We take privacy seriously and we are open and transparent about how we handle your personal information
1.Who are we?
This website is operated by Everyday Finance DAC (referred to as “we”, “us” or “our” in this privacy statement). We take privacy seriously and we are open and transparent about how we handle your personal information and about our obligations under applicable data protection laws and regulations, including the General Data Protection Regulation.
This privacy statement explains the basis on which we will control and process any personal information we collect from you or that you may provide to us through this website or otherwise. We are responsible for any such personal data in our capacity as a data controller or as a data processor, as determined in accordance with applicable data protection legislation.
We have tried to keep this statement as straightforward as possible. However, if you require any further information or clarification then please contact us directly at:
Everyday Finance DAC, 16 Briarhill Business Park, Galway
Telephone number: 00 353 (0)91 700010
Email address: email@example.com
2. Do we have a Data Protection Officer?
Yes, given the nature of our business and the data that we hold we have appointed a Data Protection Officer to help ensure that your rights are protected. You can contact our Data Protection Officer (currently Andrew McCudden Legal and Compliance) at the following email address firstname.lastname@example.org write to the Data Protection Officer at the address listed above.
3. What information do we collect?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Special Category Data
We require your explicit consent for processing special category data (e.g health data). Where relevant, we will send you a further communication asking you to confirm your consent for this processing.
We do not carry out automated decision making or any type of automatic profiling.
4. How do we collect your data?
We may collect data about you when you provide the data directly to us (for example, by sending us emails or through other forms of correspondence we have with you, such as phone calls).
We may obtain data about you from the previous (or current) owner of your account.
Third parties that we appoint may collect data from you and pass it on to us.
We may receive data from third parties such as analytics providers for example, Google, some of which may be based outside the European Economic Area. Please see section 11 below for further details.
5. What do we do with your information?
We may use your information on any of the following lawful grounds:
Our legitimate interests include the following:
6. Who do we share your information with?
We may share your information with our employees, directors, shareholders and those of our affiliates, financial institutions, investment companies, accountants, lawyers, auditors, insurers, professional advisors, or other third party service providers who provide services to us. We may also disclose information we have a legal or regulatory right or obligation to report. Further, we may share your information with third parties to whom we sell, transfer or merge parts of our business or our assets.
It is our commitment that prior to disclosing any personal information about you to another organisation we have taken all reasonable steps to ensure that that organisation will hold and protect your information with adequate security measures and in accordance with relevant regulation.
7. How do we keep your information safe?
We protect your information with appropriate security measures under the laws and regulations that apply to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed without authorisation. We confirm our security measures are subject to regular testing and updated as appropriate to the level of data that we hold.
We have procedures in place to deal with suspected personal data breaches and will notify you and any applicable regulator of a breach if we are legally required to do so.
8. How long do we keep your information for?
We will only retain your personal data for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is for which we should keep the data, we look at its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure, the processing purposes, whether these can be achieved by other means and legal requirements.
For tax purposes, in certain circumstances the law requires us to keep information about customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. What are your rights regarding your information?
You have explicit rights concerning your personal information and we will ensure that your rights are protected while your data is in our possession. Your rights include the following:
You will not have to pay a fee to access your personal data (or to access any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Please note that we may ask you to provide us with additional documentation to verify your identity before we action your request. This is to ensure we are dealing with the correct individual and also for Anti-Money Laundering purposes. We will tell you when we ask for your information whether it is a statutory or contractual requirement to give us the information and the consequences of not providing the information.
10. Data Controllers of your loan
If your loan is serviced by Link ASI Limited following the loan sale that completed in August 2018, then please click here to view the Privacy Statement of Promontoria (Redwood) DAC.
If your loan is serviced by Link ASI Limited following the loan sale that completed in June 2019, then please click here to view the Privacy Statement of Promontoria (Beech) DAC.
If your loan was recently transferred to Everyday Finance DAC then please click here to view the Privacy Statement of LC Asset 1 S.à.r.l.
11. Making a complaint
If you wish to make a complaint then you may do so in person, by telephone, in writing and/or by email. Please note that all complaints are dealt with according to our complaints policy and will be fully logged and investigated.
You can also contact the Data Protection Commissioner, which is the supervisory authority for data protection issues in Ireland at www.dataprotection.ie
We will not transfer your data to a country outside of the European Economic Area unless that country ensures an adequate level of data protection, has appropriate safeguards in place or relies on one of the derogations provided for under applicable law and regulation.
This site may contain links to other sites. We are not responsible for their privacy practices or content nor potential damage, loss or offence caused.
It is very important that the information we hold about you is accurate and up-to-date. Please let us know if at any time your personal information changes by contacting us via the details set out above.
This privacy statement may be updated by us at any time.
Everyday Finance DAC, February 2019