Waterford Credit Union Limited
Last edited: October 13, 2017
1. Who we are
We are Waterford Credit Union Limited (“we” or “us”). We are committed to protecting and respecting your privacy. This statement sets out the basis on which any of your personal data is processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we treat it. We are a data controller for the purpose of the Irish Data Protection Acts 1988 and 2003 (“Acts”) and relevant EU General Data Protection Regulations.
2. Information we may collect about you
We may collect and process the following information about you:
- Information provided at the time of registering to use our online credit union services.
- Information that you or others provide by filling in forms on our website or which you or they otherwise provide to us.
- Any instructions we accept from you or transactions we undertake to which you are a party, whether through our website, branches or otherwise.
- If you contact us, we may keep a record of that correspondence.
- Telephone calls may be recorded. This is to verify your information, for our staff training, regulatory and for service quality purposes.
- Information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Personal Information refers to information that identifies (whether directly or indirectly) a particular individual or business entity. Examples may include your name, postal address, email address, telephone number, Social Security number, PPSN or TIN Identification number, birthdate, banking information or other information.
Anonymous Information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual or business. You could provide Anonymous Information or it could be collected automatically. Examples may include information about your internet browser, device information about your device you use to access the Site (this information may include geolocation information and unique device information), demographic data such as city, usage information about your use of the Site, additional traffic data such as time and date of access, software crash reports, session identification numbers and access time, and other information regarding your use of the Site.
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.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration, to help us provide a better service; to record session information and/or to assist you in browsing the website. This may in some instances only be statistical data about how you browse our website through online tracking.
For the same reason, we may obtain information about your usage of the website by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. Cookies help us to improve the website and to deliver a better and more personalised service. They enable us:
- to estimate usage numbers and patterns;
- to store information about your preferences, and so allow us to customise the website according to your individual interests;
- to speed up your searches; and
- to recognise you when you return to the website.
The website uses Google Analytics to collect information about how visitors use the website. The Cookies used by this product collect information in an anonymous form and are used by many different websites. If you wish to opt out of being tracked by Google Analytics across all websites, please visit http://tools.google.com/dlpage/gaoptout.
4. 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
- to provide you with access to the site
- to communicate with you about your account with us and send you information about features and enhancements on or to our site
- to send you newsletters, offers and promotions for our services, third party products and services, or special events by e-mail, text, or another medium, at all times in compliance with your privacy
- to detect, investigate, and prevent activities that may violate our policies or be illegal
- to perform statistical, demographic, and marketing analyses of users of the site.
We may also use information about you to notify you about changes to our services to which you have subscribed or to provide you with information about products or services that you request from us or, where you have agreed to us doing so, which we feel may interest you. We may use anonymised or statistical information to analyse our website and services and to make improvements or other adjustments to them. We use your information to support our legal and compliance obligations.
5. Where we store your personal information
It is possible that some of the information about you that we hold may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us, one of our suppliers or someone else. For instance, if it is necessary to do so to complete a transaction, your personal information (e.g. name and account details) may be sent to a third party or one of our contracted supplies outside the EEA.
By submitting your personal data, you agree to this 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.
6. Who do we share or transmit your information with
We may share personal and anonymous information with agents, subsidiaries, affiliates, partners and other third parties that perform functions on our behalf, such as hosting, billing, content management tools, analytics, customer service, fraud protection and debt collection. These entities have access to the Personal Information needed to perform their functions and are obligated to maintain the confidentiality and security of that Personal Information. The Service Providers are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services.
7. 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. You must keep your PIN, Password and Username for CU Online, and any other security device we give you, safe and secure.
You should log off CU Online and your Online Account when finished using CU Online. 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.
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.
Please understand, however, that while we try our best to safeguard your Personal Information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. We review our security procedures to consider appropriate technology and methods to secure information and take steps to keep your personal information safe.
8. Your Rights
You have rights under the Irish Data Protection Acts 1988 and 2003 and EU GDP Regulations.
You have the right to ask us not to process your personal data for marketing purposes and to ‘opt out’ from consent. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
You also have the right to access information held about you. Your right of access can be exercised in accordance with the Acts and Regulations. Any data access request may be made in providing you with details of the information we hold about you.
Your obligations in using the site is to provide true, accurate, current and complete information. If Waterford Credit Union has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, Waterford Credit Union has the right to suspend or terminate your account and refuse any and all current or future use of the Site (or any portion thereof). You are entirely responsible for the security and confidentiality of your password and account. Furthermore, you are entirely responsible for any and all activities that occur under your account.
9. Changes to our Privacy Statement
Any changes we may make to our privacy statement in the future will be posted on this page.
10. Contact us
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to email@example.com
Waterford Credit Union is concerned about children's privacy. The websites that we operate provide a forum for all of our members, including children, to view our products and what is happening in our Credit Union world. While we encourage children to participate appropriately in our websites, their privacy is extremely important to us. This Children's Privacy Statement explains our information practices in connection with information provided by children under the age of 18 on websites that link to this Children's Privacy Statement. The websites are controlled and operated by us from Ireland and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the Republic Of Ireland. Our goal is to minimise the information gathered from and disseminated about children under 18 while permitting them active participation in the trustworthy information, education and independent voice for which Waterford Credit Union is known.
A. How We Collect and Use Information from Children
Children can explore the websites, and can view and print reviews, comments and other content without providing any personal information. We do not permit children under 16 years of age to become an on-line banking user. We may use information collected from children during the exploration of our Sites in the following manner:
- To confirm the child's account
- To determine the child's current age in order to respond to any queries in an appropriate manner.
Children may post comments on our websites provided they are eligible users of said websites. We moderate all postings including children's postings to remove personal information, and we encourage parents to discuss with their children why they should NEVER include personal information in comments posted to the websites. Children may also participate in other online activities, such as polls. All members, including children, have the ability to delete their postings to the websites. Or the member can send an email requesting deletion to firstname.lastname@example.org, noting their name and date of the comment. It is possible that deleted reviews or comments will remain in our system (such as in backups of our data), but they will not be visible through the Sites. Please note that your request or deletion does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been re-posted by another user.
- Ensure that the websites function properly
- Enable us to conduct research and analysis to understand, address and improve the use and performance of the websites, and
- Diagnose and respond to problems
We may work with third parties to perform site analytics and provide services to keep your user experience on the Site free of spam.
B. What Information About Children Is Shared?
We do not disclose to third parties any children's personal information that we collect other than as follows, consistent with applicable law: (a) with a parent's permission, (b) as required by any applicable law, (c) to third-party service providers who help us operate or manage the Sites, (d) as part of aggregated data shared with third-party service providers, (e) to comply with legal process, (f) to respond to governmental requests, (g) to enforce our Terms of Service, (h) to protect our operations, (i) for assistance in fraud detection and prevention; (j) to protect the rights, privacy, safety or property of Waterford Credit Union, your child or others, (k) to permit us to pursue available remedies or limit the damages that we may sustain, and (l) in connection with a disposition of all or a substantial portion of our business, assets or stock, such as a sale, merger, consolidation, reorganisation, joint venture, assignment, or bankruptcy or similar proceedings.
C. How May Parents Access, Change or Delete Information About Their Child?
Parents may at any time access or change the personal information that we have collected online from their children. Parents may also ask us to cease further collection of personal information from their children, or to make no further use of, or delete, the personal information we have collected online from their children, in which case, the child's account will be deleted. Parents may contact us at email@example.com. For your child's protection, we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
D. How May Parents Raise Other Questions or Concerns?
If a parent has any questions or concerns about his or her child's use of the Sites, we encourage the parent to contact us at firstname.lastname@example.org