Privacy Notice
The CUGreenerHomes Scheme is a joint collaboration of the Irish League of Credit Unions (“ILCU”), participating credit unions, House2Home (“H2H”) and Energia. The purpose of the Scheme is to promote Eco-Friendly Retrofits in Ireland in conjunction with credit union finance. The Scheme will offer a credit union member the opportunity to avail of a special loan interest rate when opting for this loan product. When the finances are made available to the member, H2H will carry out retrofitting on the member’s home, which will improve the BER Rating of their home, and which will enable the member to avail of energy credits through Energia, as well as the possibility of a grant from the Sustainable Energy Authority of Ireland (SEAI).
The Associated Entities (i.e. the participating credit unions, ILCU, H2H and Energia) are committed to respecting the rights of those people whose data is processed under this Scheme. This Privacy Notice demonstrates transparency in what personal data we use and how, why and for how long we use it.
Whose Personal Data do we Process?
The scope of this Privacy Notice is where the Associated Entities act as individual data controllers, processing personal data of members of affiliated credit unions in order to provide relevant services to those members under the Scheme. The Data Register in the Appendix provides details of the processing of such data.
Processing Activities
Participating Credit Unions
The credit unions participating under this Scheme will process your data where you make an enquiry on the CUGreenerHomes Loan/Works Calculator. The data processed will be limited to name and contact details in order to determine whether you are a member of that credit union, and to provide you with information on how to become a member if you are not already one. Once it is established that you are a member, the credit union will assess your eligibility for a CUGreenerHomes loan. The credit union may also process status updates relating to the completion of the H2H house survey and the issuing of a quotation in order to streamline the loan application process. Once you enter into a credit agreement with the credit union, there will be no further processing of your data by the credit union under the Scheme, and any further processing will only take place in accordance with the credit union’s own Privacy Policy.
The Irish League of Credit Unions
The Irish League of Credit Unions is a coordinator in this project but will take no active part in liaising with you regarding this Scheme, or providing any of the relevant services, and as such will not process any of your personal data. The ILCU will process pseudonymised data relating to building works to facilitate status updates for credit unions and streamline the loan application process.
House2Home
House2Home will process your data where you make an enquiry on the CUGreenerHomes Loan/Works Calculator. The data processed will be limited to your name and contact details, as well as basic information relating to your home in order to determine eligibility under the Scheme. House2Home will follow up the initial enquiry with a telephone consultation of your home. House2Home will also apply on your behalf for a Sustainable Energy Authority of Ireland (“SEAI”) Grant. Once you decide to engage in a contract with House2Home for the retrofitting services, any further data processing of your data will only take place in accordance with this contract and with House2Home’s own Privacy Policy.
Energia
Energia will provide energy credits under this Scheme. In order to do this, they need to process the contact details of the member and details relating to the house, such as current BER and new BER. The improvement in the energy rating of your home will allow Energia to attribute the relevant energy credits to your home.
SEAI
The SEAI will need to process your data in order to provide you with a grant towards your retrofitting works.
Loan/Works Calculator
The Loan/Works Calculator located on www.cugreenerhomes.ie has been developed to receive financial and building works enquiries. This means that the person making the enquiry will enter their data into the calculator, and this data will trigger an email to the participating credit union and an email to House2Home. The credit union and House2Home will contact the member separately to determine eligibility for their services. The calculator will not retain information relating to you or your home.
Lawful basis:
Consent:
When making an enquiry on the Loan/Works Calculator on www.cugreenerhomes.ie, you are giving House2Home and the relevant credit union (if applicable) your consent to contact you regarding your enquiry. An email will be sent to you detailing what information you have submitted in your enquiry, as well as the contact details of House2Home and the credit union.
If at any time you decide not to continue the journey with either the Credit Union or House 2 Home, and wish to remove your consent to the processing of your data, you can contact the Credit Union or House 2 Home using the details provided to you by email.
Contract:
Once you enter into a contract with the credit union for finance, or with House2Home for retrofitting services, the legal basis for processing your data will be in accordance with contractual obligations.
Retention:
Where an enquiry is made on the Loan/Works Calculator, an email is sent to the credit union and to House2Home. Both entities will contact you separately regarding your enquiry. If you decide not to continue the journey with either the credit union or House2Home, your enquiry will be deleted after 3 months.
Where you decide to continue the journey with the credit union or with House2Home, and enter a contract in relation to the relevant services, your details will be retained for no longer than 7 years.
Withdrawal of consent
If you wish to withdraw your consent to your personal data being processed by any of the associated entities, you can do so on the follow-up phone call with the participating credit union or with H2H subsequent to having submitted your enquiry, or at any time thereafter by contacting your credit union or H2H directly.
To whom do we share your data?
House2Home will share limited information with Energia, in order for you to receive the relevant energy credits, and with SEAI, in order for you to receive the relevant grant. House2Home will also provide status updates (regarding survey completion and the provision of a quotation by House2Home to the member) to the relevant participating credit union solely for the purposes of streamlining the loan application process for the member. The participating credit union will never share information with the Associated Entities regarding your finances.
In addition, subject to compliance with prevailing Data Protection Legislation, Energia and House2Home may individually contact you, once a formal contract has been entered into between you and House2Home, with a view to marketing their own products and services.
Consequences of a failure to provide information
If you fail to provide certain information when requested, we may not be able to perform the contract we have entered into with you or we may be prevented from complying with our legal obligations.
Your Rights
- To find out whether we hold any of your personal data and if we do to request access to that data and to be furnished a copy of the data. You are also entitled to further information about the processing.
Correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate about you rectified.
Erasure of your personal data in certain circumstances. You can 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 exercised your right to object to processing (see below).
Object to processing of your personal data where a legitimate interest is relied on. You also have the right to object to processing for direct marketing purposes, including profiling for direct marketing.
Restriction of processing of your personal data. You can ask us to suspend processing of personal data about you, in certain circumstances for example if you want to challenge the legality of processing.
Where we are processing your data based solely on your consent you have a right to withdraw that consent at any time and free of charge.
Portability; you can request a copy of your personal data that you have provided to us to be sent to you (or another where technically feasible) in an electronic, reusable format;
You also have a right to complain to the Regulator about any of our processing.
ROI: Data Protection Commission
Web Contact: https://dataprotection.ie/en/contact/how-contact-us
Postal Address: Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
Point of contact for your queries
For any energy or building works queries regarding your privacy rights, please contact the relevant Associated Entity. Contact details for the Associated Entities are below:
| House2Home | https://house2home.ie/ |
| Energia | https://www.energia.ie/home; or Dataprotection@energia.ie or write to the: Data Protection Officer, The Liberty Centre, Blanchardstown Retail Park, Dublin 15, D15 YT2H |
| SEAI | https://www.seai.ie/ |
For any finance queries regarding your privacy rights, please contact your local credit union.
Appendix – Register of Data Processing and Data Sharing
| Data Fields | Example Data | CU | Member | H2H | Energia | H2H SEAI Data Flows |
|---|---|---|---|---|---|---|
| Unique Lead ID | y | n | Y | y | n | |
| Name | Peter John | y | n | Y | y | y |
| testing@matrixinternet.ie | y | n | Y | y | y | |
| Address | Overbeck Cottage, Stokesley Road | y | n | Y | y | y |
| Phone | 1287632804 | y | n | Y | y | y |
| Age of Home | 1978-1982 (38-42 years) | n | n | Y | y | y |
| House Type | Basement Apartment | n | n | Y | y | y |
| Storeys | 2+ storey | n | n | Y | y | y |
| Current Rating | C2 | n | y | Y | y | y |
| New Rating | B2 | y | y | Y | y | y |
| Project Cost | €20,000.00 | n | y | Y | y | y |
| SEAI Grant | €100.00 | n | y | Y | y | y |
| Net Project Cost | €19,900.00 | n | y | Y | y | y |
| Total Loan | €19,900.00 | y | y | N | N | n |
| APR | 5.96% | Y | Y | N | N | n |
| Repayment Period | 10 years | y | y | N | N | n |
| Credit Union Name | Progressive | Y | Y | Y | Y | n |
| Member Y/N | Y | Y | Y | Y | Y | n |
| Description of Works | n | Y | Y | Y | y | |
| Energy Credit | n | y | Y | y | y | |
| Survey | Y | Y | Y | Y | N | N |
| Quotation | Y | Y | Y | Y | N | N |
