If you have been directed to this privacy notice, Promontoria (Redwood) Designated Activity Company (together, "we", "our" or "us") has an interest in your loan (or your guarantee provided in connection with a loan) legal title of which is held by Everyday Finance DAC. This means that we will process information about you in connection with the administration of your loan/guarantee. We are committed to protecting your information and acting in accordance with your rights under data protection law.
We receive and process the following information about you:
your personal details including your name, date of birth, home address (including postcode), telephone number, e-mail address, bank account details (in certain cases), and country of residence;
any information relating to your loan, including your loan application and your repayment history, your financial and employment data, and information about your dependants or those you share your home with;
any records of communications or dealings with you (including any complaints); and
in certain cases, special categories of personal data that you have disclosed in your interactions with your loan provider, such as information about your partner (which may reveal your sexual orientation), racial or ethnic origin, sex life, mental and physical health, genetic information, details of injuries, medication/treatment received, political or religious beliefs, labour union affiliation, and criminal records, fines and other like judicial records.
We receive this information from the companies that service your loan (known as servicers, in this case Link ASI Limited and Link Mortgage Services Limited) and from your loan provider. For more information about your loan servicers, click here.
We use your information for the following purposes:
Our use of your information as described above is permitted by applicable data protection law because it is:
in the case of the interests and purposes described in (a) to (e) above (other than where we process your information to comply with a legal obligation to which we are subject);
necessary for our legitimate interests in pursuing the purposes set out above in this section, such interests in each case not being overridden by your privacy interests (you may ask us for more information about how we have carried out this balancing test using the contact details.
required for us to comply with a legal obligation to which we are subject; or
in limited circumstances, processed with your consent. This privacy notice does not require you to provide consent. Where we ask for your consent, we will do this separately.
If we cannot process certain personal information about you, it may not be possible to administer or continue your loan/guarantee, and this may lead to termination of your loan. If this is the case, we will make this clear to you where relevant circumstances arise (e.g. if you object to our processing of your personal information in accordance with your rights.
We share information with the following recipients:
primarily with the companies that help us to service your loan/guarantee Link ASI Limited and Link Mortgage Services Limited ("Loan Servicers");
our suppliers, business partners and relevant members of our group;
providers of services to us and our group, such as banks and financial and legal advisors;
credit reference and fraud prevention agencies;
members of our group for other relevant purposes, such as for audit purposes or in relation to corporate transactions initiated by our group;
any new loans provider you select, if requested to do so by you;
public authorities, regulators or government bodies, including when required by law or regulation, under a code of practice or conduct, or when these authorities or bodies require us to do so; and
other persons from time to time when the disclosure is needed to exercise or protect legal rights.
The use and disclosure of your information for the purposes set out in Paragraph 2 above may in certain cases involve transferring your information to countries outside of the European Economic Area. Depending on the circumstances, those countries could include the United States of America, which is not currently the subject of an adequacy decision by the EU Commission.
We ensure that information that is required to be transferred is protected using safeguards that comply with applicable data protection rules, for example data transfer agreements approved for this purpose by the European Commission or (where applicable) relevant privacy supervisory authority. Further details (and copies, where appropriate) of these safeguards are available by contacting us.
We generally keep your information for 6 years after the later of: (i) the date on which your contractual relationship with us ends; and (ii) the date on which all repayments have been repaid.
In some cases, this period will be extended (e.g. if you have made a complaint or brought a claim), in which case we calculate the retention period based on: (a) any applicable contractual limitation periods; (b) our legal and regulatory obligations; and (c) any retention periods recommended or stipulated by relevant professional or industry bodies or associations.
You have rights under data protection law to access and correct information and (in some circumstances) to restrict its use, have it deleted or require certain of your information to be transferred to you or a third party.
To the extent the use of your information is based on your consent, you have the right to withdraw your consent.
You also have the right to object to the processing of your information in certain circumstances.
You can contact us about exercising any of these rights using the details.
There is generally no charge to you to exercise any of these rights. However, these rights ae not absolute and exceptions apply. If we do not comply with your request we will explain why.
You can also lodge a complaint about our processing of your personal information with a supervisory authority in the EU Member State where you habitually reside or work, or where a breach has taken place. Details for the Irish Data Protection Commission are at dataprotection.ie and the UK Information Commissioner at ico.org.uk.
In certain cases, it will be necessary to obtain additional information from you, for example in order to verify your identity or to help us locate information you are seeking.
This privacy notice was last updated on August 9, 2018. This document is a notice to you and not a contract between us. Any future changes or additions to the processing of personal data as described above in this privacy notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
Your loans are administered day-to-day by your Loan Servicers. They will receive and process any requests, complaints or enquiries about your rights on our behalf. You can make such requests, complaints or enquiries to: firstname.lastname@example.org.