding future financial planning in addition to the areas of investments, savings, pension planning pre and post planned retirement age, business associated protection cover and family protection.

Our principal business is to provide advice and arrange transactions on behalf of clients in relation to Life Assurance products including Life Assurance policies, Critical/Serious Illness, Income Protection, Pensions, PRSAs, ARFs, Savings and Investment products offered by insurance and investment companies.

Our client experience is paramount and we pride ourselves on building long lasting client relationships. We act as an intermediary or broker. This means that we will identify and select suitable products on a fair and personal analysis basis from insurers and on receipt of your instructions, we will transmit orders on your behalf to one or more product producers. This process applies to all classes of insurance policies. (See below under “Fair and Personal Analysis”). Clarity Financial Planning Limited does not have a tied relationship with any institution.

However, for certain types of pensions, savings and investment products, we will select suitable products on a limited basis (See below under “Limited Analysis”).

Our core beliefs are built around the Three Pillars of Clarity;

Clarity of Purpose – Defining and Understanding what our clients want and require

Clarity of Meaning – Ensuring our clients understand why our recommendations align with their objectives

Clarity of Action – Ensuring our clients understand how the goals can be achieved with guided financial planning

Our GDPR Owner can be contacted directly here:

Name: Paul Delaney
Email address: paul@clarityfinancial.ie
Phone number: 0860403548

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;

• register with or use any of our websites or online applications;

• use our website which installs cookies.

• engage with us on social media; (e.g. LinkedIn)

• 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:

• Contact and Identifying information (name, address, email, mobile)

• Unique identifiers (PPS number, pension scheme reference number, policy numbers)

• Demographic details (age, gender, marital status, date of birth, dependents, photo ID, as well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy)

• Family and Beneficiary Data (dependants, next of kin or nominated beneficiaries)

• Employment information (role, employment status)

• Publicly available sources (Director information from the Companies Registration Office)

• Health information (relevant information where medical underwriting is required)

• Pensions and Insurance Benefits information

• Financial details (bank account details, level of pension contributions, salary)

• Claims Data (relevant information where medical underwriting is required)

• Marketing preferences

• Online information (information about your visits to our websites)

• Events information (information about your interest in and attendance at our events, including provision of feedback forms)

• Social media information (e.g., likes and posts) with our social media presence

• Criminal records checks

• Sanctions and AML Checks

• Calculators on our website

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.

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, investment, protection, pension products, independent financial advice, quotes.

• Performing services for our clients and prospective clients

• Statutory and other regulatory requirements - we are required to carry out various obligations which include:

  • AML/Sanction checking

  • Knowing your customer “Fact Find”

  • Adherence to the Consumer Protection Code

• Communicate and marketing to you (This may include periodic updates relating to topics such as market performance updates and commentary, developments with the financial framework)

• Process claims

• Responding to your queries and communications to us

• Administer and improve our website

• Provide the services we have been contracted to provide to you

• Handling complaints

• To notify you about changes to our service

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 (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.

How we share your data

• Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters

• Vetting and risk management agencies such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies

• Medical professionals as part of the medical underwriting process

• Law enforcement and regulators to ensure we comply with our legal and regulatory obligations

• Third-party processors: We outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT and CRM service providers

• Internal and external auditors where necessary for the conduct of company audits or to investigate a complaint or security threat

• On the sale or reorganisation of our business whether by asset or share disposal or other transaction relating to our business.

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 Voyant, Inc. located in UK and we ensure appropriate safeguards are in place for any transfers under adequacy agreements.

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.

Security
The security of your personal data is important to us. We use appropriate technical and organisational measures to protect your personal data.

Retention
We only keep personal data as long as necessary. Data is securely disposed of.

Your rights
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 your personal data is being processed by Clarity Financial Planning Ltd or how your complaint has been handled, you have the right to lodge a complaint with our GDPR Owner or 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

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

• Risk profiling.

• Profiling for marketing purposes.

• Establishing affordability and providing quotations for financial services

• Bankruptcy check

• PEP check

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 data, we will either 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

Contact Us
Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on 0860403548 or email info@clarityfinancial.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.