Initiative Asset Management Limited (“Initiative AM”) is committed to safeguarding the personal information of individuals. Initiative Asset Management is a subsidiary of Initiative Financial Services Limited, a Data Controller registered with the Data Protection Commissioner of Ireland, registration number 16237/A. This policy outlines how we will collect and manage your information. Initiative Asset Management reserves the right in its sole discretion to amend this privacy statement at any time, you should therefore regularly check this privacy statement for any amendments.
In this statement we explain how “Initiative Asset Management” respects your privacy in relation to interactions with this website. When we talk about “Initiative Asset Management” or “us” or “we” in this statement we are referring to Initiative Financial Services Limited, its subsidiaries, affiliates and their respective parent and subsidiary companies.
If you are aged 18 or under, we do not provide any services that are suitable to you however some information may be recorded if you interact with our website or staff. As such please get your parent/guardian’s permission before you provide any personal information to us or use this website or contact us. Users without this consent are not allowed to provide us with personal information and therefore should not use this site.
Collection and Use of Information
We collect personal data about you as a User and data relating to your interactions with us on-line through InitiativeAssetManagement.com, or by phone or email. We will only collect and use individual user details where we have legitimate business reasons and where we are legally entitled to do so.
When you sign up to the platform personal information is gathered to enable us to provide services to you including but not limited to information specific to individuals and entities provided when completing the application process such as first name, second name, date of birth, nationality, postal addresses, telephone numbers, identification documents, bank documents, PPS number and e-mail addresses.
We may also collect information from third parties (including companies appointed to act as our agents or appointed to engage with you, such as our independent quantity surveyors, solicitors, valuers and other parties appointed to provide services to you or us. We may also collect information from the Central Credit Register, credit reference, fraud prevention and government agencies) and other sources with your consent.
We may also collect information from public sources including press articles or judgement searches.
We will monitor and collection information during our relationship with you monitoring your payments activity, your use and access of our systems (including cookies).
This information may be shared with our third party service providers, in order to facilitate our services, where we have in place appropriate confidentiality agreements to protect your information.
We will always let you know how we intend to use your information before collecting it, so that you can decide whether or not you wish to provide that information. You should read our Data Protection – Use of Information Notice or contact us directly for more information on how we use your information.
When you browse through our website our web servers collect data which relates to your visit such as:
- What pages you have viewed;
- Certain interactions you have had on those pages;
- The number of times you may have visited a particular page; or
- The amount of time you may have spent on certain pages.
In some cases the data we collect will be anonymous and it will simply tell us what pages have received the most activity and are of particular interest to our customers in general. Where you set up an account with us and/or log onto the Platform we will be able to identify what pages you have shown a particular interest in, what pages you have visited multiple times and also what pages you have spent the most amount of time on.
We will mostly do this work ourselves however sometimes we will use Google Analytics and other similar tracking tools to assist us. In all cases we will carry this work out in a responsible manner. This data enables us to provide you with a more efficient and effective customer service by developing a wider understanding and appreciation of our customer base. Where we are able to identify specific user activity, we can also offer those users a more bespoke user experience and assist them with customer service issues they may have experienced or may be experiencing.
Information shall be stored and used in strict compliance with Data Protection Laws applicable within the Republic of Ireland. For further information on this, please visit http://www.DataProtection.ie
Examples of Personal Information
Personal data means any information relating to an identified or identifiable natural person. Initiative Asset Management may processes the following types of personal data you provide:
- Name, address, email address, telephone number and other contact information;
- Your Personal Public Service Number (PPSN) or Tax Reference Number (TRN).
- Date and place of birth;
- Employment details;
- Copies of identity documents (passport, national ID card, driver’s license, employee identification numbers);
- Copies of utility bill, bank statement;
- Financial information you provide including ownership of companies;
- Statements you provide in relation to your relevant experience and education;
- Visual images and personal appearance (such as copies of passports or CCTV images).
- Online profile and social media information and activity based on your interaction with us and our websites and applications, including for example, your online profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, mobile phone network information, searches on our website and site visits.
- Where relevant you may notify us of health or medical conditions. Record of such Special Category information shall only be retained to the extent required by law, contract or with your consent.
If we have a lawful right to do so and in order to prevent crime, money laundering or other fraudulent activity, we will also use information about criminal convictions and alleged offences.
Where you have provided your consent for us to process your special category data, such as health or medical conditions, you can withdraw this consent at any time by contacting us.
Please note that the list is not exhaustive, and that Initiative Asset Management may also collect and process personal data to extent this is useful or necessary for the provision of our services and required to satisfy legal or regulatory requirements or with your consent.
Where you provide any additional information, on a solicited or unsolicited basis, this information may be processed.
Furthermore, when you register for a Secured Lending Account and provide an email address, we will use this email to communicate with you on an on-going basis i.e. to notify you of new loans which come available on the platform. If you wish you may contact us to ‘opt-out’ of these notices.
We will also use this email to provide service notices. You may not opt-out of service emails but you may choose terminate your account to avoid such notices, as outlined in the terms of business.
Cookies & Their Use
Cookies are small text files that are sent to and stored on your computer, smartphone, tablet or other device for accessing the internet, whenever you visit our website. Cookies are used to maintain the integrity of your browsing activities when you visit a website and can also be used to customise and so improve the individual customer experience. Cookies do not in any way compromise the security of your computer or other devices. You can continue to use this website by disabling cookies, however this may affect the functionality of the site on your computer or devise. More general information on cookies can be found on www.cookiecentral.com . This includes information on how to disable cookies.
To achieve this, there are different types of cookies in use. They all work in the same way, but have minor differences which are explained below.
Session cookies last only for the duration of your visit and are deleted when you close your browser. They are essential for secure user navigation through the site and enable the delivery of basic functionality. Specifically, they ensure the security and integrity of your session, preventing fraudulent use and keeping you signed in while you move between pages and service your account. If you disable cookies then you may not be able to use log in to your Initiative Asset Management Account.
Persistent cookies last after you have closed your browser, and allow us to remember your actions and website preferences. Initiative Asset Management uses persistent cookies to analyse customer visits to our sites. These cookies help us to understand how customers arrive at and use our sites so we can improve the overall Initiative Asset Management on-line experience.
Finally, we use analytics cookies to help us make our websites even better for those who visit them regularly. This type of cookie helps us to further understand how individual visitors use our on-line services and allows us to improve the overall service and products offered to you.
Storage of Information
How We Keep Your Information Safe
We know that you care about how your information is used, stored and shared. We appreciate your trust in us to do that. To protect your information, we use security measures that comply with Irish Law and meet international standards. This includes computer safeguards and secure files and buildings.
The data that we collect from you 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 or for one of our suppliers. By submitting your personal data, you consent 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 Policy and GDPR. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee that information you supply will not be intercepted while being transmitted to us over the internet, nor can we guarantee the complete security of our database.
Subject Access Request
Under the Data Protection Acts you have the right to see the personal information we hold about you. To request a copy of this information, write to Data Control Officer, Initiative Asset Management, Unit 2 Aspen Court, Old Bray Road, Cornelscourt, Dublin 18, D18 K3T2, Ireland or email Info@InitiativeAssetManagement.com with the subject ‘Subject Access Request’ stating you wish to request a copy of your information from the Data Control Officer in your email. You may also call us on 01 -6859259. Please note, your request must be sufficiently clear to act upon, and we must be able to verify the identity of the requester. As such, please be as specific as possible in relation to the personal data you wish to access.
Your request will be processed as soon as possible, taking no more than 30 days to process.
If your information changes or you believe we have information which is inaccurate or not up-to-date please let us know and we will change it.
We make every reasonable effort to prevent any loss, misuse, disclosure, or modification of personal information, as well as any unauthorized access to personal information. We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
As a member, your membership account information is protected by a password for your privacy and security. You must take care to protect against unauthorized access to your password and to your computer by logging off once you have finished using a shared computer.
We make every reasonable effort to ensure that personal information collected by us is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization.
If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases, we may ask for a written request for correction.
Conditions of Use
This Privacy Statement is subject to the Terms and Conditions of Use of the Initiative Asset Management website, a copy of these is available on InitiativeAssetManagement.com.
It is important that you read the terms and conditions of use as where there is a conflict between this Privacy Statement and the Terms and Conditions of Use, the Terms and Conditions of Use shall prevail.
By accessing and continuing to navigate this website you acknowledge and agree to the processing of your personal data in the manner outlined above. You also agree that in certain circumstances we may be obliged to disclose personal information relating to you to third parties in order to prevent, detect or prevent fraud.
Use of Information
Information provided to Initiative Asset Management will be managed in a manner compliant with the Data Protection Laws of Ireland.
We collect and process personal information when you contact us and at the start of and for the duration of your relationship with us. Your personal information may be retained for up to 6 years following termination of your relationship with us, to the extent required to comply with regulation.
We collect and process your personal data where:
- You have given consent to the processing of his or her personal data for one or more specific purposes
- Processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
- Processing is necessary for compliance with a legal and regulatory obligation to which we are subject;
We may sometimes collect special categories of information for the purpose of detecting and preventing financial crime or to make our services accessible to you. We will only collect or use this information when we have your explicit consent or are otherwise lawfully permitted to do so according to the law.
In addition to such general, fair use of information users should explicitly note:
As a Borrower, you should note that:
Initiative Asset Management reserves the right to use details relating to any loan applications, such as uploaded images, locations, descriptions, videos and amounts of funded projects in our promotional materials without notice or compensation. However, such promotions shall not contain any personal or otherwise commercially sensitive information without the express consent of the borrower.
Initiative Asset Management does not currently use automated credit decisioning.
As a Lender, you should note that:
Initiative Asset Management does not list the identities of lenders publicly at this time for a given loan in any public media. However, this information is recorded, to facilitate administration of the loan. Your name may be disclosed to the relevant loan parties, as required to facilitate the service we provide. If we are required to disclose or publish this information to other third parties, for legal or regulatory reasons, we reserve the right to do so to the degree that this is mandated only.
All Members should note:
User generated content that violates copyrights laws will be remove promptly by Initiative Asset Management upon notice.
Users who knowingly provide false information may be subject to legal or criminal proceedings and/or may have their membership and/or systems access revoked.
Information collected by Initiative Asset Management may be disclosed to our 3rd party service partners as necessary to provide our service and where required to meet legal and regulatory requirements which exist now or may arise in the future. This includes the reporting of suspicious transaction reports for the prevention of financial crime where deemed necessary by the appropriate officers of Initiative Asset Management, on a mandatory or voluntary basis.
To provide you with products or services, we must create records that contain your information, such as your account records, records of your activity, any lending or borrowing records and any associated electronic or written instruction received. Records can be held on a variety of media (physical or electronic) and formats.
These records are necessary for us to comply with our legal obligations and to deliver our services to you. We retain information in line with our regulatory or legal requirement. Overall we do not look to retain or use personal information other than as we consider necessary to comply with our legal, contractual or regulatory obligations.
Retention periods for records are determined based on the type of records in question. We normally keep customer account records for up to seven years after your relationship with the us ends, whilst other records are retained for shorter periods. Retention periods may be changed from time to time based on business or legal and regulatory requirements.
We may on exception retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that we will be able to produce records as evidence, if they’re needed.
Questions and Complaints
If you have a question or concern about any collection, use, or disclosure of personal information by Initiative Asset Management please write to:
Data Control Officer, Initiative Asset Management, Unit 2 Aspen Court, Old Bray Road, Cornelscourt, Dublin 18, D18 K3T2, Ireland
We hope to address your concerns through our normal complaints process, however, we may escalate your complaint to our Data Protection Officer for further investigation.
You also have the right to complain to the Data Protection Commissioner. You can contact; the Data Protection Commissioner, Canal House, Station Road, Portarlington, County Laois, R32 AP23, Ireland. For more information, visit http://www.dataprotection.ie