Initiative Financial Services is committed to safeguarding the personal information of individuals. Initiative Financial Services is a Data Controller registered with the Data Protection Commissioner of Ireland, registration number 16237/A. This policy outlines how we will collect and manage your information. Initiative Financial Services reserves the right in its sole discretion to amend this privacy statement at any time, you should therefore regularly check this privacy statement for any amendments.
Collection of Personal Information
Your Right to Privacy
In this statement we explain how “Initiative Financial Services” respects your privacy in relation to interactions with this website. When we talk about “Initiative Financial Services” or “us” or “we” in this statement we are referring to Initiative Financial Services Limited, its subsidiaries, affiliates and their respective parent and subsidiary companies.
If you are aged 18 or under, we do not provide any services that are suitable to you however some information may be recorded if you interact with our website or staff. As such please get your parent/guardian’s permission before you provide any personal information to us or use this website or contact us. Users without this consent are not allowed to provide us with personal information and therefore should not use this site.
Collection and Use of Information
We collect personal data about you as a User and data relating to your interactions with us on-line through http://www.initiativeireland.ie and/or www.initiativeireland.com, or by phone or email. We will only collect and use individual user details where we have legitimate business reasons and where we are legally entitled to do so.
When you sign up to the platform personal information is gathered to enable us to provide services to you including but not limited to information specific to individuals and entities provided when completing the application process such as first name, second name, date of birth, nationality, postal addresses, telephone numbers, identification documents, bank documents, PPS number and e-mail addresses. This information may be shared with our third party service providers, in order to facilitate our services, where we have in place appropriate confidentiality agreements to protect your information.
We will always let you know how we intend to use your information before collecting it, so that you can decide whether or not you wish to provide that information. You should read our Data Protection – Use of Information Notice or contact us directly for more information on how we use your information.
When you browse through our website our web servers collect data which relates to your visit such as:
- What pages you have viewed;
- Certain interactions you have had on those pages;
- The number of times you may have visited a particular page; or
- The amount of time you may have spent on certain pages.
In some cases the data we collect will be anonymous and it will simply tell us what pages have received the most activity and are of particular interest to our customers in general. Where you set up an account with us and/or log onto the Platform we will be able to identify what pages you have shown a particular interest in, what pages you have visited multiple times and also what pages you have spent the most amount of time on.
We will mostly do this work ourselves however sometimes we will use Google Analytics and other similar tracking tools to assist us. In all cases we will carry this work out in a responsible manner. This data enables us to provide you with a more efficient and effective customer service by developing a wider understanding and appreciation of our customer base. Where we are able to identify specific user activity, we can also offer those users a more bespoke user experience and assist them with customer service issues they may have experienced or may be experiencing.
Information shall be stored and used in strict compliance with Data Protection Laws applicable within the Republic of Ireland. For further information on this, please visit http://www.DataProtection.ie
Furthermore, when you register for a Secured Lending Account and provide an email address, we will use this email to communicate with you on an on-going basis i.e. to notify you of new loans which come available on the platform. If you wish you may contact us to ‘opt-out’ of these notices.
We will also use this email to provide service notices. You may not opt-out of service emails but you may choose terminate your account to avoid such notices, as outlined in the terms of business.
Cookies & Their Use
Cookies are small text files that are sent to and stored on your computer, smartphone, tablet or other device for accessing the internet, whenever you visit our website. Cookies are used to maintain the integrity of your browsing activities when you visit a website and can also be used to customise and so improve the individual customer experience. Cookies do not in any way compromise the security of your computer or other devices. You can continue to use this website by disabling cookies, however this may affect the functionality of the site on your computer or devise. More general information on cookies can be found on www.cookiecentral.com . This includes information on how to disable cookies.
To achieve this, there are different types of cookies in use. They all work in the same way, but have minor differences which are explained below.
Session cookies last only for the duration of your visit and are deleted when you close your browser. They are essential for secure user navigation through the site and enable the delivery of basic functionality. Specifically, they ensure the security and integrity of your session, preventing fraudulent use and keeping you signed in while you move between pages and service your account. If you disable cookies then you may not be able to use log in to your Initiative Financial Services Account.
Persistent cookies last after you have closed your browser, and allow us to remember your actions and website preferences. Initiative Financial Services uses persistent cookies to analyse customer visits to our sites. These cookies help us to understand how customers arrive at and use our sites so we can improve the overall Initiative Financial Services on-line experience.
Finally, we use analytics cookies to help us make our websites even better for those who visit them regularly. This type of cookie helps us to further understand how individual visitors use our on-line services and allows us to improve the overall service and products offered to you.
Storage of Information
How We Keep Your Information Safe
We know that you care about how your information is used, stored and shared. We appreciate your trust in us to do that. To protect your information, we use security measures that comply with Irish Law and meet international standards. This includes computer safeguards and secure files and buildings.
The data that we collect from you 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 or for one of our suppliers. By submitting your personal data, you consent 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 Policy. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee that information you supply will not be intercepted while being transmitted to us over the internet, nor can we guarantee the complete security of our database.
Your Right of Access
Subject Matter Request
Under the Data Protection Acts you have the right to see the personal information we hold about you. Our fee of €6.35 applies to such requests. To get a copy of this information, write to Data Control Officer, Initiative Financial Services, Nova UCD, Belfield Innovation Park, Belfield, Dublin 4, Ireland.
Your request will be processed as soon as possible, taking no more than 30 days to process. If your information changes or you believe we have information which is inaccurate or not up-to-date please let us know and we will change it.
We make every reasonable effort to prevent any loss, misuse, disclosure, or modification of personal information, as well as any unauthorized access to personal information. We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
As a member, your membership account information is protected by a password for your privacy and security. You must take care to protect against unauthorized access to your password and to your computer by logging off once you have finished using a shared computer.
We make every reasonable effort to ensure that personal information collected by us is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization.
If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases, we may ask for a written request for correction.
Conditions of Use
This Privacy Statement is subject to the Terms and Conditions of Use of the Initiative Financial Services website, a copy of these is available on http://www.initiativeireland.ie.
It is important that you read the terms and conditions of use as where there is a conflict between this Privacy Statement and the Terms and Conditions of Use, the Terms and Conditions of Use shall prevail.
By accessing and continuing to navigate this website you acknowledge and agree to the processing of your personal data in the manner outlined above. You also agree that in certain circumstances we may be obliged to disclose personal information relating to you to third parties in order to prevent, detect or prevent fraud.
Use of Information
Information provided to Initiative Financial Services will be managed in a manner compliant with the Data Protection Laws of Ireland. In addition to such general, fair use of information users should explicitly note:
As a Borrower, you should note that:
Initiative Financial Services reserves the right to use details relating to any loan applications, such as uploaded images, locations, descriptions, videos and amounts of funded projects in our promotional materials without notice or compensation. However, such promotions shall not contain any personal or otherwise commercially sensitive information without the express consent of the borrower.
As a Lender, you should note that:
Initiative Financial Services does not list the identities of lenders publicly at this time for a given loan in any public media. However, this information is recorded, to facilitate administration of the loan. Your name may be disclosed to the relevant loan parties, as required to facilitate the service we provide. If we are required to disclose or publish this information to other third parties, for legal or regulatory reasons, we reserve the right to do so to the degree that this is mandated only.
All Members should note:
User generated content that violates copyrights laws will be remove promptly by Initiative Financial Services upon notice.
Users who knowingly provide false information may be subject to legal or criminal proceedings and/or may have their membership and/or systems access revoked.
Information collected by Initiative Financial Services may be disclosed to our 3rd party service partners as necessary to provide our service and where required to meet legal and regulatory requirements which exist now or may arise in the future. This includes the reporting of suspicious transaction reports for the prevention of financial crime where deemed necessary by the appropriate officers of Initiative Financial Services, on a mandatory or voluntary basis.
Questions and Complaints
If you have a question or concern about any collection, use, or disclosure of personal information by Initiative Financial Services please write to:
Data Control Officer, Initiative Financial Services, Nova UCD, Belfield Innovation Park, Belfield, Dublin 4, Ireland.