PRIVACY POLICY

1. WHO WE ARE

Autopoint.ie is a trading name of First Citizen Finance DAC. In this policy, the use of “FCF”, “us”, “we” or “our” refer to First Citizen Finance DAC, and its subsidiaries and related companies, including (but not limited to): FC Capital Holdings DAC, First Citizen Agri Finance DAC, First Citizen Asset Management DAC.

Our head office is located at:

Bloom House, Gloucester Square, Railway St, Dublin 1.

2. INTRODUCTION

Data protection has always been of paramount importance to First Citizen Finance DAC (FCF), we appreciate the trust that you put in us to use your personal data only for appropriate reasons in the course of our relationship with you. With the implementation of EU General Data Protection Regulation 2018 (GDPR) as of the 25th of May 2018, anyone who holds individuals’ personal data must meet the obligations of GDPR which includes enhancing their policies and, in general, to be more transparent. GDPR also gives you greater control over how we use your personal data.

Though little has changed for FCF, you can read below our thorough privacy policy explaining our bases for collecting and using your personal data, what we do with it, and what your rights are with regard to your personal data in accordance with all applicable data protection laws and principles, including GDPR and the applicable Irish Data Protection Acts.

We thank you for your continued trust in us.

3. HOW WE COLLECT YOUR PERSONAL DATA

Personal data can be collected in the course of our relationship with you, and as you avail of our services, both directly from you and from other parties, when appropriate. Examples of when and the kind of data we may collect is listed below:

When you make an application with us, in order to process your application fully, we may share with and receive personal data from third parties such as the Irish Credit Bureau and the Central Credit Register. More information on our sharing of personal data with third-parties can be found in the “Who we share personal data with” section (section 5).

4. HOW WE USE YOUR PERSONAL DATA

Our use of your personal data is primarily in relation to the performance of a contract with, or a service to, you. We have and will continue to keep our client’s personal data secure and ensure that it is only used for the needs of our relationship with you. This may require us to share your data with selected entities and organisations such as funding partners, back-up service providers, auditors, investors, and outsourcers of services.

Examples of how we use your personal data:

5. WHO WE SHARE PERSONAL DATA WITH

We only share your personal data with third-parties when it is required in the course of our contract with you, and to fulfil the requirements of the conducting of our business. Any third-parties who we share data with are expected to have their own adequate information security measures and to be fully compliant with all applicable data protection legislation. These third-parties must enter into Data Sharing agreements with FCF prior to any transfer of personal data.

We are also bound to provide personal data in relation to regulatory or lawful requests.

Examples of situations we would share your personal data with third-parties:

  • To perform credit checks with, and provide reports on loan performance to, the appropriate credit bureaus or credit registers.
  • To process payments, such as direct debits from accounts or refunds to customers.
  • Where we service finance products on behalf of another company, they have access to your personal data.
  • Products that are offered in conjunction with another party or another party provides funding for, we must acquire their approval before we can complete loan processing.
  • In situations where another entity or person is a member of the FCF credit committee or credit assessment process.
  • To report on performance of loan portfolios owned by another company but serviced by FCF.
  • At the request of our credit intermediaries when they act on your behalf.
  • To collect debts, such as in the event of an insurance claim or the death of a client.
  • To trace missing customers.
  • To initiate legal proceedings.
  • To obtain legal advice.
  • For external audits by audit companies.
  • Assigning loans to Special Purpose Vehicles (SPVs) owned externally, but serviced by FCF.
  • Storage of hard-copy files relating to customer information by secure storage companies.
  • In relation to providing services to politically exposed persons or sanctioned persons.
  • To prevent money-laundering / financial crime.
  • In the case of joint accounts or accounts with guarantors, they will have access to certain data on the other account holder.
  • In the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms outlined in our privacy policy and that they only use your personal data for the purposes that you provided it to us.
  • To third-parties in connection with a sale or purchase of assets by us. For further information on the parties we share personal data with, please do not hesitate to contact us. Our contact details can be found in section 11 of our privacy policy.
  • 6. HOW LONG WE HOLD YOUR PERSONAL DATA FOR

    How long we hold your personal data for depends on several factors:

    Our current policy for the retention and deletion of personal data states that in typical cases we will hold your data for one year, if you applied but did not avail of a product, or six years after the last transaction if you are an active customer of ours. Data on job applicants who did not get hired is retained for one year. In the case of customers of ours who availed of our finance in partnership with the SBCI, as per EU state rule, we must retain your personal data for 10 years after the last transaction. When this time elapses, if the data does not need to be retained for other reasons, the data is permanently deleted in the next of our bi-annual system-wide data purges. In some cases this deletion of data, in practice, may also involve the anonymisation of some data so that it may be retained, and subsequently used, for statistical or analytical purposes.

    7. OUR LAWFUL BASES FOR USING PERSONAL DATA

    Under data protection lawful bases for processing, we may collect and use personal data under one or more of the following lawful bases, depending on the context:

    We process limited amounts of sensitive data (special category data) but where we do, we will have a lawful basis for doing so.

    In any situation where we have sought and acquired consent to process your personal data, you may withdraw your consent at any time by notifying us. Any processing of the data done prior to the withdrawal of consent is unaffected. Please do not hesitate to contact us if you wish to identify the specific basis for our holding of particular personal data of yours. We may rely on different lawful bases for different data elements.

    8. THE IMPLICATIONS OF NOT GIVING REQUESTED PERSONAL DATA

    We will only ever use your personal data for one or more of the reasons outlined in the lawful bases section of this document (section 7). If we ever require more personal data which falls outside of our general lawful bases (contract, legal obligation or legitimate interest) we will seek your express agreement in the collection and processing of this data.

    Though you are not obligated to provide us with any data we request, if you choose not to, it is possible we will not be able to provide the service you requested or adequately assess your application for a product.

    If you are ever concerned about what our basis for wanting particular personal data is, we can tell you under which category it falls and why.

    9. INTERNATIONAL DATA TRANSFERS

    In certain circumstances it will be required that we transfer your personal data to entities outside of the EEA in order to improve our service to you and assist us in our provision of products to you. You can be assured that if we do share your information with an entity outside of the EEA it would solely be on the basis that the recipient acts only in accordance with the agreed terms and processes the data only on our instruction, so that your data rights would never be compromised.

    10. YOUR DATA RIGHTS

    We at FCF take the protection of your personal data and our responsibility to ensure your rights very seriously. Below is a list of your data protection rights. If you have any further queries please check out the useful links section at the end of the privacy policy for further reading on the subject, or contact us for further information. Our contact details can be found in section 11 of this policy.

    Your rights are as follows:

    11. CENTRAL CREDIT REGISTER (CCR)

    Under the Credit Reporting Act 2013 (CRA) First Citizen Finance DAC are required to provide personal and credit information for credit applications and credit agreements of €500 and above to the Central Credit Register.

    The Central Credit Register is owned and operated by the Central Bank of Ireland. For more information see www.centralcreditregister.ie

    As a credit information subject (CIS) you have certain rights and duties under CRA. This applies to both borrowers and guarantors of credit agreements.

    As a CIS your rights are as follows:

    Insert an explanatory statement on your credit report

    You have a right to place an explanatory statement of 200 words or less, relating to any of your information held on the Central Credit Register, and this will be included on your credit report.

    Apply to have your information amended

    You have a right to make an application to your lender and the Central Bank to amend information held on the Central Credit Register about you, if you believe it is inaccuate, incomplete or not up to date.

    Report and be informed of suspected impersonation

    You have the right to give notice to a lender or the Central Bank if you reasonably believe you have been, are being, or may be about to be impersonated by any person.

    Obtain your credit report

    You have the right to request your credit report at any time, free of charge (subject to fair usage).

    12. OUR CONTACT DETAILS / HOW TO MAKE A COMPLAINT

    If you have any queries regarding this policy, or FCF in general, you can contact us by:

    Post: Data Protection Manager
    First Citizen Finance DAC
    Bloom House
    Gloucester Square
    Dublin 1 D01 C576
    E-mail: info@firstcitizen.ie
    Phone: +353 (0)1 8846700

    If you are concerned with our processing of personal data, or wish to make a complaint please contact us via one of the above channels with as much information on your concerns/complaint as possible. We will endeavour to respond to and resolve your issue as quickly and efficiently as possible.

    Alternatively you can make your complaint by contacting the Data Protection Commissioner via the below channels:

    Phone:   +353 (0)761 104 800
    Fax:   +353 (0)57 868 4757
    E-mail:  info@dataprotection.ie
         
    Post:   Data Protection Commission
        Canal House
        Station Road
        Portarlington
        Co. Laois R32 AP23

    13. SECURITY NOTICE

    We consider the security of our customers’ personal data a very important issue, especially with the rapid advancement of technology that is seen in modern times. We maintain a high level of internal and external security and are always seeking to improve our systems in an ongoing process.

    For your own protection we will seek to confirm your identity prior to providing you with any account information or personal data that you might request.

    14. WEBSITE COOKIE POLICY

    Our website does not uses “cookies” technology.

    15. UPDATES TO THIS POLICY

    Our data privacy policy will be updated from time to time. This may reflect changes in technology, or how we use your data. Our policy will always be updated prior to changing our practical use of any data. Updates to our privacy policy will always be dated, with the previous version available on archive for a period of time.

    Latest change to our Privacy Policy: 19/06/2019

    Link to previous version of our Privacy Policy

    16. USEFUL LINKS

    Full GDPR document link

    Data Protection Commissioner link

    GDPR and You link

    Data Protection Acts link

     
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