Privacy Notice - Ireland

This Privacy Notice governs your use of Link Group websites. For our specific services or jurisdictions.

1. Who are Link Group? 

Link Group is a trading name of Link Fund Administrators (Ireland) Limited (“LFAI”) and Link Fund Manager Solutions (Ireland) Limited (“LFMSI”) which offer a range of fund solution services, including providing UCITS Management Company and Alternative Investment Fund Manager and fund administration services. Both LFAI and LFMSI are regulated by the Central Bank of Ireland. Please refer to the “Legal and Regulatory Status” page on the Link Group website ( status/) for more details on the trading companies in the Link Group division. All of the companies are wholly owned subsidiaries of Link Administration Holdings Limited (“Link Group”). For more information on Link Group, please visit

2. What is this Privacy Notice?

At Link Group we may collect personal information about you and are committed to protecting this information and your privacy. Set out below is an explanation of how we use, collect and safeguard your personal information. This Privacy Notice applies where either company within Link Group receives personal data through its website.

3. What personal information do we collect?

The principles of data protection are that only sufficient personal data should be collected and processed as is necessary for the purpose which it was collected or obtained. Link Group will collect and use only as much personal data from you as is necessary to be able to provide you with the products and services you have requested from us.

The information we collect depends on the nature of our relationship with you. For example, if you are a client invested in our funds, we collect personal information such as your name and contact details, your date of birth and information about your bank. Where other people are named in your investment such as beneficiaries, we may ask you to provide information in relation to these people too.

As part of your use of our website you may have the option on certain pages within this site to submit personal information to us by email, online enquiry or quotation form. Depending on the services, products or information you request from us, we may ask you to provide the following personal information about you and/or about individuals connected to you and your investment, such as:

  • name, date of birth, marital status, address, email address, telephone number, gender, and other contact details which you provide us with on completing, for example, an Enquiry Form, Event Form or Application Form;
  • nationality and residency details;
  • identification information such as your national insurance number, passport, tax identification number and driving licence;
  • Bank account details or other payment or financial information;
  • Information relevant to your investment; and
  • your marketing preferences.

We also use cookies and your Internet Protocol (IP) address (see section 11 “How do Link Group websites use my IP address and collect cookies?” below for further details).

We may keep a record of any correspondence you have with us, including any telephone calls which we may have a legal or regulatory obligation to record (we will inform you at the beginning of the telephone conversation if recording will be necessary).

We collect personal information about you from things you tell us yourself and from things we ask other people or organisations to share with us. Things you tell us could come from conversations we have on the phone, what you’ve written on a form or if you send us an email. We might also collect information about you from other people and organisations, such as the Central Bank of Ireland or by checking databases like the electoral register. Please see below for a list of some of the ways we collect your personal information.

We may collect personal information directly from you:

  • via application and various event registration forms;
  • through feedback forms and other forums;
  • when you purchase any of our products or services;
  • when you fill out a survey, or vote in a poll on our website;
  • via our telephone calls with you, which may be recorded;
  • when you provide your details to us either online or offline;
  • when you send an email; and
  • via cookies, which you can find out more about in the cookies policy on our website.

Depending on the nature of our relationship with you, we may also collect your personal information from a number of different sources including:

  • through companies which validate identity for financial crime purposes using tools such as the electoral register (this is not a credit check, but a record of the search may be retained);
  • from third party registers maintained by regulators such as the Central Bank of Ireland;
  • through business interactions between your company and Link Group;
  • from your financial advisor; and
  • from family members / or your legal representative or an appropriately appointed authorised representative if you become incapacitated or unable to provide information relevant to your investment.

4. Why do we collect your information?

This is dependent upon the nature of the relationship we have with you:

  • If you are an investor, we use your personal information to administer your investment product;
  • If you are a financial advisor or an employee of a financial advisory firm, we use your personal information to provide you with information about our products, services and events;
  • If you are an employee of a firm that we have a business relationship with, we use your personal information as part of our normal course of business;

5. What is the legal basis associated with the main purpose? 

We may process your personal information for a number of different purposes. We also need a lawful reason to use and process your personal information which is called ‘lawfulness of processing’.

  • Where we are assessing your application and setting you up as an investor, administering and managing your investment, providing all related services, handling any changes to your data, making payments to you and communicating with you, then the processing is necessary for the performance of a contract to which you are party.

If you do not provide information, in the circumstances detailed above, we will be unable to offer you an investment, process your payment requests or interact with you for normal business purposes.

  • Where a regulator such as the Central Bank of Ireland requires us to maintain certain records of any dealings with you, the processing is necessary for us to meet our legal and regulatory obligations.
  • Where we need to use your personal information to establish, exercise or defend our legal rights. For example, when we need to consult a solicitor or manage any legal claims, or where we want to pursue any legal claims ourselves, the processing is necessary for us to meet our legal obligations.
  • Where we need to use your personal information to carry out anti-money laundering checks or investigate fraud, the processing is necessary for reasons of public interest.

We will usually only ask for your consent in relation to processing your Special Category information (such as health data). This will be made clear when you provide your personal information. If we ask for your consent, we will explain why it is necessary.

In addition, we are required by law to obtain “know your client” information where applicable as detailed in our service contract, or other relevant information sources and this includes certain personal information.

6. How we use your personal information?

Why we need your personal information  Personal information we may process shall include, but shall not be limited, to the types of information set out below Lawful processing condition
To review your investment application (including tax domicile status).

Your name, contact details, date of birth, PPS number, address for tax purposes.

Similar information for other individuals included in the investment, such as beneficiaries.

To provide you with your investment (contract)

To meet obligations imposed on us by tax authorities and regulator (legal obligation)
To administer, provide and service your investment. Your name, contact details, date of birth, PPS number, address for tax purposes.

Similar information for other individuals included in the investment, such as beneficiaries.

Investment performance information.

Your bank account details. 
To provide you with your investment (contract)

To meet obligations imposed on us by tax authorities and regulator (legal obligation)

To receive payments from you and to make payments to you (contract)
To regularly communicate with you.  Your name, contact details and any information relevant to your investment.

Similar information for other individuals included in the investment, such as beneficiaries

Investment performance information.

Health information if you request communications in Braille or other easier to read formats.
To provide you with your investment (contract)

To meet obligations imposed on us by tax authorities and regulator (legal obligation)

To receive payments from you and to make payments to you (contract)

Any Special Category data relating to health will only be processed to provide you with relevant material (your consent)
To resolve any complaints you may have.  Your name, contact details and any information relevant to your investment.

Similar information for other individuals included in the investment, such as beneficiaries.
To resolve any complaints (legal obligation and our legitimate interest)
To prevent financial crime such as money laundering, sanctions breaches, tax evasion and fraud. Your name, contact details, date of birth, PPS number, address for tax purposes.

Similar information for other individuals included in the investment, such as beneficiaries.

Your bank account details. 
To provide you with your investment (contract)

To meet obligations imposed on us by tax authorities and regulator (legal obligation)

Any special category data or data relating to criminal convictions will only be processed to prevent financial crime (legal obligation)
For our own internal and external management information purposes, maintaining accounting records, analysis of financial results, internal audit requirements, receiving professional advice.  Your name, contact details, date of birth, PPS number, address for tax purposes.

Similar information for other individuals included in the investment, such as beneficiaries.

Investment performance information. 
To maintain appropriate records to monitor performance and evaluate business performance (our legitimate interest)

To meet obligations imposed on us by tax authorities and regulator (legal obligation)
For analytical purposes and to improve our products and services.  Your name, contact details, date of birth, PPS number, address for tax purposes.

Similar information for other individuals included in the investment, such as beneficiaries.

Investment performance information. 
For internal analysis and service improvement (our legitimate interest)
To comply with our legal or regulatory obligations.  Your name, contact details and any information relevant to your investment.

Similar information for other individuals included in the investment, such as beneficiaries
To meet obligations imposed on us by tax authorities and regulator (legal obligation)

7. Who we share personal information with?

We will only disclose your personal information in accordance with applicable laws and regulations. We will disclose your information to the following third parties:

  • Any person with legal or regulatory power over us (such as the Central Bank of Ireland, Revenue Commissioners, or the Garda Siochana) that may require disclosure on legal or regulatory grounds,
  • Service providers engaged by us to help run our business and perform the Services / our contract with you. Such service providers will include, for example, cloud storage providers (engaged by us to provide electronic storage facilities for our business data and your information), brokerage firms (engaged by us to facilitate deals in securities you instruct us to undertake). Other services providers such as IT system suppliers, auditors, lawyers, document management providers, and tax advisers,
  • Your relatives, powers of attorney, guardians acting on your behalf or other people or organisations associated with you such as your financial advisor or your lawyer whenever you have given us permission to share your personal information with them,
  • Our third party investment product and service administrators,
  • Identity and Verification agencies,
  • Other parties in commercial relationships with Link Group, including financial organisations and advisors where necessary to enable us to fulfil our service to you, cloud storage providers (engaged by us to provide electronic storage facilities for our business data and your information), analytical optimization service providers (engaged by us to track and analyse how part of our website are used by our customers); and/or
  • Any member of the Link Group which means our subsidiaries, our ultimate holding company and its subsidiaries (from time to time) as necessary to perform the Services / our contract with you.

Some of these third parties (including Link Group subsidiaries and service providers) may be outside of the UK and European Economic Area (EEA).

For certain aspects of the processing activities, we undertake to administer your account or investments we may transfer Personal Information outside of the UK and EEA where privacy laws do not always offer equivalent protection to individual’s personal data. In this scenario we always take steps to ensure that any transfer of Personal Information outside the UK and EEA is carefully managed to protect your privacy rights and ensure that adequate safeguards are in place by putting contractual obligations in place with the party we are sending information to.

Transfers within the Link Group will be covered by an agreement entered into by members of the Link Group (an intra-group agreement) which contractually obliges each member to ensure that your Personal Data receives an adequate and consistent level of protection wherever it is transferred within the Group.

For more information about data transfers and the safeguards we have put in place, please contact us at

8. How do we keep your information secure? 

We store the information you provide about yourself in a secure database and take appropriate security measures to protect such information from unauthorised access.

We take protection of your personal information and our system security very seriously. Any personal information which is collected, recorded or used in any way will have appropriate safeguards applied in line with our data protection obligations.

We implement Internal and external audits and regular independent assurance exercises across our business to ascertain the effectiveness of our security control environment and our security strategy.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect your personal and confidential information whenever they are processing it and must undertake annual training on this.

Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

All exchanges of information between you and our website go through encrypted channels in order to prevent interception of your information. Public access to your information via our website / the portal / any web-hosted platform is protected by a login using your user ID and password. You should ensure that these are kept secret and not divulged to other people.

You recognise that your use of our website is entirely at your own risk. As Link Group websites are grouped to the internet, which is inherently insecure, Link Group cannot guarantee the information you supply will not be intercepted while being transmitted over the internet. Accordingly, Link Group has no responsibility or liability for the security of personal information transmitted via our website.

9. How long will we store your information for? 

We generally hold your personal data on our systems for as long is necessary to provide services to you. The time period for which we keep your personal data will depend on the services we provide to you. Service-specific privacy notices are available on the right of this notice. Our website uses Google Analytics where a record of some of your personal data (e.g. IP address) will be retained for 38 months.

The time period we retain your personal information for will differ depending on the nature of the personal information and what we do with it. How long we keep personal information is primarily determined by our regulatory obligations.

We typically keep personal data used for your investment product for 7 years from the end of our relationship with you. In some cases where there may be a dispute or a legal action, we may be required to keep personal information for longer.

If we anonymise your personal information so that it can no longer be associated with you, it will no longer be considered personal information, and we can use it without further notice to you.

10. Your rights

You have the following rights in relation to how we use your information. If you’d like to exercise these rights, please contact us using the contact details listed at section 15 “Who can you speak to at Link Group about this Privacy Notice?”

The right to lodge a complaint
You have a right to complain to the Data Protection Commission (“DPC”) at any time if you object to the way in which we use your personal information. More information can be found on the DPC’s website:

Right of access
You have the right to know if we are using your information and, if so, the right to access it and information about how we are using it. There will not usually be a charge for dealing with these requests. Your personal information will usually be provided to you in writing, unless otherwise requested. Where you have made the request by electronic means the information will be provided to you by electronic means where possible.

Right of rectification
We take reasonable steps to ensure that the personal information we hold about you is accurate and complete. However, if you do not believe this is the case you have the right to require us to rectify any errors in the information, we hold about you.

Right to erasure
You have the right to require us to delete your information if our continued use is not justified. However, this will need to be balanced against other factors, depending upon the type of personal information we hold about you and why we have collected it, there may be some legal and regulatory obligations which mean we cannot comply with your request.

Right to restrict processing
In some circumstances, although you may not be entitled to require us to erase your information, you may be entitled to limit the purposes for which we can use your information.

Right of data portability
You have the right to require us to provide you with a copy the personal information that you have supplied to us in a commonly used machine-readable format or to transfer your information directly to another controller (e.g. a third party offering services competing with ours). Once transferred, the other party will be responsible for looking after your personal information.

Right to object to direct marketing
You can ask us to stop sending you marketing messages at any time. Please see below.

Right not to be subject to automated-decision making
Link Group do not make decisions about you using automated decision making or profiling of your personal data.

Right to withdraw consent
For certain limited uses of your personal information, we may ask for your consent. Where we do this, you have the right to withdraw your consent to further use of your personal information. If you withdraw your consent, we may not be able to provide certain products and services to you. If this is the case, we’ll tell you at the time you ask to withdraw your consent.

In some circumstances exercising some of these rights will mean we are unable to continue providing you with your investment or maintaining a business relationship with you.

You can make any of the requests set out above using the contact details in this Privacy Notice. Please note that in some cases we may not be able to comply with your request for reasons such as our own obligations to comply with other legal or regulatory requirements. We will always respond to any request you make and if we can't comply with your request, we will tell you why.

You are in control of how we use your information for marketing, and we will only contact you if you have purchased one of our products or expressed an interest in attending one of our events. In these circumstances we may share information within the Link Group to inform you of other similar products and services that may be of interest to you, unless you tell us that you do not wish to receive this information.

If you wish to unsubscribe from any emails sent by us, you may do so at any time by following the unsubscribe instructions that appear in the email. Otherwise you can always contact us using the details set out in this Privacy Notice to update your contact preferences. In such circumstances, we will continue to send you service related (non-marketing) communications where necessary.

11. How do Link Group websites use my Internet Protocol (IP) address and collect cookies?

Each time you use our websites, we will automatically collect certain technical information, including the type of browser you use, the Internet Protocol (IP) address used to connect your computer to the internet, and information about your visit, including the full Uniform Resource Locations (URL), clickstream to, through and from our sites, traffic data and other communication data, the resources that you access, and the information derived from the cookies we place on your mobile device and/or computer.

In order to improve the quality of our website and services, we may from time to time send your computer a "cookie". Cookies are text files that identify your computer to our server and are stored on your device. Cookies in themselves do not identify the individual user, just the computer used. Cookies enable us to improve your user experience by avoiding the need for you to enter the same information more than once. They also allow us to analyse user behaviour to improve the functionality and performance of our website.

We comply with the EU cookie regulations as introduced in Ireland on 5 July 2011 through S.I. No. 336/2011 – European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.There are two types of cookies that can be stored on your device:

  • "session cookies", which only last for the duration of your visit to our website and are automatically deleted from your device when you close your browser; and
  • "persistent cookies", which remain on your device after you have visited our website and are not deleted when you close your browser. Persistent cookies are sent back to our server every time you visit our website.

We make use of session cookies, which are essential to maintain security throughout the site, and are not used for tracking purposes. Session cookies are used to help us remember your movements from page to page, avoiding the need for you re-enter the same information. Session cookies are held in memory and expire when you leave our website.

In addition, in order to develop our site in line with customers’ needs, Link Group use an analytics and optimization service provided by WT EMEA Acquisitions Ltd (WebTrends) to track and analyse how parts of the site are used. We use this information to help improve the site. The data collected by WebTrends will be stored exclusively for analytical purposes and does not result in any personally identifiable data being collected or stored. WebTrends will send your computer a persistent cookie in order to evaluate your use of this site. WebTrends store the information collected by the persistent cookie on servers in the United States, European Union Member States and other countries. WebTrends may also transfer this information to third parties where required to do so by law, or where such third parties process the information on WebTrends' behalf. WebTrends will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. WebTrends will not associate your IP address with any other data held by WebTrends. Link Group uses WebTrends to optimise this site and improve the service we provide to our visitors. This ensures that the website is fully functional and optimised to create the best possible user experience.

Our website uses Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing small text files called ‘cookies’ on your device. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, is aggregated and therefore anonymous. The retention period for data that is associated with cookies, user identifiers or advertising identifiers is 38 Months.

Your consent is required in order for your personal data to be stored in cookies or used for analytical purposes. We never gather other information from your disk or computer. We will collect a copy of the data held by the cookie from inclusion in any analysis. We use full SSL protocols when collecting visitor information on secure pages; this ensures that the site’s security is not compromised. We encrypt all transmitted visitor information (even from non-secure pages), so no-one else can read the information we gather. None of the cookies used on our websites collect, record or store personally identifiable information about you.

By continuing to use this website, you are consenting to us placing session cookies on your device for the purposes detailed above. Most users will be able to adjust their internet settings to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services cannot then be provided to that user. Please note that the websites to which this site may be linked may also make use of their own cookies. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

12. Following links from our websites 

Our site may contain links to other sites. Such other sites may also make use of their own cookies and will have their own privacy policies. You should carefully review the privacy policies and practices of other sites, as we cannot control or be responsible for their privacy practices. We do not accept any liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

13. Social Media

We use a third-party provider, LinkedIn, to manager our social media interactions. If you send us a private or direct message via social media, it will be stored by LinkedIn for the period of time your account is in existence.

We see all this information decide how we manage it. For example, if you send a message via social media that needs a response from us, we may process it in our contact management system as an enquiry or a complaint. When contacting Link Group that a social media platform, we suggest you familiarise yourself with the privacy information on that platform.

14. Changes to this Privacy Notice

Please note that this Notice will be reviewed and may be changed from time to time. Any changes we may make to our Privacy Notice in the future will be posted on this page.

15. Who can you speak to at Link Group about this Privacy Notice?

Questions, comments and the exercise of your rights regarding this Privacy Notice and your information are welcomed and should be addressed to the Compliance function by email at or by post at 1st Floor, 2 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 A342 Ireland.

Information about how Link Group collects, uses, shares and protects employee data can be found in our Employee Privacy Notice accessible on the staff intranet.

If you wish to make a complaint on how we have handled your personal information, you can contact our Data Protection Manager. If you are not satisfied with our response or believe we are processing your personal information not in accordance with the law, you can complain to the supervisory authority in Ireland responsible for the implementation and enforcement of data protection law: the Data Protection Commissioner (the “DPC”).

You have the right to complain to the DPC about our collection and use of your information. You can contact the DPC via their website – - or by post to the DPC. All information is available to view via their website.

Updated April 2021