Our Republic of Ireland online privacy statement

The www.sunlife.ie website (the “website”) is operated by Sun Life Information Services Ireland Limited (“we”, “us”, “our”). Sun Life Information Services Ireland Limited is a member of the Sun Life Financial of Canada group of companies (the “Sun Life Group”). We created this privacy statement in connection with the website, (which is maintained on sunlife.com in the Sun Life Group) to demonstrate that your privacy is important to us. We want you to understand how we safeguard your personal information and what types of information we receive and collect when you visit our website.

Sun Life Financial of Canada in the Republic of Ireland and Sun Life Information Services (Ireland) Limited takes its obligations under the Data Protection Acts 1998, 2003 and 2018 very seriously. The aim of this statement is to provide you with details of how the data collected from you via this website or through other communication channels is processed:

• Who is collecting information about you?
• Does this website use cookies?
• What information is being collected from you?
• With whom will the information be shared?
• How secure is that information?
• Your rights

Each time you use this website, you will be bound by the current privacy statement and you should review this each time you use the website to ensure that you are happy with it. This statement (together with any other documents referred to) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Who collects information?

This website is operated by Sun Life Financial of Canada in the Republic of Ireland. Sun Life Information Services Ireland Limited is a member of the Sun Life Group and is the data controller for the personal data processed through the operation of this website. If you wish to contact us in relation to the processing of your personal data collected through this website, please email our Data Protection Officer at data.protection.ireland@sunlife.com.

This website may be hosted or operated by other companies from time to time but this will always be done under a written contract and on terms that ensure that all data collected from this website is only used as set out in this statement.

Cookies that we use on our website

We use cookies only for functionality that is strictly necessary for services that are explicitly requested by the user for their session as per Regulation 5(5), SI 336 of 2011 (the ePrivacy Regulations).

This website uses session cookies, which are used to deliver the basic functions of a website i.e. to allow pages to remember technical changes or selections you may make between pages. Session cookies are temporary cookies and are generally erased when you close your browser.

Links from the Website do however redirect you to websites within the Sun Life Group or external companies that may contain cookies. If you follow a link to any of these other websites, please note that these websites have their own privacy and cookie policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

You can turn off cookies in your browser settings. If you do turn them off, it is important to remember that this may prevent some sections of this website from working properly. You can find out more about turning off cookies at the independent website allaboutcookies.org.

What information do we collect?

We may collect and process the following:

• Information that you voluntarily provide to us when using this website.
• If you contact us for any reason, we may keep a record of that correspondence.
• Employment application information which you voluntarily provide to use when making an application for employment with us – we may store this information in order to consider you for future vacancies which may become available either with us or within the Sun Life Group.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of your visits to the website including, but not limited to, traffic data, location data and other communication data and the resources, advertisements and linked sites that you access.
• Aggregated information – this is information about all of our visitors collectively such as what areas of our website visitors most frequently visit and which of the services that we offer they prefer to use. To protect our visitors' rights of privacy, this information is anonymous and aggregated. Therefore, no individual visitor can be identified from this information.

With whom will we share aggregate information?

We may share aggregate information with our business partners and website developers so that they too may understand how visitors use our site, so that together we can create a better overall experience for you. We may share personal information within the Sun Life Financial of Canada group of companies.

With whom will we share personal information that you choose to provide?

Where you enquire about or apply for a position via the website or another communication channel, we may use your information to respond to your enquiry or to assess your application. We may pass your information to other Sun Life Group companies and/or third-party service providers, intermediaries or other agents acting on our behalf.

Wherever possible, we try to keep personal information within the Republic of Ireland, however, the personal information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by third-party service providers, staff of Sun Life Group companies, intermediaries or other agents operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, conducting the recruitment process. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement.

We may, from time to time, send personal information to Canada because our websites and some of our systems are hosted there or to convert the information from one format to another whilst re-routing it electronically to the Republic of Ireland. Although Canada has its own data protection laws which are deemed to offer adequate protection by the European Commission, we also take reasonable precautions to ensure that the confidentiality and integrity of all personal information so transferred is maintained.

We may disclose your personal information to our subsidiaries or data processers working directly on our behalf for a specified purpose. We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and other agreements; or to protect the rights, property, or safety of our members, or others.

Our online recruitment application is provided by a third-party service provider operating outside of the EEA and as such any information you provide through this application will be stored outside of the EEA and subject to local laws. Such service providers, whether or not they are located in the Republic of Ireland, are required to protect the confidentiality of your personal information in a manner that is consistent with our privacy statement and practices. We take great care to keep your personal information which we collect confidential. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement.

Security of the information

We take all reasonable precautions to protect your information. When you submit information via the website, we try to ensure that the information is, as far as possible, protected both on and offline. At a minimum, we use encryption and other methods to protect sensitive information online, but we may employ other methods or forms of security from time to time as well. Please be aware, however, as no data transmission over the Internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk. Offline, your information is protected by a number of strictly regulated processes and measures.

Your rights

We would like to make sure that you are fully aware of your data protection rights. You are entitled to:

• see the data we hold about you
• require us to correct inaccurate data about you
• ask us to restrict or stop processing your data, or to object to your data being processed
• ask for your data to be deleted, this is also known as the right to be forgotten
• ask us to send you, or another organisation you have chosen, for a copy of your data in a commonly used machine readable format, and
• withdraw your consent to any processing for which you have previously given that consent

If you would like to exercise any of these rights, please email us at: data.protection.ireland@sunlife.com

Or write to us: The Data Protection Officer, Sun Life Information Services Ireland Limited, Unit 324, IDA Industrial Park, Cork Road, Waterford

We will not charge you to exercise any of these rights.

Complaints

If you are not happy with the way in which Sun Life Financial of Canada handles data collected from you on this website, you can write to us at:

The Data Protection Officer
Sun Life Information Services Ireland Limited
Unit 324, IDA Industrial Park
Cork Road
Waterford

Please detail the nature of your complaint and we will respond to you as soon as possible.

If you do not receive a satisfactory response from us, you may wish to bring your complain to the attention of the Office of the Data Protection Commissioner. Their contact details can be found on their website www.dataprotection.ie.

Notification of changes

Please be aware that we may update and modify our privacy statement at any time. Please review this section each time you access and/or use our website.

Acceptance of this privacy statement

By using this website, you signify acceptance of this privacy statement. If you do not agree with or you are not comfortable with any aspect of the privacy statement, your only remedy is to discontinue use of the website. We reserve the right to modify this privacy statement at any time. Your continued use of any portion of the website following notification or posting of such changes will constitute your acceptance of those changes.

Thank you for using the website.