Privacy Notice

 

Privacy

We treat data privacy with the utmost importance. This statement sets out how we, as a data controller, collect and process personal data about:

• visitors to our websites

• subscribers to or users of our online services

• individuals who we communicate or interact with in the course of our business

• individuals whose personal data is provided to us in connection with the provision of our services

• individuals who apply for jobs through our website

Our “websites” includes this website, all our associated sites (such as our knowledge sites and blogs) and our social media pages. This statement also sets out information about data subject rights and our obligations under data protection law.

 

Controller

JW O’Donovan is the controller and responsible for your personal data (collectively referred to as “JW O’Donovan”, “we”, “us” or “our” in this privacy notice). Our full details are on the Contact Us page of our website.

You have the right to make a complaint at any time to the Data Protection Commission (“DPC”), the Irish supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

 

Inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-party links

Our website may, from time to time, contain links to and from other websites, plug ins and applications which allow third parties to collect or share data about you. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do 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 do we collect any information about criminal convictions and offences.

 

Type of data collected and why

Purpose/Activity	Type of data	Lawful basis for processing
To manage our relationship with you which will include: (1) Notifying you about changes to our terms or privacy policy (2) Recruitment and selection	• Identity • Contact • Profile • Application details • Marketing and Communications	• Performance of a contract with you • Recruitment and selection processes • Necessary to comply with a legal obligation • Necessary for our legitimate interests (to keep our records updated and to study how clients use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)	• Identity • Contact • Technical	• Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) • Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	• Identity • Contact • Profile • Usage • Marketing and Communications • Technical	Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business, and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships, and experiences	• Technical • Usage	Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to you	• Identity • Contact • Technical • Usage • Profile	Necessary for our legitimate interests (to develop our services and grow our business)

(a) Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

(b) Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

(c) Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or received services from us and, in each case, you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any outside company for marketing purposes.

 

DISCLOSURE OF YOUR INFORMATION

We may disclose personal data to:

• Third parties, including cloud service providers, who provide a service to us

• A public authority in the event that we are required to do so by law

• A third party where we are under a legal obligation to transfer it to that third party or where we provide it on behalf of a client who is under such legal obligation

• A prospective seller or buyer of any of our assets or business

• A third party where it is necessary to protect the vital interests of the data subject or another natural person

• Third parties who we partner with to organise or sponsor events

• Third parties who tender to or provide services or goods to us

To the limited extent that it is necessary to transfer personal data outside of the EEA, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data, including standard contractual clauses under Article 46.2 of the GDPR. Please contact us if you wish to obtain information concerning such safeguards (see Contact Us below).

 

DATA SUBJECT RIGHTS

To the extent that we are a controller of your personal data you may request access to, rectification, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability. In each case, these rights are subject to restrictions as laid down by law. The following is a summary of your rights:

• The right of access enables you to receive a copy of your personal data

• The right to rectification enables you to correct any inaccurate or incomplete personal data we hold about you

• The right to erasure enables you to ask us to delete your personal data in certain circumstances

• The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances,

• The right to object enables you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party)

• The right to data portability enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.

You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

If you wish to exercise any of these rights, please contact us (see Contact Us below). We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request where there is a basis to do so in law, or if your request is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.

In limited circumstances (such as our use of social media), we may act as a joint controller with another party.  In such circumstances, upon your request to exercise any of the above rights we will advise you if there is another controller who you should contact.  Please note that any other joint controller will also have its own privacy policy.