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Retirement Privacy Policy

Last updated: 16 Oct 2026

1. Aviva Data Protection

This notice explains the most important aspects of how we use your personal information, but you can get more information by viewing our full Privacy Policy at aviva.ie/privacy or requesting a copy by writing to us at The Data Protection Team, Aviva, Building 12, Cherrywood Business Park, Loughlinstown, Co. Dublin. 

Aviva Life & Pensions Ireland DAC is the main company responsible for your personal information (known as the data controller). Additional data controllers involved in the process for obtaining and maintaining the product may include the intermediary/financial broker (who is responsible for the sale and suitability of the product), reinsurers employers and pension scheme trustees where applicable.

This Data Protection Notice applies primarily to individuals whose personal information is processed in connection with an application for, or the administration of, one of our products or services. It may also apply to other individuals whose personal information is provided to us in connection with the product or service.

We collect and use personal information about you in relation to our products and services. Personal information means any information relating to you or another living individual who is identifiable by us. The type of personal information we collect and use will depend on our relationship with you and may include more general information (such as your name, date of birth and contact details) or more sensitive information (such as details of your health). 

You do not have to provide us with your personal information, but if you do not provide the information we need, we may not be able to proceed with your application, administer your policy or process a claim. If you are providing personal information about another person, you should show them this notice. 

We may also process personal information relating to other individuals connected with the product or service, such as nominated representatives, personal representatives, attorneys acting under a power of attorney, trustees, administrators or managers of a relevant pension arrangement, employers, financial advisers or intermediaries, where applicable.

Some of the personal information we use may be provided to us by third parties. This may include information already held about you within the Aviva Group, information obtained from publicly available records or industry databases, and information provided by your intermediary, financial broker, nominated representatives, trustees, administrators, qualifying fund managers, providers of relevant pension arrangements or other insurance companies, where relevant. 

We use your personal information to provide and administer retirement products and services, process payments and benefits, manage transfers, administer policies, prevent fraud, handle complaints and manage our operations effectively. Depending on the purpose, we rely on one or more of the following legal bases under data protection law: performance of a contract, compliance with a legal obligation, our legitimate interests, or your consent. Further information about how we use your personal information, including the legal bases we rely on, can be found in our full Privacy Policy. 

We may also use profiling and other data analytics to better understand our customers (for example, what products or services may be of interest) and to predict the likelihood of certain events arising (for example, fraud risk). We may carry out automated decision-making to decide on what terms we can provide products and services, deal with claims and carry out fraud checks. More information about this, including your right to request human involvement in certain automated decisions, can be found in the automated decision-making section of our full Privacy Policy. 

Your personal information may be shared with other Aviva group companies and third parties, including suppliers, claims service providers, regulatory bodies and law enforcement agencies. We may transfer your personal information to countries outside the EEA but will always ensure appropriate safeguards are in place when doing so. 

We maintain a retention policy to ensure we keep personal information only for as long as we reasonably need it. Please see our Privacy Policy for further details.

2. Your Rights

You have certain rights in relation to your personal information, including the right of access, rectification, erasure, restriction of processing, data portability, objection and withdrawal of consent (where we rely on consent). You also have the right to complain to the Data Protection Commission. These rights may only apply in certain circumstances and are subject to certain exemptions. You can find out more about these rights in the Data Rights section of our Privacy Policy or by contacting us at DPO@aviva.com.