2. Types of Information collected
2.1 This is data that identifies you or can be used to identify or contact you and include your title, name, surname, gender, email address and contact details. We may also from time to time collect data such as your preferences and interests and other information relevant to customer surveys and/or offers.
“Non-Personal Data” & Cookies
3. Purposes for which we hold your Information
3.1 We will only process your personal data for specific purposes: i.e.
(a) to complete a transaction with you;
(b) planning and managing the Company’s business activities on the Site, including analysis of activities on the Site;
(c) to periodically send you updates about our products and services or other information which we think you may find interesting using the email address which you have provided, in accordance with data protection legislation and your preferences;
(d) internal record keeping; and
(e) to respond to any queries you submit to us.
3.2 If you have previously agreed to us using your personal information for direct marketing purposes or if you no longer wish to receive direct marketing communications, you may change your mind at any time by clicking on the ‘Unsubscribe’ link in the emails we have sent you (if any) or by contacting us at firstname.lastname@example.org
3.3 We use the non personal data gathered from visitors to the Site in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise the Site.
4. Legal Basis
4.1 We rely on the following legal bases to process your personal data through the Site:
(a) your consent to the processing (where we have specifically requested and you have provided your consent);
(b) the processing set out above necessary for the performance of the contract which you are party to or in order to take specific steps prior to you entering into a contract;
(c) the processing is necessary to comply with our legal obligations (e.g. with respect to retention of contractual records);
(d) the processing is necessary for our legitimate interests or those of a third party provided that those right are not outweighed by your rights or interests. It is within our legitimate interest to use certain personal data to establish, maintain and review a customer account with you, to enforce rights set out in the terms & conditions of sale and otherwise to protect and defend our rights, and to ensure customers are provided with the most appropriate products and services and that enquiries are resolved appropriately, to determine whether marketing campaigns are effective and to improve our security protocols.
5. Retention and Disclosure of Data
5.2 We may disclose your personal data with our sales distribution and representative network so that they can contact you regarding a matter you have shown an interest in.
5.3 We may disclose your personal data if we are under a duty to disclose or share your personal data as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, search warrant or legal process served on the Company or the Site or regulatory order or other statutory or legal requirement.
5.4 We keep a record of all correspondence sent to the Company through the Site. This means that any queries or problems may be dealt with efficiently, and also so we can ensure that any information that we send to you is relevant.
(a) any correspondence or records relating to a contract with you shall be retained for 7 years after termination or completion of the relevant contract.
(b) any contact details retained for marketing purposes shall be retained for as long as we have your permission to send you marketing information or for as long as we are permitted to do so, subject to your right to object at any stage; and
(c) any other personal data necessary for us to do so to comply with our legal requirements shall be retained in line with such legal requirements.
6. Sale of Business
7.1 Your personal data is held on secure servers hosted by our Internet Service Provider. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data.
7.2 Whilst logged in to the Site all communication between your computer and our server takes place over an SSL secured internet connection, generally regarded as offering the highest level of commercially available internet security.
7.3 Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.
8. Individual Data Subject Rights
8.1 Data Protection Law provide certain rights in favour of data subjects in respect of their personal data. The rights in question are as follows (the “Data Subject Rights”):
(b) The right of access to personal data;
(c) The right to rectify or erase personal data (right to be forgotten);
(d) The right to restrict processing of personal data;
(e) The right of data portability;
(f) The right of objection; and
(g) The right to object to automated decision making, including profiling;
8.2 These Data Subject Rights will be exercisable by you subject to limitations as provided for under Data Protection Law. You may make a request to the Company to exercise any of the Data Subject Rights by contacting us through the Site. Your request will be dealt with in accordance with Data Protection Law.
9. Data Retention
10. Data Transfers outside the EEA
10.1 From time to time, The Company may transfer personal data to countries outside the EEA which may not have the same or equivalent Data Protection Law as Ireland. If such transfer occurs, The Company will ensure that such processing of your personal data is in compliance with Data Protection Law and, in particular, that appropriate measures are in place such as entering into Model Contractual Clauses (as published by the European Commission). If you require more information on the means of transfer of your data or would like a copy of the relevant safeguards, please contact us through our Site.
11. Further Information/Complaints Procedure
11.2 While you may make a complaint in respect of our compliance with Data Protection Law to the Irish Data Protection Commission, we request that you contact us in the first instance to give us the opportunity to address any concerns that you may have.
Date: 13 November 2020