Privacy Policy
Purpose
The purpose of this policy is to outline how we use your data, how it’s protected, how long it’s stored for.
Please read this Privacy Policy carefully as it contains important information to help you understand our practices regarding any personal information that you give to us.
By accessing, browsing or otherwise using our Website, mobile or other applications you confirm that you have read and agree to this Privacy Policy. If you do not agree with any part of this Privacy Policy, you should not continue with your application or engagement with us.
1 Our Commitment
1.1 LM Operations Limited (“LM Operations”, “we”, “us”, or “our”) recognises that your privacy is important to you. The
purpose of this Privacy Notice (the “Notice”) is to explain how we collect, use, store and transfer your personal
information in the course of our business.
1.2 This Notice applies to all persons who are users or prospective users of our hire purchase products (“you”, “your”).
LM Operations is the data controller responsible for the personal information collected and processed as described
in this Notice.
1.3 LM Operations is committed to your privacy and ensuring that your personal information is:
1.3.1 processed lawfully, fairly, and transparently;
1.3.2 processed for specific purposes only, and not in any manner incompatible with those purposes;
1.3.3 processed adequately and in a manner that is limited to what is necessary;
1.3.4 processed accurately;
1.3.5 not kept for longer than necessary;
1.3.6 kept confidential and secure; and
1.3.7 processed in accordance with your rights.
1.4 Please take the time to read this Notice carefully. If you have any questions regarding our use of your personal
information, you can contact us at lmosales@lmoperations.ie.
1.5 This Notice will be brought to your specific attention when you apply for credit. You must accept the terms of this
Notice before proceeding to a credit application form. If you do not accept them, we will unfortunately be unable to
proceed with your application.
2 What personal information we collect
2.1 We collect and process your personal information including, but not limited to, the following:
2.1.1 Name and titles.
2.1.2 Physical address and address history.
2.1.3 Date of Birth.
2.1.4 Contact information such as telephone numbers and email address.
2.1.5 Employment history.
2.1.6 The personal data contained in your bank statements, such as your bank account details, your income
and expenditure.
2.1.7 Your PPS number.
2.1.8 Online identifiers (such as IP addresses and cookies) when you use our website. Please see our Cookie
Policy for more details.
2.1.9 Personal data contained in your passport (including, if relevant, your visa status) and driving licence.
2.1.10 Information on your credit history, including any debt judgements made against you or other payment
defaults. This may include information that we collect from other lenders which you have also used, for
example if you have made any settlements with them.
2.2 We will not ask you to provide us with what is known as “Special Category Data”. This means personal data revealing
racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data,
biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. However,
when you provide the information specified at clause 2.1 above it may reveal Special Category Data. For example,
where your driving licence is provided this may contain endorsements if you have been the subject of a driving
offences, or your employment history may reveal aspects of your medical history if you have had extended sick
leave, or your bank statements may disclose medical expenses.
2.3 We endeavour to keep all personal information we collect up to date and request assistance in this from you in this
regard. If there are any changes to your personal information, please notify us at lmosales@lmoperations.ie
2.4 If the provision of certain personal information is mandatory (either under law or in accordance with a contractual
requirement), we will let you know this at the time of collection, along with the impact of not providing it.
3 How we use the personal information we collect
| Activity | Type of Data | Lawful Basis for Processing |
| Considering, approving and the ongoing management and administration of your loan application and the loan itself, including contacting you about the same and dealing with an complaints which may arise. |
All personal data referenced above save for online identifiers. |
Necessary for performance of a |
| Considering and approving your loan application. |
Special Category Data revealed through the information you provide to us. See clause 2.3 above. |
Where you have given your explicit consent. |
| Administering and monitoring our website. |
Online identifiers (such as IP addresses and cookies). |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
| To improve our website, products/services, marketing, market research, customer relationships and experiences. |
All personal data referenced above save that we will never use Special Category Data and we will always minimise and, where possible, we will pseudonymise or anonymise the relevant data. |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy). |
| Complying with our legal and regulatory obligations. |
All personal data referenced above. | We may use your personal data to fulfil legal obligations to which we are such as complying with antimoney laundering obligations or complying with the requirements of the Central Bank of Ireland. |
| To provide you with marketing communications by post, text and email. |
Identity and contact information. | Where you are a potential customer will we only provide you with direct marketing where you have provided your explicit consent. You can withdraw this consent at any time. Where you are a customer will provide you with direct marketing where you have not opted out of the receipt of direct marketing. We rely on our legitimate interest. |
| To Manage our everyday business needs, including accounting, filing, audit, record keeping, sharing your information within our company group for administrative purposes, and to prevent fraud. |
All personal data referenced above provided that it is necessary for the specific purpose. |
We rely on our legitimate interest in the effective management of our business. |
3.2 All of our phone calls are recorded. We will use this information to monitor and train staff, to deal with customer
disputes and for our own compliance purposes.
4 How long we keep YOUR personal information
4.1 In instances where an application does not result in a live credit agreement, we will retain the data for a period of
six years from the end of the application process. The reason for this is to help us in the event of a complaint being
made. After that period the data is deleted from our systems or anonymised in accordance with data protection
regulations to be used for statistical analysis purposes to improve our systems and product offering.
4.2 In instances where an application does result in a live credit agreement, we will retain the data for a period of six
years from the end of the agreement. The reason for this is to help us in the event of a complaint being made. After
that period the data is deleted from our systems or anonymised in accordance with data protection regulations to
be used for statistical analysis purposes to improve our systems and product offering.
5 Personal information we share
5.1 We will share your personal information with our affiliates, public authorities and our trusted third party service
providers. For example, we share your personal information with:
5.1.1 Central credit register – as a credit referencing agency
5.1.2 Brokers – intermediaries assisting with loan applications
5.1.3 Dealers – intermediaries assisting with loan applications
5.1.4 Creditsafe – used for compliance/ insolvency / anti-money laundering checks
5.1.5 Credit reference agencies
5.1.6 Fraud prevention agencies
5.1.7 Insurance companies for administration
5.1.8 Tracing and repossession agents
5.1.9 Legal firms for the purpose of establishing and defending legal claims
5.1.10 Auction houses
5.1.11 Funders
5.1.12 External auditors
5.1.13 Our regulators, such as the Central Bank of Ireland.
5.2 If you provide us with false information we may bring this to the attention of organisations and companies who deal
in fraud/crime prevention. The same applies if we or any party we deal with suspect fraud or false or inaccurate
information has been supplied. Any reported instances may also be accessed by government entities such the
Revenue Commissioners, The Department of Social Protection, regulatory bodies or the police, for use to prevent
any possible fraud and money laundering.
5.3 When we transfer your personal information to a third party that processes your personal information on our behalf
as data processor, we require them to protect your personal information with appropriate security measures, we
prohibit them from further using your personal information for their own purposes and we prohibit them from further
disclosing your personal information to others without our approval.
5.4 All personal information you provide to us is held within the European Economic Area or the UK.
5.5 For LM Operations to continue to grow, we may buy or sell assets. It is normal, in connection with such transactions
(e.g. a corporate restructuring, sale or assignment of assets, merger, divestiture, or other changes of control or
financial status of LM Operations) for personal information to be one of the transferred business assets. Accordingly,
your personal information may be disclosed where permitted by law in such event.
6 Fraud Prevention Agencies and Credit Referencing
6.1 We may use both fraud prevention agencies and credit referencing agencies to help make relevant decisions on
any credit application you submit.
6.2 When a check with a Credit Reference Agency (“CRAs”) is made a footprint will appear on your credit file which can
be seen by other lenders. CRAs provide us with shared credit information, fraud prevention information and public
information; this information will include what is held about you on the electoral register. Information received by
CRA’s will be recorded by them.
6.3 If you have a live finance agreement with us, the activity and details of management of your account will be passed
to CRAs. In the event that you take out a finance agreement and fail to repay back the full funds required, this will
be recorded with the CRA. In this case information may be passed onto other companies by CRAs to locate and
trace you with a view to recovering any outstanding debts. We must warn you that if this does occur then this will
remain on your record for six years once a case has been closed by either settlement or default. You may contact
any/all of the credit reference agencies directly. If you choose to contact a Credit Reference Agency, please bear in
mind that the information held may not be the same so it may be useful to contact all of them.
6.4 When we assess your application and it has been approved in principle, we may also check your identity in order to
prevent fraud and crime; this includes money laundering. This information will then be used to ascertain whether to
offer any future credit that may be available. This is to comply with our regulatory obligations for responsible lending,
Fraud Prevention Agencies (“FPAs”) and CRAs assist us in fulfilling this.
6.5 The personal information we have collected from you will be shared with FPAs who will use it to prevent fraud and
money-laundering and to verify your identity. If fraud is detected, you could be refused certain services, finance, or
employment. Further information on fraud prevention agencies can be obtained by contacting us at
lmosales@lmoperations.ie.
7 How we protect personal information
7.1 We have measures in place to protect your personal information against unauthorized access, use, or disclosure.
In particular, we implement and maintain technical measures to ensure that your personal information is recorded
and processed in a confidential and secure manner.
8 Your rights
8.1 You have the following rights, though they are subject to limitation under law:
8.1.1 to request access to, correction or erasure of your personal information;
8.1.2 to object to or request restriction of processing;
8.1.3 to information portability with respect to the information you provided to us, where the personal
information are processed pursuant to your contract with us or your consent. You can choose to receive
your personal information in a usable electronic format or request direct transmission to a third party,
subject to that third party’s cooperation; and
8.1.4 to withdraw consents given at any time, for example, explicit consents for the processing of Special
Category Data.
8.2 If you have any questions about this Notice, wish to make a data subject access request or raise any concerns or
complaints with regard to the administration of this Notice, you can contact us at lmosales@lmoperations.ie or 01695
0698.
8.3 You also have a right to lodge a complaint with the Data Protection Commission (“DPC”), the Irish data protection
supervisory authority. For further information on your rights and how to complain to the DPC, please refer to the
DPC website or contact the DPC using the following details:
` Data Protection Commission,
21 Fitzwilliam Square South,
Dublin 2,
D02 RD28
+353 (0)761 104 800
info@dataprotection.ie
9 Changes to the Privacy Notice
We will update this Notice from time to time, particularly to maintain compliance with evolving information protection
laws, regulations, and needs. If this occurs, we will update the Notice which will then be posted on our website.
Please ensure that you check our website regularly for updates.
This Privacy Notice was last reviewed and updated in October 2022.