This Privacy Notice relates to our online privacy practises 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.

WHO WE ARE

We are Wexford Credit Union Limited (“we”,“us”, “the credit union”). We are committed to protecting your personal data. Your privacy and the security of your personal information are very important to us.

This Privacy Statement, along with our Website Terms and Condition, and our Cookies Notice set out the basis on which the personal data that we collect from you or that you provide to us while visiting our website, using our mobile app or when communicating with us through any of our social media or other interactive channels (collectively “Online Services”), will be processed by Wexford Credit Union. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.

By using our Online Services, 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 our Online Services. 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 use of our Online Services following notification or posting of such changes will constitute your acceptance of those changes.

Our Online Services 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. 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. The CU online service, including our mobile app, is hosted by Wellington IT solutions.

OUR CONTACT DETAILS ARE:

CONTACT DETAILS OF OUR DPO:

INFORMATION WE MAY COLLECT

WE MAY COLLECT AND PROCESS THE FOLLOWING INFORMATION:

The information processed through our Online Services includes personal information and non-personal information.

Personal Information
This is information that identifies you or can be used to identify you such as your name, online user name, credit union account number, email address, contact number, date of birth or online identifiers such as your IP address.

Non-Personal Information
Wexford Credit Union gathers statistical and other analytical information collected on an aggregate basis concerning visitors to our Online Services platforms. This information cannot be used to identify or contact you, for example anonymous statistical data involving the use of our Online Services. This information will help us to monitor online traffic, manage the performance of our Online Services and help us understand what parts of our Online Services are effective/ popular and what parts are not being fully utilised.

Mobile App
To download and use our mobile app, you are required to register for CuOnline (see above). The credit union may seek access to the camera and/or files on your digital device for specific purposes, for example, to allow you to photograph and upload documents such as proof of ID, proof of address or loan supporting documentation. We will not access your camera or files (such as photos) without your knowledge or permission and will only access it for the purposes notified to you.

Biometric Data – TouchID/Facial Recognition
If you have a digital device with fingerprint or facial recognition (e.g. using your fingerprint or face to unlock and access your phone), you will be able to access your credit union account via our mobile app using this functionality however you will need the password for your online access to authorise transactions. Where you are using the fingerprint or facial recognition functionality, we do not accept any liability for loss arising in connection with the use of biometric data to access our online service. For the avoidance of any doubt, we do not retain or store any biometric data.

For the purpose of this privacy statement, ‘biometric data’ has the same meaning as in the General Data Protection Regulation (GDPR).

USE OF COOKIES

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.

You block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be to access all or parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit the website. Our Cookie Policy can also be viewed on this website. For more information about cookies and how to stop cookies being installed visit http://www.allaboutcookies.org (opens in a new window). See our Cookies Notice here for full details.

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 info@wexfordcreditunion.ie. You may also change your preferences at any time by sending an email to info@wexfordcreditunion.ie and amending your preferences accordingly.

MARKETING

In the event that we would like to send you direct marketing, we will ask for 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 info@wexfordcreditunion.ie to withdraw your consent or change your preferences.

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 do not transfer data to destinations outside the European Economic Area (“EEA”).

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.

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.

SEARCH ENGINE:

The search facility on our website is an internal search function and only returns information that appears on the website.

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 Commission (DPC) in respect of any processing of your data by:

**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.

COMPLAINTS

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.

WHEN YOU CONTACT US

ENQUIRY FORM

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.

EMAILING US

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.

POST

When you send us correspondence via the post, the correspondence may be passed to the relevant individual / department to process the information, it may then be stored as per our retention policies.

TELEPHONE

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.

CHANGES TO OUR PRIVACY STATEMENT

We regularly review and update this Privacy Statement and encourage you to check it often. This statement was last updated March 2021

SOCIAL MEDIA POLICY

The credit union has created profiles on Facebook, Instagram and Twitter for purposes such as updating our members on services, promotions, business hours, events and competitions. This policy aims to safeguard the users of social media pages operated by Wexford Credit Union Limited.

We welcome users to post and interact on our profiles, however, please be aware, your posts or comments may be publically available to other internet users, depending on your privacy settings. Please do not post your own, or anyone else’s personal data on our social media accounts, even via direct messages. If you would like to discuss your account, we encourage you to contact the credit union via email, post, phone call or by visiting our office. The credit union will never discuss your account via social media platforms.

BE RESPONSIBLE – YOUR COMMITMENTS
Our social media profiles are used as an interactive tool to communicate with our members. We ask that you respect the wellbeing and integrity of our online community and participating individuals, including our company, staff and our members. To assist this, we have a few rules for posts or comments made on our pages:

• Your posts must be respectful and considerate towards others
• Your posts must never contain your own or anyone else’s private and confidential information or anything that infringes someone else’s rights.
• The information contained in posts must be lawful and not misleading or fraudulent.
• The contents of any post must not be insulting, disrespectful, discriminatory or offensive.
• We have a duty of care to protect our employees, therefore any comments identifying a member of staff may be removed and addressed offline.
• Do not post any material you don’t own or have the right to post.
• Do not violate (or help or encourage others to violate) this policy, including in particular, the rights of the credit union or any third party.
• Any posts must comply with applicable laws or regulations in Ireland and any other country from which they are posted
• Please do not impersonate others.
• Please do not misrepresent your affiliation with a person or entity

RESPECTING OUR VALUES

We will not be responsible, or liable to any third party, for the content or accuracy of any materials posted by any user other than Wexford Credit Unions Limited. We have the right to remove any material or posting if, in our opinion, such material does not comply with this policy or is contrary to our company values.

Our ethos is to put our members first and we trust you will respect our values by adhering to our rules. If there are any questions, comments or concerns, you can contact us by e-mail info@wexfordcreditunion.ie

We encourage you to also review the privacy policies and terms and conditions of Facebook, Twitter and Instagram.