This is the website of ILTB Limited T/A GillenMarkets and Gillen. We are committed to protecting and respecting your privacy. We wish to be transparent about how we process your data and to ensure that you understand your data protection rights. Please read this Privacy Statement carefully. It sets out the basis by which any personal data we collect from you or that you provide to us, will be processed by us, as Data Controller. By using this website, you signal your express acceptance of this Privacy Statement. If you do not agree with or you are not comfortable with any aspect of this Privacy Statement, your only remedy is to discontinue use of the website.
ITLB Limited trading as Gillen provides investment advisory services as well as investment education training and a subscription-based newsletter and website to assist investors manage their own assets directly.
Why we collect personal information from you?
As a client or potential client of Gillen we may process your data for a number of reasons:
– To provide an agreed service to you;
– To comply with legal or regulatory obligations e.g. Central Bank statutory codes;
– To provide you with information about the services we offer.
Gillen respects your right to privacy and will not collect any personal information about you without your clear knowledge and permission. Any personal information which you provide to Gillen will be treated strictly in accordance with Irish Data Protection Law and with the EU General Data Protection Regulation (Regulation (EU) 2016/679) known as the Data Protection Acts 1988-2018. Where data is submitted it will be used for the stated purpose and any reasonably incidental purposes only. We do not sell or distribute your personal information to third parties for purposes of allowing them to market products and services to you.
What personal information do we collect from you?
– As an investment advisory client: we collect your contact details including name, address, phone number(s) and email addresses. We also collect PPSN for pension accounts and such other information as is necessary for us to complete an Investment Review and make recommendations that are suitable to meet your investment needs and objectives.
– As a free bulletin subscriber: you will provide your first and last name, email address and county/country. Why do we require your county and country? In case we wish to organise a free workshop outside of Dublin, this information will allow us to decide on where in the country it would be most beneficial to arrange this.
– As a 14-day trial/annual website subscriber: you will be giving us your first and last name, email address, full billing address and phone number. Stripe will retain your credit card details on behalf of Gillen to process your future subscription payments.
– For those who attend our investment training courses: you will be giving us your first and last name, email address, full billing address and phone number. Realex Payments and/or Stripe will retain your credit card details on behalf of Gillen to process your future subscription payments.
– If you purchase a book or attend a conference: you will be giving us your first and last name, email address, full billing address and phone number. Your credit card details will not be retained.
We require your name so that we can personalise our communications to you. We require your email address so that we can communicate with you. We require your billing address and phone number to process online payments.
If you choose to register on the Gillen website, you enter into a contract with us and agree to provide Gillen with accurate data as requested. You do not have to provide us with your personal data but failure to do so may mean that we are unable to register you as an investment advisory or website client or to provide you with the service you requested. In order for us to maintain the accuracy of our data we ask that you inform us of any changes to your personal details as soon as possible.
When registering for an event or buying a book on Gillen website, you will be given the choice to be notified about new or ongoing services or events, important functional changes within our website and other offers that we think you may find beneficial.
If you do not want to receive any further notifications from us, you can unsubscribe at any time by clicking the unsubscribe button in any of our contact emails. You can also unsubscribe by emailing firstname.lastname@example.org or by calling us on 01 287 1400.
How do we collect your personal information?
For investment advisory The information we collect comes primarily from Application Forms completed by clients and from information gathered at client meetings.
For website clients the information we collect comes primarily from online registration forms, email and online contact and phone calls. Information is also collected through your use of this website in the form of ‘cookies’.
– Google Analytics: We use “persistent” cookies to learn how you, and other users, use our services and how well they perform. Google Analytics collects technical data when you visit our website. Technical data includes IP addresses and web browser information. This data helps us to understand visitors’ browsing habits and to compile statistical reports on website activity.
– We use temporary “session” cookies which enable a visitor’s web browser to remember which pages on this website have already been visited. This allows us to identify errors, learn how our services perform, and improve and develop our services over time.
Who we share your information with
We do not share your information with third parties other than as set out in this Policy. We work with other companies who help run our business (“Service Providers”). We are required to send information securely to our Service Providers, who are defined as Data Processors, to perform the services you require. Each of the following Service Providers only has access to the information required to perform their services:
– Wandsoft (for website content management system on private.gillenmarkets.com)
– WooCommerce (for eCommerce purposes)
– Realex (for payment purposes only)
– Stripe (for payment purposes only)
– Oak Tree Press (for book purchases only)
We may share your information in the following circumstances:
– Regulators and for legal reasons: We may be requested to provide personal information about our investment advisory clients to our regulators in order for them to discharge their duties.
– Other Service Providers: We may share personal information with other Service Providers, where necessary to provide our services to you. All of our Service Providers will be obliged to keep your personal information safe and secure. Communicating via the internet and sending information to you by other means necessarily involves your personal information passing through or being handled by third-parties.
– Legal and safety: In certain instances, we may share information where we reasonably believe that it is necessary for legal reasons, to defend our legal rights, to enforce our terms or to protect our rights, property, users, customers or the safety of any person. For example, we may provide personal information where ordered by a court to do so.
At all times Gillen will control and remain responsible for the use of your personal data.
How long will we retain your data for?
Gillen will only hold your personal information for the duration necessary to allow us to provide the services that you have requested or for any additional period as required for legal and regulatory purposes.
Your rights in relation to your personal information
– For processing activities for which we rely on consent as a basis for processing your data, you have the right to withdraw your consent at any time.
– For processing activities which are based on a statutory or contractual requirement, you may request your data not be processed for that purpose. However, this is not an absolute right and may be over-ridden by our legal and regulatory obligations. In other cases, requesting that data should not be processed for a particular purpose may prevent us from executing a contract or delivering a service to you.
You have the right to request:
– A copy of data we hold about you (Right of Access)
– That any error in data we hold about you is corrected (Right of Rectification)
– That data we hold about you be erased, unless we have a countervailing interest or legal or regulatory obligation to retain it (Right of Erasure)
– That we refrain from processing data for a specific purpose (Right to Restrict processing)
– A copy of the data in a structured, commonly used and machine-readable form to enable you to reuse your personal data for your own purposes across different services (Right of Data Portability)
We will accede to any such valid requests within 30 calendar days of the receipt of a valid request in writing. Please send all requests in writing to Data Protection Manager, Gillen, 29 Mount Street Upper, Dublin 2 or email@example.com. We reserve the right to request you to provide additional information to enable us to identify your personal data and/or to verify your identity.
We generally store personal information on servers located inside the European Economic Area. However, in certain cases it may be necessary for us to transfer certain information to servers located outside of the EU. It is important to be aware that the privacy protections in certain jurisdictions may not be equivalent to those in Europe. We only transfer your information outside the EEA where permitted by law and ensuring that it is subject to appropriate protections.
We take our security responsibilities seriously, employing the most appropriate physical and technical measures.
Governing Law and Jurisdiction
This legal notice and all issues regarding this website are governed exclusively by Irish law and are subject to the exclusive jurisdiction of the Irish courts.
Delay or failure on our part in enforcing any of our rights shall not constitute a waiver by us of our rights and remedies. If any part of this Privacy Notice is held to be invalid or unenforceable, the validity or enforceability of the remainder will not be affected.
Any queries or complaints concerning the collection or use of your personal data should be sent to: Managing Director, GillenMarkets, 29 Mount Street Upper, Dublin 2 or firstname.lastname@example.org. You have the right to lodge a complaint with the Data Protection Commissioner (www.dataprotection.ie) about the processing of your personal data.
Changes to this Privacy Statement
We reserve the right to modify this statement at any time. Each time you use this website you shall be bound by the then current Privacy Statement and accordingly you should review the Privacy Statement each time you visit the website. This Privacy Statement was last updated on September 2021.