As a data subject, you have the following rights under Data Protection Legislation and we, as
Data Controller in respect of Your Data, will comply with such rights in respect of Your Data:
- 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 with direct marketing;
- rights in relation to automated decision taking;
- 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 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
of 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 (see Sections 2 and
3 above);
- details of the purpose for which it is being or is to be processed (see Section 3 above);
- 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
(see Section 8 below);
- details of the period for which it is held or the criteria we use to determine how long it
is held (see Section 13 below);
- details of your rights, including the rights to rectification, erasure, restriction or
objection to the processing (set out in this Section 6);
- any information available about the source of that data (see Section 2 above);
- 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 (please note that we do not currently carry out any profiling – we will notify
you by updating this Privacy Policy if this changes); and
- where your Personal Data are transferred out of the EEA, what safeguards are in place (see
Section 8 below).
Details in respect of the above points are all set out in this Privacy Policy; however, if you
need further clarification, please contact us (see ‘How To Contact Us’ below). 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 of such request may be kept by us for our legitimate purposes in
managing the Service and our website. 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 also 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 Date 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 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 with direct
marketing We have a legitimate interest to send you electronic communications in
connection with the Service and related matters (which may include but shall not be limited to
newsletters, announcement of new features etc.). We may also ask you for your consent to send
you direct marketing from time to time. We may also ask you different questions for different
services, including competitions. We may also ask you to complete surveys that we use for
research purposes, although you do not have to respond to them. You can ask us to stop
contacting you for direct marketing purposes. If you would like to do this, please:
- email or write to us (see ‘How can you contact us’ below). You can also click on the
‘unsubscribe’ button at the bottom of the electronic communication. It may take up to 15
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 direct marketing – this
may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing
from direct marketing does not unsubscribe you from essential electronic communications in
respect of the administration of Your Account. Rights in relation to automated decision
taking (if applicable) You may ask us to ensure that, if we are evaluating you, we
don’t base any decisions solely on an automated process and have any decision reviewed by a
member of staff. Profiling may occur in relation to your Personal Data for the purposes of
targeted advertising and de-targeting you from specified advertising. This allows us to tailor
our advertising to the appropriate customers and helps to minimise the risk of you receiving
unwanted advertising. These rights will not apply in all circumstances, for example where the
decision is (i) authorised or required by law, (ii) necessary for the performance of a contract
between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour
that steps have been taken to safeguard your interests. Right to restrict or prevent
processing of Personal Data In accordance with Data Processing Legislation, you may
request that we stop processing your Personal Data temporarily if:
- you do not think that your Personal Data is accurate (but we will start processing again
once we have and confirmed that it is accurate);
- the processing is unlawful but you do not want us to erase your Personal Data;
- we no longer need the Personal Data for our processing; 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 Personal 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. In addition, 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
(please see ‘How To Contact Us’ below) 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 Privacy 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 Personal 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 (i.e. where we have a legal justification to continue to hold such
Personal Data, such as it being within our legitimate business interest to do so (e.g. retaining
evidence of billing information etc.). 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 Privacy 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