Privacy Policy

1. Introduction

This is our privacy policy. It tells you how we collect and process data received from you through our services, including via our website and mobile app (the ‘App’) and obtained from third parties. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it in line with the General Data Protection Regulation (EU) 2016/679 ('GDPR’).

2. Who we are

Zen Pensions Limited is a 100% Irish-owned insurance intermediary providing pension products to the Irish public. To enable us to provide our products and services we process your personal data, such as financial records. We need to process most of this personal data under the terms of a contract we have with you (your policy) or to meet legal obligations. For further information contact our Data Protection Officer:

  • In writing to Waterloo Exchange, Waterloo Road, Dublin 4, D04 E5W7
  • By telephone – +353 1 539 4363
  • By email – customerservice@zenpensions.com

3. What we may collect

We may collect and process the following data about you:

  • information you provide directly to us through our digital services, on any telephone conversations, over email, through the post or through our affiliated social media pages;
  • identity information and documentation you provide to us online and offline, including proof of identity and address to comply with Anti-Money Laundering law and screening customers against Financial Sanctions and Politically Exposed Persons (PEP) lists;
  • from third parties who we contact directly or indirectly using information you have provided to us;
  • details of transactions you carry out through our services;
  • details of your usage of our website and mobile app, the resources you use, how you interact with us and information about your device (e.g. your IP address, browser, operating system, etc.) or cookie settings;
  • a record of any correspondence between us including but not limited to email, live chat, post and recorded telephone conversations.

4. Why we collect this data

The legal basis for the processing of this data is where:

  • you have agreed and provided consent; you may withdraw your consent at any time;
  • it is necessary for a service or contract you have entered e.g. underwriting and issuing your plan;
  • there are legal or regulatory reasons e.g. where regulators require us to maintain records about our dealings with you or carry out checks for anti-money laundering reasons;
  • we have a legitimate interest to do so (and to which you may object). This means a business reason to use your data which takes into account your rights e.g. recording of phone calls for customer service reasons;
  • under the Irish Data Protection Act 2018 health data can be processed if it is necessary for insurance, life assurance or pension related reasons

5. How we collect this data

We collect this data:

  • directly from you via our App, email or data entered via a form on our website, letters or phone conversations;
  • through your financial broker or financial advisors;
  • from other third parties who carry out searches on our behalf on publicly available information for Financial Sanctions/PEP screening purposes.

6. How we use what we collect

We use information about you to:

  • provide, monitor, administer, maintain, develop, expand and improve our services, including, for example, enhancing our customer service and administering your account;
  • perform internal operations, including, for example, to prevent fraud and abuse of our services;
  • confirm your identity by using third-party providers (e.g. Onfido);
  • locate the existing pensions you request us to find, by liaising, amongst others, with your past and current employers, your financial adviser, relevant government agencies and your current and past pension providers;
  • undertake all activities and communications necessary, in such manner and with such third parties as we determine to be appropriate, for the purposes of achieving the consolidation of your existing pensions into your chosen pension (when you choose to consolidate any previous pensions);
  • send you communications we think will be of interest to you in relation to similar products and services you procure from us;
  • send you newsletters;
  • send push notifications to your mobile device(s);
  • respond to regulatory, government or legal requests that are either legally binding upon us or which we consider legitimate.

7. What happens if you don't provide your personal data?

If you choose not to provide us with your personal data, it may mean we are not able to:

  • provide requested products or services to you;
  • continue to provide existing products or services.

8. How long we keep your data

We only keep your information for as long as there is a business reason, or where regulations say we must. Typically, this is for six years after our relationship with you ends. It will vary depending on the type of data we hold, and the type of products/services provided to you.

9. Who we share your data with

We share your information with the following types of recipients:

  • Acorn Life DAC;
  • doctors and healthcare professionals e.g. where needed for claims;
  • fraud prevention investigators - who assist us in some specific cases in identifying, investigating and preventing fraud;
  • legal advisors;
  • service providers e.g. third parties who provide services on Zen Pensions’ behalf including: IT service providers, mail printing/delivery services, Financial Sanctions and PEP screening;
  • statutory and regulatory bodies e.g. Central Bank of Ireland, Pensions Authority, Irish Revenue and law enforcement authorities;
  • financial brokers or advisors who meet with you to provide advice and product recommendations;
  • your authorised representatives e.g. where you have asked us to share your data with them.

These data transfers are all within Ireland and the European Economic Area (EEA).

10. Your rights

At any time, you may:

  • ask us for a copy of your personal data;
  • correct and update mistakes/incomplete personal data;
  • raise a complaint with the Data Protection Commission.

In certain circumstances you may request that we:

  • delete your personal data (right to be forgotten);
  • restrict use or object to us processing your data e.g. for marketing purposes;
  • take your personal data to another provider;

Where you have consented to the use of your data, you have the right to withdraw this consent at any time. Where a request relates to one of your rights, we ask that you provide the following:

  • name, address and any further contact details such as email or phone number that you would like us to use;
  • a description of your request e.g. what types of personal data you would like a copy of;
  • policy number (where applicable). This will make it easier for us to identify you and your personal data.

Where relevant we may also ask for further proof of identity and address.

11. What happens if you have a data protection complaint

We request that you contacted us initially, to see if we can resolve any issue. But, if you have an issue with how we are processing your personal data, you have the right to raise this with the Data Protection Commission at any time by contacting them using the following details:

https://www.dataprotection.ie/contact

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28

12. Cookies

Zen Pensions uses cookies on our website. Cookies are small pieces of information, stored in data files and placed on your device when you visit our website. We use analytical software to monitor customer traffic patterns on our website. This data is aggregated, and we do not collect personal data from the individual site visitor.

See our Cookie Policy for further details.

13. Our website and links to other websites

You do not have to provide us with any personal data to use our website. Where you choose to give us your personal data through online feedback or enquiry forms, we will treat your personal data as outlined in this policy (see point 9 above).

14. Changes

If we change this privacy policy from time to time, we will post the changes on this page. Any changes will take effect immediately.

Effective Date of this Policy: 3 December 2025

ZenPensions Limited, trading as Zen Pensions. Company Registration No. 666222

Registered Office: Waterloo Exchange, Waterloo Road, Dublin 4, D04 E5W7, Ireland

Telephone+353 1 539 4363 or visit www.zenpensions.com

Zen Pensions Limited is regulated by the Central Bank of Ireland.