Privacy Policy

Last Updated: August 03, 2021

Introduction (PAW’ or ‘our’, ‘us’, ‘we’) having its registered office at 12 Thornbury, Delgany, Co Wicklow  (company registration number 641164) is the owner of this site.  We are committed to protecting and respecting your privacy.
This policy 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.
For the purpose of European Union and Irish data protection law (the Acts), we are the data controller.  Our email address is  Our nominated representative for the purpose of the Acts is Feargal McKenna.
By using our site you are deemed to fully accept this Privacy Policy, our Cookies Policy and our Website Terms of Use Policy.

Information we may collect from you

We may collect and process the following data about you:

Information you give us

You may give us information about you by filling in forms on our site, or by corresponding with us by phone, email or otherwise.  This includes information you provide when you register to use our site, subscribe to our service, and when you report a problem with our site.  The information you give us may include your name, address, email address and phone number, financial information, personal description and photograph.
Any data about you or other individuals you enter onto our website directly or include in any message to us will be subject to the Acts and you are responsible for its accuracy and relevance and must have the authority to disclose it and for us to utilise it for the purposes of any transaction concluded for or by you through this website.
If you contact us, we may keep a record of that correspondence.

Information we collect about you

With regard to each of your visits to our site we may automatically collect the following information:
technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); pages and information viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we receive from other sources

We may receive information about you if you use any of the other services we provide.  In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site.  We also work with third parties (including, for example, investment providers, sub-contractors in technical services, advertising networks, analytics providers, search information providers) and may receive information about you from them.

Uses made of the information

By agreeing to these terms and conditions you give your consent to the collection, use and retention of your data for our legitimate business purposes as explained in this Privacy Policy.  We collect, use and retain information about you only if we reasonably believe it is justified, required and useful in order to conduct our business effectively and to provide you with information and advice about products and services we believe will be of interest to you.
We maintain appropriate security standards and procedures in relation to the collection, use and retention of your information in order to prevent unauthorised access or disclosure.
We use information held about you in the following ways:

Information you give to us

We will use this information:-
to provide our investment advisory services and assess the suitability of third party investment products for you;
to provide you with information about third party investment products;
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.

Information we collect about you

We will use this information:-
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

Information we receive from other sources


We may combine this information with information you give to us and information we collect about you.  We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

We may share your personal information with any subsidiary or holding company, as defined in sections 7 & 8 of the Companies Act, 2014, if any from time to time.
We may share your information with selected third parties including:-
Investment product providers in order to properly asses the suitability of their products for you.
Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.  We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day).  We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in Dublin).  We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:-
In the event that we sell any of our business or assets or merge with another business, we may disclose your personal data to the prospective buyer of such business or assets to the extent required for the transaction and subject to the receiving party being bound by covenants of confidentiality in respect of such data.
If Moneycube is sold or merges with another business or  substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
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 of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of Moneycube, our customers, or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data 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 staff operating outside the EEA who work for us or for one of our suppliers.  Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.  Any such transfers of personal data outside of the EEA will comply with the requirements of the Acts.
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 Policy.
All information you provide to us is stored on our secure servers.  Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.  We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your personal data for marketing purposes.  We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.  You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.  You can also exercise the right at any time by contacting us.
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy 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 may inform us of any changes to your personal data and in accordance with our obligations under the Acts we will update or delete your personal data accordingly.

Access to information

The Acts gives you the right to access information held about you.  Your right of access can be exercised in accordance with the Acts.

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email.  Please check back frequently to see any updates or changes to our privacy policy.  By using our Website you agree to be bound by our Privacy Policy and any revisions in effect at the time of its use.

Website Terms of Use (‘PAW’ or ‘our’, ‘us’, ‘we’) having its registered office at 12 Thornbury, Delgany, Co Wicklow (company registration number 572680), owns and operates this website, (our site).  Our email address is

Your continued use of our site signifies your acceptance of these Terms of Use, our Privacy Policy and Cookie Policy, as revised from time to time.


Terms of website use

These terms and conditions (together with the documents referred to in it) (‘Terms of Use’) tells you the terms on which you may use our site, whether as a guest or a registered user.  Use of our site includes accessing, browsing, or registering to use our site.
By using our site, you confirm that you accept these Terms of Use and that you agree to comply with them.
If you do not agree to these Terms of Use, you should not use our site.
If you wish to avail of the services we provide, our Terms & Conditions of Service will apply.

Changes to these Terms of Use and our site

We may revise these Terms of Use at any time by amending this page.  Please check our site from time to time to take notice of any changes we have made to these Terms of Use, as they are binding on you.
We may update our site from time to time, and may change the content at any time.  However, please note that any of the content on our site may be out of date at any given time, and we are under no obligation to update it.
We do not guarantee that our site, or any content on it, will be free from errors or omissions.

Accessing our site

Our site is made available free of charge.
We do not guarantee that our site, or any content on it, will always be available or be uninterrupted.  Access to our site is permitted on a temporary basis and we reserve the right to suspend, withdraw, discontinue or change all or any part of our site without notice to you.  We will not be liable to you if for any reason our site is unavailable at any time or for any period.
You are responsible for making all arrangements necessary for you to have access to our site.  You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these Terms of Use, and that they comply with them.
Our site is directed to people over 18 years of age residing in Ireland.  We do not represent that content available on or through our site is appropriate or available in other locations.  No information provided or service we offer should be taken as an offer or solicitation to conduct investment business in any jurisdiction other than Ireland.  We may limit the availability of our site or any service or product described on our site to any person or geographic area at any time.  If you choose to access our site from outside Ireland, you do so at your own risk.
Intellectual property rights
We are the owner or the licensee of all intellectual property rights in our site, and in the material published on it including but not limited to all information, communications, software, scripting, photographs, text, video, graphics, music, sounds, images, trademarks, trade names, logos and other material and services found on our site (‘IP Content’).  This IP Content is protected by copyright, trade mark, database, sui generis rights and other intellectual property laws and treaties around the world.  All such rights are reserved.
You must not make alterations, copies, extractions, modifications or additions to the IP Content on our site and you must not sell, copy, disseminate, licence or misuse any IP Content in any way.  You must not use any graphics separately from any accompanying text.  If you want to re-publish, extract, reproduce, disseminate or otherwise use the IP Content, you must contact us in advance for permission.
Our status (and that of any identified contributors) as the authors of IP Content on our site must always be acknowledged.
You must not use any part of the IP Content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.
If you print off, copy or download IP Content in breach of these Terms of Use, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

Information on our Site

While we use reasonable care to ensure continuous access to our website, we cannot guarantee that it will be interruption-free.
We use all reasonable care to ensure that the information on our website is correct we do not guarantee that it will be error-free.  Some information may be provided by third parties and we are not liable for any inaccuracies, errors or omission in the information that they provide.
The information contained on this website does not constitute a recommendation to buy, sell or otherwise transact.  If you are unsure of whether an investment is suitable for you we would invite you to create an account and avail of our service to provide you with a Suitability Statement.  Provision of our services are governed by our Terms & Conditions of Service.

Limitation of our liability

You acknowledge that neither we nor third parties connected to us shall be liable to you for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, that may result from interruption or interception of communications or unauthorised access or hacking.  We cannot guarantee the privacy and security of such communications.
Use of our site is entirely at your own risk and you assume full responsibility and risk of loss resulting from the use of, viewing, access to, relying on our site and/ or any content.
To the extent permitted by law, we exclude all conditions, warranties, representations or other terms which may apply to our site or any content on it, whether express or implied.
We will not be liable to any user for any loss or damage, whether in contract, tort (including negligence), breach of statutory duty, or otherwise, even if foreseeable, arising under or in connection with:
use of, or inability to use, our site; or
use of or reliance on any content displayed on our site.
We will not be liable for any loss or damage caused by a virus, distributed denial-of-service attack, or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any content on it, or on any website linked to it.
We assume no responsibility for the content of websites linked on our site.  Such links should not be interpreted as endorsement by us of those linked websites.  We will not be liable for any loss or damage that may arise from your use of them.
Nothing in these Terms of Use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by law.


We do not guarantee that our site will be secure or free from bugs or viruses.
You are responsible for configuring your information technology, computer programmes and platform in order to access our site.  You should use your own virus protection software.
You may not use our site in a manner that could damage, disable, overburden or impair it, its server, or the networks connected to the server or interfere with any other party’s use and enjoyment or our site and the services on it.
You may not obtain or attempt to obtain any materials or information through any means not intentionally made available to you.
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful.  You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site.  You must not attack our site via a denial-of-service attack or a distributed denial-of service attack.  By breaching this provision, you would commit a criminal offence under law.  We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them.  In the event of such a breach, your right to use our site will cease immediately.
You must not post or transfer to our website (nor include in any message) any material that is threatening, defamatory, obscene, indecent, seditious, offensive, pornographic, abusive, liable to incite racial hatred, discriminatory, menacing, scandalous, inflammatory, blasphemous, in breach of confidence, in breach of privacy or which may cause annoyance or inconvenience.

Linking to our site

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it.
You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists.
You must not establish a link to our site in any website that is not owned by you.
Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page.
We may restrict you from linking to our site without notice if we consider that a link is prejudicial to our interests.

Third party links and resources in our site

Where our site contains links to other sites and resources provided by third parties, these links are provided for your information only and do not mean we endorse, authorise or sponsor these websites nor does it mean that we are affiliated with the third party website’s owners or sponsors.
Your use of third party website is subject to the terms and conditions of use contained within each of those website.  We have no control over the contents of those sites or resources.

Information about you and your visits to our site

Other than personally identifiable information about you, any material you transmit or post to our site shall be considered as non-confidential and non-proprietary.  We shall have no obligations with respect to such material.  We and our assignees shall be free to copy, disclose, distribute, incorporate and otherwise use such material and all data, images, sounds, text and other things embodied therein for any and all commercial and non-commercial purposes.
Full details of the type of information we collect via our site, our use of this information and the persons and companies to whom we disclose this information can be found here and here.  Both our Privacy Policy and Cookies Policy are incorporated into and form part of these Terms of Use.


If any provision of this agreement (or part of a provision) is found by any court or administrative body of competent jurisdiction to be invalid, unenforceable or illegal, the other provisions shall remain in force.

If any invalid, unenforceable or illegal provision would be valid, enforceable or legal if some  part of it were deleted, the provision shall apply with the minimum modification necessary to make it legal, valid and enforceable.


The failure by us to exercise any right or remedy under these Terms of Use shall not constitute a waiver of that right or remedy.

Applicable law

If you are a consumer, please note that these Terms of Use, its subject matter and its formation, are governed by and construed in accordance with the laws of the consumer’s country of domicile and we submit to  the jurisdiction of the courts in the consumer’s country of domicile.
If you are a business, these Terms of Use, its subject matter and its formation (and any non-contractual disputes or claims) are governed by Irish law.  We both agree to the exclusive jurisdiction of the courts of Ireland.