Privacy Policy
Your privacy matters to us. Here's how we protect and handle your personal information when you use our investment reporting services.
Effective Date: January 15, 2025
Who We Are
Diriente Leliavo is a financial services company based in Ireland, specialising in investment reporting and analysis. We operate from Main Street Lanesboro Co, Longford, Co. Longford, N39 N2F4, Ireland, and we're committed to protecting your privacy in accordance with Irish and European data protection laws.
When we say "we," "us," or "our," we're referring to Diriente Leliavo. When we say "you" or "your," we mean anyone who visits our website, uses our services, or otherwise interacts with our business.
Information We Collect
We collect information in several ways, depending on how you interact with our services. Here's what we typically gather:
Personal Details
Your name, email address, phone number, and postal address when you contact us or sign up for our services.
Financial Information
Investment portfolio details, account information, and financial goals that you share with us for reporting purposes.
Technical Data
IP address, browser type, device information, and website usage patterns when you visit our site.
Communication Records
Records of our conversations, emails, and any feedback you provide to help us improve our services.
How We Use Your Information
We use your personal information for specific business purposes. Here's what we do with the data we collect:
Service Delivery
Creating investment reports, analysing your portfolio performance, and providing the financial insights you've requested from us.
Communication
Responding to your enquiries, sending service updates, and keeping you informed about important changes to your reports or our services.
Legal Compliance
Meeting our obligations under Irish financial services regulations and maintaining records as required by law.
Service Improvement
Understanding how our website and services are used so we can make improvements and develop better tools for our clients.
Legal Basis for Processing
Under Irish and EU data protection law, we need a valid reason to process your personal information. Here are the legal grounds we rely on:
- Contract performance: When processing is necessary to provide the investment reporting services you've requested
- Legitimate interests: For improving our services, preventing fraud, and maintaining our business operations
- Legal obligation: When we must process data to comply with Irish financial services regulations
- Consent: For marketing communications or other activities where we've specifically asked for your permission
Data Sharing and Disclosure
We don't sell your personal information to third parties. However, we may share your data in certain limited circumstances:
Service Providers
We work with carefully selected companies that help us deliver our services, such as cloud hosting providers, payment processors, and IT support companies. These providers only access your information as needed to perform their specific functions and are bound by strict confidentiality agreements.
Legal Requirements
We may disclose your information if required by Irish law, court orders, or regulatory authorities. This includes compliance with anti-money laundering regulations and other financial services requirements.
Business Transfers
If our business is sold, merged, or restructured, your information may be transferred as part of that transaction, but it would remain subject to the protections outlined in this privacy policy.
International Data Transfers
Your information is primarily stored and processed within Ireland and the European Union. However, some of our service providers may be located outside the EU, particularly for cloud storage and technical support services.
When we transfer data outside the EU, we ensure appropriate safeguards are in place, such as adequacy decisions from the European Commission, standard contractual clauses, or the recipient's certification under approved frameworks.
We never transfer personal data to countries that don't provide adequate protection without implementing appropriate safeguards to protect your rights.
Your Rights Under Irish and EU Law
As an individual whose personal data we process, you have several important rights. Here's what you can do:
Access Your Data
Request a copy of the personal information we hold about you, including details about how we use it and who we share it with.
Correct Inaccuracies
Ask us to update or correct any personal information that's inaccurate or incomplete.
Delete Your Data
Request deletion of your personal information in certain circumstances, such as when it's no longer needed for the original purpose.
Restrict Processing
Ask us to limit how we use your personal information in specific situations, such as while we investigate a complaint.
Data Portability
Request a copy of your personal data in a structured, commonly used format that you can transfer to another service provider.
Object to Processing
Object to our use of your personal information for certain purposes, such as direct marketing or processing based on legitimate interests.
To exercise any of these rights, contact us using the details provided at the end of this policy. We'll respond within one month of receiving your request.
Data Security Measures
Protecting your personal information is a top priority. We implement multiple layers of security to safeguard your data:
Technical Safeguards
- Encryption of data both in transit and at rest using industry-standard protocols
- Regular security updates and patches for all systems and software
- Secure backup systems with multiple recovery points
- Multi-factor authentication for staff access to client data
Administrative Controls
- Access to personal data is limited to authorised personnel who need it for their work
- Regular training for staff on data protection and security best practices
- Clear procedures for handling and storing personal information
- Regular audits of our data processing activities and security measures
Physical Security
- Secure office premises with controlled access
- Locked storage for any physical documents containing personal data
- Secure disposal procedures for documents and electronic media
Data Retention
We keep your personal information only as long as necessary for the purposes we collected it. The retention period depends on the type of information and legal requirements:
- Client records: We retain investment reports and related data for seven years after the end of our business relationship, as required by Irish financial services regulations
- Communication records: Emails and correspondence are typically kept for three years for business continuity and dispute resolution
- Website analytics: Technical data from website visits is retained for up to two years for performance analysis
- Marketing data: Contact information for marketing purposes is kept until you withdraw consent or we determine it's no longer needed
When the retention period expires, we securely delete or anonymise your personal information. In some cases, we may need to retain certain information longer to comply with legal obligations or resolve disputes.
Cookies and Website Technology
Our website uses cookies and similar technologies to improve your browsing experience and help us understand how visitors use our site.
Essential Cookies
These cookies are necessary for the website to function properly. They enable basic features like page navigation and access to secure areas of the site. The website cannot function properly without these cookies.
Analytics Cookies
We use analytics cookies to understand how visitors interact with our website. This helps us improve the user experience and identify which pages are most useful to our visitors.
Managing Cookies
You can control and delete cookies through your browser settings. However, disabling certain cookies may affect the functionality of our website. Most browsers allow you to see what cookies are stored and delete them individually or clear all cookies.
Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we'll update the "Last Updated" date at the top of this policy.
For significant changes that affect how we use your personal information, we'll notify you by email or through a prominent notice on our website. We encourage you to review this policy periodically to stay informed about how we protect your privacy.
Complaints and Regulatory Contact
If you're not satisfied with how we've handled your personal information or responded to your requests, you have the right to lodge a complaint with the Irish Data Protection Commission.
You can contact the Data Protection Commission at:
- Website: dataprotection.ie
- Email: [email protected]
- Phone: +353 57 8684800
- Post: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
However, we'd appreciate the opportunity to address your concerns directly before you contact the regulator, so please get in touch with us first.
Contact Us About Privacy
If you have questions about this privacy policy, want to exercise your rights, or need to discuss how we handle your personal information, please contact us:
We aim to respond to all privacy-related enquiries within one month. For urgent matters, please call us directly.