Privacy policy
Privacy Notice
KAKMA Financial Ltd (hereinafter ‘KFL’) are an Irish company that operate as intermediary to gather and process customers personal information. KFL is a registered company at the address: 44 Lower Salthill Road, Galway, H91 KWY9. The company registration number 622519. KFL upholds standards of how this information is handled and processed in accord with this privacy notice which complies with the relevant law- General Data Protection Regulation (GDPR- EU 2016/679) and European Communities (Electronic Communictions Networks and Services) (Privacy and Electronic Communications) 2019. The privacy notice will provide customers with the knowledge of their rights and obligations, and how KFL will utilise information provided by them.
Data Protection Officer
In accordance with the GDPR, KFL are registered with the Data Protection Commissioner’s office, under the registration number 15587/B. The company has assigned the position of Data Protection Officer to Kieran Bowden, who can be contacted in written form to the company’s registered address, by emailing kieranfinance@outlook.com or by calling +353 (0)87 255 9548. Our Data Protection Officer oversees how KFL collects, uses and protects the personal information provided by customers, and ensures their rights are upheld in accordance to current law.
Information Collected
KFL will collect and process information to allow us to carry out our professional obligations and legal responsibilities to deliver our products and services to the best of our abilities. KFL will never ask for personal information that is not necessary to carry out our function and will never use the information other that the way it is stipulated in this notice. The type of information collected will include, but will not be exclusive to; name, date of birth, contact information, family status, employment information and relevant bank details.
KFL will retain personal information for the necessary time to carry out our service for clients. As clients’ needs vary so will this time period depending on circumstances. The period of holding this information will be compliant with the conduct outlined by the Central Bank of Ireland and outstanding legal regulations and Anti-Money Laundering obligations.
Furthermore, under the Consumer Protection Code 2012, KFL are required to retain customer data for 6 years on completion of the financial application, unless required by law to hold for an extended period. Under such circumstances the length of time the data will be held will be decided by law.
Customers are not obligated to provide personal information. However, failing to provide KFL with relevant personal information will prevent the firm’s ability to provide financial services. KFL will inform customers when personal data is necessary for a contractual requirement or to fulfil a legal obligation.
KFL withholds the right when verifying the identity of a person at the application process to access and use information provided by fraud agencies within the Republic of Ireland. This information may include criminal convictions and any outstanding allegations.
Special Category Data- All successful applicants, as part of the process of signing the finance contract, will undergo advanced technical checks on the proof of identity documents provided. There are 12 technical checks in total. KFL will seek consent prior to running a facial match check, matching the facial image of the passport or driver’s license image provided.
Method of Collecting Data
Customers shall provide their personal information by completing forms provided, or by communicating through by email, telephone, fax or other means. It is the obligation in respect of any information that is provided that does not relate to you, that the person to whom the information is regarding will be provided with a copy of this Privacy Notice and will be made aware and has consented to disclose such information.
Relevant financial information may be provided to KFL by professional advisors, accountants etc if applicable. KFL will only carry this out when assessing and preparing applications with consent. Information taken from these sources may include financial status and possible outstanding loans.
KFL may receive information from other intermediaries, such as dealers and introducers, which will include details proportionate to personal, contact, asset and financial details with the function of preparing an application for the suitable lender.
KFL may obtain information available on public databases which may include, but is not restricted to, the Companies Registration Office, electoral registry and information open in the public domain.
How the Firm Uses Personal Data
KFL upholds a strict privacy policy and will never disclose information regarding their customers with expressed consent, except when compelled to by law.
The reasons for collecting, processing and storing personal data are outlined as follows (although this is not an exhaustive and will be reviewed to reflect business as required):
- Provide relevant services and products under terms agreed;
- Fulfil the legal obligations for business accounting and tax purposes;
- Identify personalized services and products and ways we can improve our services;
- To meet our legal and regulatory obligations;
- To offer a broker service and safeguard that any financial applications are finalized to the specifications and terms of the lender;
- To aid past, future and prospective clients and answer queries;
- Inform clients of other relevant information on that which they have already agreed;
- To act as a line of communication between appropriate parties and systems to advance a legitimate sale;
- To contact present or prospective customers through post, email or telephone regarding their accounts;
- If a third party requires KFL personal data held by the firm, then it will be disclosed to the third-party buyer.
Personal Information Rights
You have the right to any information that you have provided to KFL which may involve; the personal data that KFL holds, the purposes of storing that information, the recipients of that personal data that will/has been disclosed to, the length of time the information will be retained and what other source we may have received data.
At any point with data provided you have the right to receive such information you have provided to KFL back in a structured and commonly used, electronic format
If at any point you believe information is inaccurate or needs to be altered, you may notify KFL and we will update or alter relevant information promptly.
Your ‘Right to Portability’, gives you the right to move information and where possible, KFL can share a copy of information directly with you or another organisation with your consent.
You withhold the right to restrict or remove consent from KFL to use your information. The withdrawal of your consent will not invalidate any processing carried out prior to the consent being removed.
At any point you have ‘Right to be Forgotten’ and may ask KFL to delete your personal information.
If you contact KFL to exercise any of the rights listed, we may ask you to verify your identity before acting on any request. This is to ensure appropriate data protection for all past, future and prospective customers.
In the event that a lender bases the decision of your application solely on an automated decision making process, you will have the right to have a member of KFL review such a decision so that it may be contested and have your perspective and circumstances put forward.
Disclosing and Sharing Data
Any personal data that you have provided to KFL will not be disclosed or shared without your consent, except where this notice has specified or there is a legal requirement. KFL utilises third parties to carry out services as laid out in the Terms of Business. Any third parties provided with data will only process that data in accordance to instructions from KFL and will fully comply with this Privacy Notice. All our third parties are located in Ireland, unless expressed otherwise.
Third parties which may be used by KFL to carry out its services include:
-Accountants and bookkeepers will be provided with your personal data for tax purposes. This information includes invoices and your name for the purpose of completing our end of year accounts.
-Insurance companies may require us to share your personal data for insurance or legal reasons. This will include supplying personal data under the requirements of our contract with our insurance company in relation to a claim we make or receive.
-Lenders and Brokers will be provided will your data in order for KFL to carry out our services, depending on the finance being sought and the asset looking to be financed. Lenders may forward your application to the Irish Credit Bureau (ICB) in order to carry out a credit check. Under GDPR Article 6(f) the ICB hold ‘Legitimate Interests’ to process your personal data. ICB are fully compliant with legal regulations and obligations mentioned in this Privacy Notice and should you wish to see the process by which they use your data you may refer to ICB’s Fair Processing Notice. Some lenders may use a system of profiling or automated decision making in processing finance applications. In compliance with the Credit Reporting Act 2013 lenders are required to provide personal data and credit information for application and agreements for €500 and above to the Central Credit Register. This information may be utilised by other lenders when making decisions. The Central Credit Register is maintained and operated by the Central Bank of Ireland and for more information please see their website: www.centralbank.ie
-Dealerships that a vehicle is being purchased from, may be provided your data under such circumstances as when you finance application has been approved. This is necessary for the dealer to be able to provide the lender with an invoice, which will be used in formulating finance documents. KFL ensures that all deals that are used are fully compliant with all relevant legal obligations and requirements as laid out in this Privacy Notice. Car dealerships are located in Ireland, but commercial dealerships may be located in the UK and within the EU.
-Due to the nature of the business KFL carries out paper sources of confidential information may be received by the firm. Confidential information received in electronic forms are only printed when essential. When the paper form of the information is no longer required, KFL will utilise the services of a secure and confidential waste disposal service that will ensure the information is disposed of securely and environmentally.
Complaints Process
In the event you have a complaint regarding the use of your personal information, please inform a member of KFL. Or if you wish you make a complaint you hold the right to lodge a complaint with the Data Protection Commissioner’s Office.
To contact KFL please see:
KAKMA Financial Ltd, Kieran Bowden,
44 Lower Salthill Road, Galway, H91 KWY9.
+353 (0)87 255 9548
To contact the Data Protection Commissioner please see:
Data Protection Commissioner,
Canal House, Station Road, Portalarington, Co. Laois, R32 AP23.
+353 (0)57 868 4800
Sale of Business
KFL reserve the right to transfer information, including your personal data in the event of a sale, merger, liquidation, receivership or transfer or substantially all of the assets of KFL. This will be providing that the third party adheres to legal regulations and obligations, and this Privacy Notice. KFL will ensure that the third party will only use your personal data for the purposes that you provided to us. In such an event you will be duly notified and provided will the opportunity to withdraw such personal data.
Updates to this Notice
Updates or changes to this Privacy Notice may occur from time to time to allow KFL to keep up to date will current technologies, services and products. Any such changes will be made available on the Privacy Notice on the KFL website: www.kakmafinanciallimited.com
This statement was updated 13/08/2020