Privacy Statement for Online Media and Mobile Banking.

Introduction
In this Privacy Statement we explain how Woohoo Pay (WP) deals with information which we collect about you or you provide to us while visiting our website, using the WP Mobile Banking App or when communicating with us through any of our social media or other interactive channels (collectively “WP Online Services”). We are committed to protecting your privacy and to ensuring that your personal information is treated in a fair, secure and lawful manner in any dealings with us.

Information we collect and use
We collect two types of information from you when you use WP Online Services:

1. “Personal Information”: This is information that identifies you or can be used to identify you directly or indirectly and may include your name, postal address, email address, telephone number, date of birth, location data or online identifiers such as your IP address.

When we collect Personal Information from you, we will let you know how we intend to use this information by sharing with you a copy of our Data Protection Notice. Our Data Protection Notice explains the terms on which your Personal Information will be collected and used by us or by a trusted third party on our instruction and the rights you are legally entitled to avail of. Our Data Protection Notice is reviewed and regularly updated by us and the most recent version is made available online at www.woohoobank.com.

2. “Non-Personal Information”: Like most online banking platforms, WP gathers statistical and other analytical information collected on an aggregate basis concerning visitors to our WP Online Services platforms.

This information cannot be used to identify or contact you, for example demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of WP Online Services. WP collects this information to help us monitor online traffic and manage the performance, efficiency and capacity of WP Online Services. This information also helps us understand what parts of WP Online Services are effective/ popular and what parts are not being fully utilized. This technical data may be used for administrative and statistical purposes and may be shared with our internet service provider.

Downloading and using the WB Mobile Banking App
In order to download and use our WP Mobile Banking App, you are required to register and activate the service. We will process your Personal Information during this registration and activation stage and we will transmit an activation code to the mobile number or email address provided by you for this purpose.

WP will require access to the camera on your digital device for specific purposes, for example, to allow you to photograph and upload your proof of ID and proof of address documentation and to use our IBAN scanner functionality. We will not access your camera without your knowledge or permission and will only access it for the purposes notified to you.

Touch ID
If you have a mobile device with fingerprint recognition functionality (e.g. using your fingerprint to access your device), you will be able to access the WP Mobile Banking App using this functionality however you will require your Mobile PIN to authorize transactions. If your mobile device does not have fingerprint recognition functionality you will be automatically logged into the WP Mobile Banking App once you have entered your mobile PIN.

Where you are using fingerprint recognition functionality, we do not accept any liability for loss arising in connection with the use of biometric data to access WP Online Services. For the avoidance of doubt, we do not retain or store any biometric data.

For the purposes of this Privacy Statement, ‘biometric data’ means personal data resulting from specific technical processing relating to the physical, physiological or behavioral characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images.

WP Live Chat service
Live Chat is a form of real-time online communication between you and one of our representatives. For your own security, you should never disclose account information or Personal Information when using the Live Chat service and our representatives will never ask for this information during a Live Chat interaction with you. If Personal Information is disclosed by you when accessing the Live Chat service, some Personal Information will be retained for a period of 13 months.

Any Personal Information disclosed by you when accessing the Live Chat service will only be used to contact you and will not be used for any other administrative, statistical or any other purposes.

WP Mobile Banking App and ‘Push’ notifications
A ‘Push’ notification is a message from an app which pops up on your device. You may receive ‘Push’ notifications from us about our services, offers and product information. When you download or update the WP Mobile Banking App, you will be asked to give your consent to enable location and notification services. You can choose at any time to switch off these services on your device.  

Social media and third party websites
If you choose to access an official WP social media page, your social media profile may also be made available to us. The Personal Information made available is determined by how you set your privacy settings on your social media profile. You should therefore familiarize yourself with the privacy statement of social networks if you choose to access WP Online Services through a social network channel.

In addition, some of the pages on WP Online Services contain hypertext links to websites not maintained by WP. Different terms and conditions of use will apply to you as a user of these websites. In addition these websites may not attain the same privacy standards that WP maintains.

Security
We use internal technical and organizational measures to protect your information from unauthorized access, to maintain data accuracy and to help ensure the appropriate use of your Personal Information by WP.

Further information regarding the security measures applied by WP is contained in the Data Protection Notice and the WB Terms and Conditions. Even so, data transmission over the Internet cannot be guaranteed to be 100% secure.

As a result, while WP will take all reasonable steps to protect your Personal Information used in connection with WP Online Services, for example by verifying the IMEI code on your device each time you use WP Online Services, the nature of the Internet is such that WP cannot guarantee or warrant the security of any information you transmit to us while using WP Online Services. Any information that you do provide to WP is at your own risk.

Internet Fraud
Banking organizations and their customers may from time to time be the target of hoax e-mails or SMS messages that are aimed at gathering Internet/account details of the customers. Some of these hoax e-mails and SMS messages have encouraged or facilitated contact with hoax websites that purport to be (but are not) the website of the relevant banking organization.

We would always advise you to be cautious as regards disclosing your Personal Information. In particular, you should note that we will only ever request your personal details if: (i) you are seeking to initiate e-mail contact with us via WP Online Services; or (ii) you initiate a request for a particular service via WP Online Services and we require certain personal details to provide you with the requested service. You should never publish your account details or other private information using a social media channel.

Changes to the Privacy Statement
Any changes to this Privacy Statement will be posted on this website and on the log-in page of the WP Mobile Banking App so you are always aware of what information WP collects through WP Online Services and how WP uses that information.

If at any time WP decide to use your Personal Information in a manner significantly different from that stated in this Privacy Statement, in the WP Data Protection Notice or otherwise disclosed to you at the time it was collected, WP will notify you using the appropriate contact channels.

Terms and Conditions
This Privacy Statement is subject to the Terms and Conditions of Use of the WP Bank  website which are available on www.woohoopay.com.

Where there is a conflict between this Privacy Statement and the Terms and Conditions of Use, the Terms and Conditions of Use shall prevail.

Any applications submitted using WP Online Services will be subject to the same terms and conditions as those completed by hand in paper form, including any additional terms and conditions relating to credit checking, money laundering and regulatory notices.

You may receive additional data protection notifications from us at the time you complete the application. Prior to providing any information to WP through WP Online Services which relates to other individuals, please ensure that those persons have agreed to us using this information or that you are otherwise allowed to give us this information for the purposes set out in the Data Protection Notice and for any additional purposes notified to you.

Woohoo Bank Ireland . Social Media Terms of Use
Please read these Terms of Use carefully. We reserve the right to amend these Terms of Use at any time for any reason. You should check these Terms of Use regularly as you are bound by the current version of the Terms of Use when accessing our social media sites.

If you are a WP  employee please review WB’s internal Social Media Policy.

Applicability
1. When you access any of the WP . social media profiles across social media sites these Social Media Terms of Use (“Terms of Use”) will apply. These Terms of Use are in addition to and are not in substitution for the terms and conditions applicable to our website. If there is any inconsistency between the terms and conditions for our website and these Terms of Use, these Terms of Use shall apply unless expressly stated to the contrary.

2. In addition to these Terms of Use, each social media site (such as Facebook or Twitter) may have their own terms and conditions which will also apply. You must comply with their terms and conditions as well as our Terms of Use.

3. WP’s social media channels and their content are designed for Irish residents and those over the age of 18.

Use of Social Networks
4. You access WP’s social media channels at your own risk and WP is not liable or responsible for any loss, or damage howsoever arising as a result of your use of our social media channels.

5. While WP has official profiles on social media sites, we do not endorse any social media site. In addition and without limitation, WP does not endorse or approve either expressly or by implication any third parties or their advice, opinions, information content, product or services which may appear on our social media profiles including any advertisements and or link to third party sites.

6. If you are unable to access the social media site, it is the responsibility of the social media site to resolve the matter. WP is not liable or responsible for any loss or damage that you may incur arising from the unavailability of the social media site.

7. You may not use our social media channels for any illegal or improper purpose.

Content
8. We would encourage you to share and comment on the content that we post through our social media channels so long as you do not amend or change it and acknowledge WP as the source.
Please note that WP’s social media profiles and the content that we post is the copyright of WP and we reserve all our rights therein. All trademarks, company names, logos and designs used in our social media channels and on our social media profiles are the intellectual property of WP and you may not use, copy or reproduce them in any way.

9. All products and services referred to by us through our social media channels are subject to specific eligibility criteria and terms and conditions which are set out in detail in the documentation applicable to that product or service and which should be read in detail before entering into the particular product or service.

10. The information and content available through our social media channels does not in any way constitute business, investment, financial, taxation, legal or other professional advice and we strongly recommend that you seek advice from an appropriately qualified professional prior to entering into any product or service with us.

11. We reserve the right to update and change our social media profiles and the content available through our social media channels at any time and without notification. We do not guarantee that our social media profiles are up to date.

Posting
12. You are fully responsible and liable for any material you post through our social media channels and WP is not liable or responsible for any content posted through our social media channels by any third parties.

13. When posting on our social media profiles, you must be respectful, considerate, polite, honest, accurate and relevant.

14. We are entitled to assume that you have the right and are permitted to submit any material that you post through our social media channels. You may not post any material which is confidential, breaches contractual obligations or impacts upon the rights of any third party.

15. You agree not to post any material which:

  •  is threatening, defamatory, obscene, indecent, offensive, pornographic, abusive, discriminatory, menacing, scandalous, inflammatory, blasphemous, unlawful, defamatory, obscene, false or inaccurate  or liable to incite racial hatred;
  • encourages, promotes or constitutes conduct that is a criminal offence;
  • may be technically damaging to our social media channels or contain any software viruses or Trojan horses which may damage our computer systems;
  • harms or exploits children in any way;
  • infringes any trademark or copyright or intellectual property rights of a third party; or
  • impersonates any person or entity or misrepresents your association with them.
  1. We may use any ideas or suggestions submitted to us through our social media channels without any further permission from you or compensation to you and you hereby agree to allow any such material to be re-used or quoted by us without further notification to you.

    17. You hereby grant us a perpetual, royalty free, irrevocable license to use, modify, reproduce, translate, publish, adapt, display and distribute in any format material and content posted by you through our social media channels.

    18. Please note we cannot respond to any complaints through our social media channels. Please see our complaints procedures which are available on our website www.woohoopay.com if you wish to make a complaint.

    Moderation Policy
    19. We reserve the right and have absolute discretion to screen, review, edit and monitor any content or material posted through our social media channels. We may, at our discretion, refrain from publishing material posted by you. In addition we may at our sole discretion at any time and without any notice or liability to you remove any material or content posted by you.

    Privacy
    20. You should be aware that anything that you post to or appears on a social media site is not confidential and anyone can read and comment on the posts that you make. In addition anything you post or comment on may also appear through results from internet search engines.

    21. You should NEVER under any circumstances post your personal account details or any sensitive personal or financial information through our social media channels.

    22. Our Data Protection Notice sets out in detail how we use your Personal Information and our obligations under applicable data protection law. Our Data Protection Notice is available on our website www.woohoopay.com.

    Access
    23. We reserve the right at our discretion at any time to temporarily or permanently suspend, withdraw or discontinue all or part of our social media channels without any notice or liability to you.

    Competitions/Promotions/Discounts/Offers
    24. We may from time to time offer promotions, competitions, prize draws, special offers and discounts through our social media channels.

    25. Such promotions, competitions, prize draws, special offers and discounts will be subject to their own eligibility criteria and terms and conditions.

    26. These promotions, competitions, prize draws, special offers and discounts are associated with or endorsed by the social media sites unless clearly stated to the contrary.

    27. WP reserves the right at its discretion to cancel, suspend or withdraw any promotion, competition, prize draw, special offer or discount and shall not be liable or responsible to any person for any loss or damage arising out of such, cancellation, suspension or withdrawal.

    General disclaimer and indemnity
    28. You agree to be bound by these Terms of Use as may be amended from time to time and to the fullest extent permitted by law indemnify WP in connection with any loss, or damage arising or occasioned by your use of social media sites and or a breach of these Terms of Use.

    29. WP, to the fullest extent permitted by law, is not accountable for and does not accept any liability or responsibility for any loss, damage (including without limitation, incidental, punitive, exemplary, special or consequential damages, loss of profit or damages resulting from lost date or business interruption) or expense resulting from:

  • using and accessing our social media channels whether with or without authorization;
  • the performance, functionality, non-performance, unavailability, inaccessibility, or disruptions to our social media channels;
  • using and accessing social media sites;
  • any reliance you place on content or material available through our social media channels whether posted by us or third parties.

Miscellaneous
30. Each of the clauses and sub clauses of these Terms of Use is severable and distinct from the others. If at any time such clauses or sub clauses is or becomes invalid, illegal or unenforceable, this will not affect the validity, enforceability and legality of any of the others clauses or sub clauses of these Terms of Use.

31.  WP reserves the right at its sole discretion to amend these Terms of Use at any time.  Any changes to these Terms of Use will be posted on our website www.woohoopay.com.

32. These Terms of Use shall be governed by and construed in the accordance with the laws of Ireland and the Courts of Ireland shall have exclusive jurisdiction to resolve any disputes arising out of or in connection with them.