This Policy sets out:
- what data we collect about you & how we use it;
- who we share your data with;
- information on international data transfers;
- how long we keep your data;
- your rights and how to contact us; and
- information on cookies and other technologies.
1. What data do we collect about you?
We collect data directly from you or automatically via our Services.
1.1 Data you are sharing with us
1.1.1 When you use our Services or otherwise interact with us, for example to ask us a question or subscribe to our newsletter, we will collect data you are sharing with us such as your name, e-mail address, phone number or the content of your request.
We do this
- with your consent. For example, we have implemented a double-opt in process for the subscription to our newsletter to ensure that it was you who provided us with your e-mail address. This means that you will be asked to confirm your subscription before we send you our newsletter. The purpose of this procedure is to be able to verify your registration and, if necessary, to clarify any possible misuse of your personal data
- in our legitimate interests to provide you with the information you request when you contacted us.
1.1.2 We may collect your name, e-mail address, user name, social media handles or submission content (e.g. your posts) in order to participate in social media discussions with you or to provide you with information on our social media accounts. We do this in our legitimate interests to interact with you.
We have social media accounts with
- Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Irland; for further details on Facebook’s processing of your data please read https://www.facebook.com/about/privacy.
- Twitter, Inc., 1355 Market St, Suite 900, San Francisco, California 94103, USA; for further details on Twitter’s processing of your data please read https://twitter.com/privacy.
- YouTube by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; for further details on Google’s processing of your data please read https://policies.google.com/privacy.
- LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; for further details on LinkedIn’s processing of your data please read https://www.linkedin.com/legal/privacy-policy.
Please note that the social media providers will also collect your personal data and may set cookies even if you do not have a profile with such providers. We cannot influence the processing of your personal data by social media providers. Please refer to their respective privacy policies, linked above.
1.2 Data we collect about your use of our Services
We may collect data from you each time you visit our Services or subscribe for our newsletter:
- to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and/or survey purposes;
- to improve our Services to ensure that content is presented in the most effective manner to you and your device;
- to keep our Services safe and secure; and
- to enable us to verify your newsletter registration and, if necessary, to clarify any possible misuse of your personal data.
The type of data we collect may include:
- technical data such as your Internet protocol (IP) address, your login data, your browser type and version, your time zone setting, your browser plug-in types and versions, your operating system or your platform; and
- data about your visit of our website and social media accounts such as the URL, clickstream to/through and from our website, including date and time of access, information you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs) or methods used to browse away from the page.
We do this:
- with your consent; or
- in our legitimate interests to provide you with certain features of our website and with a secure and stable website.
2. Why we do this? (legal basis)
Consent: We use your personal data to send you promotional or marketing content if you have given us your consent to do so. You can opt-out of receiving future marketing communication at any time by selecting the “unsubscribe” link at the end of our promotional information sent to you or by sending us an e-mail to the email address listed in Section 8 below.
We also rely on consent for some of the cookies we use (see Section 7 below for more detail).
Legal Obligation: We may need to process your personal data to comply with our legal obligations under applicable law and/or court orders.
Legitimate interests: We may process your personal data if it is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not outweighed by your rights and interests.
Our legitimate interests include:
- providing you with data, products and services requested by you;
- to allow you to participate in interactive features on our website;
- to gain insights into how you are using our Services;
- to deliver, develop and improve our Services;
- to keep our Services safe and secure;
- to improve our website to ensure that content is presented in the most effective manner for you and for your device; and
- to administer our website, including for troubleshooting, data analysis, testing, research, statistical and survey purposes.
3. Who do we share your data with?
We may share your data with selected third parties, including our business partners, payment providers, suppliers or sub-contractors as well as the following parties:
3.1 Service providers which support us in processing your data and which include:
- technology providers who provide the Services we offer, for example, by hosting our website, storing data, or providing IT support services;
- social media providers who we have an account with;
- companies that help us distribute communications and facilitate feedback on our Services.
Our service providers will only use your data to the extent necessary to perform their supporting functions.
3.2 Regulators and public authorities to comply with applicable legal obligation.
3.3 Analytics and search engine providers that assist us in improving and optimizing our Services.
3.4 Auditors, legal advisors and other professional advisors.
3.5 Anyone who you give us explicit permission to share your data with.
3.6 We may also disclose your personal data to third parties if we buy or sell part of our (or another party’s) business or if we are required to do so in order to comply with legal obligations.
4. International transfers
Your data may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") which may not be subject to equivalent data protection law. Where your data is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards (such as relying on a recognized legal adequacy mechanism) and that it is treated securely and in accordance with this Policy.
We may transfer your personal data outside the EEA:
- in order to store it (e.g. on webservers of our hosting provider);
- where we are legally required to do so;
- in order to facilitate the operation of our business, where it is in our legitimate interest and we have concluded that our interest is not overridden by your rights;
- where you have consented to such transfer.
5. How long will we keep your data
We retain your data for as long as necessary to provide our Services, to meet our legal obligations and to identify any issues and resolve any legal proceedings. We may also retain aggregate data beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate data retained or used for these purposes.
6. Your rights
You have the right under certain circumstances:
- to be provided with a copy of your personal data;
- to request the correction or deletion of your personal data;
- to request a restriction of the processing of your personal data;
- to object to the processing of your personal data; and
- to request that your data be moved to a third party.
If the processing of your personal data is based on consent you have the right to withdraw your consent without detriment at any time without affecting the lawfulness of processing based on your consent before its withdrawal.
You can exercise the rights above at any time by contacting us under the contact data listed in Section 8 below.
You may also approach a data protection authority (e.g. the authority at your place of residence) and lodge a complaint.
7. Cookies and other technologies
7.1 We may use the following types of cookies
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to view our website correctly.
Functionality cookies. These are cookies that are used to recognize you when you return to our website. This enables us, subject to your choices and preferences, to personalize our content, greet you by name or remember your preferences.
Analytical/performance cookies. These are cookies that allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Targeting/Advertising cookies. These are cookies that are used to record your visit to our website, the pages you have visited and the links you have followed. We use this data, subject to your choices and preferences, to make the website more relevant to your interests. We may also share this data with third parties who may provide you with personalized advertising based on your personal interests.
7.2 Detailed Information
With your consent, we use the following types of cookies on our website:
|Type of Cookie
||Tool, Provider and further information
||Consent management, provided by Cookiefirst (Digital Data Solutions BV) to store and manage cookie consent by website visitors.
We use certain functions of the web analysis service Google Analytics to optimize our website offer. We have activated the IP anonymisation function so that your IP address is shortened by Google before it is transmitted to the USA. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide further services to the website operator in connection with website and internet use. According to Google, the IP address transmitted by your browser within the scope of Google Analytics is not combined with other data.
Further information can be found in our Cookies Consent Tool.
7.3 Disabling cookies
If you want to disable cookies on our website, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.
You can also change your settings in our Cookies Consent Tool.
8. Contact us
Questions, comments and requests regarding this Policy or our processing or your personal data should be addressed to:
9. Changes to this policy
We reserve the right to change this Policy at any time. Changes will be posted on our website. This policy was last updated on 04 September 2020.