1. Introduction

Doyle Pittam Limited trading as Progressive Financial Services is committed to protecting your personal data and respecting your privacy.

This Privacy Notice explains:

• What personal data we collect;
• How and why we use it;
• The lawful bases on which we process it;
• Who we may share it with;
• How long we retain it; and
• Your rights under data-protection law.

For the purposes of the General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018, the data controller is:

Doyle Pittam Limited, trading as Progressive Financial Services
CRO Number: 663902
Registered Office: Unit 1, Ardee Court, Ardee Street, Dublin 8
Telephone: (01) 416 5598
Email: info@progressivefs.ie

Our Data Protection Contact is:

Laura Doyle
Email: laura@progressivefs.ie
Telephone: (01) 416 5598

This Privacy Notice applies to clients, prospective clients, website visitors, people who contact us, trusted contacts, beneficiaries, representatives, professional contacts and job applicants.

2. Personal Data We Collect

Depending on the services you request, we may collect:

• Your name, address, contact details, date of birth and identification documents;
• Information about your family, dependants, beneficiaries or representatives;
• Employment, income, expenditure, assets, liabilities and bank details;
• Details of your mortgages, pensions, investments, savings and insurance policies;
• Information about your financial needs, objectives and attitude to investment risk;
• Health and lifestyle information where required for insurance, pension or mortgage purposes;
• Information required for identity, anti-money-laundering, sanctions and fraud-prevention checks;
• Communications, complaints and marketing preferences;
• Information submitted through our website and information collected through cookies; and
• Recruitment information where you apply for a position with us.

We will only collect personal data that is relevant and necessary for the services being provided or to meet our legal and regulatory obligations.

3. How We Collect Personal Data

We may collect personal data:

• Directly from you;
• From a joint applicant, authorised representative, employer or professional adviser;
• From lenders, insurers, pension providers, investment providers or other intermediaries;
• From identity-verification, regulatory and publicly available sources; and
• Through our website, email, customer relationship management system and other digital services.

Where you provide information about another person, you should ensure that you are authorised to do so and, where appropriate, make them aware of this Privacy Notice.

4. Why We Use Your Personal Data

We may use your personal data for the following purposes:

Providing financial services

We use personal data to:

• Understand your circumstances, needs and objectives;
• Complete a fact-find and needs analysis;
• Assess affordability and suitability;
• Provide financial planning and advice;
• Obtain and compare quotations;
• Recommend, arrange and administer mortgages, pensions, investments, savings, life assurance and protection products;
• Submit and progress applications;
• Communicate with product providers, lenders and other relevant parties;
• Assist with claims and policy servicing; and
• Provide ongoing services where agreed.

The lawful basis is generally that processing is necessary to take steps at your request before entering into a contract or to perform our contract with you.

Meeting legal and regulatory obligations

We process personal data where necessary to comply with legal and regulatory requirements, including:

• Customer identification and verification;
• Anti-money-laundering and counter-terrorist-financing requirements;
• Sanctions and politically exposed person checks;
• Central Bank of Ireland requirements;
• Consumer-protection requirements;
• Suitability and record-keeping obligations;
• Tax and Revenue requirements;
• Complaint handling;
• Fraud prevention; and
• Responding to regulators, courts and other public authorities.

The lawful basis is compliance with our legal obligations.

Operating and protecting our business

We may use personal data to:

• Administer client relationships;
• Maintain accurate business records;
• Protect our systems and information;
• Prevent and investigate fraud or misuse;
• Conduct audits and compliance reviews;
• Manage complaints and disputes;
• Establish, exercise or defend legal claims;
• Improve our services; and
• Manage a sale, merger, reorganisation or transfer of our business.

We rely on our legitimate interests where they are not overridden by your rights and interests. Our legitimate interests include operating an efficient, secure and compliant financial-services business, protecting our clients and defending legal claims.

You may request further information about our assessment of legitimate interests.

Consent

We may rely on your consent where required, including for:

• Certain uses of health or other special-category data;
• Direct electronic marketing;
• Non-essential cookies;
• Recording and using trusted-contact information; and
• Retaining certain prospective-client records where no financial service is ultimately provided.

You may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.

Where information is required to provide a service, withdrawing consent or refusing to provide the information may mean that we cannot obtain a quotation, provide advice, complete an application or continue providing the requested service.

5. Trusted Contacts

At your request, we may record the name and contact information of a person nominated as your trusted contact.

We may contact that person in the circumstances permitted under applicable consumer-protection requirements, including where:

• We have concerns about possible financial abuse;
• We need to confirm your current contact information, health status or the identity of an appointed representative; or
• We experience difficulty communicating with you.

We will obtain the required consent from you and the trusted contact before recording and using the information.

A trusted contact does not have authority to make decisions, give instructions or conduct business on your behalf solely because they have been nominated as a trusted contact.

6. Profiling and Automated Decision-Making

We may use questionnaires, calculators and other tools to assist with:

• Assessing your attitude to investment risk;
• Reviewing affordability;
• Identifying potentially suitable products;
• Obtaining quotations;
• Conducting anti-money-laundering, sanctions and politically exposed person checks; and
• Reviewing insurance information.

These tools support our advisers and do not replace the adviser’s professional assessment.

Progressive Financial Services does not ordinarily make decisions that produce legal or similarly significant effects based solely on automated processing.

A lender, insurer or product provider may conduct its own automated assessment as an independent data controller. Further information will be available in that organisation’s privacy notice.

7. Who We Share Personal Data With

Where necessary and lawful, we may share personal data with:

• Insurance companies;
• Pension, investment and savings providers;
• Banks, mortgage lenders and credit institutions;
• Other intermediaries or secondary brokers used to access a lender or provider;
• Pension trustees, administrators and employers;
• Medical professionals and insurance underwriters;
• Identity-verification, sanctions, anti-money-laundering and fraud-prevention services;
• Our customer relationship management, IT, cloud-storage, email, cybersecurity, telecommunications and digital-signature providers;
• Accountants, auditors, compliance consultants, solicitors and other professional advisers;
• Regulators, including the Central Bank of Ireland;
• Revenue, An Garda Síochána, courts and other public authorities where legally required; and
• A purchaser, successor or adviser in connection with a proposed sale, merger, transfer or reorganisation of our business.

Product providers, lenders and other financial-services firms will generally act as independent data controllers and will process your data in accordance with their own privacy notices. Service providers processing personal data on our behalf are required to protect it and act only in accordance with our instructions and applicable data-protection law. We do not sell your personal data.

8. International Transfers

Some service providers may process or store personal data outside Ireland or the European Economic Area.

Where personal data is transferred outside the EEA, we will ensure that an appropriate legal transfer mechanism is used. This may include:

• A European Commission adequacy decision;
• The European Commission’s Standard Contractual Clauses;
• The EU–US Data Privacy Framework, where the US recipient is a participating organisation; or
• Another lawful safeguard permitted under the GDPR.

You may contact us for further information about the safeguards applying to a particular transfer.

9. How Long We Retain Personal Data

We retain personal data only for as long as necessary for the purpose for which it was collected and to meet our legal, regulatory, contractual and professional obligations.

The following periods will generally apply:

Consumer transaction records

Records detailing consumer transactions relating to our regulated activities will generally be retained for at least six years after the particular transaction is completed or discontinued.

Other regulated consumer records

Other records concerning regulated financial services provided to a consumer will generally be retained for at least six years after we cease providing any financial service to that consumer.

Prospective clients

Where a consumer requests or is offered a financial service but the service is not ultimately provided, relevant records may be retained for up to 12 months where the required consent has been obtained.

Complaints

Comprehensive complaint records relating to a particular transaction will generally be retained for at least six years after the transaction is completed or discontinued.

Other complaint records will generally be retained for at least six years after we cease providing financial services to the consumer concerned.

Anti-money-laundering records

Identification, verification and transaction records required under anti-money-laundering legislation will be retained for the applicable statutory period.

Where another applicable regulatory requirement imposes a longer period, the longer period will apply.

Marketing information

Marketing information will be retained until you withdraw your consent, object to marketing or the information is no longer required.

We may retain a minimal suppression record to ensure that we continue to respect an opt-out request.

Website enquiries

Website enquiries that do not result in a client relationship will generally be deleted within 12 months unless they are required for a legal, regulatory or complaint-related purpose.

Recruitment information

Information relating to an unsuccessful job application will generally be retained for no longer than 12 months after the recruitment process concludes, unless a longer period is agreed with the applicant or required by law.

Legal and regulatory holds

Information may be retained for longer where necessary in connection with:

• An active or reasonably anticipated complaint;
• A Financial Services and Pensions Ombudsman referral;
• A regulatory review or investigation;
• An audit;
• Litigation or other legal proceedings;
• The establishment, exercise or defence of legal claims; or
• Another applicable legal or regulatory obligation.

Once the relevant retention period expires and there is no lawful reason to retain the information, it will be securely deleted or anonymised.

10. Data Security

We use appropriate technical and organisational measures to protect personal data against accidental or unlawful loss, alteration, destruction, unauthorised disclosure or access.

These measures include access controls, secure systems, staff training, appropriate contractual protections and procedures for managing suspected personal-data breaches.

Access to personal data is limited to people who require it for a legitimate business purpose.

11. Direct Marketing

We will send electronic direct marketing only where we have your consent or another lawful basis permitted under applicable direct-marketing rules.

You may withdraw your consent or object to direct marketing at any time by:

• Using the unsubscribe option in the communication;
• Emailing info@progressivefs.ie; or
• Contacting us on (01) 416 5598.

We will not use special-category personal data for direct-marketing purposes.

12. Cookies

Our website uses cookies and similar technologies.

Cookies that are not strictly necessary will be used only where the required consent has been obtained. You can change or withdraw your cookie preferences through the website’s cookie-management tool.

Further information is available in our Cookie Policy.

13. Your Data-Protection Rights

Subject to the conditions and exemptions contained in data-protection law, you may have the right to:

• Request access to your personal data;
• Request correction of inaccurate or incomplete personal data;
• Request deletion of your personal data;
• Request restriction of processing;
• Object to processing based on legitimate interests;
• Object to direct marketing;
• Request the transfer of information you provided to us in a structured, commonly used and machine-readable format;
• Withdraw consent at any time;
• Request not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects; and
• Lodge a complaint with the Data Protection Commission.

These rights are not absolute. For example, we may be legally required to retain information despite a request for deletion.

To exercise your rights, please contact:

Laura Doyle
Email: laura@progressivefs.ie
Telephone: (01) 416 5598

We may request information necessary to verify your identity before responding.

We will respond without undue delay and ordinarily within one month. This period may be extended by up to two additional months where a request is complex or numerous. We will inform you if an extension is required.

There is generally no fee for exercising your rights. A reasonable fee may be charged, or a request may be refused, where it is manifestly unfounded or excessive.

You do not have to complete a particular form to exercise your rights.

14. Complaints

If you have a concern about how we process your personal data, please contact Laura Doyle at laura@progressivefs.ie so that we have an opportunity to address the matter.

You also have the right to lodge a complaint directly with:

Data Protection Commission
6 Pembroke Row
Dublin 2
D02 X963
Ireland

Telephone: (01) 765 0100 or 1800 437 737
Website: www.dataprotection.ie

A complaint concerning our financial services may also be submitted in accordance with our Complaints Procedure.

15. Changes to This Privacy Notice

We may update this Privacy Notice to reflect changes in our business, legal obligations, regulatory requirements or the way we process personal data.

The current version will be published on our website. Where a change materially affects how we use personal data, we will take reasonable steps to bring it to the attention of affected individuals.

Last reviewed: May 2026

Doyle Pittam Limited, trading as Progressive Financial Services, is regulated by the Central Bank of Ireland.