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Cookie Policy

Cookies are small text files placed on your computer and are commonly used on the internet. There are various types of cookies which perform different functions, such as remembering which items you have placed in your shopping basket or analysing your browsing behaviour to enable advertisers to present you with adverts more relevant to you and your interests. For more information about cookies, visit www.allaboutcookies.org.

Accepting or Rejecting Cookies

Most web browsers will accept cookies, but if you would prefer we did not collect data by this method, you can disable this function within your browser settings. If you want to delete any cookies that are already on your computer, please refer to the instructions for your file management software to locate the file or directory that stores cookies.

We may use cookies to:

Collect information that will help us to distinguish visitors, to understand visitors’ browsing habits on our website and to improve their experience.
Compile statistical reports on website activity e.g. numbers of visitors and the pages they visit.
Collect information that will allow us to tailor advertising to make it more relevant for you, based on your previous interactions with our website.
Remember information about you when you visit our site. Some of the cookies are essential in order to provide our services to you.

Below, we have set out the four categories of cookies that we may use on our website.

These cookies are:

Strictly necessary cookies
Performance cookies
Functionality cookies
Targeting cookies

This website may also include third party cookies, which are cookies not set by Linehan & Co. Insurances Ltd trading as Breeze Insurance. In each of the four categories above, we have specified where third party cookies are used.

The following types of cookies may be used during your visit to our website:

Strictly Necessary Cookies

These cookies are essential to enable you to move around a website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for, such as obtaining a quote, cannot be provided.

These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

These cookies will be reviewed on a quarterly basis.

Performance Cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the website, all of which enables us to see how visitors use the website to improve the way that our website works. These cookies do not collect information that identifies a visitor, as all information these cookies collect is anonymous and is only used to improve how our website works.

Cookie	Purpose of Cookie
Campaign	User campaign reference.
Url Referrer	User URL referrer.
Google analytics: _utma, _utmb, _utmc, _utmz	Used to anonymously track website use*.

*To opt out of being tracked by Google Analytics across all websites please visit http://tools.google.com/dlpage/gaoptout. These cookies will be reviewed and updated on a quarterly basis.

Functionality Cookies

These cookies allow a website to remember choices you make (such as your language or the region you are in) and provide enhanced features. For instance, a website may be able to provide you with news or updates relevant to the policies you buy. These cookies can also be used to remember changes you have made to text size, font, and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised. They do not gather any information about you that could be used for advertising or remember where you have been on the internet. These cookies will be reviewed and updated on a quarterly basis.

Targeting Cookies

These cookies are not used on this website. These cookies collect several pieces of information about your browsing habits. They are usually placed by advertising networks rather than website operators. They remember that you have visited a website and share this information with other organisations such as advertisers. They do this to provide you with targeted adverts more relevant to you and your interests. Quite often they will be linked to site functionality provided by the other organisation. Although the cookies can track your visits around the web they do not usually know who you are. Without these cookies, online advertisements you encounter will be less relevant to you and your interests. These cookies will be reviewed and updated on a quarterly basis.

These cookies will usually be third party cookies, although if you are visiting the advertising network’s own website, it is technically possible these could be first party cookies. These cookies can be associated with services provided by the third party, but this is not always the case. All information these cookies collect is anonymised, although they contain a unique key that can distinguish individual user browsing habits or store a code that can be translated into a set of browsing habits or preferences. The third party’s Privacy Policy on their website will typically indicate if the cookie is being used as part of an advertising network.

Examples include:

Cookies placed by advertising networks to collect browsing habits to target relevant adverts to you. The site you are visiting need not actually be serving adverts, but often this will also be the case.

Information on deleting or controlling cookies is available at www.allaboutcookies.org.

Please note that if you disable cookies, the website functionality may be impaired and prevent you from obtaining a quotation or completing your purchase online.

Privacy Policy

Privacy Notice

Linehan & Co. Insurances Ltd trading as Breeze Insurance is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights.

For the purposes of the GDPR the data controller is Linehan & Co. Insurances Ltd trading as Breeze Insurance. Our contact details are:

Address: Main St., Boherbue, Mallow, Co. Cork
Phone: +353 1 576 6894
Email: care@breezeinsurance.ie

When we refer to we/us, we mean Linehan & Co. Insurances Ltd trading as Breeze Insurance.

Please read this Privacy Notice carefully as this sets out the basis on which any personal data, we collect from you, or that you provide to us, will be processed by us.

Who are we?

We are a digitally led Irish based insurance intermediary providing general and life insurances intermediary services. We retain a focus on delivering best in class customer service, coupled with providing our clients with great products offered by our diverse panel of insurers.

Our GDPR Owner can be contacted directly here:

Name: John Linehan
Email address: care@breezeinsurance.ie
Phone number: +353 1 576 6894

How do we collect your information and what information do we collect?

Our organisation collects personal data in the following ways, if you:

request a service from us; request a quotation for insurance; request further contact regarding our products or services; request advice regarding investment products or services;
register with or use any of our websites or online applications; to obtain a quotation; to request follow up contact regarding a product or service;
use our website/apps and it installs cookies or other tracking technologies onto your device.
engage with us on social media through LinkedIn, Facebook or Instagram;
contact us with a complaint or query;
apply for a position with us through email, LinkedIn or via or website.

What information do we collect?

The information we collect about you includes the following:

1.	Contact and Identifying information, e.g., name, address, contact details; email, mobile, landline
2.	Unique identifiers e.g. · PPS number – the reason why we collect your PPS number is to assist with providing services in connection with life insurance products that we sell whereby the insurer mandates the collection of such information, or otherwise. · pension scheme reference number- the reason why we collect this is for use when we sell life insurance related products · insurance policy numbers, the reason why we collect this is to be able to reference this policy is we need to communicate with agents or providers of existing policies you might have, given your consent.
3.	Demographic details, age, gender, marital status, lifestyle, and insurance requirements; date of birth, dependents, photo ID, as well as collecting personal information about you, we may also use personal information about other people, for example family members you wish to insure on a policy. E.g., your children/spouse
4.	Family and Beneficiary Data, e.g., dependants, next of kin or nominated beneficiaries, Power of Attorney, Enduring Power of Attorney. Details of Solicitor/Tax Advisor/Accountant.
5.	*Employment information* e.g., role, employment status (such as full/part time, contract), salary information, employment benefits, and employment history; This information is necessary for our Fact Find with our clients.
6.	Publicly available sources: e.g., Information about you in the public domain such as Director information from the Companies Registration Office.
7.	Health information such as information about your health status, medical records and medical assessment outcomes; We collect medical information relating to personal habits (e.g., smoking and consumption of alcohol), medical history. We may also process certain special categories of information, for example information about your personal characteristics (biometric information) or disability information. This information may be collected for the benefit of us proving insurances in the form of Life cover, health insurance, etc.
8.	Pensions and Insurance Benefits information such as current benefits, pension entitlement information, date of retirement and any relevant matters impacting your benefits such as voluntary contributions, PAO, etc.
9.	Financial details e.g., bank account details, details of your credit history and bankruptcy status, salary, tax code, third-party deductions, bonus payments, benefits and entitlement data, national insurance contributions details, etc.
10.	Claims Data (From you and any relevant third parties)
11.	*Marketing preferences*: we will only send you direct marketing if you explicitly consent, either through our website, by phone, email or written correspondence.
12.	Online information: e.g., information about your visits to our websites; please refer to our Cookies Notice at the footer of our webpage for further information.
13.	Events information e.g., information about your interest in and attendance at our events, including provision of feedback forms;
14.	Social media information (e.g., likes and posts) with our social media presence; this includes LinkedIn, Facebook and Instagram
15.	Criminal records information e.g., the existence of or alleged criminal offences, or confirmation of clean criminal records for motor products.

When our organisation collects sensitive personal data as defined within the GDPR we will ensure that we require this information, and we have your explicit consent and/or authorisation prior to our collection. Please see the further information contained in this Privacy Notice that outlines special categories of personal data.

Information we automatically collect.

We sometimes automatically collect certain types of information when you visit our websites and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. Other cookies such as functional cookies, marketing cookies and analytical cookies will only be used with your expressed consent. Further information about our use of cookies can be found in our Cookie Notice at the footer of our web page, here.

How do we use your personal data?

Your Personal Data will be used to enable us to fulfil our contractual obligations in relation to your request for insurance, investment, protection, pension products, independent financial advice, quotes.

1.	Performing services for our clients and prospective clients – when you require insurance/investment products, we use your data to enable us to provide the required product
2.	Statutory and other regulatory requirements – we are required to carry out various obligations which include: · AML/Sanction checking · Knowing your customer “Fact Find” · Adherence to the Consumer Protection Code
3.	Communicate and marketing to you – We do this by phone, through email, Google Ad services, Bing Ad services, Social Channels (LinkedIn, Facebook & Instagram).
4.	Process claims – We do this by gathering information relative to the claim by sending you our Claims Form and asking that you fill this in and return it to us for onward issue to the relevant insurer.
5.	To contact you if required or to respond to any communications that you might send to us.
6.	To administer our site including data analysis, testing, research, statistical and survey purposes.
7.	Carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request.
10	Handling complaints Please refer to a our Complaints Handling Procedure here for further details.
11	To notify you about changes to our services

Legal Basis

We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to collect and use your personal data.

Performance of a contract	When we enter a contract with you, we will collect and use your personal data to enable us to fulfil that service.
Legal obligation	The use of some of your personal data is necessary for us to meet our legal obligations e.g., pension contributions for Revenue Certificates, Regulatory purposes to the Central Bank.
Consent	Sometimes we may rely on consent as a legal basis for processing your information. For example, we rely on consent to collect and use personal data for any criminal convictions or alleged offences. This is used when we need to assess risk relating to an insurance policy for you. We share this information with other third parties where it is necessary to manage these services provided to you – these services include insurance underwriters, reinsurer and other insurance providers. We may also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely. We will also ensure that we use clear and plain language and if you give us your consent you can withdraw this easily at any time. Sometimes if you refuse to provide information that we reasonably require to provide the services, we may be unable to offer you the services and/or we may terminate the services provided with immediate effect.
Legitimate interests	Where we rely on this legal basis to collect and use your personal information, we shall take appropriate steps to ensure the processing does not infringe the rights and freedoms conferred to you under the applicable data privacy laws.

If you require further information on any of the above basis for processing your data, we can provide you with further details.

How we share your data

When required, we may make your information available to third parties with whom we have a relationship, where that third party is providing services on our behalf. We will only provide those third parties (data processors) with information that is necessary for them to perform the services. We will take measures to protect your information, such as putting in place Standard Contractual Clauses and confidentiality agreements.

1.	Insurance Partners where we need to manage the services provided to you such as Product Providers and insurance underwriters, reinsurers, and loss adjuster. You can refer to their privacy statements on their website for more information about their privacy practices.
2.	Vetting and risk management agencies such as credit reference, criminal record, fraud prevention, data validation and other professional advisory agencies, where necessary to prevent and detect fraud in the insurance industry and take steps to assess the risk in relation to prospective or existing insurance policies and/or the services.
3.	Legal advisers, loss adjusters, and claims investigators, where necessary to investigate, exercise or defend legal claims, insurance claims or other claims of a similar nature;
4.	Medical professionals, e.g., where you provide health information in connection with a claim against your insurance policy; or when we are providing a quote for insurance.
5.	EU Law enforcement bodies, when required to do so by law and/or regulation, or another legal request.
6.	Public authorities, regulators and government bodies, where necessary for us to comply with our legal and regulatory obligations, or in connection with an investigation of suspected or actual illegal activity;
7.	Third-party processors: We outsource our processing operations to suppliers that process personal information on our behalf. Examples include IT service providers who manage our IT and back-office systems and telecommunications networks, and accounting and payroll providers, CRM providers. These processing operations remain under our control and we have data processing agreements in place with all our third party processors to ensure all processing is carried out in accordance with our security standards and the GDPR.
8.	Internal and external auditors where necessary for the conduct of company audits or to investigate a complaint or security threat.
9.	On the sale or reorganisation of our business whether by asset or share disposal or other transaction relating to our business.

Security

The security of your personal data is important to us, we have implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk. We have processes in place to protect your personal data from loss, unauthorised access, misuse, alteration and destruction.

Retention

Linehan & Co. Insurances Ltd trading as Breeze Insurance shall not keep personal data in a form that permits identification of data subjects for a longer period than is necessary.

Linehan & Co. Insurances Ltd trading as Breeze Insurance may store data for longer periods if the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, subject to the implementation of appropriate technical and organisational measures to safeguard the rights and freedoms of the data subject.

The retention period for each category of personal data will be set out in our Retention Schedule along with the criteria used to determine this period, including any statutory obligations we have.

Personal data will be disposed of securely.

Liability insurance

If you hold insurance against a liability that may be incurred by you against a third party, where for whatever reason you cannot be found or you become insolvent, or the court finds it just and equitable to so order, then your rights under the contract will be transferred to and vest in the third party even though they are not a party to the contract of insurance. The third party has a right to recover from the insurer the amount of any loss suffered by them. Where the third party reasonably believes that you as policyholder have incurred a liability the third party will be entitled to seek and obtain information from the insurer or from any other person, who is able to provide it including Linehan & Co. Insurances Ltd trading as Breeze Insurance concerning:

the existence of the insurance contract,
who the insurer is,
the terms of the contract, and
whether the insurer has informed the insured person that the insurer intends to refuse liability under the contract.

Data Subjects Rights:

Linehan & Co. Insurances Ltd trading as Breeze Insurance will facilitate your rights in line with our data protection policy and the Subject Access Request procedure. This is available on request.

Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. (The erasure of such data will be dependent on our other legal obligations, and whether the data is subject of legal privilege).
Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling.
Right to make a complaint: if we refuse your request under rights of access, we will provide you with a reason as to why.

All the above requests will be forwarded on, should there be a third party involved, as we have indicated in the processing of your personal data.

Complaints

If you wish to make a complaint about how your personal data is being processed by Linehan & Co. Insurances Ltd trading as Breeze Insurance or how your complaint has been handled, you have the right to lodge a complaint with our GDPR Owner.

Failure to provide further information.

If we are collecting your data for a contract and you cannot provide this data, the consequences of this could mean the contract cannot be completed or details are incorrect.

When you fail to provide us with information we require to fulfil our obligations to you, we may be unable to offer our services to you.

Profiling – automatic decision making.

An automated decision is when we input your personal data into a computer programme and this programme analyses your personal data to provide us with a result. There is no human involvement in the decision making. An example of this is our use of Applied Systems eQuote and Relay software to facilitate the generation of quotations from our insurance panel. If a decision is taken by automated means, you have the right to object to this and ask us to reconsider the service you have asked us to provide.

Special Categories of personal data

Special categories of data are sensitive in relation to your fundamental rights and freedoms and therefore require specific protection when processed as these could create significant risks to the rights and freedoms of individuals.

If we collect any special categories of personal data, such as health data, we will either obtain your explicit consent or we will adhere to the Data Protection Act 2018. This Act allows us to process special categories of personal data for insurance and pension purposes. We will ensure we have suitable and specific measures in place to safeguard the rights and freedoms of you and the processing of your data. These measures relate to the below:

a policy of insurance or life assurance,
a policy of health insurance or health related insurance
an occupational pension, a retirement annuity contract or any other pension arrangement
the mortgaging of a property

Contact Us

Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on:

Email address: care@breezeinsurance.ie
Phone number: +353 1 576 6894

Privacy notice/ statement changes

When we update this Privacy Notice/Statement, we will post a revised version online. Changes will be effective from the point at which they are posted. We would encourage you to review our Privacy Notice so that you are aware of updates.

Term of Business

Breeze Insurance Ltd trading as Breeze Insurance

These Terms of Business set out the general terms under which our firm will provide business services to you and the respective duties and responsibilities of both the firm and you in relation to such services. Please ensure that you read these terms thoroughly and if you have any queries we will be happy to clarify them. If any material changes are made to these terms we will notify you.

Authorisation with the Central Bank of Ireland

Breeze Insurance Ltd trading as Breeze Insurance (109879) is regulated by the Central Bank of Ireland as an insurance intermediary registered under the European Union (Insurance Distribution) Regulations 2018 and as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995. Copies of our regulatory authorisations are available on request. The Central Bank of Ireland holds registers of regulated firms. You may contact the Central Bank of Ireland on 1890 777 777 or alternatively visit their website at www.centralbank.ie to verify our credentials.

Codes of Conduct

Breeze Insurance Ltd trading as Breeze Insurance is subject to the Consumer Protection Code, Minimum Competency Code and Fitness & Probity Standards which offer protection to consumers. These Codes can be found on the Central Bank’s website www.centralbank.ie

Our Services

Breeze Insurance Ltd. is a member of Brokers Ireland. Our principal business is to provide advice and arrange transactions on behalf of clients in relation to life & pensions and general insurance products. A full list of insurers, product producers and lending agencies with which we deal is available on request. Insurance Intermediary Services (except for Insurance based Investment Products (IBIPs)) We act as an Independent Broker which means that:

a) the principal regulated activities of the firm are provided on the basis of a fair and personal analysis of the market; and
b) you must pay for our services by means of a fee. We provide our services on the basis of independent advice. This means that the firm does not accept any third-party payments (i.e. commissions) from Providers.

Fair and Personal Analysis The concept of fair and personal analysis describes the extent of the choice of products and providers offered by an intermediary within a particular category of life assurance, general insurance, mortgages, and/ or a specialist area. The number of contracts and providers considered must be sufficiently large to enable an intermediary to recommend a product that would be adequate to meet a client’s needs. The number of providers that constitutes ‘sufficiently large’ will vary depending on the number of providers operating in the market for a particular product or service and their relative importance in and share of that market. The extent of fair analysis must be such that could reasonably be expected of a professional conducting business, taking into account the accessibility of information and product placement to intermediaries and the cost of the search. In order to ensure that the number of contracts and providers is sufficiently large to constitute a fair and personal analysis of the market, we will consider the following criteria:

the needs of the customer,
the size of the customer order,
the number of providers in the market that deal with brokers,
the market share of each of those providers,
the number of relevant products available from each provider,
the availability of information about the products,
the quality of the product and service provided by the provider,
cost, and
any other relevant consideration.

Investment Intermediary Services We are renumerated by commission for our investment intermediary services.

Insurance based Investment Products We are remunerated by commission for the advice we provide on our insurance based investment products.

Life & Pensions/Deposits & Life Wrapped Investments We provide life assurance and pensions on a fair and personal analysis basis i.e. providing services on the basis of a sufficiently large number of contracts and product producers available in the market to enable us to make a recommendation, in accordance with professional criteria, regarding which contract would be adequate to meet your needs. We will provide assistance to you for any queries you may have in relation to the policies or in the event of a claim during the life of the policy and we will explain to you the various restrictions, conditions and exclusions attached to your policy. However, it is your responsibility to read the policy documents, literature and brochures to ensure that you understand the nature of the policy cover; particularly in relation to PHI and serious illness policies. Specifically on the subject of permanent health insurance policies we will explain to you; a) the meaning of disability as defined in the policy; b) the benefits available under the policy; c) the general exclusions that apply to the policy; and d) the reductions applied to the benefit where there are disability payments from other sources. For a serious illness policy, we will explain clearly to you the restrictions, conditions and general exclusions that attach to that policy.

Non-Life We can provide advice on and arrange products from the following range: household, motor, commercial, public liability, employer liability, life/mortgage, travel, pet, and farm insurance. We provide general insurance on a fair and personal analysis basis (providing services on the basis of a sufficiently large number of contracts and product producers available in the market to enable the firm to make a recommendation, in accordance with professional criteria, regarding which contract would be adequate to meet your needs). In some cases we may be granted authority from an insurance undertaking to conduct tasks on their behalf, for which we will be remunerated. Where we place your business with this insurance undertaking under this authority you will be notified in advance of the placement. We will also offer assistance to you in relation to processing claims on policies taken out with us and in seeking renewal terms on your cover. To ensure continuity of cover, where you have an existing policy which is due to expire and where we have been unable to contact you, we may put continuing cover in force whilst awaiting your instruction. You will be liable for any premiums payable to the relevant insurer for the period of time between renewal and when we receive your instruction. You have the right not to avail of this service.

Sustainability Factors – Investment/IBIPs/Pension Advice

In accordance with the Sustainable Finance Disclosure Regulation (‘SFDR’), we inform you that when providing advice on insurance-based investment products/Investments, we do not assess, in addition to relevant financial risks, relevant sustainability risks as far as this information is available in relation the products proposed/advised on. This means that we do not assess environmental, social or governance events/conditions that, if they occur, could have a material negative impact on the value of the investment. Considering Principal Adverse Impacts on sustainability factors in the advice: When providing advice on insurance-based investment products (‘IBIPs’) or investment advice we do not consider the impacts of our advice that result in negative effects on sustainability factors (namely environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters), because currently there is limited relevant products on the market which meet these criteria. The area of sustainable is relatively new and as the issue progresses, we will review our position. The firm will review this approach on an annual basis in June.

Impact on Return

We have not assessed the likely impacts of sustainability risks on the returns of Investment/Pensions since we have not been able to identify any sustainability risks that are relevant. We will reference information contained in the product documentation provided by the product manufacturer as and when made available to us.

Statement of Charges

We may earn our remuneration on the basis of fee, commission and any other type of remuneration, including a non-monetary benefit or on the basis of a combination of these methods. A non-monetary benefit will only be accepted if it enhances the quality of the service to our clients. You may choose to pay in full for our services by means of a fee. Where we receive recurring commission, this forms part of the remuneration for initial advice provided. We reserve the right to charge additional fees if the number of hours relating to on-going advice/assistance exceeds 2 hrs.

Life and Pensions You may elect to deal with us on a fee basis. Our hourly fees are outlined below and in such circumstances would be agreed in advance: Principles / Directors €110 p/hr Senior Advisers €75 p/hr Associates €55 p/hr Support staff €40 p/hr Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency, our scale of fees for such cases range from a minimum of €75 per hour to a maximum of €110 per hour. We will notify you in advance and agree the scale of fees to be charged.

Investment Fees Principles / Directors €110 p/hr Senior Advisers €75 p/hr Associates €55 p/hr Support staff €40 p/hr Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency, our scale of fees for such cases range from a minimum of €75 per hour to a maximum of €110 per hour. We will notify you in advance and agree the scale of fees to be charged.

Personal Retirement Savings Accounts (PRSAs) – Fees Where advice is requested for PRSAs, the following hourly fees will apply: Principles / Directors €110 p/hr

Senior Advisers €75 p/hr

Associates €55 p/hr

Support staff €40 p/hr

Additional fees may be payable for complex cases or to reflect value, specialist skills or urgency. We will notify you in advance of providing you with these services. Our scale of fees for such cases range from a minimum of €75 per hour to a maximum of €110 per hour. If we receive commission from a product provider, this will be offset against the fee which we will charge you. Where the commission is greater than the fee due, the commission will become the amount payable to the intermediary unless an arrangement to the contrary is made.

Clawback If we receive commission from a product provider [and off-set the commission against the fee which we would otherwise have charged you] but the commission is subsequently clawed-back by the provider because of early encashment by you or because of the transferring of the assets or business to another provider or in any circumstances consequent on your actions or omissions, we will charge a fee to you that is equal to 100% of the clawed-back commission. That fee will be owing in simple contract upon the claw-back of the commission.

Insurance Based Investment Products We will return to customers or offset against fees to be paid by the customer, any fees, commissions or non-monetary benefits paid or provided by any third party or person acting on behalf of a third party in relation to the services provided to that customer as soon as reasonably possible after receipt.

General Insurance We may be remunerated by commission from insurers on completion of business. Details of the commission arrangements are available on our website. Where an override commission is received, this will be disclosed to you in general terms.

	Initial Fee	Renewal Fee	Policy Alterations / Cancellation Fee
Motor	Up to a max of €230	Up to a max of €230	Up to a max of €90
Household	Up to a max of €230	Up to a max of €230	Up to a max of €90
Commercial	Up to a max of 25% of premium	Up to a max of 25% of premium	Up to a max of 25% of premium
Fees are calculated depending on the complexity of the product and the amount of time spent assisting the Client with the Services.

Life, Pensions and Investments

Time spent and disbursement basis with an applicable hourly rate of €110 for advisory consultants and €50 for administration and compliance support or
A percentage of the transaction value, the precise rate will be outlined to you in advance of execution of the transaction.

We reserve the right to amend these fees should the complexity of the product require a higher fee. We will confirm and agree this fee with you prior to any increased charge being applied. All such fees and charges are non-refundable in the event of policy alternation and/or cancellation. Any bank fees charged on unpaid cheques will be charged back to the client and are payable in full together with any other outstanding balance. An administration fee of up to 10% may be charged on premium finance arrangements. Fees of up to €20 may also be applied for duplicate documentation; both for existing and past clients, for advice provided, mortgages, life and pension policies arranged. In all circumstances, fees will be declared to the client in writing. Any third-party fees or charges that apply in connection with your policy will be included in the premium charged. The following fee table sets out our Schedule of Rates. These rates will be separately charged in the event that extraneous insurance consultation services are provided to our Client outwith the aforesaid circumstances.

Director	€230 per hour
Consultant/Account Executive	€150 per hour
Qualified Financial Advisor	€110 per hour
Administration	€50

Claims handling: Depending on case. We will inform you of the amount of fee to be charged. Where it is not possible to provide the exact amount, we will provide you the method of calculation of the fee.

Ongoing Suitability

Investments The firm’s services does not include ongoing suitability assessments.

Insurance based Investment Products

The firm’s services does not include ongoing suitability assessments.

Regular Reviews

It is in your best interests that you review, on a regular basis, the products which we have arranged for you. As your circumstances change, your needs will change which may result in you having insufficient insurance cover and/or inappropriate investments. We would therefore advise that you contact us to ensure that you are provided with up to date advice and products best suited to your needs.

Conflicts of interest

It is the policy of our firm to avoid conflicts of interest in providing services to you. However, where an unavoidable conflict of interest arises we will advise you of this in writing before providing you with any service. A full copy of our conflicts of interest policy is available on request. In some cases, we may be a party to a profit-share arrangement with product producers where we provide extra services for the provider. Agreements to this effect are in place with the following: [NA currently]. Any business arranged with these providers on your behalf is placed with them as they are at the time of placement the most suitable to meet your requirements taking all relevant information, demands and needs into account.

Default on payments by clients

We will exercise our legal rights to receive payments due to us from clients (fees and insurance premiums) for services provided. In particular, without limitation to the generality of the foregoing, the firm will seek reimbursement for all payments made to insurers on behalf of clients where the firm has acted in good faith in renewing a policy of insurance for the client. Product producers may withdraw benefits or cover in the event of default on payments due under policies of insurance or other products arranged for you. We would refer you to policy documents or product terms for the details of such provisions. Mortgage lenders may seek early repayment of a loan and interest if you default on your repayments. Your home is at risk if you do not maintain your agreed repayments.

Complaints

Whilst we are happy to receive verbal complaints, it would be preferable that any complaints are made in writing. We will acknowledge your complaint in writing within 5 business days and we will fully investigate it. We shall investigate the complaint as swiftly as possible, and the complainant will receive an update on the complaint at intervals of not greater than 20 business days starting from the date on which the complaint is made. On completion of our investigation, we will provide you with a written report of the outcome. In the event that you are still dissatisfied with our handling of or response to your complaint, you are entitled to refer the matter to the Financial Services and Pensions Ombudsman (FSPO). A full copy of our complaints procedure is available on request.

Data Protection

We are subject to the requirements of the General Data Protection Regulation 2018 and the Irish Data Protection Act 2018. Breeze Insurance Ltd trading as Breeze Insurance is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client. The data will be processed only in ways compatible with the purposes for which it was given and as outlined in our Data Privacy Notice, this will be given to all our clients at the time of data collection. We will ensure that this Privacy Notice is easily accessible. Please refer to our website www.breezeinsurance.ie, if this medium is not suitable we will ensure you can easily receive a copy by hard copy, or telephonic environment. (pre-recorded). Please contact us at care@breezeinsurance.ie if you have any concerns about your personal data.

Consumers: Duty of Disclosure when completing documentation for new business/renewals and midterm adjustments

You are required to answer all questions posed by us or the insurer honestly and with reasonable care – the test will be that of the ‘average consumer’[1]. Before renewal of the contract of insurance, specific questions will be asked. Again, you will be required to answer honestly and with reasonable care. Where you do not provide additional information (after being requested to do so) it can be presumed that the information previously provided remains unchanged. Failure to answer all questions honestly and with reasonable care can result in the Insurer being able to rely on proportionate remedies for misrepresentation, which include but are not limited to the insurer voiding the contract of insurance. If a policy is cancelled by an insurer for any reason including payment default you may encounter difficulty in purchasing insurance in the future.

Completed proposal forms/statement of fact

Completed proposal forms or Statements of Facts will be provided to you. These are important documents as they form the basis of insurance contract between the insurer and you the consumer. You should review and confirm that the answers contained within are true and accurate. You are under a duty to pay your premium within a reasonable time, or otherwise in accordance with the terms of the contract of insurance. A court of competent jurisdiction can reduce the pay-out to you if you are in breach of your duties under the Act, in proportion to the breach involved. Cancellation of a Contract of Insurance

You may cancel a contract of insurance, by giving notice in writing to the insurer, within 14 working days after the date you were informed that the contract is concluded. This does not affect the notice periods already provided under European Union (Insurance and Reinsurance) Regulations 2015 ( I. No. 485 of 2015) or the European Communities (Distance Marketing of Consumer Financial Services) Regulations 2004 ( S.I. No. 853 of 2004 ) which is 30 days in respect of life policies, irrespective of whether the sale took place on a non-face to face basis, and 14 days in respect of general policies and only on sales that took place on a non-face to face basis (distance sales).

If you have taken out a life insurance contract, you may cancel the contract by giving notice in writing to us within 30 days after the date you were informed the contract is on cover.

If you have taken out a general insurance contract, and we have not met face to face during the process, you may cancel the contract by giving notice in writing to us within 14 days after the date you were informed the contract is on cover. If you have taken out a general insurance contract, and we have met face to face during the process, you may cancel the contract by giving notice in writing to the insurer within 14 working days after the date you were informed the contract is on cover. The giving of notice of cancellation by you will have the effect of releasing you from any further obligation arising from the contract of insurance. The insurer cannot impose any costs on you other than the cost of the premium for the period of cover. This right to cancel does not apply where, in respect of life insurance the contract is for a duration of six months or less, or in respect of general insurance, the duration of the contract is less than one month. Post-Contract Stage and Claims If, in respect of the insurance contract the insurer is not obliged to pay the full claim settlement amount until any repair, replacement or reinstatement work has been completed and specified documents for the work have been furnished to the insurer, the claim settlement deferment amount cannot exceed

5% of the claim settlement amount where the claim settlement amount is less than €40,000, or
10% of the claim settlement amount where the claim settlement amount is more than €40,000.

An insurer may refuse a claim made by you under a contract of insurance where there is a change in the risk insured, including as described in an “alteration of risk” clause, and the circumstances have so changed that it has effectively changed the risk to one which the insurer has not agreed to cover. Any clause in a contract of insurance that refers to a “material change” will be interpreted as being a change that takes the risk outside what was in the reasonable contemplation of the both you and the insurer when the contract was concluded. You must cooperate with the insurer in an investigation of insured events including responding to reasonable requests for information in an honest and reasonably careful manner and must notify the insurer of the occurrence of an insured event in a reasonable time. You must notify the insurer of a claim within a reasonable time, or otherwise in accordance with the terms of the contract of insurance. If you become aware after a claim is made of information that would either support or prejudice the claim, you are under a duty to disclose it. (The insurer is under the same duty). If you make a false or misleading claim in any material respect (and know it to be false or misleading or consciously disregards whether it is) the insurer is entitled to refuse to pay and to terminate the contract. Where an insurer becomes aware that a consumer has made a fraudulent claim, they may notify the consumer advising that they are voiding the contract of insurance, and it will be treated as being terminated from the date of the submission of the fraudulent claim. The insurer may refuse all liability in respect of any claim made after the date of the fraudulent act, and the insurer is under no obligation to return any of the premiums paid under the contract.

Commercial Customers: Non-Consumers

Disclosure of Information

It is essential that you should bring to our attention any material alteration in risk such as changes of address or use of premises. Any failure to disclose material information may invalidate your claim and render your policy void.

Compensation Scheme

We are members of the Investor Compensation Scheme operated by the Investor Compensation Company Ltd. See below for details.

Investor Compensation Scheme

The Investor Compensation Act, 1998 provides for the establishment of a compensation scheme and the payment, in certain circumstances, of compensation to certain clients (known as eligible investors) of authorised investment firms, as defined in that Act. The Investor Compensation Company Ltd. (ICCL) was established under the 1998 Act to operate such a compensation scheme and our firm is a member of this scheme. Compensation may be payable where money or investment instruments owed or belonging to clients and held, administered or managed by the firm cannot be returned to those clients for the time being and where there is no reasonably foreseeable opportunity of the firm being able to do so. A right to compensation will arise only:

If the client is an eligible investor as defined in the Act; and
If it transpires that the firm is not in a position to return client money or investment instruments owned or belonging to the clients of the firm; and
To the extent that the client’s loss is recognised for the purposes of the Act.

Where an entitlement to compensation is established, the compensation payable will be the lesser of:

90% of the amount of the client’s loss which is recognised for the purposes of the Investor Compensation Act, 1998; or
Compensation of up to €20,000.

For further information, contact the Investor Compensation Company Ltd. at (01) 224 4955.

Brokers Ireland Clients’ Compensation and Membership Benefits Scheme (BIC)

We are also members of the Brokers Ireland Clients’ Compensation and Membership Benefits Scheme (BIC). Subject to the rules of the scheme the liabilities of its members firms up to a maximum of €100,000 per client (or €250,000 in aggregate) may be discharged by the fund on its behalf if the member firm is unable to do so, where the above detailed Investor Compensation Scheme has failed to adequately compensate any client of the member. Further details are available on request.

Insurance Distribution Directive Disclosures

Breeze Insurance Ltd. trading as Breeze Insurance Commercial Business Insurers

The following is a list of the main insurers with whom Breeze Insurance Ltd. trading as Breeze Insurance may and do conduct business. Please note that due to our governance process, these could change as and when a new product offering is reviewed: Insurers: AXA Aviva Insurance Ireland DAC, Zurich Insurance plc [1] Average consumer as per Directive No. 2005/29/EC of the European Parliament and of the Council of 11 May 2005 is reasonably well informed and reasonably observant and circumspect, taking into account social, cultural and linguistic factors.

Recording and Monitoring of Communications

By engaging with Breeze Insurance, you acknowledge and consent that any communications between you and us — including but not limited to telephone calls, video calls, emails, SMS messages, web chat, instant messaging, social media messages, or any other written or electronic communications — may be recorded, monitored, stored, and used for the purposes of staff training, quality assurance, regulatory compliance, record keeping, dispute resolution, and marketing (including the review and analysis of customer interactions to improve our products, services, and promotional materials).

We will, where practicable, inform you at the beginning of any call or interaction that recording or monitoring may take place. All recordings and stored communications will be kept securely and accessed only by authorised personnel in accordance with our data protection and confidentiality policies, the General Data Protection Regulation (GDPR), the Data Protection Acts 1988–2018, and the Central Bank of Ireland’s Consumer Protection Code.

These recordings may be used to verify instructions, improve customer experience, train staff, ensure compliance with our obligations, and enhance our marketing activities in a way that protects your privacy. If you do not wish for a call or other communication to be recorded or used for these purposes, please inform us before or at the outset of your interaction so that we can arrange an alternative means of communication.