Privacy
This is the GRID Privacy Policy. We have tried to make our Privacy Policy as easy to use and understand as possible. We have kept this information as simple as possible but if you have any questions, please get in touch through info@gridfinance.ie. This policy was last updated on 13 July 2022.
Your Personal Information
We will keep your personal information completely confidential. It will only be shared with others for the reasons that we have outlined below – Our Terms and Conditions of business are available here.
Who is Collecting Your Data
Data is being collected by the various facets of GRID (these being GRID Finance Impact Limited, GRID Cash Advance DAC, GFIL, GCAD, GRID Business Platform DAC & GRID Wealth DAC). As data controller we follow the 8 core rules as set down by the Irish data protection commissioner, these can be found here.
What Personal Data is Collected
Personal data that is collected on you is predominantly provided by you via email, calls, KYC (ID , Utility bill, tax documents) letters your authorised third parties. The only other sources of personal data are from publicly available information from the Companies Registration Office or judgment searches. This data is required in due diligence process of assessing applications from prospective borrowers. Personal Information or data can be considered any Information relating to a living individual who is, or can be, identified by that information, including data that can be combined with other information to identify an individual. This can be a very wide definition, depending on the circumstances, and can include data which relates to the identity, characteristics or behaviour of an individual or influences the way in which that individual is treated or evaluated.
What is the Basis for Us Processing (Including Storage) of Your Personal Data?
We process (including storage) your data in the performance of a contract. Namely, to assess the creditworthiness of business applicants (and any relevant persons connected with such businesses, including employees, directors, representatives, partners, shareholders, guarantors and beneficial owners) for a loan and facilitate the connection of feasible business loans, with lenders seeking an appropriate return for their investment.
By accessing and using our website, platform and services, you confirm that you have had proper opportunity to read this Privacy Policy, that you understand it and that you agree to be bound by its terms. If you do not, you must immediately stop using our website and platform, and any services provided by us.
Who Will Your Information Be Shared With?
In the completion of any loan facilities, it will be necessary to share your personal information with third parties in a variety of circumstances:
– To assess your credit risk with a third-party credit reference agency such as Experian, Stubbs, Vision-Net or other credit search systems; all of which are GDPR compliant.
– To one of our debt collection agencies or legal representatives so that they may secure payment.
– To inform credit rating agencies that you have an account with us.
– To any external underwriting services provider in assessing any application
– To inform credit rating agencies how your account is performing.
– IT and CRM systems which are GDPR compliant.
– To fulfil present and future regulatory and tax requirements as set down in law.
– To fulfil any present/future law mandating us to share your information.
– To mitigate the risk of fraud by completing some anti-money laundering checks.
– To get information from third parties whom you have asked us to.
– To secure funding from lenders to fulfil your financial request.
– Third parties we need to share your information with to facilitate payments to and from you and those you ask us to share your information with. For example, SWIFT, credit card issuers, Financial Services Companies and merchant banks.
– Any Security Trustees.
– Guarantors and joint borrowers.
– Companies that provide support services for the purposes of protecting our legitimate interests. Your personal information remains protected when our service providers use it. We only permit service providers to use your information in accordance with our instructions, and we ensure that they have appropriate measures in place to protect your information.
– Borrowers will be able to see lender’s usernames who make offers on their loans (this may not be personal information depending on the naming convention you decide).
– If GRID is taken over or merged with another organisation, your information will be transferred to the acquiring company/organisation to share with another peer-to-peer lending agency or credit provider, where we believe they may be able to fulfil your loan request when your loan request has been unsuccessful.
– Credit checks via ICB or CCR
– Lead applicants, authorised users, authorised partners you have appointed may be able to see your personal details and Utility bills or Photo ID, tax documents that have been uploaded. It is the responsibility of the account holder to control access of users to the account and not of GRID. This can be amended by the relevant party contacting GRID via business@gridfinance.ie or via the helpdesk functionality.
– Any personal information regarding marketing materials or testimonials etc will only be done with your express consent.
– To satisfy Anti Money Laundering Requirements (these may be stored on our platform and viewed by other users of your account)
– Details of Signatories and Ultimate Beneficial Owners for loan documents or guarantees
– User names authorised on the platform may be viewable by other users of your account
By using the platform, you agree that GRID may share certain transactional data associated with loans entered on the platform. The sharing of this transactional data will not result in your identity or personal details being shared.
How Long Will Your Information Be Retained For?
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Platform Data) for seven years after they cease being customers for tax purposes. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
We will retain and securely destroy your personal information in accordance with applicable laws and regulations.
Third Party Liability
In the very specific incidences where data is shared, GRID cannot be held liable for any use or misuse of this data. If you become aware of any use/misuse of data, you will inform us immediately through the customer care centre info@gridfinance.ie
Banking and Payment Information
Our payment providers are Fire Financial Services Ltd, Nua Pay and Stripe. When payments are processed through these providers, your details are processed and controlled by them. They are responsible for compliance with the Payment Card Industry (PCI) data security standard.
GRID uses a regulated third party provider, Plaid, to retrieve and view the customers bank account information (account balances and transactions) for those customers who choose give us permission to do so as part of either an application for loan funding or any analytics services provided by GRID. GRID does not have a license for PIS – Payment Initiation Services, so therefore cannot execute, request or initiate payments on the behalf of any customer for whom GRID can access their account information.
Your Rights as a Data Subject
Your Personal Data is defined as information relating to a living individual who is, or can be, identified by that information, including data that can be combined with other information to identify an individual.
You have the following rights in relation to your personal data. You have the right to:
– Find out if we use your personal information to access your personal information and to receive copies of the personal information we have about you.
– Request that inaccurate information is corrected, and incomplete information updated.
– Object to particular uses of your personal data, where the legal basis for our use of your data is in our legitimate business interests, or the performance of a task in the public interest. However, doing so may have an impact on the services and products we can / are willing to provide.
– Object to use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes.
– Have your data deleted or its use restricted – you have a right to this under certain circumstances. For example, where you withdraw consent you gave us previously and there is no other legal basis for us to retain it, or where you object to our use of your personal information for legitimate business interests.
– Obtain a transferable copy of certain data which can then be transferred to you
– Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
– Rights of Automated Decision-Making & Profiling: GRID do not make any decisions regarding financial assessment without the intervention of staff nor do we undertake the profiling by personal data.
– If you want to exercise any of the above rights, please contact us on info@gridfinance.ie
We are obliged to respond without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons why. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise.
How to Contact Us or Make a Complaint
How to contact us: if you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact us at info@gridfinance.ie
You have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner here
Security
We value your trust in providing us with your personal information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.
We know how frustrating it is to receive unsolicited email. Our commitment is to be as email friendly as possible. We will not sell your email address to other commercial entities or advertise the products of other commercial entities to you. We will need to contact you by email for a variety of reasons. These reasons include:
– To set you up in the community lending platform.
– Account maintenance and management.
– Loan applications and processing.
to inform you of platform developments and activity and of changes to our products and services.
– Loan repayments.
– Loan performance.
– Lodgements and withdrawals.
– Account closure.
– Availability of loans to be funded.
– Recommendations of other GRID products suitable for you.
– ou can manage some of these settings within your user profile on the platform.
– We undertake to manage your preferences regarding direct marketing or conveying information to you (outside of the reasons outlined above) on a regular basis, via your opted in consent. However, if you wish to alter your preferences at any stage, that can be completed by: emailing info@gridfinance.ie (or unsubscribing on e-mails).
Location of Your Data
It is our explicit intention to retain your data in Ireland or another jurisdiction within the European Union. However, we may transfer your information to countries whose data protection laws are less strict than Ireland. If so, we will ensure the information is held securely and to the same standards as Ireland, and only used for the purposes set out in this Privacy Policy.
Credit Reference Agencies
When you apply for a loan on the GRID Platform we will perform a credit check with a range of credit reference agencies. They may maintain a record of such a search on their database. If you should fall into default, we may record this on your credit file with a variety of credit reference agencies. We are not obliged to give you notice of recording this default on your credit file, but we will make every effort to inform you. For these purposes, default is referred to as a payment not received within 1 month of its due date. This is in line with regulated financial institutions.
Access to Your Personal Information
Under the Data Protection Acts 1988 and 2003 you may request access to your personal records. Although there is an indicative charge set down in the acts for such requests it is not envisioned that GRID will charge for requests from customers of the platform. This is subject to review anytime and without notice. You may request access to your personal records by emailing info@grid.finance.
Member Content
You agree that none of your member content will violate or infringe upon the rights of any third party. This includes copyright, trademark, privacy, publicity or other personal or proprietary rights; or contain libellous, defamatory or otherwise unlawful material. Member content is not necessarily considered personal information and personal information is dealt with separately within this Privacy Policy.
In addition:
– You agree not to use the community lending platform to secure email addresses or other financial, personal or contact information of members, or other users from the lending platform, by electronic or other means, for the purposes of sending unsolicited communications or inviting any person to lend or borrow outside the community lending platform.
– You agree not to use the community lending platform for any unlawful activity, or to engage in any activity that will reduce the functionality, or the ability of other members to use the platform. This includes not engaging in any activity that may collapse the site or impact on the servers on which the site sits.
– You agree not to use automated scripts or other screen scraping techniques to collect information from the community lending platform.
– You agree to only register on the community lending platform once and not to use any aliases or alternative/false identities.
– You agree not to impersonate any person or entity, or falsely state or otherwise misrepresent yourself, your age, your financial employment or personal circumstances, or your affiliation with any person or entity; use or attempt to use another’s account, service or system without authorisation from us.
– You agree not to solicit any personal information (passwords etc) from anyone for any commercial or unlawful purposes.
– You agree not to use the community lending platform to invite members to lend/borrow/transact outside of the platform.
– You agree not to upload, post, publish, display, transmit, share, store or otherwise make available on the lending platform any content that we, or any objective third party, may deem:
– to be misleading, harmful, threatening, unlawful, libellous, defamatory, infringing of any intellectual property rights, abusive, inflammatory, harassing, vulgar, obscene, fraudulent, invasive of privacy or publicity rights, hateful, or racially, ethnically or otherwise objectionable;
– to contain software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment;
– to be unsolicited or unauthorised advertising, solicitations, promotional materials, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” or any other form of solicitation;
– to be the private information of any third party, including, without limitation, addresses, phone numbers, email addresses, National Insurance numbers or other identifiers, credit card numbers and/or debit card numbers;
– to be an attempt to promote or market any goods or services for your own financial benefit;
You are entirely responsible for the legality and appropriateness of your member content. You may not post, transmit, or share other member’s content on the lending platform that you did not create or that you do not have permission to display, publish or post either within or outside the community lending platform.
You understand and agree that we may, but are not obligated to delete or remove (without notice), any content that in our judgment violates our values and philosophy as a company. You are solely responsible at your sole cost and expense for creating backup copies and replacing any of your content.
When you post your member content, you have authorised us to make such copies thereof as we deem necessary in order to facilitate the publication, display and storage of the member content on the community lending platform.
By posting member content to any part of the community lending platform, you automatically grant, and you represent and warrant that you have the right to grant, to us an irrevocable, perpetual, non-exclusive, transferable, fully paid, worldwide license (with the right to sublicense) to use, copy, publicly perform, publicly display, reformat, translate, excerpt (in whole or in part) and distribute such member content for any purpose on or in connection with the lending platform, to prepare derivative works of, or incorporate into other works, such member content, and to grant and authorise sublicenses of the foregoing.
You may remove your content from the community lending platform at any time. If you choose to remove your member content, the license granted above will automatically expire. You accept that where you have removed your content an archived copy may remain. This is separate from personal information, the removal / updating of same or exercising any other rights can be completed as outlined separately within this document.
You agree to indemnify and hold each other member, us, our subsidiaries and affiliates, and each of GRID’s directors, officers, agents, contractors, partners and employees, harmless from and against any loss, liability, claim, demand, damages, costs and expenses. This includes reasonable legal fees, arising out of or in connection with any of your content, your use of the community lending platform, your conduct in connection with the lending platform, or with other users of the lending platform or of any law or the rights of any third party.
You are solely responsible for your engagement with other members of the community lending platform. We reserve the right, but have no obligation, to monitor and manage disputes between you and other members of the community lending platform. Our cookie policy is an integral part of this document.
IP Address
When you visit the community lending platform, our servers automatically interpret your domain name and IP address. There is no other personal information interpreted. Interpreting your IP address allows us to better manage the platform for all members. This IP information is not shared with third parties unless there is a law enforcement reason to do so.
Cookies
A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone browser from a website’s computer, and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. Many websites do this whenever a user visits their website to track online traffic flows.
When you are on the GRID Platform, cookies tell us how you are engaging with the platform. We use this information to help improve our services to you, and to ensure that you have the best customer experience possible on our platform. It also helps us understand what type of device you are using the platform from. This assists us to design the best user interface for each device. It also helps us to recommend certain projects to you based on previous visits.
We use two types of cookies:
- Session cookies
- These cookies help make the customer experience more pleasant. As you move from page to page, these cookies prevent you from having to resubmit certain data and they keep you logged into the site for a period of time. They also support the security of your account by logging you out after 15 minutes of inactivity.
- Persistent Cookies
- These cookies help us recognise you as a unique visitor. This helps us understand how you are engaging with the site and what type of content you like to view on the site.
Accepting and rejecting cookies
You can configure your browser to warn you when a cookie is about to be installed from any website. When it warns you, you will have a choice to accept/reject the cookie. Please note that if you reject a cookie, it will have a negative impact on your customer experience and the usability of the community lending platform.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.
