Any reference in this notice to “applicable laws” is a reference to the domestic laws that apply in Ireland, including local data protection law and the European Union’s General Data Protection Regulation.
If you have any questions regarding the processing of your personal data or if you believe your rights have been violated, please contact email@example.com. If you are aware of unauthorised disclosure of data, please also refer this to us for guidance as to the applicable reporting requirements.
What are your Data Protection Rights?
NoFrixion would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access - You have the right to request NoFrixion for copies of your personal data. We may charge you a small fee for this service.
- The right to rectification - You have the right to request that NoFrixion correct any information you believe is inaccurate. You also have the right to request NoFrixion to complete information you believe is incomplete.
- The right to erasure - You have the right to request that NoFrixion erase your personal data, under certain conditions.
- The right to restrict processing - You have the right to request that NoFrixion restrict the processing of your personal data, under certain conditions.
- The right to object to processing - You have the right to object to NoFrixion's processing of your personal data, under certain conditions.
- The right to data portability - You have the right to request that NoFrixion transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
What Personal data do we collect?
There are a number of reasons for gathering personal data about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity and we need to comply with regulatory requirements regarding the provision of services.
Personal Data means any information about an individual from which that individual can be identified. The information you provide to us might include but is not limited to:
- your full name, postal address, email address, phone number, (contact details);
- date of birth;
- marital status and dependents;
- PPS number or equivalent;
- bank account details and copies;
- tax status or tax codes;
- salary, bonus, pension and benefits information;
- copy of passport and driving licence
- copy of proof of address, ex. utility bill;
- answers to surveys and questionnaires;
- company & business details
- financial and transaction information
- information you provide us about others and/or others provide to us about you
- information gathered from publicly available sources
- information you have consented to us to use ex. your contact details and marketing preferences are used to share news about relevant services, products and offers that we think may be of interest to you
- information from online activities
- we collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers and by using our cookie preference centre on our website. For detailed information on the cookies we use and the purposes for which we use them, see our Cookies Policy, which is available on our website.
- we collect information about your internet browser settings and Internet Protocol (IP) address and other relevant information to help us identify your geographic location when providing you with our services.
- sensitive data
- you may provide us with more sensitive information known as Special Category (“Sensitive”) information. This may include details about your racial or ethnic origin, political opinions, religious, philosophical or similar beliefs, trade union membership, genetics, biometrics, health, sexual life, sexual orientation or about criminal offences or proceedings. This type of information will be treated differently, and we will explain why we are collecting it.
- other personal information
- telephone recordings and email communications
- information in relation to requests made by you e.g. data access, correction, restriction, deletion, reporting and complaints
How do we collect your data?
You directly provide NoFrixion with most of the data we collect. We collect data and process data when you:
- Apply to be a NoFrixion customer
- Voluntarily complete a customer form, survey or provide feedback on any of our services
- Use or view our website via your browser's cookies
- When you use our products or services, including making transactions on your account, or instructing a third-party payment service provider to initiate payments on your account, we gather details about who you get money from, who you pay money to, how much the payments are for and when the payments are made.
- Apply for employment
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. All cookies apart from strictly necessary cookies will require your consent.
Third parties or publicly available sources
We may receive personal data about you from various third parties such as;
- Public registers including company registration or beneficial ownership registers,
- Information providers who facilitate customer screening including financial sanctions, politically - exposed persons and adverse media
- Other open sources of information such as social media sites
How will we use your data?
NoFrixion gathers your data for the following purposes:
- To establish your eligibility for our products and services
- To process your applications for products and services
- To manage and administer your accounts
- To process payments that are paid to you or by you
- To comply with our legal and regulatory obligations
- To contact you by post, phone, text message, email, digital message, using our website or other means, but not in a way contrary to your instructions to us
- To monitor and record our conversations when we communicate (for example, to check your instructions to us, to analyse, to assess and improve customer service; for training and quality purposes; and for verification, fraud analysis and prevention purposes).
- To protect our business, reputation, resources, and equipment, manage network and information security (for example, developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services) and prevent and detect fraud, dishonesty and other crimes.
- To manage and respond to a complaint or appeal
How is your data stored?
We use appropriate technical and organisational security measures to protect the security of your personal data both online and offline including the implementation of encryption, access controls, implementation of firewalls, network intrusion detection and use of anti-virus software. Please note that no system is completely secure. So, while we strive to protect your data, we cannot guarantee that unauthorised access, hacking, data loss or a data breach will never occur.
For what purpose do we gather Data?
We will only use your personal data where the law allows us to. Most commonly we will use data in the following situations;
a. To enter into and perform a contract with you
In order to provide customers with electronic money, payment or virtual asset services, we are legally obligated to gather and process your information prior to entering a business relationship with you.
b. To comply with our legal obligations
As NoFrixion is authorised and supervised by the Central Bank of Ireland, we are required to process your personal information to comply with certain legal and regulatory obligations to which we are subject.
c. For our legitimate business interests
We may use your personal information for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.
d. With your consent
We will request your consent for the use of all cookies on our websites outside of strictly necessary. You can withdraw this consent at any time by clicking “cookie settings” at the bottom of our webpage.
Generally, we do not rely on consent as a legal basis for processing of personal data although we will request consent before sending you third party direct marketing communications, passing on your personal information to a third party for marketing purposes or before sending digital marketing to you if you are not an existing customer. You can revoke your consent at any time by contacting firstname.lastname@example.org.
Who do we share information with?
Third Party Service Providers:
NoFrixion discloses Personal Data to third parties in certain instances. For example, NoFrixion uses third parties for the purposes of providing some of its payment and electronic money services, customer screening and identity verification.
These service providers are subject to a contractual obligation to only process Personal Data obtained from NoFrixion for purposes for which it was obtained and in accordance with our instructions.
In certain circumstances NoFrixion will disclose personal data to other external third parties such as its professional advisors as necessary in the context of the performance of their services. Such recipients may include external legal advisors, auditors, actuaries, pension and tax advisors, pension administrators and other professional advisors.
Disclosure of such data will take place for a variety of reasons including in order to ensure that NoFrixion meets its statutory obligations.
Potential Sale or Merger: If we sell any part of our business and/or integrate it with another organisation, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs, the new owners of the business will only be permitted to use your information in the same or similar way as set out in this data protection statement.
Central Bank of Ireland, Garda Síochána, Government or Quasi-Government Bodies, Courts and Tribunals: We may share your personal information with these organisations and bodies, where required to do so by our legal and regulatory obligations.
Transfers outside the EEA
Where the laws of such countries do not afford an equivalent level of protection of personal information as the laws of Ireland, we will take specific steps in accordance with data protection law to protect your personal information.
We will use one of these safeguards:
- Transfer to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract (in a form that is approved by the European Commission) with the recipient of the personal information that means they must protect it to the same standards as the EEA.
- Transfers to organisations that are part of an EU Framework that sets privacy standards for data sent between countries. These frameworks make sure those standards are similar to what is used within the EEA.
How long will we keep your Personal Data?
In general terms, NoFrixion shall adhere to the GDPR requirement to process personal data for no longer than is necessary for the purpose for which it was collected in the first place.
For data which is gathered for the purposes of providing electronic money services, payment services or virtual asset services NoFrixion will retain records in accordance with our obligations under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended). In this regard, NoFrixion will retain data for a period of not less than five years after the end of the customer relationship.
NoFrixion would like to send you information about products and services of ours that we think may be of interest. If you have agreed to receive marketing, you may always opt out at a later date. You have the right at any time to stop NoFrixion from contacting you for marketing purposes.
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
For further information, visit allaboutcookies.org.
- Keeping you signed in
- Understanding how you use our website
What types of cookies do we use?
There are a number of different types of cookies, however, our website uses:
- Functionality - NoFrixion uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
- Advertising - NoFrixion uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address.
How to manage cookies?
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
Changes to our Policy
Email us at: email@example.com
Or write to us:\
8 Harcourt Street,
How to Contact the Data Protection Commissioner
Should you wish to report a complaint or if you feel that NoFrixion has not addressed your concern in a satisfactory manner, you may contact the Data Protection Commissioner at: