Privacy Policy
Data Privacy Notice
Introduction
Irish Mortgage Corporation Ltd trading as Irish Mortgage Corporation, Moneycoach, (hereinafter called Irish Mortgage Corporation/Moneycoach and/or “firm” or “we”) is committed to protecting and respecting your privacy. We will always clearly identify ourselves in correspondence and on our website. We share information within this group to help us provide our services and comply with the regulatory requirements and improve our service standards. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
This Privacy Notice will inform you of the information we gather and how it will be used. Irish Mortgage Corporation/Moneycoach maintains the same privacy practices with respect to data that is collected off-line and on-line, and this notice also covers both those methods of data collection and use. Irish Mortgage Corporation/Moneycoach complies with EU General Data Protection Directive (GDPR) for the collection, use, and retention of all personal data. It is the intention of this privacy statement to explain to you the information practices of Irish Mortgage Corporation/Moneycoach in relation to the information we collect about you.
For the purposes of GDPR the data contact is:
- Annette Forristal
- Contact details [email protected] or
- Write to:
Irish Mortgage Corporation Ltd
Attn: Compliance Manager
118 Lower Baggot St.
Dublin 2.
Telephone 01 669 1032
Please read this Statement carefully as this sets out the basis on which any personal data, we collect from you, or that you provide to us, will be processed by us. If you would like any clarification on any points in this summary document, please contact us.
1. Who are we?
Irish Mortgage Corporation Ltd trading as Irish Mortgage Corporation, Moneycoach, IMC and Irish Pension Corporation is regulated by the Central Bank of Ireland as an Insurance Intermediary registered under the European Communities (Insurance Mediation) Regulations 2005: as an Investment Intermediary authorised under the Investment Intermediaries Act, 1995 and as a Mortgage Intermediary authorised under the Consumer Credit Act, 1995, and as a Mortgage Credit Intermediary under the European Union (Consumer Mortgage Credit Agreements) Regulations 2016.
The company is incorporated Ireland registration number 155087 and is based at 118 Lower Baggot St, Dublin 2.
The company has been trading since the 15th of February 1990. Initially as a mortgage broker working closely with Banks, Lenders, Accountants, Solicitors, and Estate Agents, specialising in the facilitation of home purchase via best practices and competitive mortgage rates, appropriate products, and efficient processing.
Having this experience ultimately means our clients benefit from the process of obtaining home loan research for those which we have an agency, dealing with the customers’ needs and objectives. This service runs in tandem with our other Moneycoach advisory services being Life Assurance, Pensions, Investments, Savings and Deposits.
2. The information we collect about you
In order for us to provide you mortgages and associated insurance products such mortgage protection, life assurance, critical illness, income protection and pension and investment products Irish Mortgage Corporation Ltd need to collect your personal data to allow us to proceed with the product.
We will hold:
- data to identify you, including your contact information i.e. name, address, telephone number(s), email address, gender, date of birth, occupation, PPS number, photographic identification, nationality, family members/dependents.
- your financial details/financial circumstances, where necessary i.e., employment, income, assets, liabilities, bank account details (where applicable);
- your marital or civil status;
- other sensitive information e.g. medical information which you provide to us, where necessary for the service to be provided;
- information about you provided by others e.g. your spouse/partner, third parties connected to your policy, professional advisors, etc.;
- information which you have consented to us using;
- other personal information, if applicable e.g. criminal conviction data, driving penalty points; and
- information provided when exercising your rights.
Sometimes we may use your information even though you are not our customer. For example, you may be a director of a client company, an employee of a client, or be a potential customer applying for one of our products or services.
3. When we collect your information
We collect information in the following ways:
- request a service from us; e. interested in obtaining a mortgage/investment and you contact us via telephone or website. Our websites uses cookies and you must consent to the use of cookies when first logging onto our website. Further information in relation to cookies is available on our website.
- engage with us on social media i.e. linkedin, Facebook etc.
- contact us with a query;
- if you are interested in seeking a mortgage, we will send you a link to upload the required information onto our portal (mortgage application system).
We collate information at the initial point of contact with you and aim to update this whenever you require a further service or product.
4. How and why we use your information
We collate, use and share information only where there is a legal basis for doing so. This includes where you have given us information in order to provide you with a service, product, or arrange a transaction for you.
Typically, the legal basis for using your data is to provide a service or arrange a transaction which you have requested. The legal basis will also include complying with our legal and regulatory obligations, e.g. under our Central Bank authorisations, interaction with the Data Protection Commissioner, Financial Services and Pensions Ombudsman (FSPO), Revenue and when conducting Anti-Money Laundering checks.
We may have to collect “special categories of personal data” e.g. health details. Subject to suitable and specific measures being taken to safeguard the fundamental rights of data subjects, the processing of data concerning health shall be lawful where the processing is necessary and proportionate for the purposes of the following:
(a) a policy of insurance or life assurance,
(b) an occupational pension, a retirement annuity contract or any other pension arrangement, or
(c) where you have agreed or explicitly consented to the using of your data in a specific way, you may withdraw your consent at any time.
We may use your data if necessary to protect your “vital interests” in exceptional circumstances e.g. where we suspect a fraud may be in the course of perpetration.
Data may also be used for our legitimate interests such as managing our business, providing service information, conducting marketing activities, training and quality assurance and strategic planning.
5. How we use automated processing or “analytics”
We may analyse your information using automated means:
- to help us understand your needs and develop our relationship with you;
- to help us to offer you products and service information which we believe will be of interest to you, providing that you have given us consent to use your data for this purpose;
- by using product providers IT systems and similar systems where you apply for a policy or financial product e.g. to obtain underwriting terms from an insurer.
The types and sources of the information, we may process by automated means about you are listed in Section 2 above.
We also use automated processing to assist in compliance with our legal obligations in connection with the prevention of money laundering, fraud and terrorist financing e.g. uploading a copy of your passport/driving licence and a selfie via our portal.
If we intend to further process your personal data for a purpose other than for which the data was collected, we will provide this information prior to processing this data.
6. Who we share your information with
When providing our services to you, we may share your information with:
- Financial institutions/Lenders/Life Assurance companies with whom we hold a written appointment with as outlined on our Terms of Business;
- Introducers of business to us with whom we may share details of any transactions arranged for you;
- Our home insurance partner to whom, we forward details of your home insurance requirements for the purposes of arranging your mortgage;
- Irish and EU regulatory and enforcement bodies such as the Central Bank of Ireland, an Garda Siochána, the courts, fraud prevention agencies and other bodies to enable us cooperate by law as we are required to do so;
- We use a number of IT platforms to assist us in delivering our services;
- We also have a number of service providers we use to store and manager our data.
7. How long we hold your data
Our aim is to hold your data for no longer that is necessary and subject then to the timescales imposed by our legal and regulatory requirements set by authorities such as the Central Bank of Ireland, Office of the Data Protection Commission, Financial Services and Pensions Ombudsman. The timescales may also depend on the type of product provided to you.
8. Implications of not providing your data
If you do not provide information we may not be able to:
- provide requested products or services to you;
- continue to provide and/or renew existing products or services;
- assess suitability; and
- where relevant, give you a recommendation for a financial product or service which you require.
9. Transfer of information outside the European Economic Area (EEA)
It is our aim to retain any information which we hold within the EEA. The data which you provided to us is held on our systems within the EU. However, given the nature of our business relationships with certain product providers, such providers may have legitimate business reasons to transfer information outside the EEA. The product providers with which we arrange business on your behalf are obliged to comply with the provisions of the GDPR in relation to the transfer of data within or outside the EEA.
10. Data Subject Rights – How to exercise your rights
Under the GDPR, you will have additional rights in relation to how your data is used, including the rights to:
- Right of access– you have the right to request a copy of the information that we hold about you.
- Right of rectification– you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten– in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing– where certain conditions apply to have a right to restrict the processing.
- Right of portability– you have the right to have the data we hold about you transferred to another organisation.
- Right to object– you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling– you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review:in the event that Irish Mortgage Corporation Ltd refuses your request under rights of access, we will provide you with a reason as to why.
If you wish to exercise any of your rights you can contact us at the address noted above. We will respond to your Subject Access Request within one month. If you make your request electronically, we will try to provide you with the relevant information electronically.
11. Website
In general, you may visit our website without identifying yourself or revealing any personal information. Irish Mortgage Corporation/Moneycoach collects domain information from your visit to customise and improve your experience on our website.
Our website may collect certain information from your visit, including the date and time of your access, the pages you have accessed, the name of the Internet Service Provider and the Internet Protocol (IP) address by which you are accessing the Internet, and the Internet address from which you linked to our site, if applicable. We use this information to better understand how our website is being used so that we can improve its performance.
Some portions of this website may request that you give us information about yourself, from which we are able to identify you, such as your name, email or other address. Some of the ways in which we may collect information from you are:
- Subscription to newsletters or other Irish Mortgage Corporation/Moneycoach content-related correspondence
- Customer Reviews
The information we collect about you or your computer is used to run the website and respond to requests.
Consent and the right to withdraw consent
We require your consent to collect and use personal information on our website which includes contacting you about products which may be of interest to you from carefully selected product providers. We will only send you direct marketing content where we have your consent. When we request your consent, we will explain what we need it for and how you can change your mind in the future. If we process your personal information based on you having provided consent, you have the right to withdraw that consent at any time. The opt-out methods will depend on how the consent was collected and will be explained when you give us your consent, e.g. you can change your mind using the opt-out link in any direct marketing emails sent to you. You can also opt out at any time by emailing us at [email protected].
12. Complaints
If you are dissatisfied with our services or how we use your data, you have the right to complain to the Data Protection Commission, contact details as follows:
Address: Office of the Data Protection Commission,
Dublin offices: 21 Fitzwilliam Square South Dublin 2 D02 RD28
Portarlington Office: Canal House, Station Road,Portarlington,R32 AP23 Co. Laois
Telephone : (01) 765 01 00/ 1800 437 737
Email: [email protected]
13. Updates
We will update our Data Privacy Notice from time to time. You may request copies of our notices at any time or refer to our website www.irishmortgage.com and www.moneycoach.ie for the latest versions of these documents.
Updated June 2024
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