Cookie and Privacy Statement

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Who We Are?

We are Enniscorthy Credit Union Limited (“we” or “us”). We are committed to protecting and respecting your privacy.

This statement sets out the basis on which any of your personal data is processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.

We are a data controller for the purpose of the Irish Data Protection Acts 1988 and 2018 (“Acts”).

Full contact details are available on the home page of this website.

Information We May Collect About You

We may collect and process the following information about you:

• Information provided at the time of registering to use our online credit union services.
• Information that you or others provide by filling in forms on our website or which you or they otherwise provide to us.
• Information relating to your financial details/circumstances.
• Any instructions we accept from you or transactions we undertake to which you are a party, whether through our website, offices or otherwise. This information may be provided by others e.g. joint account applications.
• Other personal information such as: CCTV images at our offices.
• If you contact us, we may keep a record of that correspondence.
• Telephone calls may be recorded. This is to verify your information, for our staff training, regulatory requirements and for service quality purposes.
• Information you have consented to us using.
• Sometimes we may use your personal information even if you are not our member. For example, you may be a nominee on an account, a guarantor, or a third party acting on behalf of one of our members. You could also be a potential member applying for membership of the credit union.

This information may be Personal Information or Anonymous Information as described in this Privacy Statement.
Personal Information refers to information that identifies (whether directly or indirectly) an individual or business entity. Examples may include your name, postal address, email address, telephone number, PPSN or TIN Identification number, birthdate, banking information or other information.

Anonymous Information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual or business. You could provide anonymous information, or it could be collected automatically. Examples may include information about your internet browser, device information about the device you use to access the site (this information may include geolocation information and unique device information), demographic data such as common bond, usage information about your use of the site, additional traffic data such as time and date of access, software crash reports, session identification numbers and access time, and other information regarding your use of the site.

Use of Cookies

We may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our website and to deliver a better and more personalised service. Some of the cookies we use are essential for the website to operate.

You block cookies by activating the setting on your browser which 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 to access all or parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit the website.

They enable us:

•  to estimate usage numbers and patterns;
• to store information about your preferences, and so allow us to customise the website according to your individual interests;
• to speed up your searches and
• to recognise you when you return to the website.

The website uses google analytics to collect information about how visitors use the website. The cookies used by this product collect information in an anonymous form and are used by many different websites. If you wish to opt out of being tracked by google analytics across all websites, please visit http://tools.google.com/dlpage/gaoptout.

We use service providers such as google analytics, which use cookies and other similar technologies, to collect information about use of the site anonymously and report website trends, without identifying individual visitors.

By using the site, you are accepting the practices described in this privacy statement. If you do not agree to the terms of this privacy statement, please do not use the site.

What We Do With Your Information

We use information held about you in the following ways:

• to provide credit union and other related services, products and facilities to you;
• to assess eligibility and credibility for the services, products and facilities we offer;
• to implement any contracts, we have entered with you;
• to conduct credit searches with credit reference agencies in order to provide credit facilities and, where necessary, for fraud prevention and debt recovery;
• to provide you with access to the site;
• to communicate with you about your account with us and send you information about features and enhancements on or to our site;
• to send you newsletters, offers and promotions for our services, third party products and services, or special events by e-mail, text, or another medium, always in compliance with your privacy;
• to detect, investigate, and prevent activities that may violate our policies or be illegal and
• to perform statistical, demographic, and marketing analyses of users of the site.

We may also use information about you to notify you about changes to our services to which you have subscribed or to provide you with information about products or services that you request from us or, where you have agreed to us doing so, which we feel may interest you.

We may use anonymised or statistical information to analyse our website and services and to make improvements or other adjustments to them. We use your information to support our legal and compliance obligations.

Where Do We Store Your Personal Information?

Your personal data will be stored on our secure servers at our office in Enniscorthy and at other dedicated secure data backup locations.

It is possible that some of the information about you that we hold 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, one of our suppliers or someone else. For instance, if it is necessary to do so to complete a transaction, your personal information (e.g. name and account details) may be sent to a third party or one of our contracted suppliers outside the EEA.

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 statement. You thereby consent to the general use of such information as provided in this privacy statement and to the transfer of that information to, and/or storage or processing of that information in the EEA and you understand that your information may be available to government authorities under lawful orders and laws as applicable.

We will retain your personal information for the period necessary to fulfil the purposes outlined in our Data Protection Policy and Records Management Policy, unless a longer retention period is required or permitted by law.

We will comply with applicable laws that govern the transfer of personal information in transactions and provide with appropriate notification and choice, as required by law. As a result, please be aware that in such event and to the extent permitted by law we may transfer some or all your information to a company acquiring all or part of our assets or to another company with which we have merged. Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this privacy statement, as it may be amended from time to time. Nevertheless, to the extent permitted by law, we may not be able to promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in our Data Protection Policy.

Who Do We Share Or Transmit Your Information With?

We may share personal and anonymous information with agents, subsidiaries, affiliates, partners and other third parties that perform functions on our behalf, such as hosting, billing, content management tools, customer service, fraud protection and legal as applicable. These entities have access to the personal information needed to perform their functions and are obligated to maintain the confidentiality and security of that personal information. The service providers are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services.

Our service partners

We may use the following third-party service providers named below to process and store your data:

Mailchimp (The Rocket Science Group, LLC), which we use to manage email marketing subscriber lists and send emails to our subscribers. Read their Privacy Policy.

Google LLC, we use Google Analytics service to measure the performance of this website. Read their Privacy Policy.

WordPress.org whose WordPress software (and associated add-ons) we use to manage the content of this website. Read their Privacy Policy.

If we issue you a debit card, Transact Payments Malta Limited (which is an authorised e-money institution) will also be a controller of your personal data. In order for you to understand what they do with your personal data, and how to exercise your rights in respect of their processing of your personal data, you should review their privacy policy which is available at http://currentaccount.ie/files/tpl-privacy-policy.pdf.

We will not share your personal information with or sell it to third-party marketers.

Security For CUOnline+

All information you provide to us through CUOnline+ is stored on secure servers. Any payment transactions undertaken through CUOnline+ are encrypted using SSL technology.

You must keep your PIN, Password and Username for CUOnline+, and any other security device we give you, safe and secure.

You should log off CUOnline+ and your Online Account when finished using CUOnline+.

The use of the Internet, by its nature, is not always secure. As a result, while we have reasonable IT security measures in place, we cannot guarantee the security or privacy of communications made over the Internet including any related to CUOnline+, the Online Services or your Online Account.

You are responsible for providing all you require to safely and properly access and use CUOnline+ and the Online Services including a computer, an Internet connection and security software.

Please understand, however, that while we try our best to safeguard your personal information once we receive it, no transmission of data over the internet or any other public network can be guaranteed to be 100% secure. We review our security procedures to consider appropriate technology and methods to secure information and take steps to keep your personal information safe.

Your Rights

You have rights under the Irish Data Protection Acts 1988 and 2003 and the General Data Protection Regulation (EU) 2016/679.

You have the right to ask us not to process your personal data for marketing purposes. We will usually 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 at info@enniscorthycu.ie.

You also have the right to access information held about you. Your right of access can be exercised in accordance with the Acts. Any access request may be subject to a statutory fee to meet our costs in providing you with details of the information we hold about you.

You have the right to have your personal information corrected, if inaccurate, or erased, if the credit union does not have a legitimate reason for retaining that information. We do however need members to submit a written request for such rectification or erasure by email, fax or post, providing enough details for us to identify the person and data concerned.

Your obligations in using the site are to provide true, accurate, current and complete information. If Enniscorthy Credit Union has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, we have the right to suspend or terminate your account and refuse any and all current or future use of the site (or any portion thereof). You are entirely responsible for the security and confidentiality of your password and account. Furthermore, you are entirely responsible for any and all activities that occur on your account.

Changes To Our Privacy Statement

We reserve the right to modify or amend the terms of our privacy statement from time to time. We will post any privacy statement changes on this page, and if the changes are material, we will provide a more prominent notice. Your continued use of the site following the posting of changes to these terms will mean you accept those changes. If we intend to apply the modifications or amendments to this privacy statement retroactively or to personal information already in our possession, we will provide you with notice of the modifications or amendments and if required by law, obtain your consent.

Any changes we may make to our privacy statement in the future will be posted on this page.

Children’s’ Privacy Statement

Enniscorthy Credit Union is concerned about children’s privacy.

The websites that we operate provide a forum for all our members, including children, to view our products and what is happening. While we encourage children to participate appropriately in our websites, their privacy is extremely important to us. This Children’s Privacy Statement explains our information practices in connection with information provided by children under the age of 16 years old on websites that link to this Children’s Privacy Statement. The websites are controlled and operated by us from Ireland and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the Republic Of Ireland. Our goal is to minimise the information gathered from and disseminated about children under 16 years old while permitting them active participation in the trustworthy information, education and independent voice for which Enniscorthy Credit Union is known

A. How do we Collect and use Information from Children?

Children can explore the websites, and can view and print reviews, comments and other content without providing any personal information. We do not permit children under 16 years of age to become an CU Online user. We may use information collected from children during the exploration of our sites in the following manner:

• To confirm the child’s account
• To determine the child’s current age in order to respond to any queries in an appropriate manner.

Children may post comments on our websites provided they are eligible users of said websites. We moderate all postings including children’s postings to remove personal information, and we encourage parents to discuss with their children why they should never include personal information in comments posted to the websites. Children may also participate in other online activities, such as polls. All members, including children, can delete their postings to the websites. Or the member can send an email requesting deletion to info@enniscorthycu.ie, noting their name and date of the comment. It is possible that deleted reviews or comments will remain in our system (such as in backups of our data), but they will not be visible through the sites. Please note that your request for deletion does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been re-posted by another user.

When children interact with the websites, certain technical information may automatically be collected, both to make our websites more interesting and useful and for various internal purposes related to our business. Examples of information that is automatically collected include: the type of computer operating system, the device’s IP address or mobile device identifier, the web browser, the frequency with which the child visits various parts of our websites, and information regarding the online or mobile service provider. This information is collected using technologies such as cookies, flash cookies, web beacons, and other unique identifiers (which we define under the “Use of Cookies” section of our general Privacy Statement). This information may be collected by us or by a third party. Persistent identifier information is used by Enniscorthy Credit Union for the sole purpose of providing support for our internal operations, including in order to:

• Ensure that the websites function properly
• Enable us to conduct research and analysis to understand, address and improve the use and performance of the websites and
• Diagnose and respond to problems.

B. What Information about Children is Shared?

We do not disclose to third parties any children’s personal information that we collect other than as follows, consistent with applicable law:

(a) with a parent’s permission,
(b) as required by any applicable law,
(c) to third-party service providers who help us operate or manage the Sites,
(d) as part of aggregated data shared with third-party service providers,
(e) to comply with legal process,
(f) to respond to governmental requests,
(g) to enforce our Terms of Service,
(h) to protect our operations,
(i) for assistance in fraud detection and prevention;
(j) to protect the rights, privacy, safety or property of Enniscorthy Credit Union, your child or others,
(k) to permit us to pursue available remedies or limit the damages that we may sustain, and (l) in connection with a disposition of all or a substantial portion of our business, assets or stock, such as a sale, merger, consolidation, re-organisation, joint venture, assignment, or bankruptcy or similar proceedings.

C. How Parents can Access, Change or Delete Information about their Child?

Parents may at any time access or change the personal information that we have collected online from their children. Parents may also ask us to cease further collection of personal information from their children, or to make no further use of, or delete, the personal information we have collected online from their children, in which case, the child’s account will be deleted. Parents may contact us at info@enniscorthycu.ie. For your child’s protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

D. How can Parents Raise other Questions or Concerns?

If a parent has any questions or concerns about his or her child’s use of the sites, we encourage the parent to contact us.

Contact Us

Comments and requests regarding this privacy statement are welcomed and should be addressed to:

Data Protection Officer,

Enniscorthy Credit Union,

Abbey Square

Enniscorthy

Co. Wexford

Email: info@enniscorthycu.ie

Phone: 053 9233835

You have a right to complain to the Data Protection Commissioner (DPC) in respect of any processing by using the details below (or completing a webform by going to: https://www.dataprotection.ie :

Data Protection Commission,

21 Fitzwilliam Square South,

Dublin 2,

D02 RD28,

Ireland.

Tel: 0761 104800

Enniscorthy Credit Union is regulated by the Central bank of Ireland

Dated: January 2020