Vista Advisers Limited — Privacy Notice
1. INTRODUCTION
Vista Advisers Limited (“Vista”, “we”, “us” or “our”) is committed to protecting your privacy and handling your personal information responsibly.
This Privacy Notice explains how we collect, use, store, share and protect your personal information when you:
- visit our website;
- enquire about our services;
- engage us to provide financial planning or investment advice;
- communicate with us; or
- otherwise interact with Vista Advisers Limited.
We recognise that clients entrust us with highly confidential personal and financial information. We take this responsibility seriously and seek to process personal information fairly, lawfully and transparently in accordance with applicable data protection legislation, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Irish Data Protection Act 2018.
Please read this Privacy Notice carefully. If you have any questions regarding the processing of your personal information, please contact us using the details provided in Section 12.
2. WHO WE ARE
Vista Advisers Limited is an independent financial planning and investment advisory firm regulated by the Central Bank of Ireland.
Our registered details are:
Vista Advisers Limited Registered Office: 2 Redwood Grove, Blackrock, County Dublin, A94 Y058, Ireland. Company Registration Number: 804064. Central Bank of Ireland Reference Number: C576851. General enquiries: info@vistaadvisers.ie Privacy and compliance enquiries: compliance@vistaadvisers.ie
For the purposes of data protection legislation, Vista Advisers Limited is the Data Controller in relation to the personal information described in this Privacy Notice.
Vista has not appointed a Data Protection Officer, as it is not required to do so under applicable legislation. Responsibility for overseeing data protection compliance rests with Vista’s compliance contact, who can be reached at compliance@vistaadvisers.ie.
3. THE PERSONAL INFORMATION WE COLLECT
The personal information we collect will depend upon the nature of your relationship with Vista and the services we provide.
Information may include:
Identity Information — name; date of birth; gender; PPS Number (where required); passport or driving licence details; photographic identification; signature.
Contact Information — postal address; email address; telephone numbers; preferred communication methods.
Financial Information — where relevant to the services being provided, we may collect information relating to income, expenditure, assets, liabilities, investments, pensions, insurance arrangements, banking information, tax status, employment and business interests, source of wealth and source of funds.
Family Information — where relevant to the advice being provided, we may collect information regarding marital or civil partnership status, dependants, beneficiaries, attorneys, executors, trustees and family financial arrangements.
Sensitive (Special Category) Personal Data — in certain circumstances, we may need to process special category personal data where this is necessary to provide financial advice or arrange financial products. This may include information relating to health, medical history, capacity and vulnerability.
We will only process special category data where you have given your explicit consent, or where another condition under Article 9 of the GDPR and the Data Protection Act 2018 applies, such as the establishment, exercise or defence of legal claims. Where we rely on your explicit consent, you may withdraw it at any time.
Regulatory Information — to comply with our legal and regulatory obligations we may also collect information relating to anti-money laundering requirements, Politically Exposed Person (PEP) status, financial sanctions, tax residency, and FATCA and CRS reporting.
Website Information — when you visit our website we may collect certain technical information including IP address, browser type, device information, website usage information and cookie information. Further details are contained within our Cookie Policy.
Information about individuals connected with a client
In some circumstances we hold limited personal information relating to individuals connected with a client, such as spouses, partners, dependants, beneficiaries, attorneys, executors or trustees, where this is necessary for the provision of our services or to comply with legal or regulatory obligations. We usually receive this information from the client rather than from the individual concerned. We ask clients to make those individuals aware of this Privacy Notice. The categories of information, and the uses described in this Notice, apply equally to that information.
Providing your information
Some information is required by law (for example, identity and verification information under anti-money laundering legislation), and some is necessary for us to provide advice. If you do not provide information we are legally required to obtain, we may be unable to act for you. If you do not provide information needed to advise you, we may be unable to provide advice, or our advice may be limited.
4. HOW WE COLLECT YOUR INFORMATION
We collect personal information in a number of ways.
Information You Provide — most personal information is obtained directly from you. This may occur when you contact us; complete forms or questionnaires; attend meetings; communicate by email or telephone; provide documents; or engage Vista to provide advice.
Information From Third Parties — where appropriate, and usually with your authority, we may receive information from third parties including product providers, pension providers, investment platforms, investment managers, insurance companies, accountants, solicitors, tax advisers, trustees, employers and other professional advisers.
Information Collected Automatically — when you use our website, certain information may be collected automatically through cookies and similar technologies. Please refer to our Cookie Policy for further information.
Information Required by Law — certain information is collected because Vista is subject to legal and regulatory obligations, including obligations relating to anti-money laundering, taxation, regulatory reporting and financial services legislation.
5. WHY WE PROCESS YOUR PERSONAL INFORMATION
Vista only processes personal information where there is a lawful basis for doing so under applicable data protection legislation.
The table below summarises the principal purposes for which we process personal information and the legal basis relied upon.
| Purpose of Processing | Typical Information Used | Legal Basis |
|---|---|---|
| Responding to enquiries and arranging introductory meetings | Contact details and enquiry information | Legitimate Interests |
| Providing financial planning and investment advice | Identity, contact, financial and family information | Performance of a Contract |
| Assessing suitability of financial products and recommendations | Financial, investment and personal information | Performance of a Contract and Legal Obligation |
| Preparing financial plans, reports and recommendations | Financial and personal information | Performance of a Contract |
| Carrying out anti-money laundering and client due diligence | Identity documents, source of funds, source of wealth and related information | Legal Obligation |
| Complying with Central Bank of Ireland and other regulatory requirements | Client records and regulatory information | Legal Obligation |
| Maintaining client files and records | Advice records, correspondence and supporting documentation | Legal Obligation and Legitimate Interests |
| Communicating with clients regarding services | Contact details and engagement information | Performance of a Contract and Legitimate Interests |
| Introducing clients to third-party professional advisers where requested | Relevant contact and engagement information | Performance of a Contract or Consent, depending on the circumstances |
| Sending marketing communications | Contact details | Consent, or where permitted for existing clients under the ePrivacy Regulations |
| Improving our website and online services | Technical and website usage information | Consent (for non-essential cookies); Legitimate Interests for any subsequent analysis |
Where we rely on your consent to process personal information, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.
Where we rely on legitimate interests, those interests are: administering and managing our business; maintaining accurate records; ensuring the security of our systems and information; communicating with clients about our services; and establishing, exercising or defending legal claims. We rely on legitimate interests only where they are not overridden by your interests or rights.
Automated decision-making
Vista does not make decisions about you using solely automated means that produce legal or similarly significant effects. Where we use questionnaires or planning tools, the outputs inform the judgement of your adviser; they do not by themselves determine the advice given.
6. WHO WE MAY SHARE YOUR INFORMATION WITH
Vista treats client information as confidential and will only share personal information where there is a legitimate reason to do so.
Depending on the services being provided, we may share information with:
- Product providers and investment platforms.
- Pension providers.
- Insurance companies.
- Investment managers.
- Custodians.
- Accountants.
- Tax advisers.
- Solicitors.
- Trustees.
- Professional advisers appointed by you.
- Regulatory authorities.
- Government bodies where required by law.
- Our professional advisers, including legal advisers, auditors and insurers.
- Technology and IT service providers who support the operation of our business.
We will only share information that is reasonably necessary for the relevant purpose.
Where third parties process personal information on our behalf (for example, technology and IT service providers), they do so under written contracts that require them to protect it and to act only on our instructions.
Where appropriate, we will seek your authority before sharing information with third parties, unless disclosure is required or permitted by law.
Vista does not sell personal information to third parties.
7. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
Vista primarily stores and processes personal information within Ireland and the European Economic Area (EEA).
Where personal information is transferred outside the EEA, we take appropriate steps to ensure that suitable safeguards are in place. Depending on the destination and the provider, we rely on an adequacy decision (including, where applicable, the EU–US Data Privacy Framework), Standard Contractual Clauses, or another lawful transfer mechanism recognised under the GDPR.
Some technology providers engaged by Vista may process limited information outside the EEA. Where this occurs, appropriate contractual and technical safeguards are implemented to protect personal information. A copy of the relevant safeguards is available on request.
8. HOW LONG WE KEEP YOUR INFORMATION
Vista retains personal information only for as long as is necessary to:
- provide our services;
- comply with legal and regulatory obligations;
- respond to complaints or legal claims; and
- protect the legitimate interests of Vista and its clients.
Retention periods vary depending on the nature of the information and the services provided.
Certain records are retained for minimum periods prescribed by law and regulation (for example, under anti-money laundering, taxation and financial services legislation). Details of Vista’s record retention practices are available on request.
When personal information is no longer required, it will be securely deleted, destroyed or anonymised, as appropriate.
9. HOW WE PROTECT YOUR PERSONAL INFORMATION
Vista takes the security of personal information seriously and maintains appropriate technical, organisational and administrative measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
These measures include, where appropriate:
- Secure cloud-based business systems (currently provided through Microsoft 365).
- Multi-factor authentication.
- Encrypted devices and communications where appropriate.
- Access controls based on business need.
- Regular software and security updates.
- Secure document storage and disposal procedures.
- Appropriate oversight of third-party technology providers.
While no method of electronic transmission or storage can be guaranteed to be completely secure, Vista continually reviews its security arrangements and seeks to apply appropriate safeguards to protect personal information.
10. YOUR RIGHTS
Subject to applicable data protection legislation, you may have the right to:
- Request access to the personal information we hold about you.
- Request correction of inaccurate or incomplete personal information.
- Request erasure of personal information in certain circumstances.
- Request restriction of processing in certain circumstances.
- Object to certain processing activities, including the right to object at any time to the use of your information for direct marketing.
- Request the transfer of your personal information to another organisation where applicable.
- Withdraw consent where processing is based upon your consent.
- Lodge a complaint with the Data Protection Commission.
Requests relating to your personal information should be submitted to:
Compliance contact Vista Advisers Limited Email: compliance@vistaadvisers.ie
We will respond to requests in accordance with applicable data protection legislation.
11. COOKIES
Vista’s website uses cookies and similar technologies to improve website functionality, analyse website usage and enhance user experience.
Where required by law, your consent will be requested before non-essential cookies are placed on your device.
Further information regarding the cookies used on our website can be found in our Cookie Policy.
12. CONTACTING VISTA REGARDING PRIVACY
If you have any questions regarding this Privacy Notice or the way in which Vista processes your personal information, please contact:
Compliance contact Vista Advisers Limited Registered Office: 2 Redwood Grove, Blackrock, County Dublin, A94 Y058 Email: compliance@vistaadvisers.ie General enquiries: info@vistaadvisers.ie
13. MAKING A COMPLAINT
If you are dissatisfied with the way Vista has handled your personal information, we would encourage you to contact us in the first instance so that we can seek to resolve your concerns promptly.
You also have the right to make a complaint to the Data Protection Commission. Details can be found at www.dataprotection.ie.
This does not affect any other legal rights or remedies that may be available to you.
14. CHANGES TO THIS PRIVACY NOTICE
Vista may update this Privacy Notice from time to time to reflect changes in legal or regulatory requirements, technology, business operations or the services we provide.
The current version will be available on our website. Clients will be notified of material changes where required by law.