What data do we collect?

There are a number of reasons for gathering personal data about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity and we need to comply with regulatory requirements regarding the provision of financial services. The personal data we collect falls into various categories, such as:

Identity & Contact information

Name, date of birth, copies of ID, contact details, PPS number (or foreign equivalent), security details to protect identity, nationality, home status and address, email address, work and personal phone numbers, marital status, family details, tax residency and tax related information. If you engage with us through social media then this may also include your social media contact details, such as your LinkedIn address or Twitter username.

Company Details

Company name, date of incorporation, company number, registered address, VAT number, details of directors and shareholder information including proof of identity and proof of address.

Information we collect about you from publicly available sources

We may collect information available from social media (depending on your settings and the applicable privacy policies), including social media engagement metrics such as numbers of connections, followers and clicks, and information from resources such as Companies Registration Office and Companies House.

Sensitive or special categories of data

We may hold information about you which includes sensitive or special categories personal data, such as but not limited criminal conviction information or biometric information used to uniquely identify you. We will only hold this data when we need to for the purposes of the product or services we provide to you, where we are processing the data for a substantial public interest, where we have a legal obligation or where we have your consent to do so. Examples of when we use this type of data include:

• If you have criminal convictions, we may process this information in the context of compliance with our anti-money laundering obligations.
• We may use your biometric information to help identify you when you open or operate an account.

Information which you have consented to us using

Your contact details and marketing preferences are used to share news about relevant services, products and offers that we think may be of interest to you. You can find out more about how we use your personal information in relation to marketing activities including updating your marketing preferences in Section 5 below.

Information from online activities

• We collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers and by using our cookie preference centre on our website. For detailed information on the cookies we use and the purposes for which we use them, see our Cookies Policy, which is available on our website.
• We collect information about your internet browser settings and Internet Protocol (IP) address and other relevant information to help us identify your geographic location when providing you with our services.

Other personal information

• Telephone recordings and email communications.
• Information in relation to requests made by you e.g. data access, correction, restriction, deletion, porting and complaints.

Sometimes we may collect and use your information even though you are not a customer of ours

For example, you may be a beneficiary, guarantor, director, cardholder or representative of one of our customers, or you may be in the process of making an application for a NoFrixion product or service. In other cases, your own circumstances may have a material impact on the ability of our customer to perform their obligations to us, and we will need to consider these. If so, we will apply the principles outlined in this Data Privacy Policy when dealing with your information.

When and how do we collect your data?

You directly provide NoFrixion with most of the data we collect. We collect data and process data when you:

• Register online or apply to be a customer of our services.
• Voluntarily complete a customer survey or provide feedback on any of our services.
• Use or view our website via your browser's cookies.
• When you use our products or services, including making transactions on your account, or instructing a third-party payment service provider to initiate payments on your account, we gather details about who you get money from, who you pay money to, how much the payments are for and when the payments are made.
• Tracking cookies.

How will we use your data?

NoFrixion collects your data so that we can:

• Establish your eligibility for our products and services.

• Manage and administer your accounts.

• Process your applications for financial services.

• Process payments that are paid to you or by you.

• To comply with our legal and regulatory obligations, including:

  • Complying with your information and privacy rights.
  • Providing you with statutory and regulatory information and statements.
  • Establishing your identity, residence, and tax status in order to comply with law and regulation concerning taxation and the prevention of money laundering, corruption, fraud and terrorist financing.
  • We are required by law to screen applications that are made to us to ensure we are complying with the international fight against terrorism and other criminal activities. As a result, we may need to disclose information to government and other statutory bodies.
  • Preparing returns to regulators and relevant authorities including preparing income tax, capital gains tax, capital acquisition tax, Deposit Interest Retention Tax and other revenue returns.
  • Reporting to and, where relevant, conducting searches on the Central Credit Register, State registers (such as the Register of Beneficial Owners), and other industry registers.
  • Complying with binding requests from regulatory bodies, including the Central Bank of Ireland.

• Complying with binding requests for information from other payment service providers you have instructed to act for you, including complying with our obligation to provide access to your Account information to an Account Information Service Provider (AISP), Card Based Payment Instrument Issuer (CBPII) or a Payment Initiation Service Provider (PISP), where you or your joint Account Holder has instructed the AISP, CBPII or the PISP to access the information.

• Complying with binding requests for information about you from other payment service providers from whom you may have received payments in error so that the payer's financial service provider may contact you directly. This information will include your name, address, and relevant transaction information.

• Complying with binding production orders or search warrants, and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies/ prosecutors.

• For other reasons where a statutory reason exists, including use of your Personal Public Service (PPS) number (or foreign equivalent).

• Complying with court orders arising in civil or criminal proceedings.

• Performing a task carried out in the public interest.

• Where required to comply with our obligations under the Payment Services Regulations relating to fraud prevention - including monitoring your use of our online banking software or security tools

• Contact you by post, phone, text message, email, digital message, using our website or other means, but not in a way contrary to your instructions to us or contrary to law.

• Monitor and record our conversations when we communicate (for example, to check your instructions to us, to analyse, to assess and improve customer service; for training and quality purposes; and for verification, fraud analysis and prevention purposes).

• Protect our business, reputation, resources, and equipment, manage network and information security (for example, developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services) and prevent and detect fraud, dishonesty and other crimes.

• Recover debts you may owe us.

• Manage and respond to a complaint or appeal.

• Carry out strategic planning

If you agree (and you may withdraw permission at any time), NoFrixion will share your data with our partner companies so that they may offer you their products and services.

When NoFrixion processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.

Whether we're using it to confirm your identity, to help in the processing of an application, for a product or service or to improve your experiences with us, your information is always handled with care and the principles outlined in this Data Privacy Policy are always applied. Whether we're using it to confirm your identity, to help in the processing of an application, for a product or service or to improve your experiences with us, your information is always handled with care and the principles outlined in this Data Privacy Policy are always applied.

How do we store your data?

NoFrixion engages Microsoft as a Cloud Service Provider for the secure storage of your data in their Azure cloud service. Microsoft Azure has adopted numerous standards and codes of practice pertaining to system and data security in the cloud.

Your data is fully encrypted both in transit and while stored as part of this arrangement.

How long do we store your data?

As a general rule, we keep your information for a specified period after the date on which a transaction has completed or you cease to be a customer. In most cases this period is 7 years after the end of a transaction, or 6 years after you cease to be a customer.

However, the length of time we hold your data depends on a number of factors, such as regulatory rules and the type of financial product we have provided to you.

Those factors include:

• The regulatory rules contained in laws and regulations or set by authorities like the Central Bank of Ireland, for example, in the Consumer Protection Code.
• The type of transaction we have executed on your behalf.
• Whether you and us are in a legal or some other type of dispute with another person or each other.
• The type of data we hold about you.
• Whether you or a regulatory authority asks us to keep it for a valid reason.

Marketing

NoFrixion would like to send you information about products and services of ours that we think you might like.

If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop NoFrixion from contacting you for marketing purposes.

What are your data protection rights?

NoFrixion would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access - You have the right to request NoFrixion for copies of your personal data. We may charge you a small fee for this service.
• The right to rectification - You have the right to request that NoFrixion correct any information you believe is inaccurate. You also have the right to request
• NoFrixion to complete the information you believe is incomplete.
• The right to erasure - You have the right to request that NoFrixion erase your personal data, under certain conditions.
• The right to restrict processing - You have the right to request that NoFrixion restrict the processing of your personal data, under certain conditions.
• The right to object to processing - You have the right to object to NoFrixion’s processing of your personal data, under certain conditions.
• The right to data portability - You have the right to request that NoFrixion transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
• If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: dpo@nofrixion.com

Or write to us:
c/o- Data Protection Officer
NoFrixion,
Carmichael House,
60 Baggot Street Lower,
Dublin 2,
D02 KP79,
Ireland.

Cookies

Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.

For further information, visit allaboutcookies.org.

How do we use cookies?

NoFrixion uses cookies in a range of ways to improve your experience on our website, including:

• Keeping you signed in
• Understanding how you use our website

What types of cookies do we use?

There are a number of different types of cookies, however, our website uses:

• Functionality - NoFrixion uses these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising - NoFrixion uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address.
• How to manage cookies? You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The NoFrixion website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Changes to our privacy policy

NoFrixion keeps its privacy policy under regular review and places any updates on this web page. This privacy policy was last updated on 15 February 2022.

How to contact us

If you have any questions about NoFrixion's privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: info@nofrixion.com

Or write to us:
c/o- Data Protection Officer
NoFrixion,
Carmichael House,
60 Baggot Street Lower,
Dublin 2,
D02 KP79,
Ireland.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that NoFrixion has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office:

dataprotection.ie/en/contact/how-contact-us