Privacy Policy

Privacy Policy

In this Privacy Policy we explain how “Initiative Ireland” respects your privacy in relation to interactions with this website and the services we provide. When we refer to “Initiative Ireland”, “we”, “us” or “our” in this Policy, we are referring to Initiative Financial Services Limited, its subsidiaries, affiliates and their respective parent and subsidiary companies.

This website and our services are not directed at children, and we do not knowingly collect personal data from children in connection with the services described on this website.

Collection and Use of Information

We collect personal data about you as a user, client, prospective client, funding partner, prospective funding partner, introducer, adviser, service provider or other relevant contact, and data relating to your interactions with us online, by phone, by email and through our websites.

We will only collect and use personal data where we have a lawful basis for doing so and where such collection and use is necessary for legitimate business purposes, for the performance of a contract, to take steps at your request prior to entering into a contract, to comply with legal or regulatory obligations, or otherwise with your consent where required.

Where you enquire about, apply for or use our services, personal information may be gathered to enable us to provide services to you. This may include information relating to individuals and entities, including names, addresses, contact details, dates of birth, nationality, identification documents, bank documents, PPS numbers, tax information, company ownership information, financial information and other information relevant to the provision of our services.

We may also collect information from third parties where appropriate, including agents appointed by us or by you, solicitors, valuers, quantity surveyors, professional advisers, credit reference agencies, fraud prevention agencies, public bodies, regulatory authorities and other service providers relevant to the services being provided.

We may also collect information from public sources, including company registries, court judgments, press reports and other publicly available materials where relevant to our services, legal obligations or legitimate interests.

During our relationship with you, we may monitor and collect information relating to your payment activity, communications with us, your use of and access to our systems, and your use of our websites, including through cookies and similar technologies.

This information may be shared with third-party service providers where reasonably necessary to facilitate our services, operate our business, comply with legal or regulatory obligations, or protect our legitimate interests, and subject to appropriate confidentiality and data protection safeguards.

We will seek to make clear how we intend to use your information before or at the time of collection, so that you can decide whether or not you wish to provide that information.

When you browse our website, our web servers and service providers may collect data relating to your visit, such as:

1. the pages you have viewed;
2. certain interactions you have had on those pages;
3. the number of times you have visited a particular page; and
4. the amount of time spent on certain pages.

In some cases the data we collect will be anonymous and will simply tell us which pages receive the most activity and are of most interest to users generally. Where you set up an account with us or otherwise identify yourself to us, we may be able to associate particular page visits and interactions with your account or profile.

We may use analytics and similar tools to help us understand how users interact with our websites and services and to improve the overall user experience. In all cases, we will seek to carry out such activity in a responsible manner and in accordance with applicable data protection law.

Information will be stored and used in compliance with applicable data protection laws in Ireland.

Examples of Personal Information

Personal data means any information relating to an identified or identifiable natural person. Initiative Ireland may process the following types of personal data, depending on the nature of your interaction with us:

• name, address, email address, telephone number and other contact information;
• Personal Public Service Number (PPSN) or Tax Reference Number (TRN), where relevant;
• date and place of birth;
• nationality;
• employment details;
• copies of identity documents, such as passport, national identity card, driving licence or employee identification;
• copies of utility bills or bank statements;
• financial information, including company ownership information where relevant;
• statements regarding your experience, education or professional background;
• visual images and personal appearance, including copies of identity documents and CCTV images where applicable;
• online profile, login and social media information, and information relating to your interaction with our websites and applications, including IP address, device information, approximate location data, mobile network information, searches and site visits; and
• where relevant, health or medical information, but only to the extent required by law, contract, accessibility needs or with your consent.

If we have a lawful basis to do so, and where necessary to prevent crime, money laundering, terrorist financing or other fraudulent activity, we may also process information relating to criminal convictions and alleged offences.

Where you have provided consent for us to process special category personal data, such as health or medical information, you may withdraw that consent at any time by contacting us. This will not affect the lawfulness of processing carried out before that withdrawal.

Please note that the above list is not exhaustive and that Initiative Ireland may also collect and process personal data where this is useful or necessary for the provision of our services, the operation of our business, compliance with law or regulation, or with your consent.

Interactive Areas

Our website may from time to time offer chat options or other interactive areas which allow you to communicate directly with Initiative Ireland staff while browsing online. These services are optional and you can decide whether or not you wish to use them.

When using chat functions or other interactive areas, including discussion forums, bulletin boards or blogs, you should do so responsibly. You should not provide account details, usernames, passwords, or sensitive personal or financial information through these services unless specifically requested through a secure and appropriate channel.

You may choose to provide us with information such as your name and contact details if you would like us to contact you directly. If you do so, we will use that information solely to respond to and deal with your comments or queries, unless another lawful basis applies.

Where you provide an email address in connection with our services, we may use that email address to provide service-related notices, updates and communications relevant to your relationship with us. Where marketing communications are sent, these will be sent only where we are legally permitted to do so, and you may opt out where applicable.

Cookies and Similar Technologies

We use cookies and similar technologies in connection with our website and online services. For information on how we use cookies and similar technologies, including how consent is obtained and managed, please see our separate Cookie Notice.

How We Keep Your Information Safe

We appreciate the importance of keeping your information secure. To protect your information, we use technical and organisational security measures that are designed to comply with applicable Irish and EU law and that reflect recognised industry standards. These measures include computer safeguards, access controls, secure systems, secure premises and appropriate procedures for handling personal data.

In limited cases, and only where reasonably necessary for the provision of our services or in connection with a client’s investment in, or fundraising from, organisations outside the European Economic Area, personal data may be transferred outside the EEA. Where this occurs, we will take appropriate steps to ensure that the data is protected in accordance with applicable data protection law, including by relying on appropriate safeguards where required.

While we take reasonable steps to protect personal data, no method of transmission over the internet and no electronic storage system is completely secure. We therefore cannot guarantee absolute security.

Your Rights

Subject to applicable law, you may have the right to request access to personal data we hold about you, to request correction of inaccurate personal data, to request erasure of personal data, to request restriction of processing, to object to certain processing, and to request portability of personal data where applicable.

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

You also have the right to lodge a complaint with the Data Protection Commission.

Subject Access Requests

If you wish to request a copy of the personal information we hold about you, please write to the Data Control Officer, Initiative Ireland, 13 Adelaide Road, Dublin 2, D02 P950, Ireland, or email Team@initiativeIreland.ie with the subject line “Subject Access Request”.

Your request should be sufficiently clear for us to understand the information sought, and we must be able to verify the identity of the requester before responding. Please therefore be as specific as possible in relation to the personal data you wish to access.

We will respond to your request without undue delay and in any event within one month of receipt of the request, subject to any extension permitted by applicable law.

If your information changes, or you believe we hold information about you which is inaccurate or out of date, please let us know and we will seek to correct it where appropriate.

Security

We take reasonable steps to prevent the loss, misuse, unauthorised disclosure, alteration or destruction of personal information, and to prevent unauthorised access to personal information.

Where personal information is no longer required, we use appropriate methods to destroy or delete it securely, including shredding paper records and permanently deleting electronic records where appropriate.

If you hold an account with us, account information may be protected by a password. You are responsible for protecting against unauthorised access to your password and device, including by logging off after use on a shared device.

We rely on individuals to notify us where personal information changes. If you believe that information we hold about you is inaccurate, please let us know and we will seek to correct it where appropriate. In some cases, we may ask you to make your request in writing.

Conditions of Use

This Privacy Policy is subject to the Terms and Conditions of Use of the Initiative Ireland website.

It is important that you read those Terms and Conditions of Use, as where there is a conflict between this Privacy Policy and the Terms and Conditions of Use, the Terms and Conditions of Use shall prevail to the extent permitted by law.

By accessing and continuing to use this website, you acknowledge and agree that your personal data may be processed in the manner described in this Policy. You also acknowledge that in certain circumstances we may be obliged to disclose personal information to third parties in order to prevent, detect or investigate fraud, money laundering or other unlawful activity, or to comply with legal or regulatory obligations.

Use of Information

Information provided to Initiative Ireland will be managed in a manner compliant with applicable data protection law in 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. We process personal data where:

• you have given consent to the processing of your personal data for one or more specific purposes;
• processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
• processing is necessary for compliance with a legal or regulatory obligation to which we are subject; or
• processing is necessary for the purposes of legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.

We may sometimes collect special categories of personal data for the purpose of complying with legal obligations, detecting and preventing financial crime, making our services accessible to you, or where you have explicitly consented and we are otherwise lawfully permitted to do so.

In addition to the general uses of information described above, you should note the following:

Clients and prospective clients:

We may process personal and related business information provided in connection with enquiries, advisory mandates, capital raising activities, funding applications, onboarding, due diligence, transaction execution, compliance, and ongoing relationship management.

Funding partners and prospective funding partners:

We may process personal and related business information in connection with funding opportunities, investment activity, due diligence, transaction administration, compliance, and ongoing relationship management.

Initiative Ireland does not publicly identify funding partners in relation to individual transactions unless required to do so by law, regulation, contract, court order, or with the relevant consent.

Historic relationships and records:

Where required for legal, regulatory, compliance, anti-money laundering, financial crime prevention, tax, accounting, audit, or record-keeping purposes, we may retain information relating to historic clients, historic funding partners, and historic private lenders, including associated personal information, for the applicable retention period.

All users and contacts:

Information collected by Initiative Ireland may be disclosed to third-party service providers, professional advisers, compliance providers, and other counterparties where reasonably necessary to provide our services, administer transactions, meet legal or regulatory obligations, or protect our legitimate interests.

Users who knowingly provide false information may be subject to legal or criminal proceedings and may have their access to our services or systems restricted or withdrawn.

Data Retention

To provide products or services, we create and maintain records that contain your information, including records relating to enquiries, advisory mandates, capital raising activities, funding relationships, transaction records, compliance records, and associated electronic or written communications and instructions. Records may be held in physical or electronic form.

These records are necessary for us to comply with legal, contractual, regulatory, tax, accounting, anti-money laundering, and record-keeping obligations and to deliver our services.

We retain personal data only for as long as necessary for the purposes for which it was collected and to comply with applicable obligations. In general, where relevant to a client or funding partner relationship, and including historic private lender information where applicable, we retain core records for up to seven years after the end of the relationship, unless a longer or shorter period is required by law or is justified by the nature of the records concerned.

In exceptional cases, we may retain information for longer periods where required by law, court order, regulatory direction, or in connection with actual or anticipated investigations, disputes, or proceedings.

Questions and Complaints

If you have a question or concern about the collection, use or disclosure of personal information by Initiative Ireland, please write to:

Data Control Officer
Initiative Ireland
13 Adelaide Road
Dublin 2
D02 P950
Ireland

We hope to address your concerns through our normal complaints process. Where appropriate, your complaint may be escalated internally for further review.

You also have the right to lodge a complaint with the Data Protection Commission.

General Notice

We only collect and use personal data where we have legitimate business reasons and where we are legally entitled to do so. We may collect and process information you provide to us directly or information gathered via our websites, systems and other interactions with us, including through cookies and similar technologies.

Information gathered about you may be used in order to deliver our services, administer our business, comply with law and regulation, improve our website and user experience, and protect our legal and commercial interests.

All information you provide to us is stored using appropriate safeguards. Where we have given you, or where you have chosen, a password that enables you to access certain parts of a website or system, you are responsible for keeping that password confidential and for not sharing it with anyone else.

If you wish to obtain copies of your personal information, or to request correction of inaccurate information, please contact us using the contact details set out above. We may require sufficient identifying information from you in order to process your request.