Privacy Policy
Close Brothers takes privacy very seriously. It is very important to us to maintain the confidentiality of any personal details or other information that you may provide to us. This Policy sets out what sort of information we collect and hold about you, how the information is collected, how we use your
information and how information may be corrected and/or updated.
Use of your Personal Data
This Privacy Policy is issued by Close Brothers Finance DAC of Unit 18 Northwood House, Northwood Business Campus, Santry, Dublin 9 (“Close Brothers”, “we”,“us”). Close Brothers Finance DAC is the controller of this personal data. Should you have any questions regarding the use of your personal data, we can be contacted by calling 01 644 8900 or by writing to Privacy, Close Brothers Finance DAC, Unit 18 Northwood House, Northwood Business Campus, Santry, Dublin 9.
Personal Data that we Collect from You and Other Sources
Close Brothers will collect and process personal data relating to you from you in connection with your application for a loan (an “Application”) or any loan agreement, hire purchase agreement or leasing agreement that we may enter into you (an “Agreement”). We may also process such data in relation to any guarantor of, or joint applicant for the loan. In the processing of your Application and the administration of your account, we may also collect personal data relating to you from other sources, including:
● The Central Credit Register (“CCR”);
● Close Brothers records;
● Archives of publicly held information such as the Electoral Register and registers of court judgments;
● Your current and previous lenders, employers, landlords, accountant and, bankers;
● The Property Registration Authority
● The Office of the Revenue Commissioners; and
● any intermediary instructed by you in relation to your Application or an Agreement with you.
This personal data may include:
● Your name, address, contact details, email address, telephone numbers;
● Your date of birth, and if relevant, residency, citizenship, nationality, and any information about your health and any vulnerability;
● Financial details, including your income and expenditure, savings, borrowings and debts
● Your employment record;
● Your marital status and details of your dependents;
● Your transactional history;
● The nature of occupier status (e.g. whether you are a tenant or owner occupier) and address history; and
● Your credit rating.
We may also make a credit search with the CCR. Each search will be registered on your credit file(s) individually, and a number of searches within a short period may impact on your ability to obtain credit. If an Application is made in the joint names of two or more individuals and we search the files of a credit referencing agency, an “association” will be created with the other person(s) named in the Application. We or other lenders may take this association into account in future applications for credit or financial services. The association will remain between you until one of you successfully applies for “disassociation” with the credit reference agency. Information held about you by credit reference agencies may be linked to records relating to other persons. Your Application will be assessed with reference to any “associated” records.
Purposes of Processing and Legal Basis
We may use that data to:
● Verify your identity;
● Make credit decisions relating to you;
● Ensure that any offer which is made to you is appropriate to your circumstances;
● Administer your account;
● Trace you, and enforce, or allow forbearance in relation to your loan or an Agreement with you;
● Comply with legal and regulatory obligations;
● Generate and analyse statistics to assist us in running our business;
● Assist the CCR to facilitate responsible lending;
● Consider and deal with any complaints you may have or any other problems which may arise in relation to your loan;
● Prevent fraud, money laundering and financial crime;
● Send you promotional and marketing materials in relation to products or services that we think may be of interest to you, subject to any preferences that you express when we collect your contact details or subsequently. You can opt out of receiving promotional and marketing materials from us
at any time by writing to us at: Privacy, Close Brothers Finance DAC, Unit 18, Northwood House, Northwood Business Campus, Santry, Dublin 9.
● Establish, exercise or defend legal claims; or
● For any other purpose for which you provide us with your personal information. The legal bases on which we collect, process and transfer your information in the manner described above are:
● That this is necessary for the performance of our contract with you or in order to take steps at your request prior to entering into a contract;
● That this is necessary for the purposes of our legitimate interests in conducting our business in a responsible and commercially prudent manner.
We will not process your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms;
● And that this is necessary for compliance with a legal or regulatory obligation that applies to us. The legal bases on which we collect, process and transfer special categories of data relating to you in the manner described above are:
● That you have given your explicit consent to such processing
Recipients of Data
In connection with the above purposes, we may disclose your personal data to other organisations, including:
● The CCR- we may periodically submit information to the CCR throughout the term of your loan. If you do not repay money owed to us on time and in full, we may inform the CCR who will record the outstanding debt, and this may impact on your ability to obtain credit;
● Any intermediary assisting you with your Loan application;
● Other Close Brother group companies;
● Any company providing insurance or other products in connection with your loan;
● Third parties which provide services to us in connection with your loan;
● Your guarantors;
● Our guarantors, investors, or funders and any entity proposing to do so;
● Actual or proposed assignees of our rights against you;
● Any party with whom we or our agents have, or are considering entering into a contractual agreement in relation to the loan;
● Any receiver, and any party who it may be necessary to inform in connection with any contemplated litigation against you;
● Regulatory or governmental bodies including the Central Bank of Ireland and An Gardai Siochana, if required to do so to comply with our regulatory or legal obligations;
● Professionals employed in relation to the loan documents, or as advisors to persons referred to above;
Direct Marketing
Direct marketing is on the basis of consent rather than legitimate interest. If you have expressly agreed to us contacting you, or sharing your information with third parties, for the purpose of sending you details of products or services that we think may be of interest to you, we may also pass your information to such third party suppliers for these purposes. You will have the right at any time to stop us from contacting you, or giving your details to others, for these purposes. You can write to us at Privacy, Close Brothers Finance DAC, Unit 18, Northwood House, Northwood Business Campus, Santry, Dublin 9 if you wish to opt out of receiving marketing material from us.
Retention
We will not hold your data for longer than is necessary. We will retain and hold your personal data, and all details and documents relating to your loan, for up to 7 years after the date on which either your loan is repaid, or your Application does not proceed, or the date of expiry of an Agreement with you, or for such period of time thereafter as is necessary to comply with our legal and regulatory obligations.
Transfers Abroad
In connection with the above we might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. If you would like to receive further details of the measures that we have taken in this regard, we can be contacted by calling 01 644 8900 or by writing to Privacy, Close Brothers Finance DAC, Unit 18, Northwood House, Northwood Business Campus, Santry, Dublin 9.
Requirement to Provide Data
You are not under a statutory or contractual duty to provide us with any personal data. However, there are some pieces of information that you must provide to us so that we can process your Application. If you do not provide us with this information, we may not be able to process your Application or enter into an Agreement with you.
Automated Decision Making
As part of the processing of your personal information, decisions may be made by automated means, e.g. we may use credit scoring methods or other automated decision making systems to assess your credit status. We may 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; or is inconsistent with your previous submissions; or you appear to have deliberately hidden your true identity.
Your Rights
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:
● Right to access the data – You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
● Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
● Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
● Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
● Right to data portability – You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.
If you wish to exercise any of the rights set out above, we can be contacted by calling 01 644 8900 or by writing to: Privacy, Close Brothers Finance DAC, Unit 18 Northwood House, Northwood Business Campus, Santry, Dublin 9.
Complaints
If you have any queries or complaints in connection with our processing of your personal data please contact us by phone at the customer service number 01 644 8900, or by email at: [email protected], or in writing to our contact address:
Privacy
Close Brothers Finance DAC
Unit 18, Northwood House
Northwood Business Campus
Santry
Dublin 9
You also have a right to complain to the Data Protection Commission if you are not happy with the way we have used your information or addressed your rights. Details of how to lodge a complaint can be found at: https://www.dataprotection.ie/en/contact/how-contact-us, or you can call the Data Protection Commission at 01 765 0100.