Privacy Policy Statement

Our Company are committed to processing personal information about our  customers in ways that comply with our legal obligations as well as being  clear with our customers about what we do with their personal information.  Some of the key points of our privacy statement are:

✔ We don’t sell your data to third parties

✔ We do make it easy for you to manage your information, you can change  your communication preferences at any time

✔ We do use data to help us provide great customer service, which includes  tailoring the information we share with you to help ensure that it’s relevant,  useful and timely,

Our company share your concern about the protection of your personal  information and are committed to safeguarding your privacy.  This document covers information we collect about you, whether via our  website: (our “Websites”), through our office, our agents or otherwise. Please  read it carefully to understand how your personal information will be treated.

We will be the “controller” of the personal information which you provide to us  or which we collect from you.

1. Personal information that we collect

We collect a range of personal information relating to you, including your: 

  • name; 
  • email address; 
  • telephone number;
  • credit or debit card information and/or other payment information; • IP address; and;
  • any other personal information that you choose to provide to us when you  complete our online contact forms or otherwise make contact with us directly.

2. How we use your personal information 

  • We use your personal information as follows:
  • to maintain our relationship with you whilst you are a customer;
  • to process orders and provide agreed goods and services to you;
  • for invoicing, processing payments, account set up and maintenance;
  • to communicate with you, including to respond to information requests  /enquiries submitted and/or to obtain your feedback on our products and  services;
  • for record keeping, statistical analysis and internal reporting and research  purposes;
  • to ensure data security and to provide you with access to secure areas of  our Websites;
  • to notify you about changes to our products and services;
  •  to decide on and notify you about price changes;
  • to monitor the quality of our products and services;
  • for logistical purposes, including to plan and log delivery routes;
  •  for logistical purposes, including to plan and log delivery routes;
  • to investigate any complaint, you make;
  • to provide evidence in any dispute or anticipated dispute between you and  us; 
  • to customise various aspects of our Websites to improve your experience; • to pre-complete online forums on our Websites. For example, if you have  provided an address when using one service, the Websites computers may  automatically fill in that information on an order form for another service; 
  • as we may otherwise consider necessary to support the operation of our  Websites;
  • to obtain credit references, credit checks and for debt collection, fraud  detection and prevention and risk management purposes;
  • to monitor and/or record telephone conversations to or from you in order to  offer you additional security, resolve complaints, improve our service  standards and for staff training purposes; and
  • to protect the rights, property, and/or safety of our company, its personnel, and others.

Marketing 

We may send you direct marketing in relation to our own products and  services by phone and post, if this is in line with any marketing preferences  that you have provided to us.

We will only send you direct marketing in relation to our own products and  services by email or SMS:

  • where you have consented to this; or
  • where you have not objected to this, and we are marketing similar products  and services to those which were the subject of a previous sale or  negotiations of a sale to you.

Your agreement to the use of your personal information for direct marketing  purposes is optional and if you choose not to consent, your visit to and use of  our Websites will not be affected. 

You can choose to opt out of receiving direct marketing information from us at  any time, through the ‘Unsubscribe’ link at the bottom of any emails you  receive, or by contacting our companies Customer Service Centre Directly:

All contact information can be found on our website. You can contact us via mail, email or telephone or by filling in the enquiry form on our websites.

Recruitment

If you click on the “careers” button (or equivalent) on our Websites, you  will be directed to our dedicated recruitment portal, provided by our  supplier: Cornerstone OnDemand Limited. Before you can apply for a job  on this portal, we will ask you to create an account using some basic  contact details. This allows you and us to keep track of your applications(s)  and you to tell us if you would like to receive email notifications about  upcoming vacancies. If you choose to apply for a job that is listed on our  recruitment portal, we will ask you to complete an application form and  upload a C.V. and a covering letter. You can also upload supporting  documentation. Before you submit these documents to us, you will be  provided with a privacy notice, which provides specific information about  how your personal information will be handled in connection with your  application. 

3. Automated decision making/profiling

Pricing Variations

  • We use software that processes your personal information (including  contact details) and information about your transaction history with us in  order to produce recommendations for periodical variations in the pricing  of our products and services. We use this software to help us to decide  how and when to change our prices. Our Sales Teams ultimately decide if  any price change recommendations produced by the software will be  applied.

Google 

  • We use Google for a variety of marketing services, including the Google  Customer Match service which matches your email address as provided to  us, with information held in your Google account (if you have one) in order  to enable Google to show you adverts for our products and services when  you are searching on Google, using Google’s search network, shopping  function, on YouTube or on Gmail. 
  • Other marketing services of Google’s we use include Google Search which  places our adverts within search results; Google Display Network which  makes available to us advert space on third party websites; and Google  Remarketing which places our company’s adverts on third party websites  following a user having visited our website. These services use cookies  (and in some instances information held in your Google account, if you  have one) in order to build profiles about you, for the purposes of providing  you with personalised adverts. See section 7 below for further details on  cookies. 
  • You can find out more about how your personal information may be used in  connection with Google’s advertising functions and options for opting out  here: www.google.co.uk/intl/en/policies/technologies/ads
  • If you object to profiling made in relation to you or would like more information  about the personal information which has been used to create a profile, you  may contact us directly.

4. Legal basis for processing

In terms of the legal bases we rely on to process your personal information,  these are as follows:

  • where you have provided your consent: for direct marketing  communications in respect of our own products and services,  including in respect of marketing communications sent by electronic  means (e.g. email and SMS); 
  • for the performance of a contract with you (such as a contract for the  provision of good and services) or to take steps at your request prior  to entering into this contract;
  • to comply with legal obligations, including in relation to health and  safety and environmental legislation, performing anti- money  laundering, terrorism prevention and sanctions screening checks,  complaints and investigations or litigation;
  • to protect your vital interests or the vital interests of another person,  e.g. where you or they are seriously injured or ill, or 
  • for our legitimate interests in:
  • management of your account (including processing payments) and  our relationship with you, and communicating with you 
  • operating our Websites 
  • sending direct marketing in respect of our own products and  services where you have not provided your consent and the  marketing communication is sent by non-electronic means (e.g. post  or telephone); processing orders and supplying our products and  services; and 
  • our internal business purposes which may include processing for  the purposes of: record keeping, research, reporting and statistics,  data security, to ensure the quality of our products and services,  investigating and responding to queries and complaints, obtaining  credit references and credit checks, providing payment performance  data to credit reference agencies, changing our pricing, debt  collection, fraud detection and prevention, risk management,  recruitment and training of our personnel, and protecting our rights,  property and safety (and that of others). You can object to  
  • processing carried out based on our legitimate interests at any time  by contacting our company.

See also “Your Rights – The right to object”

5. How we share your personal information In addition, we may share your personal information with:

  • third party provider(s) who provide the following types of  services to us: marketing, market research, warehousing and  logistics, software, recruitment and customer relationship management;
  • third party providers for us to process payments that are due  to us, in doing so we provide bank card details to such  providers.
  • third party providers and agents we appoint as our sales  agents or to perform services on our behalf, who are provided  with access to certain customers account details to process  sales or provide services on our behalf.
  • third party advertising partners, such as Google in order for  them to assist us in providing you with targeted adverts (as  explained above);
  • third party loyalty schemes that you are enrolled in so that  they can award your points/rewards and otherwise handle  
  • your personal information in accordance with the terms and  conditions applicable to that scheme;
  • licensed credit reference agencies, debt collection agencies  and lawyers when we carry out credit checks, to report on  
  • your payment performance and/or or seek to recover debts due to us;
  • our accountants, auditors, lawyers or similar advisers when  we ask them to provide us with professional advice;
  • emergency services if we need to report accidents or incidents or request emergency assistance.
  • any Government Department, public body or other third party  where we believe in good faith that the law requires this; in the  interests of public health and safety; or to protect the rights,  property, or safety of our company its employees or others.
  •  investors and other relevant third parties in the event of an  actual or potential sale or other corporate transaction related  to our company.
  • any other third parties, if authorised by you to do so. 

We ensure that, where your personal information is transferred to any  country outside the European Economic Area this is done using “model  clauses” (standard contractual clauses which have been approved by the  European Commission as providing adequate safeguards to enable personal data to be transferred outside the European Economic Area) or  other specific legally-approved safeguards. You can request further details  and/or a copy of the relevant safeguards by con tact our company directly.  The performance of services by our third-party service provider(s) may be  subject to a separate privacy statement provided to you by the relevant  third party. You should read any such statement carefully.

6. How long we keep your personal information We retain your personal information for no longer than is necessary for the  purposes for which the personal information is collected. When  determining the relevant retention periods, we will consider factors  including:

  •  legal obligation(s) under applicable law to retain data for a  certain period. 
  • statute of limitations under applicable law(s);
  • (potential) disputes, and;
  • guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information once this is no longer  needed.

7. Cookies

Where you use our Websites, we will process your personal information  collected by using cookies in accordance with our Cookie Policy.

8. Links to third party websites

  • Our Websites contain links to other Internet websites. Unless otherwise  explicitly stated, we are not responsible for the privacy practices or the  content of such websites, including such sites use of any personal  information. Nevertheless, in the event you encounter any third party  associated with our Websites (or who claims association with our  Websites) who you feel is improperly collecting or using information about  you, please contact us directly and we will be happy to forward your  message to the third party.
  • If and when we sponsor promotions, or third parties sponsor promotions in  conjunction with our website, either we or the third party will post relevant  privacy information in the official rules and/or registration area for the  promotion. That privacy information, to the extent (if any) it conflicts with  this Privacy Statement, will govern that promotion.

9. Security

  • We use reasonable security methods to protect the personal information  that we process, including Internet standard encryption technology (“SSL or “Secure Socket Layer “technology) to encode personal information that  you send to us through our websites. SSL works by using a private key to  encrypt data that’s transferred over the SSL connection. To check that you  are in a secure area of the Website before sending personal information to  us, please look at the bottom right of your website browser and check that  it displays an image of a closed padlock or an unbroken key.
  • However, please note that whilst we take appropriate technical and  organisational measures to safeguard the personal information that you  provide to us, no transmission over the Internet can be guaranteed to be  secure. Consequently, please note that we cannot guarantee the security of  any personal information that you transfer to us over the Internet.

10. Your rights

The following section explains your rights. The various rights are not  absolute, and each is subject to certain exceptions or qualifications.

We will grant your request only to the extent that it follows from our  assessment of your request that we are allowed and required to do so  under data protection laws. Nothing in this Privacy Statement is intended to  provide you with rights beyond or in addition to your rights as a data  subject under data protection laws.

1. The right to be informed 

  • You have the right to be provided with clear, transparent and easily  understandable information about how we use your personal information  and your rights. Therefore, we’re providing you with the information in this  Privacy Statement.

2. The right of access

  • You have the right to obtain a copy of your personal information (if we’re  processing it), and other certain information (similar to that provided in this  Privacy Statement) about how it is used.
  • This is so you’re aware and can check that we’re using your personal  information in accordance with data protection law.
  • We can refuse to provide information where to do so may reveal personal  information about another person or would otherwise negatively impact  another person’s rights.

3. The right to rectification

  • You can ask us to take reasonable measures to correct your personal  information if it’s inaccurate or incomplete. E.g. if we have the wrong date  of birth or name for you.

4. The right to erasure

  • This is also known as ‘the right to be forgotten’ and, in simple terms,  enables you to request the deletion or removal of your personal  information where there’s no compelling reason for us to keep using it or  its use is unlawful. This is not a general right to erasure; there are  exceptions, e.g. where we need to use the information in defence of a legal  claim.

5. The right to restrict processing

  • You have rights to ‘block’ or suppress further use of your personal  information when we are assessing a request for rectification or as an  alternative to erasure. When processing is restricted, we can still store your  personal information, but may not use it further. We keep lists of people  who have asked for further use of their personal information to be ‘blocked’  to make sure the restriction is respected in future.

6. The right to data portability 

  • You have rights to obtain and reuse certain personal information for your  own purposes across different organisations. This enables you to move,  copy or transfer your personal information easily between our IT systems  and theirs (or directly to yourself) safely and securely, without affecting its  usability. This only applies to your personal information that you have  provided to us that we are processing with your consent or to perform a  contract which you are a party to (such as pay and compensation services),  which is being processed by automated means.

7. The right to object

  • You have the right to object to certain types of processing, on grounds  relating to your situation, at any time insofar as that processing takes place  for the purposes of legitimate interests pursued by our company or by a  third party. We will be allowed to continue to process the personal  information if we can demonstrate “compelling legitimate grounds for the  processing which override [your] interests, rights and freedoms” or we  need this for the establishment, exercise or defence of legal claims. 
  • You have the right not to be subject to a decision based solely on  automated processing (including profiling), which significantly affects you,  subject to some exceptions. Where this is the case, you have the right to  obtain human intervention, voice your concerns and to have the decision  reviewed.

11. Updating this statement

  • We review our privacy practices from time to time. We ask that you  bookmark and periodically review this page for updates to our Privacy  Statement. We reserve the right to modify this policy effective seven (7)  days after the posting of the revised Privacy Statement.

12. Contact us

  • For further information regarding these rights, about this Privacy Statement  generally or to make a complaint please contact our company. 
  • Please provide as much information as possible to help us identify the  information you are requesting, the action you are wanting us to take and  why you believe this action should be taken.  
  • Before assessing your request, we may request additional information in  order to identify you. If you do not provide the requested information and,  as a result we are not able to identify you, we may refuse to action your  request.  
  • We will generally respond to your request within one month of receipt of  your request. We can extend this period by an additional two months if this  is necessary considering the complexity and number of requests that you  have submitted.

We will not charge you for such communications or actions we take,  unless:

  • you request additional copies of your personal data undergoing processing, in which case we may charge for our  reasonable administrative costs, or
  • you submit manifestly unfounded or excessive requests, in  particular because of their repetitive character, in which case  we may either: (a) charge for our reasonable administrative  costs; or (b) refuse to act on the request.

If after contacting our company you are still unhappy you may also  complain to the Information Commissioner, all contact details are available  on the Information Commissioners Website: dataprotection.ie