In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Website;
means a small text file placed on your computer or device by Our Website when you visit certain parts of Our Website and/or when you use certain features of Our Website. Details of the Cookies used by Our Website are set out in Part 14, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
Our Website are owned and operated by Advantio Limited, a private limited company registered in the Republic of Ireland under company number 478729 with its registered office at Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland, DO2HW77.
Personal data is defined by the GDPR and the DataProtection Act, 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identified or identifiable natural person... who can be identified, directly or indirectly, in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
b. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
c. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
d. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
e. The right to restrict (i.e. prevent) the processing of your personal data.
f. The right to object to us using your personal data for a particular purpose or purposes.
g. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with our principal supervisory authority, the Irish Data Protection Commission. Details of how to lodge a complaint can be found on the Data Protection Commissioner’s website. Alternatively, you can contact another local supervisory authority.
We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. This information is only collected for the purposes of providing our services to you.
The following table describes how we will use your personal data, and our lawful bases for doing so:
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our services. You will not be sent any unlawful marketing or spam.
For non-customers we rely on your consent to contact you and consent will always be provided in the form of a clear opt-in. You have the right to withdraw your consent at any time using our contact details as listed below. For existing or past customers, we may rely on legitimate interest, being to develop and grow our business, to contact you for marketing purposes.
We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We will only use your personal data for the purpose(s) for which it was originally collected in a manner compatible with GDPR unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
For further information about our retention periods, please contact us on the details above.
We will take reasonable steps necessary for ensuring that your personal data is treated securely and in accordance with this privacy notice. We will use all reasonable efforts to put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
We might transfer your personal data outside theEuropean Economic Area by enabling remote access to your personal data by our subsidiaries/branches and/or service providers for support services, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority, Tax representative, Central Bank, Data Protection Commissioner, Law Enforcement Agencies and other government agencies.
We may sometimes contract with the following categories of companies to supply certain services or allow access to our systems:
If any of your personal data is shared with a third party, we will provide reasonable notice where necessary and will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
Any such third parties are obliged to keep your details securely, and to use them only to fulfil the service that they provide to us, they will dispose of the details in line with their/our data protection policy. If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards.
If you would like to know more about the third parties’ we may share your personal data with, or to find out more on how they will use your data, please contact us using the details at Part 15.
In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Website, you may be given options to restrict our use of your personal data. We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails, at the point of providing your details and by managing your Account).
You may access certain areas of Our Website without providing any personal data at all. However, to use all features and functions available on Our Website you may be required to submit or allow for the collection of certain data.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “Subject Access Request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of two months from the date we receive your request. You will be kept fully informed of our progress.
If you make a request to erase/be forgotten data, we will do so where we do not hold a legal obligation to keep this data.
If you would like to update any personal details, please contact us on the details provided at Part 15.
To contact our Privacy Team about anything to do with your personal data and data protection, including to make a subject access request, please use the following contact details: