Personal data is any or all data relating to a natural person who is identified, or can be identified, from the data.
Johnson Kenny & Co. Limited, T/A YourMoneyBack (“we”, “our”, “us”) is the data controller and is fully committed to ensuring that your privacy is protected. We understand that how your personal data is used and shared online matters to you, and we take the privacy of those who visit our website, https://yourmoneyback.ie, (“the site”) very seriously.
Our site may contain links to other sites, so be aware that if you choose to click on those links, your data may be processed by other organisations hosting those sites. We cannot control or monitor this, and you should have regard to their privacy policies.
YourMoneyBack may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy was updated on the 2nd October 2019.
Who we are:
- The site is owned and operated by Johnson Kenny & Co. Limited, Trading as YourMoneyBack with an address of Kilberry, Athy, Co. Kildare, R14 YK53.
- Our company registration number is 598617 and our VAT number is 3460025OH.
- Our email address is email@example.com and our telephone number is 045-241 943.
- We are regulated by Chartered Accountants Ireland & The Association of Chartered Certified Accountants.
What data do we collect:
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes information about you that you give us whether by filling in our online registration form on our website, by completing our manual registration form, from information that you give to us whether verbally or in writing when you ask for our service, or by correspondence with us by phone, post, social media or email. Identity data also includes Identity and Contact Information such as name, address, email address, phone number(s), PPS number or foreign equivalent, date of birth, nationality, marital status, family details, copies of ID and online identities such as Facebook, Instagram and Twitter.
Marital Status and / or Financial Associations Data includes if you are married or financially linked to another person in the context of a particular service, a financial association may be created between your records and their records, including any previous and subsequent names by you. This means that we may treat your financial affairs as affecting each other. These links will remain on your file and their files until you or they break that link or you request us to break that link.
Contact Data includes billing address, delivery address, email address(s) and telephone number(s).
Financial Data includes bank account details, credit/debit card details, income details including P60’s and / or P45’s, Department of Employment Affairs and Social Protection income statements, application processing and administration records, employment status of you and your partner, life assurance, pension and investment details, transaction details, financial needs / attitudes, information relation to power of attorney arrangements.
Transaction Data includes details about payments to and from you and other details of services you have purchased from us, and details about who you get money from, who you pay money to, how much the payments are for and when the payments are made.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website.
Usage Data includes information about how you use our website and services or if you make a complaint about our services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Special Categories of Personal Data which we may henceforth collect and process certain personal data in this category, such as health information, where for example you apply for health expenses tax credit, or investment products. Where personal data we collect from you is within article 9 of the GDPR, we will only process this personal data, where you have given your explicit consent.
Information you provide to us about others which you give us information about someone else (for example, information about a spouse provided to us during the course of or related to a joint assessment with that person), we may add it to any personal information we already hold and we will use it in the ways described in this privacy notice. Before you disclose information to us about another person, you should be sure that you have their agreement to do so. You should also ensure they read and accept this privacy notice. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this privacy notice. Accordingly, in providing us with the personal data of a third party, you warrant and undertake to us that you have the consent of the third party to process their information including giving it to us for the purposes provided in this notice. You undertake to immediately notify us if that third party withdraws their consent.
Information about you provided by others which someone gives us personal data about you, for example, where another person provides your information to us during the course of a joint application or taking another example, where you are named in a pension policy application, we may add it to any personal data we already hold and use it in the ways described in this privacy notice.
Information we obtain about you from public forums or that is otherwise publicly available about you – for example in trade directories, online forums, website, Facebook, Twitter, YouTube or other social media. When you make information about yourself publicly available on your social media accounts or where you choose to make information available to us through your social media account, and where it is appropriate for us to use it, this information can help enable us to:
a) improve our service (for example, identifying common service issues)
b) contact you through the social media services, and
c) enable you to share your experience and content via social media services.
Information from your online activities with third parties where you have given us your consent (for example, by consenting to our use of certain cookies or other location tracking technologies).
Information from fraud prevention agencies or public agencies such as property registration authorities, the Companies Registration Office or judgement registries.
Information which you have consented to us using. For example, if we have your agreement to allow us to contact you through certain channels to offer you relevant services.
How is your personal data collected:
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Marital Status and/or Financial Associations and Special Categories of Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: – apply for our services; – request marketing information or data to be sent to you; – enter a competition, promotion or complete a survey; or – give us some feedback.
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
Third parties or publicly available sources. We may receive personal data about you from various third parties, and/or public sources as set out below: – Technical Data from the following parties: i. analytics providers such as Google and Facebook based outside the EU; and ii. advertising networks such as Google Ads based outside the EU; – Identity and Contact Data from publicly available sources such as the Companies Registration Office inside the EU.
How your information is used:
We will process and store your data securely, and we will only keep it for as long as we need it for the purposes(s) for which it was collected.
We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
- To register you as a new client,
- To process your tax refund or Income Tax returns,
- To prepare returns to regulators and relevant authorities including capital gains tax, capital acquisition tax, relevant contracts tax and other revenue returns,
- To carry out Companies Registration Office searches,
- To process payments that are paid to us, for you or by you,
- To contact you by email, post, phone, text message, social media, newsletters, or other means, but not in a way contrary to your instructions to us or contrary to law,
- To monitor conversations when we speak on the telephone to ensure that we check your instructions and to improve our customer service,
- To recover fees you may owe us,
- To manage and respond to a complaint or appeal,
- To protect our business, reputation, resources and equipment, mange network and information security,
- To prevent and detect fraud, dishonesty and other crimes such as identify theft,
- To comply with our legal and regulatory obligations,
- To comply with your information rights,
- To comply with binding requests from regulatory bodies,
- To comply with binding search warrants and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies,
- To comply with court orders arising from criminal or civil proceedings,
- To provide you with statutory and regulatory information and statements,
- To establish your identity, residence and tax status in order to comply with law and regulation concerning taxation and the prevention of money laundering, fraud and terrorist financing.
If there are changes to your personal information regarding contact details, please get in contact via email at firstname.lastname@example.org or by phone at 045-241 943 so that we can update our records.
You have the right to withdraw your consent to our use of your personal data at any time, and to request that we delete it.
Disclosure of your personal data:
We may have to share your personal data with external third parties: External Third Parties – Service providers (acting as processors) based in Ireland who provide IT and system administration services. – Professional advisers (acting as processors or joint controllers) including lawyers, bankers, auditors and insurers based in Ireland who provide consultancy, banking, legal, insurance and accounting services. – Revenue Commissioners, regulators and other authorities (acting as processors or joint controllers) based in Ireland, who require reporting of processing activities in certain circumstances.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. If for example, you require a bank transfer to an account held outside the EEA. Those external organisations may process and store your personal information abroad and may disclose it to foreign authorities to help them in their fight against crime and terrorism.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. As a general rule, we keep your information for a specified period after the date on which a transaction has completed or you cease to be a customer. In most cases this period is six (6) years. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. More particularly, the length of time we hold your data depends on many factors, such as regulatory rules. Those factors include:
- The regulatory rules contained in laws and regulations or set by authorities like the Revenue Commissioners.
- The type of service that we have provided to you
- Whether you and us are in a legal or some other type of dispute with another person or each other.
- The type of data we hold about you.
- Whether you or a regulatory authority asks us to keep it for a valid reason.
You have certain rights as a data subject under the General Data Protection Regulation (GDPR), which governs the collection, processing and disposal of personal data by organisations such as ours.
In relation to personal data about you, you have the right:
- to be informed about how and why we collect and use the data
- to be informed about who may receive your data, where it may be transferred and how long it will normally be retained
- to be given access to the data we hold
- to have any inaccurate or incomplete data rectified
- to ask us to delete personal data earlier than we might already dispose of it
- to prevent us from processing the data further
- to object to us using the data for particular purposes.
No fee usually required – You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you – We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond – We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you wish to exercise any of the rights set out above, please contact us at email@example.com or using any of the other contact details provided above.
If you are not satisfied with the way we deal with this issue, you have the right to lodge a complaint with the Data Protection Commission, which is the body in charge of supervising personal data use in Ireland. Their details are as follows:
You have a right to:
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy;
- where our use of the data is unlawful, but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;
- you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.