Privacy Policy

Phoenix American Financial Services, Inc. and PAFS Ireland LTD - Privacy Policy

PAFS Ireland Ltd along with its parent company, Phoenix American Financial Services, Inc., (together ”PAFS”) is committed to protecting and respecting your privacy - please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We adhere to the following Privacy Policy (the “Policy”) together with any disclaimers which sets out the basis on which any personal data we collect from you or that you provide to us, or that is provided to us relating to you by any means will be processed. Please read the following carefully to understand our use of personal data. Please note that the Policy relates only to living individuals in relation to personal data relating directly to themselves, and not to persons in any other capacity. 

Information we may collect from you

We collect personal data from you, which you volunteer when you provide such personal data to us, or via your employment or provision of our services with which you interact. We may also be given other personal data relating to you by other persons, or we may obtain such other personal data about you as may be provided to us in the course of our legitimate business activities. We may collect and process personal data, including the following in the course of providing services to you, which could contain your Personal data:your full nameyour address your various email addresses your various phone numbers including mobile phone numbersyour nationality your PPS / tax identification number(s) financial information about you, including your bank account details, or other payment details details of contracts you have entered with third parties for us to provide services to you details of your relationship to other parties details of your membership of professional or other organisations your date of birth details of your car registration number /driving licence details of your passport all other Personal data which we may be required to process on your behalf, or which is necessary for us to process in order for us to fulfil our roles (i) providing services to or on behalf of you or (ii) employing you.You may give us information about yourself, when you enquire about our services, through your employment with us or correspond with us by phone, e-mail or otherwise provide us with personal data. 

Security and where we store your personal data

We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We will continue to revise policies and implement additional security features as new technologies become available. By submitting your personal data, you agree to this transfer, storing and processing. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorised access.

Uses made of your personal data 

We use your personal data that we hold to:

  • Carry out our obligations arising from any contracts entered into between you and us; 
  • Carry out our obligations providing services to you or in relation to clients we both have responsibilities to;
  • We may be required by law or litigation to disclose your personal information; 
  • We may also disclose information about you if we determine that for national security, law enforcement, or other issues of public importance, the disclosure is necessary;  
  • Comply with legislation; and/or notify you about changes to our services; 
  • We do not sell or rent your contact information to any third party marketers.  

List of services 

  • We may use your personal data to send you information relating to our services. If you do not want us to use your personal data in this way, please notify us to that effect. We keep your personal data for varying periods according to our retention policies. 

Disclosure of your information 

We may disclose your personal data to third parties or share your personal data in order to comply with any legal obligation, or to protect our rights, property, or safety of staff or customers. We may disclose your personal data to other service providers as deemed necessary or appropriate by us to fulfil our obligations. Some jurisdictions may not have adequate safeguards for the protection of personal data, and where this is the case we comply with our obligations under applicable law governing such transfers to provide an alternative method of safeguarding your personal data . If PAFS is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. 

Links to other sites 

Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and that we do not accept any responsibility or liability for those policies.  

Your rights 

You have rights under Irish Data Protection legislation, with regard to our processing of your personal data.You have the right to be informed about any personal data which PAFS holds relating to you, including how we acquired such personal data, and the purposes for which it is being used. This right requires that you will be given a copy of your personal data which you may have supplied to us. To exercise this right, you must make your request in writing, posting it to our address as specified below and including with the request, a copy of appropriate legal form of identification. No fee is required for this service. A request will be dealt with as soon as possible and we will respond to your request within one month from the date on which your request is received. You have the right to have inaccurate personal data corrected. If you discover that we hold inaccurate personal data about you, you have a right to instruct us to correct that information. Such an instruction must be in writing and must contain evidence of the correct information. We will respond as soon as possible, and in any event within one month from the date on which your instructions are received.In certain circumstances, you have the ‘Right to be Forgotten’. This means that you can request that PAFS removes any and all references to you from our records and systems. We will comply with all such requests in a timely manner, as required by GDPR, unless other operational or legal obligations require us to retain such personal data for a particular purpose or period of time. You have the right, at all times, to object to processing of your personal data which you find intrusive, excessive or unwarranted. PAFS will respect your right to do so, but may need to continue such processing where required do to so by law, or within the terms of an existing contractual arrangement.

Changes to this policy

We reserve the right to change this Policy from time to time in our sole discretion. If we make any changes, we will post those changes to our website so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. As long as we have obligations (i) to provide services to you or (ii) in relation to clients we both have responsibilities to or (iii) arising from any contracts entered into between you and us, after we post any such changes, you accept and agree to this Policy as modified. 


PAFS has worked diligently to provide you with accurate and updated information about our Policy, however, we cannot be absolutely certain that everything is free of errors or omissions. We will not be liable for any direct, indirect, incidental, consequential, or punitive damages arising out of your access to or use of our Policy. 

Contact Us 

Questions, comments, requests and complaints regarding this Policy and the personal data we hold are welcome and should be addressed to us as follows:PAFS Ireland Ltd Unit J Block 1, Shannon Business Park, Shannon, Co. Clare, Ireland, with a copy to Phoenix American Financial Services, Inc., 2401 Kerner Boulevard, San Rafael, CA 94901, USA. All requests will be dealt with promptly and efficiently.