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Privacy Policy

Last updated 8 April 2020

Introduction:

Prima Finance Ltd trading as Azucko (referred to as either “Azucko”, “we”, “us” or “our” in this Privacy Policy) is registered in the Republic of Ireland (company number: 327668); and its registered address is : 77 New Street, Killarney, Co Kerry, Ireland V93 YCY5. Prima Finance / Azucko is regulated by the Central Bank of Ireland as a Payment Institution (reference number C11208). Azucko can be contacted in writing at the above address or by email at Support@azucko.com

Azucko’s Privacy Policy describes how Azucko collects and processes your Personal Data, which may be either through your use of the Azucko Platform, including any data you may provide through this Platform; or through your interaction with Azucko through our website, mobile App, social media and marketing activities. The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

For the purposes of the Data Protection Act 2018 and General Data Protection Regulation (EU) 2016/679 as amended from time to time (“DPA”), we may be a data controller or processor of the data we hold that may be used to identify you (“Privacy Statement"). Azucko is committed to keeping your information private. We understand that your privacy and the security of your information are very important to you.

Terms of Service:

Azucko Privacy Statement is subject to the Terms of Service of the Azucko platform.
We recommend that you read our Terms of Service. If there is a conflict between our Terms of Service and this Privacy Statement, our Terms of Service shall prevail. Except as otherwise provided, terms used herein and defined in our Terms of Service have the same meaning that is given to them in the Terms of Service. Please read this Privacy Statement carefully as it contains important information to help you understand our practices regarding any personal information that you give to us.

What Information we Collect:

We apply the data minimisation principle and only collect the minimum necessary data for the process. Personal Data we may collect about you from you, from your employer and from third parties about you, is outlined in the table below.

Category of Personal Data collected:

Identity Data
First name, surname, last name, username or similar identifier, title, and date of birth, company of employment

Contact Data
Your home address, email address and telephone numbers.

Financial Data
Your bank sort code and account number.

Transaction Data
Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with 3rd parties.

Behavioural Data
Inferred or assumed information relating to your behaviour and interests, based on your online activity and/or in app. This is most often collated and grouped into “segments” (e.g., there may be a segment for users, living in Dublin/London and aged under 25, who use our services twice a month).

Technical Data:
Related to website visits and app usage, such as Internet Protocol (IP) address, mobile device identifier, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, download errors, response time, page interaction (such as scrolling, clicks, and mouse-overs) device type and model, operating system and platform and other technology on the devices you use to access this Platform or use our services.

What personal information we process:

  • name;
  • date of birth;
  • address and your address history (which includes, your main residential property);
  • telephone number;
  • email address;
  • tax number (PPSN);
  • Employer ID
  • Net and Gross salary details;
  • passport, driving licence or national identity card when you provide this as proof of identity;
  • details of expenditure;
  • bank details;
  • details of your bank accounts and bank transactions if you use the open banking-bank accounts section;
  • employment - employer details;
  • income and taxation information;
  • information regarding whether you have any dependents;
  • identifiers assigned to your computer or other internet connected devices including your IP address;
  • information linked to your mobile telephone number;
  • details about whether you own your property, rent it or live with others/parents;
  • information about your residency and/or citizenship in the Republic of Ireland, UK or European Union;
  • information you make public (for example on social media and on public registers);
  • information relating to how you conduct your account and our dealings on it;
  • information about unspent criminal convictions or pending prosecutions relating to any aspect of dishonesty, which may have a bearing on your future employment or the likely conduct of the account.

If you authorise a third party to act on your behalf, for example setting up a Power of Attorney for your account, we record the individual’s name, date of birth, address, telephone number, email address, solvency status for Powers of Attorney, and bank details if the third party makes payments by direct debit for your account.

Where information fields are marked as mandatory on any application form that you complete, you will need to provide such information in order for us to continue with your application.

We may use and share personal data as “Aggregated Data” for  statistical purposes only. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data:

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Special categories of Personal Data:

Special categories of personal data include information about an individual’s health and other categories of personal information which are closely protected (e.g. biometric data).
We do not generally process such information, unless you have voluntarily provided that information to us.

How we use your personal information:

In summary, we use your personal information for the purposes of:

  • servicing and internal processing;
  • management of our relationship with you (e.g to develop your relationship with us);
  • resolving queries/problems (e.g. responding to complaints or contacting you if you do not complete your application);
  • training and service review (e.g. to help us enhance our services);
  • statistical analysis (e.g. to help us enhance our products and services);
  • complying with legal obligations (e.g. to prevent, investigate and prosecute crime, fraud and money laundering).

Azucko process your personal information to fulfil our contract with you, where we have a legitimate interest to do so (except where it would override your interests or fundamental rights and freedoms which require the protection of personal information), where otherwise permitted by law, or to comply with applicable law and regulation.

We will only use your Personal Data where we have a lawful basis to do so. We do not sell your personal information to any third parties.

However, we may share your personal information with third parties as follows:

  • Selected other parties including: business partners, suppliers and sub-contractors for the performance of any contract we enter into with your employer and you;
  • Analytics and search engine providers that assist us in the improvement and optimisation of our site and service;
  • To comply with legal or regulatory obligations.

We have set out below, how we use your Personal Data, the purpose, categories of data retained, why we do this and the legal basis for same.

Account Creation and Transfer Identity Data & Contact Data
To register you as a new user and provide you with the Azucko services.

Performance of contract, Fraud Prevention, Identity Data, Contact Data, Behavioural Data, Technical Data
To keep our website, our services and associated systems operational and secure. To keep your data and identity secure.

Performance of contract, Troubleshooting, Technical Data
To track issues that might be occurring on our systems.

Performance of contract, Optimisation and Analytics, Identity Data, Contact Data, Transactional Data, Technical Data & Behavioural Data
To understand and measure how users use our Platform to improve it and report relevant aggregated management information.

Performance of contract, Legitimate Interest, Marketing, Identity Data & Contact Data
To capture interest in Azucko and to keep prospects and clients informed.

Consent, Product Referrals, Identity Data & Contact Data
To allow interested employees to refer Azucko to their employer.
Legitimate Interest

What happens when you do not provide necessary Personal Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and your employer and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Platform). In this case, we may have to stop you using our Platform have with us, but we will notify you if this is the case at the time.

Third Part Data Sources:

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we may also collect certain of your Personal Data from third party sources. These sources are broken down in the below, together with a description of whether they are publicly available or not.

Third Party Data Sources;

  • Your Employer
  • Identity Data, Contact data, Financial Data & Transaction Data
  • Azucko Service Provision

How we retain your information:

he personal information that you provide will be retained by us in accordance with applicable laws. We take reasonable steps to destroy or anonymise personal information we hold if it is no longer needed for the purposes set out above.

Given our obligations under the Consumer Protection code 2012 (as amended) and our regulatory responsibilities under our authorisation we retain personal information for 6 years after the closure of your account or the ending/termination of the customer relationship with you.

This includes;

  • General personal data - personal information, e.g. DOB, address and financial personal data, e.g. salary, employer details.
  • Special categories and criminal offence personal data may be captured if voluntarily provided to us.
  • Call recordings - these are retained for either 1 or 3 years.

Security of Your Personal data:

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Measures we take include:

  • Firewalls;
  • Data encryption;
  • Intrusion detection systems;
  • Background checks for all employees accessing our physical facilities

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g. where we are legally required to do so) we may notify you of breaches affecting your Personal Data. If you suspect any misuse or loss of, or unauthorised access to, your data, you should let us know immediately.

How & Who we share your information:

Below we describe who and why we share your Personal Data with, what we share and why we share it.

Who: Your Employer(s)
What: Financial Data Transaction Data
Why: Your employer(s) engage Azucko to provide the Platform and Azucko services. We share your personal data with your employer(s) to provide them and you with such Platform and services.

Who:  Within EEA
What: Business partners, suppliers and subcontractors, Identity Data, Contact Data, Technical Data & Financial Data
Why: For the performance of any contract we enter into for the uses set out in the section
Within EEA Within the United States

In addition, the recipients with whom we share personal information are:

  • our third party service providers who act on our instruction and need to know the information in order to provide us or you with a product or service;
  • our third party service providers who act on our instruction and process information on our behalf to help run some of our business operations including email distribution, electronic signature processing, storage of customer documentation, IT services and websites, diallers and for statistical analysis, customer and loan management software and system providers;
  • our partners including brokers, introducers and any retailers;
  • our subsidiaries or affiliates, for the purpose of managing our customer relationships, administering our business and to provide you with information about other products and services which might be of interest to you;
  • our advisors, for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
  • our regulators comply with our legal and regulatory obligations;
  • entities who may or do acquire any rights in us for the purpose of a business sale or reorganisation;
  • law enforcement bodies in order to comply with any legal obligation or court order;
  • where you have agreed to receive such marketing, we may make your details available to reputable suppliers of credit and insurance related services that we feel may be of interest to you; and

Transfer outside of the EEA:

Recipients with whom we share your personal information, for example our service providers, may be located in the Republic of Ireland, other countries in the European Economic Area or elsewhere in the world. Different privacy laws may apply in these countries and you understand and unambiguously agree to the transfer of personal information to these countries and parties.

Whenever we or our service providers transfer your personal information outside of the European Economic Area, we or they impose the standard contractual obligations approved by the European Commission on the recipients of that information to protect your personal information to the standard required in the European Economic Area or require the recipient to subscribe to ‘international frameworks’.

Monitoring:

We monitor communications with us, including call recordings, for training purposes and to enhance or review the service we provide.

For crime and fraud prevention and anti-money laundering:
Before we offer a product or service, we will undertake checks for the purposes of detecting and preventing crime, fraud and money laundering, and to verify your identity. These checks require us to process your personal information. We may ask you to provide additional information. We continue to undertake these checks even after we have given you an account, for the same purposes.

Automated Decision Making:

Our processes to verify your identity and undertake checks to detect and prevent money laundering checks can result in an automated decision. This means we automatically decide that you pose a fraud or money laundering risk if:

  • our processing reveals your behaviour to be consistent with that of known fraudsters or money launderers;
  • is inconsistent with your previous submissions; or
  • you appear to have deliberately hidden your true identity.

Marketing:

From time to time, we may send you information regarding our products and/or services or those from carefully selected third parties, which we think may be of interest to you where we have your agreement. You opt to receive this information by letter, telephone, SMS and / or email.
If, at any time, you prefer not to receive further communications from us in any or all forms (except in connection with information, products or services that you specifically request), you will have the ability to unsubscribe from such communications by means of a link provided in every e-mail that is sent to you by us or by contacting us. To unsubscribe from such communications by SMS, reply ‘STOP’ to the SMS.

Third Party Websites:

If at any stage this website contains links to other websites, mobile App or any Azucko platform, we accept no responsibility or liability for the content of other websites which are not under our strict control, in particular, we are not responsible for the protection and privacy of any information which you provide whilst visiting other websites and such sites are not governed by this Privacy Statement.

Email:

Emails sent via the internet can be subject to interception, loss or possible alteration, therefore we cannot guarantee their security. Although we will do our best to protect your personal information, we cannot guarantee the security of your information sent by email and therefore will have no liability to you for any damages or other costs in relation to emails sent by you to us via the internet.

Children's Privacy:

The Website/platform is not intended for use by individuals under the age of 18 without the agreement and involvement of a parent or guardian. We do not knowingly collect personal information from individuals under the age of 18.

Updates:

We will keep this Privacy Statement under review and make updates from time to time. We will notify you of any major changes which will affect the processing of your personal data.  We may make minor changes (such as to correct typographical errors, or to add information about other products or services which do not affect your personal information at this time) without notifying you.

Cookies:

Cookies are used to monitor website traffic and enhance your experience of our website. Cookies are pieces of data which your computer, mobile or tablet device downloads when you visit a website. Cookies are used to keep track of your preferences and to recognise return visitors.
You can set your browser to reject cookies. However, if you choose to reject cookies, you may not be able to use or access certain of our online or mobile services.

We respect your rights:

You have the right to request copies of certain of your personal information within our custody and control and details of how we use that information. Your request should be made in writing.
If you think any of the personal information we hold about you is inaccurate, you can also request it is corrected or erased.
You also have rights, in certain circumstances:

  • to object to our processing of your personal information;
  • to request human intervention if a decision has been made solely on the basis of automated decision making;
  • to require us to stop processing your personal information; and
  • to withdraw your agreement to processing based on 'consent'.

You have a right to port personal information you have provided to us to a different service provider.

Complaints process:

Our aim is to please but we know that sometimes things go wrong. If you have a problem, we want to know. Our staff will be happy to help you either on the telephone or in writing. Should you need to write to us, please address your complaint to Customer Resolutions, Azucko, 77 New Street, Killarney, Co Kerry V93 YCY5.