This Privacy Statement (v3.4) is effective from this day 26th January 2017.
1 General Information
1.1 Fire Financial Services Limited (trading as fire.com and fire) is regulated by the Central Bank of Ireland.
1.2 We comply with the Data Protection Acts 1998 and 2003 as well as the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (together “Data Protection and Privacy legislation”). We are registered with the Data Protection Commission as a Data Processor. Please refer to http://www.dataprotection.ie for further details. We and our operating partners are committed to safeguarding the privacy and security of the information we collect.
2 Important information about this privacy statement
2.1 This Privacy Statement sets out the basis, on which any personal data you provide to us, or we collect from you through our website(s), our Applications and Services, or our operating partners will be processed by us.
2.2 Definitions are as per Definitions in our Terms and Conditions.
2.3 If you do not agree with this Privacy Statement, you should not open and/or operate an Account.
3 Statement of Data Protection and Privacy
3.1 We will take appropriate measures to ensure confidentiality of all information, both paper and electronic required for the operation of our business. We will take appropriate steps to protect data stored or transmitted against accidental or unlawful destruction, accidental loss or alteration, and unauthorised or unlawful storage, processing, access or disclosure.
3.2 We are committed to and comply with all relevant Data Protection and Privacy legislation and/or regulations of the jurisdictions within which we operate.
3.3 We will ensure that your personal data can be used only by authorised personnel for legally authorised purposes.
3.4 We will only use personal data in our possession for its intended specific and authorised purpose.
3.5 Your personal data may be transferred to contracted third parties, e.g. banks and other firms external to us for the purposes of providing our services to you.
3.6 We may share your personal information with authorities both within Ireland and abroad to prevent money laundering, terrorism and fraud in order to meet our legal obligations.
3.7 Your personal data will be retained and maintained in accordance with applicable Data Protection and Privacy laws and regulations.
3.8 Via our Applications or upon written request, we will amend the personal data we hold if factually incorrect, and provide you with a copy of any personal data held by us.
3.9 All our employees are trained in applicable Data Protection and Privacy legislation and will act with due care and diligence when handling personal data. Privacy Statement
4 Minors and Vulnerable Persons
4.1 Persons under the age of 16 (sixteen), are not permitted to open a Fire Personal Account or open or operate a Fire Business Account and we ask that persons under 16 do not submit any personal information to us or use our services.
4.2 A “vulnerable person” means a natural person who:
- has the capacity to make his or her own decisions but who, because of individual circumstances, may require assistance to do so (for example, visually impaired); and/or
- has limited capacity to make his or her own decisions and who requires assistance to do so (for example, persons with intellectual disabilities or mental health difficulties).
4.3 Vulnerable Persons should contact us at email@example.com before registering for an account with us or have their guardian or attorney contact us.
5 Information we collect
5.1 Our customers are individuals and businesses. The information we receive and collect from prospects and customers is strictly related to our customers and the services we provide and execute. The information we collect may include financial and other information. We understand that such information is sensitive and take appropriate steps to protect the confidentiality and security of all information collected by us in accordance with this Privacy Statement.
5.2 When you complete and submit a form on our website(s) or Application(s), send us an e-mail, send us a letter, or contact us by telephone to solicit information about our services or us in general, we may store the inquiries and their contents. Information you submit via an inquiry is collected only with your knowledge and active participation, and may be used by us to respond to your inquiries, to contact you, to inform you of services of ours or our partners that may be of use to you. Information collected during the course of an inquiry will not be disclosed to any third party; provided that such information may be shared internally with our affiliated entities for the business purposes set forth above.
6 IP Address and Device Data
6.1 When you visit our website(s) or use any of our Applications we collect your IP address and other information such as the domain and host from which you access the internet, the browser and browser version, the operating system, and type of device. We do so in order to administer our services and optimise our websites and Applications for you and to diagnose problems with our website(s) or Applications. We also use the information to assist in the fight against fraudulent or malevolent use and to ensure a better user experience. We may also employ location services to determine your approximate location.
8 Use of Third Parties
8.1 In accordance with the Criminal Justice (Money Laundering and Terrorist Financing) Acts 2010 and 2013, we may obtain information about you from third parties such as your bank, electoral register or Privacy Statement
any other public application or register in order to verify your identity and protect against fraud, money laundering or terrorist financing.
9 Third Party Websites & Applications
9.1 We may integrate to third-party websites and/or applications (Facebook, Twitter, and LinkedIn for example). We will always ask for your consent before performing any activities on such applications. In addition, we may authorise third-parties to integrate to our application(s). We are not responsible for the content or privacy practices employed by third-party websites/applications. Neither do we control or warrant the utility, merchantability or workmanship of the products or services offered at third-party websites/applications.
10.1 We must comply with a number of statutory and regulatory requirements in relation to the retention of data. Your personal data must be retained for a period of no less than six years following the closure of your account with us, or six years from the date of the last transaction, whichever is the later.
10.2 We do not sell or rent your personal information to any third parties for marketing purposes.
11 Changes to this Privacy Statement
11.1 We continue to review our controls and processes to assure that they are effective in meeting our commitments to our customers. We reserve the right to change this Privacy Statement without notice at any time and from time to time, including as needed to comply with the laws and regulations of the jurisdictions within which we operate.
12 Accessing and Correcting your Personal Information
12.1 Under the Data Protection Acts 1988 and 2003 (as amended), you have a right to seek access to information which we hold about you. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. Any such request should be made to us in writing to: Data Protection Officer, Fire Financial Services Limited, 3rd Floor, The Observatory, 7-11 Sir John Rogerson’s Quay, Dublin 2, Ireland or by email to firstname.lastname@example.org.
12.2 To obtain a copy of your personal information you should write to us at the address stated above, quoting reference “Data Access Request”, along with a payment to Fire Financial Services Limited for €6.35 or submit a request by making a Data Access Request payment. We will ordinarily provide you with a print-out of the relevant personal information from our current databases, or with photocopies of records which are held only on current paper files. Your request will be dealt with as soon as possible and in any event within 40 days.
12.3 You also have the right, in certain circumstances to request that we delete your personal information. Any such request should be made in writing to us at the address provided above.