Privacy Policy

Numus Privacy and Cookies Policy

This Privacy policy contains twelve sections. The headings below are for reference only and do not limit the scope of each section.

  1. Introduction
  2. Information we may collect from you
  3. Information we may collect about you from other sources
  4. Uses made of your information
  5. Cookies
  6. Information sharing
  7. Marketing
  8. External links
  9. Security
  10. Storage of your information
  11. Data Protection Registration
  12. Privacy related questions or complaints

Introduction

This is the privacy and cookies policy for www.numus.eu (the "Site") and its responsive browser based web application, (the "App"). The Site and the App are operated by Numus P2P Limited trading as "Numus"("we", "us" and "our") (a technical service provider of Prepaid Financial Services Ltd for provision of E-Wallet services).

We are committed to protecting your privacy online. We appreciate that you do not want the personal information you provide to us distributed indiscriminately and here we explain how we collect information, what we do with it and what controls you have. We are not party to any Loan Contracts and do not provide any E-Wallet services and we only act as a service provider in providing services to facilitate such transactions.

By using the Site and our App you consent to the collection and use of information in accordance with this privacy policy without prejudice to our right to otherwise process personal data for purposes permitted or required by law such as where required for the performance of our obligations under our Terms of Service; to comply with applicable law (such as anti-money laundering legislation or compliance with legal orders or requests); for the purpose of our legitimate interests (such as the prevention or investigation of fraud or misuse of our services, the marketing and administration of our services (including identifying trends and improvements to our services)). We also act as a data processor in our provision of services to third parties (e.g. the Collections Agency, Numus Recoveries Limited and Prepaid Financial Services Limited) and any such processing is subject to the instructions of such third parties to the extent applicable.

We reserve the right to change this policy from time to time by changing it on the Site. Any amended terms will take effect 30 days after they are posted. If you continue to use the Site and the App after this time we will take your continued use as acceptance of the new terms. We may also notify you of changes through our communications with you. This privacy and cookies policy was last updated on March 30th , 2017.

Information we may collect from you

We may collect and process the following information about you:

  • information such as your name, date of birth, postal address, email address and telephone number that you provide when completing an application to open a Numus account and access our App;
  • in connection with an account sign-in facility, we collect information for security, verification and identification purposes such as a user name, log-in and password details;
  • details of any payment instructions you execute through the App including payment account details in relation to a transaction instruction;
  • identification documentation for compliance with anti-money laundering legislation;
  • communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Site, the App or our service;
  • whether you have chosen to sign-up for our newsletters;
  • information about your age, gender and interests from information you provide and from information derived from how you use our service;
  • information from surveys that we may, from time to time, run on the Site or App for research purposes, if you choose to respond to, or participate in, them; and

 

You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to provide you with certain services.

When you visit the Site or the App we may automatically collect additional information about you, such as the type of internet browser you use, any website from which you have come to the Site or App and your IP address, (the unique address which identifies your device on the internet) which is automatically recognised by our web server. This information is only used to assist us in providing an effective service on the Site and App and to collect broad demographic information for aggregate use about how visitors to the Site or users of the App interact with our services.

Information we may collect about you from other sources

We may also receive information about you from other sources and add that to the information we hold in relation to your Numus account. In particular, we may collect the following information about you:

  • information relating to the sums held in the E-Wallet for the operation of your Numus account through the App from our designated E-Wallet Provider, including details relating to transactions against value issued in the E-Wallet,
  • demographic information that is publicly available or information from credit or fraud prevention agencies where permitted by law.

Uses made of your information

We will use the information you provide to:

  • identify and verify your access to the App;
  • complying with anti-money laundering legislation;
  • deciding whether to accept your application to set up an account through the Site or App for the purpose of entering into a Loan Contract and to conduct fraud and credit checks in accordance with our own internal policies and guidelines (this is without prejudice (and in addition) to any assessments and checks carried out by any Lender who retains sole responsibility for its decision to lend to any Borrower);
  • operate the App and administer your account with us;
  • administer peer to peer lending for borrowers and lenders including charging Servicing Fees and Borrower Fees in accordance with our Terms of Service;
  • engaging the appointment of a Collections Agency or Numus Recoveries Limited where required in the event of a default on a Loan Contract;
  • create, verify your payment instructions and other requests to the E-Wallet Provider;
  • contact you, where requested, by messaging, email or telephone to provide customer support and investigate any problems with your use of the App;
  • improve the layout and/or content of the pages of the Site or the App;
  • carry out research on our users’ demographics and goals information, to tailor the content of the App and provide more relevant information on products, services and offers available through selected partners;
  • produce aggregated, summary information relating to use of the Site or the App, such as the number of users, numbers of goals set and average savings targets achieved. Individual users will not be identifiable from this information;
  • where you have consented, send you information we think you may find useful or which you have requested from us, including information about our products and services or those of selected third parties;
  • reporting fraudulent or suspected fraudulent activity to the relevant law enforcement authorities; and

 

You can tell us not to contact you with information regarding our products and services or those of third parties, either at the point of application or at the point such information is collected, (by checking or unchecking (as directed) the relevant box) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise the right at any time by using the Contacting us details at the end of this privacy policy.

Cookies

When you interact with our content and services, we try to make that experience simple and meaningful. When you visit our Site or App our web server sends a cookie to your device. Cookies are small pieces of information which are issued to your device when you visit a website and which store and sometimes track information about your visit. A number of cookies we use last only for the duration of your browser session and expire when you close your browser. Other cookies are used to remember you when you return and will last for longer. Some of the cookies used by the Site or App are set by us, and some are set by third parties who are delivering services on our behalf.

 

We use the following types of cookies:

Strictly necessary cookies

We use a session cookie on our Site so that users can move easily from one page to another within the Site and so that page requests are loaded in smooth manner. We also use login-in session cookies for security purposes to authenticate valid users accessing the secure area of the App.

 

Functionality

We use functional cookies that enable the user to operate the Site or App by storing their preferences and selections. In particular we use a cookie to set the correct language in the App for the user.

 

Performance

We use cookies to collect statistical information about how visitors behave on our Site and App so that we can make improvements to our content and services. For example we log what pages in the Site or App are visited and what a user clicks on, as well as remember that a user has visited us before so that we can count the number of unique visitors we receive to different parts of the Site or App. This also allows us to make sure we have enough capacity for the number of users that we get and to customise elements of the promotional layout and/or content. We use Google Analytics cookies for this purpose. You can opt out from Google Analytics tracking at http://tools.google.com/dlpage/gaoptout

 

In addition, tracking Gifs and web beacons working with cookies and may be set by us or third parties in respect of your use of the Site or App. Tracking Gifs are small image files within the content of the Site or App or the body of our electronic newsletters, so we or can understand which parts of the Site or App are visited and whether particular content is of interest.

Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note, however, that by blocking or deleting cookies you may not be able to access all the features of the Site or App.

 

Information sharing

We will disclose your personal information to the E-Wallet provider in order that they can carry out payments, conduct transactions or fulfil your other E-wallet account mandates that you instruct Numus to transmit.

We may provide your personal information to service providers or contractors who assist us in providing the services we offer through the Site or App including in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks, from time to time. Our service providers and contractors will only use your information to the extent necessary to perform their functions and are subject to confidentiality obligations in respect of the processing of such information..

We may also disclose aggregate statistics about visitors to the Site and App in order to describe our services to prospective partners or other reputable third parties and for other lawful purposes, but once again, these statistics will include no personally identifiable information.

In the event that we undergo re-organisation or are sold to a third party, you agree that any personal information we hold about you may be transferred to that re-organised entity or third party.

We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or cybercrime or to protect the Site or App or the rights, property or personal safety of any person.

Marketing 
We and/or our partners will only use the personal information obtained from you to enable us to provide you with information by email, telephone or post regarding products and services that we feel may be of interest to you if you have provided your consent for us to do so by ticking the relevant box(es) on this website where your personal information is collected.
If you wish to withdraw consent to use this information at any time for either us and/or our partners', then you should contact the Information Officer at Numus using the contact details set out below.

External links

The Site or App may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

Security

We place great importance on the security of all personally identifiable information associated with our users and implement appropriate technical and organisational security measures to protect your personal data from unauthorised use, access, disclosure or destruction. Payment instructions will be encrypted using transport layer security (TLS) technology before they are submitted by you to us or from us to the E-Wallet provider. We have security measures in place to attempt to protect against the loss, misuse and alteration of personal information under our control. For example, our security and privacy policies are periodically reviewed and enhanced as necessary and only authorised personnel have access to personal information. Whilst we cannot ensure or guarantee that loss, misuse or alteration of information will never occur, we use all reasonable efforts to prevent it.

Storage of your information

We may store, process and/or transfer the personal information you submit to us through use of the Site to countries outside of the European Economic Area including (without limitation) to the USA. Personal data transferred outside of the EEA will be stored and processed by our group companies or representative offices for business and management purposes, to perform a contractual obligation owed by us to you and/or to provide you with information or services that you have requested. By using this Site, you consent to us transferring your personal information to countries outside the EEA for our legitimate business purposes as outlined in this paragraph. This is without prejudice to any other measures we may have in place in accordance with applicable law to protect your personal data if transferring it outside the EEA.
 

DATA PROTECTION REGISTRATION
Numus P2P Limited has notified the Irish Data Protection Commissioner that it processes personal data and appears on the register of data processor.
 

PRIVACY RELATED QUESTIONS OR COMPLAINTS
If you have any questions relating to this Privacy Policy or how we use your personal information, or if you believe that we have not complied with this Privacy Policy with respect to your personal information, you may write to our Information Officer at PFS, 36 Carnaby Street, W1F 7DR or the Managing Director of Numus P2P Limited 4 Cannon House, Clancy Quay, South Circular Road, Dublin 8, D08 CD99. You should also use this address if you would like to request a copy of your personal information from us or to review or modify any part of your personal information at any time. Any such requests shall be handled in accordance with applicable data protection laws and if permitted, we reserve the right to charge a fee for each copy request.

You may also contact us by sending an email to hi@numus.eu by telephone on +353 (01) 9060471 between the hours of 9am to 5pm, Monday to Friday or by accessing the help section within the App. In your communication please clearly set out your question or request or, if you have a complaint, describe in as much detail as possible the ways in which you believe that our Privacy Policy has not been complied with and we will investigate and provide you with a response.

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