Savings and Investment Privacy Policy

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, Dublin 18.

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 insurance cover include the intermediary/financial broker (who is responsible for the sale and suitability of the product).

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 (e.g., your name, DOB, contact details) or more sensitive information (e.g., biometric data for the purposes of Anti-Money Laundering obligations).

We are obliged to collect information on the tax residency of each Applicant/Policy Owner (and where relevant controlling persons). We will ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records. As part of our Anti-Money Laundering obligations, we must also receive information on the source of funds, source of wealth, income, and occupation.

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.

Some of the personal information we use may be provided to us by a third party. This may include information already held about you within the Aviva group, information we obtain from publicly available records, and from industry databases, from your intermediary, financial broker, or other nominated representatives or from other insurance companies.

We process your personal information to provide and administer your product, meet legal and regulatory obligations (including anti-money laundering and tax reporting requirements), prevent fraud and improve our products and services. Depending on the purpose, we rely on the one or more of the following legal bases under data protection law, performance of a contract, compliance with a legal obligation, legitimate interests, or your consent. For more information about the legal bases we rely on, please see our full Privacy Policy at aviva.ie/privacy.

We may also use profiling and other data analytics to understand our customers better (e.g., what kind of content or products would be of most interest) and to predict the likelihood of certain events arising (e.g. to assess insurance risk or the likelihood of fraud). 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 that certain automated decisions we make have human involvement, 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 our suppliers e.g. claim service providers, and regulatory and law enforcement bodies). We may transfer your Personal information to countries outside the EEA but will always ensure appropriate safeguards are in place when doing so.

There is an obligation on financial institutions including Aviva, to collect and report certain information about the tax residence of Policy Owners (and where relevant controlling persons). In certain circumstances, we are required by law to provide Policy information to the Irish Revenue Commissioners who may, in turn, share this information with tax authorities in applicable jurisdictions. Ireland has and will be entering into a number of exchange of information agreements to share tax information, where applicable, with the tax authorities in other territories.

We are obliged to ask for details of tax residency and tax identification numbers (where applicable) and will record this on our records. In certain circumstances, we may be legally required to share the information listed below with the Irish Revenue Commissioners and they may transfer that information to the applicable country:

• Name, address, the jurisdiction of tax residence, Tax Identification Number (TIN or PPSN), and date of birth.
• Policy number and that the Policy is held with Aviva.
• The value of the Policy at the end of the year or at the date it was closed (and the date of closure).
• The gross amount of interest, dividends, proceeds from the sale or redemption of financial assets, or other amounts paid or credited to the controlling person or Policy during the year.
• Where relevant, details of certain controlling persons.

Only information that is legally required to be reported to the Irish Revenue Commissioners will be included in the annual return that we may be obliged to submit. The Irish Revenue Commissioners will only exchange that information with another jurisdiction where there is a legal agreement to do so. In accordance with the applicable exchange of information agreements, Irish tax authorities will also begin to receive information from tax authorities of other territories about non-Irish accounts held by Irish tax residents. For further information on the cross-border sharing of tax information by tax administrations please refer to the Irish Revenue website at http://www.revenue.ie/en/business/aeoi/index.html

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.

You have certain rights in relation to your Personal information including a right to access personal information, a right to correct personal information and a right to erase or suspend our use of your personal information. You also have the right to request for your personal information to be transferred to another organisation, a right to object to our use of your personal information, a right to withdraw consent (where we rely on consent) and a right to lodge a complaint with the Data Protection Regulator. 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 sections of our full privacy policy or by contacting us at DPO@aviva.com.