Microfinance Ireland Privacy Statement
Last Updated 18th January 2017.
A few things to note:
- You: When we say “you” in this policy, we mean both you and any other individuals you let use your email or device. As microfinance is for businesses, we expect you are acting in your business capacity.
- Microfinance Ireland: When we say, “we”, “MFI” or “us” we mean Microfinance Ireland – please see “Who we are”below for more information in this regard.
- Personal information: When we talk about “personal information”, we mean information that can be used to identify you, such as your name, address, email address or phone number. It does not include depersonalised or aggregated information.
- Referral partners: When we refer to our “referral partners” we mean the entities, such as the Local Enterprise Office or other enterprise agencies or business advisors, which introduce you to us or to whom we refer you – please see “Who are our referral partners?” below for more information in this regard.
- Mentors: when we refer to “mentors” we mean the mentors appointed by our referral partners to assist you with your microfinance application – please see “Who are mentors?” below for more information in this regard.
- External credit assessors: when we refer to “external credit assessors”, we mean the entities which we engage to assist us in evaluating your microfinance application – please see “Who are external credit assessors?” below for more information in this regard.
How do we collect your information?
We collect personal information when you provide it to us, such as when you contact us, when you visit the MFI website, when you post on our social media pages or when you apply to us for microfinance. While you generally will know when you are providing information to us, in some cases it may be done automatically by your device (please see “What information we collect” for examples of this).
MFI also works with our referral partners and the mentors they appoint who assist Microfinance Ireland applicants through training and guidance. In some cases, they may submit your application to us on your behalf – they should do this with your consent.
We may also use service providers, such as external credit assessors, to assist us in assessing your microfinance application. They may provide us with information that you give to them or that they create in the assessment of your Microfinance Ireland application.
If you provide personal information about another person (e.g. in a microfinance application), we will assume that you have that person’s permission to provide us with that information.
What information do we collect?
- Information you give us: Information we ask you to provide us may include, for example, your name, email address, phone number. When you are submitting an application to Microfinance Ireland, you may have to submit a business plan, cash flow and other detailed financial information such as savings amounts, loan statements and bank statements, billing address, credit card information and age or other demographic information. We may also ask you to complete surveys.
- Information automatically transferred to us: By using our website, information such as network and other location and equipment related information may be automatically transferred to us. This may include, for example, de-personalised data about your device such as how your device uses and interacts with the website, the device’s model number, operating system, software versions and unique identifier as well as the device’s location (such as GPS data, MAC address, zip code, and time zone) and mobile network information or platform information.
- Information from other sources: We might receive additional personal information about you from other sources. These other sources include:
- Referral partners and mentors: These may pass us information about you with your consent. For example, they may submit your application to us on your behalf or contact us to discuss your application.
- Credit bureaus: The Irish Credit Bureau or banks may be contacted for the purpose of obtaining details of your current and past credit payment history.
- Banks: We may contact banks you say declined your credit application to validate information you submitted as part of the microfinance application.
The way in which these other sources collect, use, disclose, and protect information received from or about you is set out in their own privacy statements, not this privacy statement. You are encouraged to review their privacy policies before providing them with personal information. We are not responsible for what they do with your personal information.
- Information we log: We may also log information about you when you access and use our website. For instance, we may log your Internet Protocol (IP) address, access times, browser type and language, ISP, the pages and content on our website you use and the URL of the webpage you visit.
- Service providers such as our external credit assessors: Our service providers may also collect information about you on our behalf. For example, our external credit assessors may contact you to discuss aspects of your loan application. Our service providers have agreed to use your information only for the purposes we request.
We may combine and link information from these different sources.
How do we use your information?
We use personal information we collect for various reasons. These include:
- to provide you with the products and services you request such as to assess eligibility for a microfinance loan or respond to your queries;
- to tell you about the products and services offered by MFI and our referral partners and to promote the microfinance program;
- to refer you to our referral partners so that they can help you with your microfinance loan application or provide you with other assistance;
- to respond to your queries;
- to enable certain features of our website;
- to notify you of changes to our policies;
- to conduct surveys, webinars, podcasts, teleconferences or seminars;
- to improve our existing products and services and develop new ones; and
- to otherwise operate our business.
If you submit a query to us, we may also follow up with you subsequently to make sure you have no more queries or to tell you more about our products or services.
We may (subject to applicable law) also combine and link your personal information with information we obtain from other sources. This could occur, for example, in circumstances where we receive new, updated or additional information from the referral partners or mentors regarding your microfinance application.
As part of providing you with enhanced website or services, we may use personal information we collect to:
- analyse your usage habits (which lets us continually customise and improve the site and our services); and
- analyse the aggregated profiles of users of our website – we will only ever do this having first de-personalised your information or with your consent.
We may also use personal information we collect to show you more relevant ads on third party websites.
Disclosure of your information
We are not in the business of selling your personal information to third parties. We will disclose your personal information to third parties from time to time including in the following circumstances:
- Consent: we get your consent;
- MFI parent: we may give information to our parent company.
- Referral partners or mentors: we may pass information about you to our referral partners or the referral partner mentors with your consent.
- Credit bureaus: we may provide details of your microfinance payment history to the Irish Credit Bureau or banks.
- Debt Collection Agencies: MFI may use these agencies if your microfinance repayments fall into arrears.
- External Credit Assessors: MFI may provide personal information to external credit assessors that we appoint to assist us in the assessment of your microfinance application. They may contact you directly.
- European Investment Fund (EIF): MFI has obtained a credit guarantee from the EIF. Consequently, we may be subject to external review by representatives of the EIF, the European Investment Bank, the European Commission or other members of the European Investment Bank Group.
- Required by law: we are required to by applicable law, legal process or governmental authorities.
- Protection: we believe disclosure is necessary to protect our rights, our customers or others.
- Corporate transaction: we are involved in a merger, acquisition, partial or total sale of assets or other corporate change.
- Illegal activities: to investigate, prevent or take action regarding illegal activities, suspected or potential fraud or brand protection matters (such as unauthorised use of our trademarks).
- Third party service providers: they provide services to us (such as external credit assessors) and have agreed to use your information only for the purposes we request.
We want to promote microfinance success stories so others like you can use microfinance to benefit their business. If you agree to participate in a microfinance promotional campaign, your personal information may be disclosed in connection with such a campaign with your consent.
We may disclose non-personal information to third parties in our discretion (and we treat aggregated or depersonalized information as non-personal). For example, we may provide reports showing aggregated or otherwise depersonalized information regarding our users to advertisers, networks, and others. De-personalised reports may also be sent to the Department of Jobs, Enterprise and Innovation for progress review, reporting and other related purposes.
We may also share aggregated information that cannot identify you. For example, we may disclose the number of visitors to the MFI website or the number of applicants for microfinance.
Who will contact you about your microfinance loan?
MFI and its service providers (e.g. external credit assessors) may contact you directly by phone, email or post in connection with your application for microfinance and may also ask to meet you in this regard.
Who are referral partners?
When we refer to our “referral partners” we mean the entities, such as the regional Local Enterprise Offices,other enterprise agencies or business advisers, which introduce you to us or to whom we refer you.
We refer some microfinance applicants to our referral partners as they can assist with training and guidance in the microfinance application process. In some cases, they may submit your microfinance application to us on your behalf – they should do this with your consent.
While we may refer you to a referral partner or they may recommend you apply for microfinance from us, you should be aware that they operate independent of us when providing you with assistance and training. We are not responsible for the quality of their service.
Our referral partners have their own policies that govern their collection, use, and disclosure of information. We suggest that you read their privacy policies to learn about their practices, as we are not responsible for them.
A referral partner may undertake an initial local evaluation of a microfinance application; in this case (unlike above) they do so on our behalf, i.e. as our service provider. This initial assessment is not definitive; we always draw our own conclusions based upon a detailed assessment.
Who are mentors?
Our referral partners will often allocate an individual to mentor you in connection with your microfinance application. These individuals are referred to as “mentors”.
Mentors operate independent of us when providing you with assistance and training. They are engaged by our referral partners. We are not responsible for the quality of their service. Please see “who are our referral partners” for more information in this regard.
Who are external credit assessors?
In some cases, we engage third parties to assist us in connection with the assessment of your microfinance application. These third parties are referred to as “external credit assessors”. They provide services to us and have agreed to use your information only for the purposes we request.
We may work with third-party advertising companies that collect and use information to deliver more relevant advertising across the Internet and when you are using our website. To learn more about this practice and your choices with regard to companies participating in industry self-regulation, visit http://www.aboutads.info.
Location of personal information
We currently host your personal information within the European Economic Area. However, it is possible that at some point your personal information may, for example, be maintained, processed and stored by us and our service providers in countries outside of the European Economic Area (EEA). These countries may have different data protection rules and standards to those in Ireland. We will handle your personal information in the manner described in this privacy statement, even in countries whose laws provide less protection for your information. You agree to the transfer and hosting of your personal information outside of the EEA by using or accessing the website and/or by submitting information to us.
Protection of personal information
We recognize that security is important to you. While no product or service is completely secure, we have implemented reasonable industry-standard physical, electronic, and organisational measures to safeguard the security of your personal information.
Third-party services / websites
We may refer you to third parties such as our referral partners, and our website may contain links to third-party websites. Such third parties have their own policies that govern their collection, use, and disclosure of information. We suggest that you read their privacy policies to learn about their practices, as we are not responsible for them.
Accessing and updating personal information
We need your help to keep your personal information accurate and up-to-date.
You can access, update and correct or delete inaccuracies in your personal information that we collect and maintain by emailing us.
Your choices/opt out
You can exercise choices regarding our use of your personal information:
- Promotional Communications: We will only send you promotional communications where we are permitted to do so by applicable law. If you do not want to receive promotional communications from us, you can change your preferences by following the instructions at the point you originally submit information to us (e.g. when submitting a query) or on the communication (e.g. clicking unsubscribe in an email) or by emailing us.
Who we are?
Microfinance Ireland is established under the Microenterprise Loan Fund Act 2012. We are registered in Ireland as a private company limited by shares, the members of which have limited liability with company number 516555. We are registered as a charity under company number CHY20447 and have our registered office at Earlsfort Centre, Earlsfort Terrace, Dublin 2.
Changes to this Policy
Our business changes constantly and our privacy statement will also change, so please review it frequently. We will notify you of any changes by posting the new policy at this location with a new version number and effective date. If we make a material change in how we treat your personal information, we will take reasonable steps to notify you in advance of the planned change.
Updated versions of the privacy statement will always be posted on www.microfinanceireland.ie. The date the privacy statement was last updated is set out at the top of this privacy statement.
If you have any questions about this policy, please send an email to firstname.lastname@example.org, or send a letter to Microfinance Ireland, 13 Richview Office Park, Clonskeagh Road, Dublin 14.