This Privacy Notice relates to our online privacy practices only. Please review our Fair Processing Notice here which sets out what personal data we collect and process, where and who we obtain the data from; how we process the data; who we share data with and how we manage your rights in relation to your personal data.
1. Who We are
We are Wexford Credit Union Limited (“we” or “us”). We are committed to keeping your personal information private. We understand that your privacy and the security of your personal information are very important to you.
This Privacy Statement, along with our Website Terms and Condition, and our Cookies policy sets out the basis on which the personal data that we collect from you or that you provide to us online, will be processed by Wexford Credit Union in. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.
By using this website, you signify acceptance of this Privacy Statement. If you do not agree with or you are not comfortable with any aspect of the Privacy Statement, your only remedy is to discontinue use of the website. We reserve the right to modify this Privacy Statement from time to time at our sole discretion. When we do, we will also revise the ‘last updated’ date at the bottom of the privacy statement. We encourage you to periodically review this Privacy Statement to stay informed about how we are helping to protect the personal information we collect. Your continued used of any portion of the website following notification or posting of such changes will constitute your acceptance of those changes.
This website may, from time to time, contain links to and from the websites of third parties. Any external links to other websites are clearly identifiable and as such and we are not responsible for the content or the privacy statements of these other websites. The CU online service is operated by Wellington IT solutions. If you follow a link to any of these websites, or logon to your account online, 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.
Our contact details are:
Contact details of our DPO:
||Data Protection Officer
Wexford Credit Union Limited
Luke Wadding House
||email@example.com (FAO The DPO)
2. Information we may collect
We may collect and process the following information you provide to us:
By registering your credit union account online, you are entering into a contract with us. We require you to provide us with a unique user name. This user name is used to identify you and will be stored by our core IT software providers a trusted representative of the credit union. Wexford Credit Union will be able to view your user name and it will be retained by us until you deactivate your online account.
We will ask you to provide us with your credit union account number, your name and your date of birth to verify your online registration.
You need an email address to register your account and will be asked for this when registering, this is for security purposes and to verify your identity. We will also request your contact number should we need to contact you regarding your account.
To access your account securely, you will have to choose a password; this information is stored by our core IT software providers and is not visible to the credit union.
You will be issued an eight digit pin to enhance the security on your account. This will be posted to the address on your account. This pin is stored by our core IT software providers and is not available to the credit union.
If you make a loan application online, we will store and process your financial details such as your income and expenditure and your personal details such as your occupation and the purpose of the loan. This processing is necessary prior to entering into a contract for credit as we have a legal obligation to assess your ability to repay the loan.
As part of the assessment on the loan application, we have a legitimate interest to check your credit history with a credit referencing bureau. The performance of your loan will also be reported to the credit referencing bureau on a monthly basis.
We have a legal obligation under the Credit Reporting Act 2013 to check your credit history on and report to the Central Credit Register.
If you wish to upload any documents to your online account, these will be saved to your account on our core IT software. These may be further processed, where we have a legal basis to do so, by the credit union, for example, we are legally obliged to verify your income when assessing your loan, therefore if you upload a payslip as your proof of income, we will download the payslip and use for that purpose, this information will then be stored by us as per our retention policy.
We have a legal obligation to store the details of any instructions we accept from you or transactions we undertake to which you are a party, whether through our website, branches or otherwise.
If you wish to use your online account to transfer money electronically, you will need to request this access level from the credit union. To do this, you will need to verify your identity by providing us with your Photo Identification and Proof of Address; this is a legal requirement under the 4th Anti-Money Laundering directive / Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 & 2013. These documents will be stored in hard copy with your membership application form. You will then be asked to provide us with security questions and answers; these will be recorded on your account and then scanned into a secure folder on our servers. The purpose of which is for added security to your account. If you contact us, we may keep a record of that correspondence.
2.1 We may collect and process the following information about you:
- When you log into cuAnywhere, we will collect information about you and your use of our services. For example we will be able to identify you as a customer, what pages you navigate to and your actions while logged in. This helps us to optimize the service we provide to you, deliver relevant communications to you and allows you to get the most out of your account online. By using any of our channels, you consent to the collection of this type of personally identifiable information and use of this information for these purposes
- We may process information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. We may also collect information such as the number of people who visit the website, date and time of visits, number of pages viewed, the amount of time spent on the website and popular sections of the website to help enhance your experience online. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
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, such as logging in to CU Online.
4. 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 into with you; and
- To conduct credit searches with credit reference agencies in order to provide credit facilities and, where necessary, for fraud prevention and debt recovery.
- We may use anonymised or statistical information to analyse our website and services and to make improvements or other adjustments to them. We do not, without your consent, disclose information about identifiable individuals to third parties, but we may provide anonymised statistical data to them for research and survey purposes. If you do not want us to use your data in this way, please contact us by sending an email to firstname.lastname@example.org. You may also change your preferences at any time by sending an email to email@example.com and amending your preferences accordingly.
When applying for membership of the credit union, we do ask for your preferences in relation to direct marketing. However, Wexford Credit Union does not engage in direct marketing at this time.
Should that change in the future, the processing of your personal data for marketing purposes requires your explicit consent. If we request your consent for this purpose, it will be presented in a manner which is clearly distinguishable as consent to marketing. If you had provided such consent, you have the right to withdraw it at any time, free of charge and such withdrawal will be as easy to as to give consent.
If you had previously consented to us using your personal information for marketing purposes and would like to withdraw such consent, you will be able to do so by clicking “unsubscribe” option at the end of any marketing email sent to you or by following the instructions to “unsubscribe” on any text message sent for marketing purposes. Alternatively, you could email us at firstname.lastname@example.org to withdraw your consent or change your preferences.
6. Third Parties
Your personal data may be disclosed to third parties in the following instances:
- We may disclose your personal information to approved contractors or sub-contractors working on our behalf. This can include the core IT service provider, our auditors, hardware IT support, our payment services providers, provider of a member’s credit history, printers, insurers, tracing agent, other credit union and solicitors.
- We may be 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 and other agreements; or to protect our rights, property, or safety and that of our users, or others.
- By submitting your personal data, you agree to the above 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.
- We are not aware that any of the information about you that we hold, is transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
7.Security for CU Online
All information you provide to us through CU Online is stored on secure servers. Any payment transactions undertaken through CU Online are encrypted using SSL technology.
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 CU Online, the Online Services or your Online Account. For this reason we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk.
You are responsible for providing all you require to safely and properly access and use CU Online and the Online Services including a computer, an Internet connection and security software.
7.1 How you can protect yourself:
- Keep your PIN, Password and Username for CU Online, and any other security device we give you, safe and secure
- Never reveal your user name, password or PIN to anyone
- Never give your PIN or login details to anyone who calls you or in an email or by text message, the credit union will never ask you for this information this way
- Never login to your account through a link contained in an email
- Only download the cuAnywhere app from official sources such as Apple App Store or Google Play
- Log off CU Online and your Online Account when you are finished using them
- Lock your phone, computer or tablet when inactive
- Check for suspicious money transfers, payments, payees or unauthorised access on your accounts on a regular basis, this is an effective way to detect fraudulent activity quickly.
8. Search engine:
The search facility on our website is an internal search function and only returns information that appears on the website.
9. Your Rights
You have rights under the General Data Protection Regulation (GDPR) and Wexford Credit Union respects these rights. We have appropriate procedures and policies in place to manage you exercising any of those rights.
- To find out whether we hold any of your personal data. If we do, you can request access to that data and be furnished with a copy of that data. You are also entitled to request further information about the processing (see below).
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you rectified.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes
- Request the restriction of processing of your personal information. You can ask us to suspend processing personal information about you, in certain circumstances.
- Where we are processing your data based solely on your consent you have a right to withdraw that consent at any time and free of charge.
- Request that we: a) provide you with a copy of any relevant personal data in a reusable format; or b) request that we transfer your relevant personal data to another controller where it’s technically feasible to do so.
You have a right to complain to the Data Protection Commissioner (DPC) in respect of any processing of your data by:
|Telephone +353 57 8684800 +353 (0)761 104 800
Lo Call Number 1890 252 231
Data Protection Commissioner
Canal House Station Road
Portarlington R32 AP23 Co. Laois
**Please note that the above rights are not always absolute and there may be some limitations.If you want to access or obtain a copy of any of your personal data or if you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we send you a copy/a third party a copy your relevant personal data in a reusable format please contact The Data Protection Officer in writing using their contact details in section 1 of this notice. You can do this via email, post or handing it into our office. Our “Rights Request” form can be downloaded from our website or requested from our office to assist you in exercising these rights.
Wexford Credit Union endeavours to meet the highest standards when collecting, using, storing and destroying your personal information. We urge you to notify us if you think that our processing activities are unfair, misleading or inappropriate. We also welcome any suggestions for improving our procedures.
This on line privacy statement does not provide a comprehensive detail of all aspects of our data processing and we encourage you to review our Fair Processing Notice available on www.wexfordcreditunion.ie/downloads.
11. When you Contact us
You can enquire about a loan by completing the “pop up” box that appears when you use our loan calculator, you will be asked for your name, contact number and email address and these details will be passed on to our loans team to contact you. When you log in to your account online, you will have the facility to send the credit union a secure message, this will be passed on to the relevant department to deal with.
Any emails sent to us are recorded and forwarded to the relevant individual or department. Your email address and the contents of the email will remain visible to all staff tasked with dealing with the query. We encrypt and protect our emails. We will also monitor any emails sent to us, including file attachments, for viruses or malicious software.
When you send us correspondence via the post, the correspondence may passed to the relevant individual / department to process the information, it may then be stored as per our retention policies.
When you contact us by telephone, or we contact you, the call may be recorded. This is for quality, training & verification purposes. These calls will be stored by us for six months. If you leave a voice message, it will be deleted once it has been read.
12. Changes to this Privacy Statement
Any changes we may make to our privacy statement in the future will be posted on this page. This Privacy Statement was last updated 24th May 2018.