The terms "personal data", "data controller", "data processor", "process" and "processing" have the same meaning as set out in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “GDPR”).
The Site is not intended for children and the Operator does not knowingly collect data relating to children.
1. IMPORTANT INFORMATION
The “data controller” within the meaning of the GDPR is the legal person responsible for the processing of personal data and which decides alone or in cooperation with others which personal information (which includes Personal Data as defined under the GDPR and set out below) is being collected as well as the purposes and the technical and organizational means with regard to the processing of that personal information.
You have the right to make a complaint at any time to the Data protection Commission (the "DPC"), the Irish supervisory authority for data protection issues using the contact details provided here. The Operator would, however, appreciate the chance to deal with your concerns before you approach the DPC.
2. THE DATA COLLECTED ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
The Operator may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Profile Data includes any username and password used by you to create an account (if applicable), your interests, preferences, feedback and survey responses.
The Operator does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) – nor does it collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where the Operator needs to collect personal data by law, or under the terms of any contract with you, and you fail to provide that data when requested, the Operator may not be able to perform the contract or enter into the contract with you.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
The Operator will only collect personal data from you in limited circumstances – specifically direct interactions via the Site. This may include you providing the Operator with your identify or contact data by filling in forms or by corresponding with the Operator by post, phone, email or otherwise. Other circumstances where your personal data may be collected include when you:
enter a survey or
provide feedback to or otherwise contact the Operator.
4. HOW YOUR PERSONAL DATA IS USED
The Operator will only use your personal data in accordance with the law and particularly the GDPR. Most commonly, the Operator will use your personal data in the following circumstances:
- Where the Operator needs to perform a contract it is about to enter into or has entered into with you.
- Where it is necessary for the Operator's legitimate interests (or those of a third party) – and your interests and fundamental rights do not override those interests.
- Where the Operator needs to comply with a legal obligation.
PURPOSES FOR WHICH YOUR PERSONAL DATA IS USED
Set out below is a description of the ways the Operator may use your personal data, and which of the legal bases under the GDPR it relies on to do so. Also identified are the legitimate interests of the Operator for such use.
COOKIES AND GOOGLE ANALYTICS
CHANGE OF PURPOSE
The Operator will only use your personal data for the purposes for which it was collected, unless it reasonably considers that it needs to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the Operator. If the Operator needs to use your personal data for an unrelated purpose, it will notify you and will explain the legal basis which allows it to do so. Please note that the Operator may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. THIRD PARTY AND INTERNATIONAL TRANSFERS
The Operator will not transfer your personal data outside the European Economic Area. Save for the circumstances outlined at 7 (Data Security) below, the Operator will not transfer your personal data to third parties. As mentioned above, the Site uses the third-party Google Analytics tool. Please note that Google may transfer your data outside of the European Economic Area (i.e. to the United States). Please see here for information from Google as to the legal frameworks it relies on for these data transfers.
7. DATA SECURITY
The Operator has put in place appropriate technical and organisational security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, the Operator limits access to your personal data to those employees, agents, contractors and other third parties who have a legitimate need to access it (for example, where Site maintenance is being carried out by the Operator's IT services provider). They will only process your personal data on the Operator's instructions and they are subject to a duty of confidentiality.
The Operator will notify you and the DPC of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
The Operator will only retain your personal data for as long as reasonably necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, regulatory, reporting requirements. The Operator may retain your personal data for a longer period in the event of a complaint or if it reasonably believes there is a prospect of litigation in respect of its relationship with you.
To determine the appropriate retention period for personal data, the Operator considers the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which it processes your personal data and whether it can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are the rights to request the transfer, access to, erasure of and / or correction of your personal data. You also have the right to object to the processing or request the restriction of your personal data. You also have the right to withdraw your consent to the processing of your personal data. If you wish to exercise these rights, please contact the Operator.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, the Operator may charge a reasonable fee in certain circumstances or refuse to comply with your request if it is unfounded, repetitive or excessive.