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Privacy Policy

Privacy Statement

Finance For You Ltd is committed to keeping your information private. We understand that your privacy and the security of your information are very important to you.

Finance For You Ltd’s registered office is 77 New Street, Killarney, Co Kerry  V93 YCY5 is registered in the Republic of Ireland (Registration Number : 582973).

 

Terms and Conditions

Finance For You Ltd’s Privacy Statement is subject to the Terms and Conditions of Use of your Finance For You Ltd products and services.

We recommend that you read our Terms and Conditions of Use. If there is a conflict between our Terms and Conditions of Use and this Privacy Statement, our Terms and Conditions of Use shall prevail. Except as otherwise provided, terms used herein and defined in our Terms and Conditions of Use shall have the same meaning that is given to them in the Terms and Conditions of Use.

 

Please read this Privacy Statement carefully as it contains important information to help you understand our practices regarding any personal information that you give to us.

What information we collect

We process your personal information including:

  • the personal information that you give us during an application for or purchase of any product or service from us, or that you have given to us during a previous application or as a customer;
  • the personal information that we obtain about you from the retailer, broker, introducer or motor dealer who helps arrange the application for you;
  • the personal information that we receive from third parties such as credit reference agencies and fraud prevention agencies (see below), or tax authorities, where we need to contact these third parties as part of your application or in servicing your account with us. For personal loan or and motor finance applications, we receive information from your employer where you have provided your employment details;
  • the personal information that you give us while servicing your account via our website, in writing or over the phone; and
  • the personal information that you give us if you register interest in a product and/or service, request information or assistance from us or make a complaint.

What personal information we process

This personal information includes your:

  • name;
  • date of birth;
  • address and your address history (which includes, your main residential property and  the rental property if you are applying for a Buy To Let mortgage);
  • telephone number;
  • email address;
  • tax number (PPSN) with effect from 30th June 2019;
  • passport, driving licence or national identity card when you provide this as proof of identity;
  • details of expenditure;
  • bank details;
  • credit history and records relating to your partner or anyone else you are financially linked with (we receive this information from the credit reference (ICB & CCR) agencies and fraud prevention agencies);
  • details of your existing borrowings, credit cards, asset finance committments and loans or mortgages;
  • insurance details of the vehicle for motor finance;
  • transaction information on payments into and out of an account, and debit or credit card information;
  • employment/self employment details for motor and retail finance;
  • income and taxation information
  • information regarding whether you have any dependants;
  • identifiers assigned to your computer or other internet connected device including your IP address;
  • information linked to your mobile telephone number;
  • details about whether you own your property, rent it or live with others/parents;
  • information about your residency and/or citizenship in the Republic of Ireland for motore or retail finance products and services;
  • information you make public (for example on social media and on public registers);
  • your proposed or financed vehicle details for motor finance;
  • information relating to how you conduct your account and our dealings on it.
  • information about unspent criminal convictions or pending prosecutions relating to any aspect of dishonesty, which may have a bearing on your future employment or the likely conduct of the account.

If you make a joint application for motor finance or other retail finance products, we collect this type of information about the other applicant.

 

If there is a guarantor associated with your motor or retail financial products we record the individual’s name, date of birth, address, telephone number, email address, solvency status for Powers of Attorney, and bank details if the third party makes payments by direct debit for your account.

If you authorise a third party to act on your behalf, for example setting up a Power of Attorney for your account, we record the individual’s name, date of birth, address, telephone number, email address, solvency status for Powers of Attorney, and bank details if the third party makes payments by direct debit for your account.

In the unfortunate circumstance that one of our customers passes away, we record the following details of the next of kin and any executors of the estate: name, address, telephone number, and email address.

If you make an application on behalf of a business, we will process personal information about shareholders, directors, partners and owners, including name, date of birth, address, credit history and information made public (for example on social media and on public registers).

Where information fields are marked as mandatory on any application form that you complete, you will need to provide such information in order for us to continue with your application.

Special categories of Personal Data

Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected (e.g. biometric data).

We do not generally process such information, unless you have voluntarily provided that information to us, for example, where you have notified us of a health issue that would mean you would be classed as a ‘vulnerable customer’ (i.e. if you, due to your personal circumstances or personal characteristics, are especially vulnerable to financial detriment or where you have notified us of a custodial sentence that will impact your ability to manage your account).Criminal offence information is not defined as special categories of personal data, however, this information does require additional protections. Criminal offence information covers information related to convictions and offences, including alleged offences, court proceedings, and sentencing.

Where permitted by law, we process criminal offence information for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks with law enforcement and regulatory bodies.

 

How we use your personal information

In summary, we use your personal information for the purposes of:

  • servicing and internal processing (including by way of automated decision making for motor finance and retail finance);
  • management of our relationship with you (e.g. to develop your relationship with us);
  • tracing customers and recovering debts;
  • resolving queries/problems (e.g. responding to complaints or contacting you  if you do not complete your application);
  • training and service review (e.g. to help us enhance our services);
  • statistical analysis (e.g. to help us enhance our products and services); and
  • complying with legal obligations (e.g. to prevent, investigate and prosecute crime, fraud and money laundering).

Finance For You Ltd process your personal information to fulfil our contract with you, where we have a legitimate interest to do so (except where it would override your interests or fundamental rights and freedoms which require the protection of personal information), where otherwise permitted by law, or to comply with applicable law and regulation.

 

How we retain your information

The personal information that you provide will be retained by us in accordance with applicable laws. We take reasonable steps to destroy or anonymise personal information we hold if it is no longer needed for the purposes set out above.

Given our obligations under the Consumer Protection code 2012 (as amended) and our regulatory responsibilities under our authorisation we retain personal information for 6 years after the closure of your account/Hire Purchase/loan or the ending/termination of the customer relationship with you.

This includes ;

  • General personal data – personal information, e.g. DOB, address, and financial personal data, e.g. salary, employer details.
  • Special categories and criminal offence personal data may be captured if voluntarily provided to us.
  • Call recordings – these are retained for either 1 or 3 years.

 

How we share your information

The recipients with whom we share personal information are:

  • our third party service providers who act on our instruction and need to know the information in order to provide us or you with a product or service;
  • our third party service providers who act on our instruction and process information on our behalf to help run some of our business operations including email distribution, electronic signature processing, storage of customer documentation, IT services and websites, diallers and for statistical analysis, customer and loan management software and system providers;
  • independent debt recovery agencies or service providers, tracing agents or investigators, solicitors or other agents for the purpose of collecting monies due or outstanding on your account;
  • our partners including brokers, introducers, retailers and motor dealers we work with;
  • our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and to provide you with information about other products and services which might be of interest to you;
  • our advisors, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
  • our regulators comply with our legal and regulatory obligations;
  • entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
  • credit reference agencies (including Irish Credit Bureau (ICB) and the Central Credit Register (CCR) and fraud prevention agencies – see sections below ‘Sharing with Credit Reference Agencies’ and ‘For crime and fraud prevention and anti-money laundering’);
  • Hire Purchase Ireland (HPI) in order to register our legal interest in the asset being financed;
  • law enforcement bodies in order to comply with any legal obligation or court order;
  • third party lenders with whom we have a relationship, in case we do not wish to lend to you but another lender might. We will tell you before we do this and give you the opportunity to choose whether or not to allow your information to be shared in this way.
  • where you have agreed to receive such marketing, we may make your details available to reputable suppliers of credit and insurance related services that we feel may be of interest to you; and
  • we reserve the right to sell accounts/loans. In some circumstances, the firm to whom we sell accounts may require us to continue to process personal information. We will inform you if we do this.

 

Transfer outside of the EEA

Recipients with whom we share your personal information, for example our service providers, may be located in the Republic of Ireland, other countries in the European Economic Area or elsewhere in the world. Different privacy laws may apply in these countries and you understand and unambiguously agree to the transfer of personal information to these countries and parties.

Whenever we or our service providers transfer your personal information outside of the European Economic Area, we or they impose the standard contractual obligations approved by the European Commission on the recipients of that information to protect your personal information to the standard required in the European Economic Area or require the recipient to subscribe to ‘international frameworks’.

Monitoring

We monitor communications with us, including call recordings, for training purposes and to enhance or review the service we provide.

Sharing with Credit Reference Agencies

Before we offer motor or retail finance, we will undertake checks with credit reference agencies for the purposes of assessing whether to lend to you. These checks require us to process personal information about you and include credit scoring. We continue to undertake these checks after we have given you motor or retail finance to evaluate our risk and for statistical analysis (see ‘Statistical Analysis’ section).

In order to process the application for a business of which you are shareholder, director, partner or owner, we will undertake checks on you for the purposes of detecting and preventing crime, fraud and money laundering, and to verify your identity.  These checks require us to process your personal information with the credit reference agencies and fraud prevention agencies. We continue to conduct regular or extraordinary checks for the same purposes while you have a relationship with us, for example an annual check with credit reference agencies and fraud prevention agencies or for a change in company structure.

Automated decision making is used for motor or retail finance applications (see ‘Automated Decision Making’ section).

Credit reference agencies add to the record about you, and your partner or anyone else with whom you are financially linked, information about your application and repayment history, including any default or failure to keep to the terms of an agreement with us.

Credit reference agencies hold your personal information for up to five years.

Any information you disclose to us that is false or inaccurate will also be recorded by the credit reference agencies. These records will be shared with other organisations and may be used and searched by us and them to:

  • consider applications for credit and credit related services, such as insurance, for you and any associated person; and
  • trace customers, recover debts, prevent or detect money laundering and fraud, and to manage accounts.

We use the Irish Credit Bureau(ICB) and the Central Credit Reference (CCR) as our credit reference agencies. More information about the credit reference agencies and how they process your personal information is available at:  www.icb.ie/ and www.centralcreditregister.ie/

For crime and fraud prevention and anti-money laundering

Before we offer a product or service, we will undertake checks for the purposes of detecting and preventing crime, fraud and money laundering, and to verify your identity. These checks require us to process your personal information with the credit reference agencies or fraud prevention agencies. We may ask you to provide additional information. We continue to undertake these checks even after we have given you an account, for the same purposes.

The consequences of these checks may mean that:

  • If we determine that you may pose a risk of non or late repayment, we may refuse to lend to you.
  • If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to open an account for you or to lend to you, or we may require repayment of your mortgage or loan or we may stop providing existing services to you.

If you have an agreement with us (for example, if we wish to require the repayment of an existing motor finance or loan) then the terms of that agreement will dictate how we do this.

A record of any fraud or money laundering risk will be retained by the fraud prevention agencies and may result in others refusing to provide services or financing or employment to you. If you have any questions about this, please contact the fraud prevention agencies on the details below.

We, and fraud prevention agencies, may also enable law enforcement agencies to access and use your personal information to detect, investigate and prevent crime.

 

 

Automated Decision Making

As part of the processing of your personal information, some decisions for motor finance and retail finance are made by automated means.

Our processes to verify your identity and undertake checks to detect and prevent money laundering checks can result in an automated decision. This means we automatically decide that you pose a fraud or money laundering risk if:

  • our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers;
  • is inconsistent with your previous submissions; or
  • you appear to have deliberately hidden your true identity.

In some cases, we also use automated decision making to decide whether to offer you a motor finance or retail finance loan and the rate of interest for the loan, whether we think that you can afford the loan and will abide by the terms of any loan agreement including whether you will repay the loan.  This will involve us using logic to process different sources of information about you, such as from credit reference agencies, as well as our own algorithms to control our risk. Credit scores are produced from information such as credit commitments, whether you have made repayments on time, whether you have any history of insolvencies or court judgements, and how long you have lived at your current address.

If we make a decision solely on the basis of automated decision making, you have rights, for example, you can request human intervention and ask us to reconsider your application. If you want to know more please contact Customer Services.

Debt recovery

If you owe us money, or if we suspect fraud, we process your personal information in connection with pursuing the recovery of that money or prevention of that fraud.  We disclose information about non-payment, late payment or suspected or actual fraud to credit reference agencies, fraud prevention agencies, and law enforcement or government agencies in accordance with the law. We may share your personal information with independent debt recovery agencies or service providers, tracing agents or investigators, solicitors or other agents in order to recover monies you owe us. We use additional sources of personal information such as data obtained from providers of debt recovery agencies or fraud prevention agencies and we also process other personal information about you such as CCTV footage and information that you make public, for example on social media.

In the unfortunate circumstance that one of our customers passes away, we share the name, address, telephone number, and email address of the next of kin and any executors of the estate with our third party service provider in order to recover monies from the estate.

Statistical analysis

We use personal information of individuals who have applied for a motor loan or other loan account with us (whether accepted or declined) for statistical analysis to create scorecards in connection with the assessment of credit, fraud, risk, to refine lending and fraud strategies, and for analysis such as loss forecasting.

The personal information we use is obtained from credit reference agencies. Wherever possible, this information is processed on an anonymised basis.

Marketing

From time to time, we may send you information regarding our products and/or services or those from carefully selected third parties, such as lenders and brokers, which we think may be of interest to you where we have your agreement. You opt to receive this information by letter, telephone, SMS and / or email.

If, at any time, you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us or by contacting us. To unsubscribe from such communications by SMS, reply ‘STOP’ to the SMS.

Third Party Websites

If at any stage this website contains links to other websites, we accept no responsibility or liability for the content of other websites which are not under our strict control, in particular, we are not responsible for the protection and privacy of any information which you provide whilst visiting other websites and such sites are not governed by this Privacy Statement.

Email

Emails sent via the internet can be subject to interception, loss or possible alteration, therefore we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your information sent by email and therefore will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet.

Children’s Privacy

The Website is not intended for use by individuals under the age of 18 without the agreement and involvement of a parent or guardian. We do not knowingly collect personal information from individuals under the age of 18.

Updates

We will keep this Privacy Statement under review and make updates from time to time. We will notify you of any major changes which will affect the processing of your personal data, for example if we change the credit reference agencies we use.  We may make minor changes (such as to correct typographical errors, or to add information about other products or services which do not affect your personal information at this time) without notifying you.

Cookies

Cookies are used to monitor website traffic and enhance your experience of our website. Cookies are pieces of data which your computer, mobile or tablet device downloads when you visit a website. Cookies are used to keep track of your preferences and to recognise return visitors.
You can set your browser to reject cookies. However, if you choose to reject cookies, you may not be able to use or access certain of our online or mobile services.

 

We respect your rights

You have the right to request copies of certain of your personal information within our custody and control and details of how we use that information. Your request should be made in writing.

If you think any of the personal information we hold about you is inaccurate, you can also request it is corrected or erased.

You also have rights, in certain circumstances:

  • to object to our processing of your personal information;
  • to request human intervention if a decision has been made solely on the basis of automated decision making;
  • to require us to stop processing your personal information; and
  • to withdraw your agreement to processing based on ‘consent’.

You have a right to port personal information you have provided to us to a different service provider.

Complaints process

Our aim is to please but we know that sometimes things go wrong. If you have a problem, we want to know. Our staff will be happy to help you either on the telephone or in writing. Should you need to write to us, please address your complaint to Customer Resolutions, Finance For You Ltd, 77 New Street, Killarney, Co Kerry V93 YCY5.

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