Home

My Irish Life App Tracking Policy

App Tracking Policy 

Effective: September 2026 

This App Tracking Policy explains how Irish Life Assurance plc, Irish Life Health DAC and Irish Life Financial Services Ltd (collectively referred to as “We”, “Our” or “Us” in this policy) use technologies within the MyIrishLife mobile app and how you can manage your choices. 

The MyIrishLife App uses software and services supplied by Irish Life and external technology providers. Technologies incorporated into a mobile app are often referred to as Software Development Kits or SDKs. 

For these technologies on our MyIrishLife Mobile App, our companies act as joint data controllers, as outlined in each company’s Privacy Notice. The essential information about our joint controller arrangement, including which company is responsible for what and how you can exercise your rights, is explained in our privacy notices. 

You can find more information on our privacy notices using the following link: 

Privacy Notices | Irish Life Group 

1. Introduction 

This App Tracking Policy explains how we use technologies within the MyIrishLife mobile application and how users can manage their consent preferences. 

Unlike websites, mobile applications may use a range of technologies, including Software Development Kits, known as SDKs, local app storage, device-level technologies, platform identifiers and similar tracking or measurement mechanisms. These technologies can be used to: 

  • help the app function correctly and securely; 
  • improve the user experience and support enhanced features; 
  • enable analytics and, where the user agrees, marketing-related services. 

Some of these technologies are strictly necessary to provide the MyIrishLife App and the core services requested by the user. Others are optional and are only used where the user gives us their consent. 

The fact that technology is supplied by an external provider does not necessarily mean that the provider uses your information for its own purposes or that your information is used for third-party advertising. External technology may be used to provide services to Irish Life and for the purposes described in this policy and within the app’s Privacy Settings. You can find information about the individual technologies used within the app, including their providers, purposes and categories, within the app’s Privacy Settings. 

Device and operating-system permissions, such as biometrics, notifications, camera or photo access, location and Apple’s App Tracking Transparency permission where applicable, are controlled separately through iOS or Android and are explained separately in this policy. 

Because consent in a mobile app is managed through app-based controls and operating system prompts rather than a browser cookie banner, the mechanism, technologies used and wording presented to users may differ from the notices used on our websites 

2. How Consent Is Managed 

We use UserCentrics as our Consent Management Platform (CMP) provider, within the MyIrishLife App. 

The platform enables users to: 

  • Review information about the technologies used within the app; 
  • Provide or withhold consent for non-essential technologies; 
  • Update their preferences at any time; 
  • Withdraw previously provided consent. 

Consent choices are recorded and applied before non-essential technologies are activated. Users can review, update or withdraw their preferences at any time through the Privacy Settings section of the app. 

 We will resurface the consent interface after 6 months so that users can confirm or update their choices. 

The interface may be shown again sooner following changes to matters such as: 

  • The technologies used within the app; 
  • The purposes for which they are used; 
  • The organisations involved; 
  • The technology categories; or 
  • The information provided about a technology. 

We may also manually resurface the consent interface where required. 

Do users have a choice? 

For Functional & Analytical and Marketing technologies, we rely on your consent under data protection law and ePrivacy regulations. These technologies will not operate unless you choose to enable them. You can also review the individual technologies and change or withdraw your choices through the app’s Privacy Settings. 

Strictly Necessary technologies cannot be rejected because they are required for the app’s essential operation. 

3. Categories of Technologies Used Within the App 

The technologies used within the MyIrishLife App are grouped into the same categories displayed in the CMP within the Privacy Settings of the app: 

  • Strictly Necessary 
  • Functional & Analytical 
  • Marketing 

For each category, users can see more detail, including the providers involved, the purposes of the technologies and the types of data processed, in the Privacy Settings section of the app. 

Strictly Necessary  

Strictly Necessary technologies are essential for the operation, security and delivery of core app functionality. 

These technologies are used to: 

  • provide the MyIrishLife App and the services you request (for example, access to your account and policy information) and 
  • protect the app and your data from fraud, abuse or unauthorised access 

Because these technologies are strictly necessary for the operation of the app, they do not require consent and cannot be disabled. They are not used for any unrelated analytical or marketing purposes. 

Functional & Analytical  

Functional & Analytical technologies provide additional app functionality and helps us understand the performance of the app and improve the user experience. These technologies may collect information such as screen views, feature usage, session activity, app performance data, device and operating system information, error reports and customer journey events. 

They may be used to: 

  • Understand how users interact with the app; 
  • Measure app usage and performance; 
  • Identify errors or technical problems;  
  • Help Irish Life improve the app and its services; 
  • Measure adoption of features; and 
  • Support service improvements 

 

This is an optional category. Technologies within it, including Firebase Analytics and Snowplow, will only undertake the optional processing described within the Privacy Settings where you have allowed the Functional & Analytical category or the relevant individual technology. 

 

You can accept or reject this category and change your choice at any time through the app’s Privacy Settings. 

Marketing  

Marketing technologies help us measure the effectiveness of our marketing communications and campaigns and, where applicable, attribute interactions or responses to campaigns. 

They may be used to: 

  • Record whether users engage with marketing communications or campaigns  
  • Help Irish Life understand which communications are most effective.  
  • Support the creation of audience segments or profiles for marketing purposes 
  • enable, where permitted, personalised advertising within the app or across other digital services. 

They are not used for any unrelated third-party advertising purposes. 

This is an optional category and will only operate where you have provided the required consent. The technologies currently used within this category, if any, will be shown within the app’s Privacy Settings. You can manage your preferences at any time through the app’s Privacy Settings. 

4.  How Consent Choices are Applied 

 The MyIrishLife App uses CMP to: 

  • Provide information about the technologies used within the app; 
  • Present the available technology categories; 
  • Collect your choices; 
  • Make those choices available to the app; and 
  • Allow you to change or withdraw your choices. 

The app uses your choices to control the relevant optional technologies. 

Functional & Analytical and Marketing technologies will only undertake the optional processing where you have provided the relevant consent. 

Firebase Analytics and Snowplow are included within the Functional & Analytical category. They will not collect or transmit analytical data unless you have allowed that category or the relevant individual technology. 

Any technology assigned to Marketing will remain inactive unless you have allowed the Marketing category or the relevant individual technology. 

Strictly Necessary technologies will continue to operate where they are required for purposes such as security, authentication, fraud prevention, consent management or providing a service requested by you. 

If you withdraw consent, the app will stop the relevant technology from undertaking further optional processing. Withdrawing consent does not affect processing that took place before consent was withdrawn. 

You can manage optional categories and individual technologies at any time through the Privacy Settings within the MyIrishLife App. 

Rejecting optional technologies will not prevent you from using the app’s essential functions. However, functionality that depends upon an optional technology may be unavailable. 

5.  Device and operating-system permissions 

Some app functions may require a separate permission provided through your device or operating system. These may include: 

  • biometric authentication; 
  • notifications; 
  • access to your camera or photographs; 
  • access to location information; and 
  • Apple’s App Tracking Transparency permission, where applicable. 

These permissions are controlled through the prompts and settings provided by iOS or Android. They are separate from the technology choices managed through our app. 

Refusing or withdrawing a device permission may prevent the associated feature from operating. 

Changing a device permission does not automatically change your choices within our app. Changing a choice within our app does not automatically alter the permissions held within your device settings. 

6.Changing or confirming your choices 

You can change or withdraw your choices at any time through the Privacy Settings within the MyIrishLife App. 

7. Consent Records 

We will resurface the consent interface after 6 months and we will always only use your current consent preferences.  

Consent records are used solely for consent management, compliance and regulatory purposes. 

8. Personal Data and Privacy 

The technologies described in our policy may involve the processing of personal data depending on their purpose and functionality. 

Further information about how we collect, use, share and protect personal data, including your rights under data protection law and how to exercise them, can be found in our Privacy Notices as outlined above. 

9. Changes to This Policy 

We may update this App Tracking Policy from time to time to reflect changes in legal requirements, technology, business practices or the services available within the MyIrishLife App. 

The latest version will always be available within the application. 

10. Contact Us 

If you have any questions regarding this policy, consent preferences or your privacy rights, please refer to our Privacy Notices and the contact details provided therein.