Privacy Policy
What rights do you have?
As a data subject, you have the following rights under the Data Protection Legislation:
• the right of access to personal data relating to you;
• the right to correct any mistakes in your personal data;
• the right to ask us to stop contacting you;
• the right to restrict or prevent your personal data being processed;
• the right to have your personal data ported to another data controller;
• the right to erasure; and
• the right to complain to the DPC if you believe we have not handled your personal data in accordance with the Data Protection Legislation.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see ‘How to contact us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Right to access to personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
• a summary of such personal data and the categories of personal data held;
• details of the purpose for which it is being or is to be processed;
• details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
• details of the period for which it is held (or the criteria we use to determine how long it is held);
• details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
• any information available about the source of that data;
• whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
• where your personal data are transferred out of the EEA, what safeguards are in place.
Requests for your personal data must be made to us (see 'How to contact us' below) specifying what personal data you need access to, and a copy will be retained on your personal file. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your personal data or correct any mistakes in your personal data
You can require us to correct any mistakes in your personal data which we hold free of charge. If you would like to do this, please:
• email, call or write to us (see ‘How can you contact us’ below);
• let us have enough information to identify you (e.g. name, registration details); and
• let us know the information that is incorrect and what it should be replaced with.
If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).
Right to ask us to stop contacting you
You can ask us to stop contacting you. If you would like to do this, please:
• email, call or write to us. Details can be found at this link. You can also click on the ‘unsubscribe’ button at the bottom of any email sent to you from us. It may take up to 5 days for this to take place; and
• let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
We will provide you with information on action taken on a request to stop contacting you - this may be in the form of a response email confirming that you have ‘unsubscribed’.
Right to restrict or prevent processing of personal data
In accordance with Data Protection Legislation, you may request that we stop processing your personal data temporarily if:
• you do not think that your data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
• the processing is unlawful but you do not want us to erase your data;
• we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
• you have objected to processing because you believe that your interests should override the basis upon which we process your personal data.
If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:
• you consent to such processing;
• the processing is necessary for the exercise or defence of legal claims;
• the processing is necessary for the protection of the rights of other individuals or legal persons; or
• the processing is necessary for public interest reasons.
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.
The right to data portability also only applies where:
• the processing is based on your consent or for the performance of a contract; and
• the processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us to erase your personal data where:
• you do not believe that we need your personal data in order to process it for the purposes set out in this Policy;
• if you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
• you object to our processing and we do not have any legal basis for continuing to process your personal data;
• your data has been processed unlawfully or have not been erased when it should have been; or
• the personal data have to be erased to comply with law.
We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.
Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC
If you do not think that we have processed your personal data in accordance with this Policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the DPC website at https://www.dataprotection.ie
As a data subject, you have the following rights under the Data Protection Legislation:
• the right of access to personal data relating to you;
• the right to correct any mistakes in your personal data;
• the right to ask us to stop contacting you;
• the right to restrict or prevent your personal data being processed;
• the right to have your personal data ported to another data controller;
• the right to erasure; and
• the right to complain to the DPC if you believe we have not handled your personal data in accordance with the Data Protection Legislation.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see ‘How to contact us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Right to access to personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
• a summary of such personal data and the categories of personal data held;
• details of the purpose for which it is being or is to be processed;
• details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
• details of the period for which it is held (or the criteria we use to determine how long it is held);
• details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
• any information available about the source of that data;
• whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
• where your personal data are transferred out of the EEA, what safeguards are in place.
Requests for your personal data must be made to us (see 'How to contact us' below) specifying what personal data you need access to, and a copy will be retained on your personal file. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your personal data or correct any mistakes in your personal data
You can require us to correct any mistakes in your personal data which we hold free of charge. If you would like to do this, please:
• email, call or write to us (see ‘How can you contact us’ below);
• let us have enough information to identify you (e.g. name, registration details); and
• let us know the information that is incorrect and what it should be replaced with.
If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).
Right to ask us to stop contacting you
You can ask us to stop contacting you. If you would like to do this, please:
• email, call or write to us. Details can be found at this link. You can also click on the ‘unsubscribe’ button at the bottom of any email sent to you from us. It may take up to 5 days for this to take place; and
• let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
We will provide you with information on action taken on a request to stop contacting you - this may be in the form of a response email confirming that you have ‘unsubscribed’.
Right to restrict or prevent processing of personal data
In accordance with Data Protection Legislation, you may request that we stop processing your personal data temporarily if:
• you do not think that your data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
• the processing is unlawful but you do not want us to erase your data;
• we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims; or
• you have objected to processing because you believe that your interests should override the basis upon which we process your personal data.
If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:
• you consent to such processing;
• the processing is necessary for the exercise or defence of legal claims;
• the processing is necessary for the protection of the rights of other individuals or legal persons; or
• the processing is necessary for public interest reasons.
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.
The right to data portability also only applies where:
• the processing is based on your consent or for the performance of a contract; and
• the processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us to erase your personal data where:
• you do not believe that we need your personal data in order to process it for the purposes set out in this Policy;
• if you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
• you object to our processing and we do not have any legal basis for continuing to process your personal data;
• your data has been processed unlawfully or have not been erased when it should have been; or
• the personal data have to be erased to comply with law.
We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.
Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC
If you do not think that we have processed your personal data in accordance with this Policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the DPC website at https://www.dataprotection.ie
