Website Privacy Statement
This is the website privacy statement of Spry Finance, the retail division of Seniors Money Mortgages (Ireland) DAC, trading as Spry Finance and Seniors Money. In this document, "we", "our", or "us" refer to Spry Finance. Spry Finance will be the Data Controller of the personal data that you provide to us.
We are company number 409589 registered in the Republic of Ireland.
Our registered office is Fifth Floor, 40 Mespil Road, Dublin 4, D04 C2N4, Ireland.
This is a notice to inform you of our policy about the information that we record about you on our website. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this statement, “process” means collect, store, transfer, use or otherwise act on information.
We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them and will not accidentally fall into the hands of a third party.
We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR). The key principles relating to the processing of personal data under the GDPR are lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability.
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now, through this website privacy notice and by requesting that you read the information provided at Your Rights under the GDPR | Data Protection Commissioner.
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
2. What data do we collect?
Spry Finance collects the following data:
- Personal Data: (i) basic personal information such as a data subject’s name and date of birth, (ii) contact information, such as a data subject’s postal address, email address and phone number(s), and (iii) any other personal data provided to Spry Finance during the provision of its services; and
- Special Category Data: We may also process special category data received directly from data subjects (or through their legal representatives or other representatives) as part of our loan application process. This may include: (i) personal data revealing racial or ethnic origin (e.g. passport / birth certificate); and (ii) data concerning health. Special category data is not currently collected via our website.
3. How do we collect your data?
You directly provide Spry Finance with most of the data we collect. We collect and process data when you:
- Complete a New Loan Enquiry Form on our website;
- Complete an application form for one of our products or services;
- Voluntarily complete a customer survey by phone or via email;
- Use or view our website via your browser’s cookies; and
- Raise a query or provide us with feedback by:
- Phone call - Phone calls to our service desk may be recorded. In addition, a record of personal data received during the course of phone calls may be recorded in the form of notes made on the relevant case file.
- Email - All emails received by Spry Finance are recorded, forwarded to the relevant section of the company and are stored for the purposes of the matter to which the email relates. The sender’s email address will remain visible to all Spry Finance staff tasked with dealing with the query.
- Post - All post received by Spry Finance is scanned, forwarded to the relevant section of the company and stored for the purpose of the matter to which the post item relates.
We may also receive your data indirectly through the following sources:
- From your legal representative(s) or nominated alternative contact(s); and
- During the course of automated screening checks such as credit checks, anti-money laundering, fraud and terrorist financing screening.
4. How do we use your data?
Spry Finance collects and processes personal data for a number of different purposes, which arise in the provision of its services. Some examples of the purposes for which Spry Finance may collect and use personal data in accordance with these services are:
- New loan inquiries - including personal data received from data subjects directly (or through their legal, or other representatives) where the data subject contacts us by telephone or email, or uses our website to request us to provide them with information in relation to our products and/or services;
- New loan applications - including personal data received from data subjects directly (or through their legal, or other representatives) where they are submitting an application in order to access our products and/or services;
- Loan servicing - including personal data received from data subjects directly (or through their legal, or other representatives) in the ongoing servicing of our products, including personal information provided as part of our annual questionnaire process;
- Queries and concerns - including personal data received from individuals who have raised queries or concerns with Spry Finance;
- Complaint handling - including personal data received from a data subject directly (or through his or her legal representatives) where the data subject makes a complaint to Spry Finance;
- Service providers and suppliers - including personal data obtained from service providers or suppliers engaged by Spry Finance; and
- Job applications - including personal data received from persons applying for roles within Spry Finance.
At present, Spry Finance only collects personal data via our website for the purposes of (i) facilitating new loan enquiries, and (ii) gathering information in relation to our website user’s browsing activity.
Spry Finance does not currently use automated decision making processes that will be applied to your data (e.g. profiling). However, automated screening checks such as credit checks, anti-money laundering, fraud and terrorist financing screening may be completed where you apply for a loan with us.
5. Who do we share your data with?
We do not disclose your personal information received through our website to any third party (except as set out in this notice). Nor do we receive data that is made up from your personal information from third parties (except as set out in this notice).
Where you enter into a Lifetime Loan with Spry Finance, we may share your data with:
- your authorised representatives;
- third parties with whom: (i) you ask us to share your information; and (ii) we need to share your information to facilitate a transaction on your behalf;
- service providers who provide us with support services;
- Seniors Money Group companies;
- statutory and regulatory bodies and law enforcement authorities;
- credit reference/rating agencies (e.g. Irish Credit Bureau); and
- third parties in connection with a sale, purchase, or financing of assets by us; and
- business or joint venture partners.
Our service providers are obliged to keep your details securely and use them only to fulfil the service they provide to you on our behalf.
6. The legal bases on which we process information about you
The law requires us to determine under which bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data. If the basis changes then if required by law, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
i. Information we process because we have a contractual obligation with you
At present, our website does not collect data that requires a contract be formed between you and us.
When you take out a loan with us, or otherwise agree to our terms and conditions, a contract is formed between you and us. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information. We may use it in order to:
- verify your identity for security purposes;
- provide you with our products and services;
- provide you with suggestions and advice on products, services; and
- advise you on how to obtain the most from using our website.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. If you decide not to provide the data required to enter into a contract with us, we may be unable to provide you with our products and/or services.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
ii. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at [email protected]. This will not affect the lawfulness of processing based on consent before its withdrawal. However, if you do withdraw your consent, it may limit your ability to use our website or our services further.
iii. Information we process for the purposes of legitimate interests
We may process information on the basis that there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means;
- whether processing (or not processing) might cause you harm; and
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our website;
- responding to unsolicited communication(s) from you to which we believe you would expect a response;
- protecting and asserting the legal rights of any party;
- insuring against or obtaining professional advice that is required to manage organisational risk; and
- protecting your interests where we believe we have a duty to do so.
iv. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation. For example, we may be required to give information to legal authorities if they so request, or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
7. How do we store your data?
The Spry Finance website is hosted in Europe. We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business. For example, historic Lifetime Loan application and settlement details are stored in New Zealand with Seniors Money Mortgages (Ireland) Limited’s loan account management systems provider. Data is also stored on Salesforce CRM systems providers in Europe. Accordingly data obtained within Ireland or any other country could be processed outside the European Union.
We use the following safeguards with respect to data transferred outside the European Union:
- the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing; and/or
- the data protection clauses in our contracts with data processors include strict transfer clauses relating to protection of your information.
8. Your Data Protection Rights
Under data protection law, data subjects have certain rights. You can exercise these rights in relation to your personal data held and processed by Spry Finance.
Your data subject rights are:
- The right to be informed about the processing of your personal data. If you require any further information in relation to how we collect, store or process your data please let us know.
- The right to access your personal data. You have the right to request Spry Finance for copies of your personal data. Please note that we may charge a small fee for this service.
- The right to rectification of your personal data. You have the right to request that Spry Finance corrects any information you believe is inaccurate. You also have the right to request us to complete any information you believe is incomplete.
- The right to erasure of your personal data. We do not display any personally identifiable information about you on our website. However, you have the right to ask us to erase your personal data from our records and systems, under certain conditions.
- The right to data portability. You have the right to request Spry Finance to transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
- The right to object to processing of your personal data. You have the right to object to Spry Finance’s processing of your personal data, under certain conditions.
- The right to restrict processing of your personal data. You have the right to request that Spry Finance restrict the processing of your personal data, under certain conditions.
- Rights in relation to automated decision making, including profiling. You have the right to not be subject to a decision based solely on automated processing.
At any time you may review or update personally identifiable information that we hold about you. Please note that we shall first take reasonable steps to verify your identity before granting you access to your information or otherwise taking any action. This is important to safeguard you and your information.
Where we receive a request to access, edit or delete personal identifiable information we will attempt to deal with this request as quickly and efficiently as possible. However, please note that it may take up to one month to fully respond to your request.
To obtain a copy of any personally identifiable information that we hold about you, or to exercise any of the above rights please contact the Spry Finance Data Protection Advisor at [email protected].
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
- to register your visit to our website,
- to track your privacy preference settings (i.e. your cookie consent), and
- to analyse how you use our website.
10. Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed into our website.
Spry Finance may like to send you information about products and services that we think that you might like. However, we will never use your personal data for marketing purposes unless you have specifically consented to this use. If you have agreed to receive marketing material from us, you may always opt out at a later date.
You have the right at any time to stop Spry Finance from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please let us know at [email protected].
12. Our use of re-marketing
We currently do not use any form of re-marketing. We do not advertise our products and services on third party websites based on the pages on our website that you may have visited.
13. Third party advertising on our website
At present, third parties do not advertise on our website.
14. Use of this site by children
We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.
15. Encryption of data
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
16. Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
- to provide you with the services you have requested;
- to comply with our legal obligations, including for the period demanded by our regulator and tax authorities; and
- to support a claim or defence in court.
17. Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this website privacy notice from time to time as necessary. The terms that apply to you are those posted on our website on the day that you use our website. We advise you to print a copy for your records.
19. How to contact us
By telephone: (01) 5822 570
By email: [email protected]
Or, if you would prefer, you can write to:
Spry Finance Data Protection Advisor
38 Pembroke Road
Dublin 4 D04 E3E6
If a dispute is not settled to your satisfaction, then we hope that you will agree to attempt to resolve it by engaging with us in good faith in a process of mediation or arbitration.
20. How to contact the regulatory authority
If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Data Protection Commission. To raise a query, concern or complaint regarding a data protection matter, you can engage with the Data Protection Commission in the following ways:
- By webform on the DPC website - Data Protection Commission
- Or in writing to:
Data Protection Commission
21 Fitzwilliam Square South
|Spry Finance Data Protection Advisor
|1st March 2022