PRIVACY POLICY

SPEIRE INNOVATION LIMITED is a Company incorporated under Irish law with Company Number 641814 having its registered office at The Rubicon Centre, Bishopstown, Co. Cork (the”Company”).    We are fully compliant with the General Data Protection Regulation (“GDPR”) and all applicable legislation made in the Republic of Ireland thereunder.   The purpose of this policy is to explain how our organisation uses the personal data we collect from you when you use our website and services.    This privacy policy sets out how the Company uses and processes any information which you give to us.   We respect your privacy and are committed to protecting your personal information.

Our Data Protection Representative is Stephen Wilson Downey who can be contacted at Stephen@speire.ie

What Data do we collect?

We may collect personally identifiable information and data in relation to our Customers and prospective customers.

Our Company collects the following data:

  • Name
  • Address
  • Email address
  • Telephone number
  • Occupation
  • Tax Number
  • Log in details/ Credentials
  • Photographs
  • Digital Communications
  • Hosting Details
  • IP Address
  • Financial Information (in exceptional circumstances only)

In limited circumstances, we may also obtain certain sensitive personal data from our data subjects with their express consent where necessary for performance of our obligations and provision of our services.  Where such information is provided, the information will be shared only where necessary taking into account the nature of the information provided and the proposed services. Sensitive data will not be retained for any longer than necessary for the performance of the Contract with the Company.   We will not disclose sensitive personal data without your consent, reliance of the contractual obligations, specifically authorised or required by law, protection of the vital interest of the Data Subject or of any other natural person or where necessary for the establishment, exercise or defence of legal claims.  We will ensure that processing of sensitive personal data is carried out in compliance of the GDPR at all times.

// How do we collect your Data?

The Company collects data from our data subjects and process it in the provision of our products and services as aweb development,branding, graphic designand marketing company.

We will collect data from our customers and prospective customers through our website and directly from our customers and in particular throughany email, telephone or personal enquiries made by our customers. We will also continue to collect their data through the performance of our obligations pursuant to the contract with youfor provision of web development branding services. The Company will operate as a Data Controller in respect of the personal data supplied by its customersand prospective customers.We will collect personal data about you through the meetings, instruction forms, telephone consultationsand any questionnaires which you may be asked to complete in the context of the provision of our products and services together with records of all correspondence telephone calls, emails, details of your visit to the website, publicly available information including social media and through use of browser cookies. Our company will collect data primarily by way of direct production of same by the data subject. On occasion we may also receive your data indirectly via publicly available information including social networking sites.

// How will we use your Data?

Our Company collects Data from our customers and prospective customers so that we can:

  • Process your request for information regarding our services and products
  • To prepare a scope of work and proposals for provision of products and services
  • To enable you and us to manage your account for the provision of those products and services
  • To contact you with special offers on other products and services and updates which may be of interest to you
  • To engage with you and respond to any requests which you may have.
  • To improve our level of products and services
  • For general marketing purposes which are in the legitimate interest of our business
  • To process payments in connection with the provision of products and services to you
  • To enable us to comply with our legal and contractual obligations to you and third parties
  • To meet our legal and statutory obligations (including, defence of legal claims, if applicable)

// Basis of processing Data

The Company will process data on behalf of natural persons comprising their customers, prospective customers, employees and contractors and will ensure that your data is processed in a lawful, clear and transparent manner at all times for a specific and legitimate purpose.  The Company relies on the following legal basis for the processing of data.

  1. Processing necessary for the performance of a Contract
  2. Processing necessary for the compliance with a legal or statutory obligation
  3. To protect the vital interest of a Data Subject
  4. With the consent of the Data Subject for one or more specific and legitimate purposes.
  5. Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller
  6. Processing necessary for the purposes of the legitimate interest pursued by the Controller or a third party except where such interest is overridden by the fundamental rights and freedoms of the Data Subject.

Where we rely on the legitimate interest of the Company for the processing of the personal data, we will take all reasonable measure to ensure that the interests of the Data Subject are protected. The legitimate interests of the Company in this context include direct marketing, prevention of fraud and information system security. 

We will rely on our legitimate interests as a company to process your data for direct marketing purposes. We consider it to be a legitimate interest of our company in promoting its services, products and in the administration operation of our business. Any such processing will not be carried out where such interest is overridden by the rights and freedoms of the Data Subject. In all direct marketing communications, we will give an unsubscribe option. A Data Subject can unsubscribe at any time.

We will only rely on consent as the basis for processing in limited circumstances. Where consent is utilised as the basis for processing, such consent can be withdrawn at any time. In that event, we will cease processing your data, unless there is a separate basis upon which we can rely to process your data, such as same being necessary for the performance of the contract between us or necessary for us to comply with our legal and statutory obligations.

// How do we store your Data?

The Company securely stores your data at Rubicon Centre, Bishopstown, Cork. We also utilise secure cloud storage.  We will ensure the appropriate, technical and organisational measures are put in place commensurate with the level of security required for the data  held on your behalf.   We will use all appropriate and reasonable measure to ensure integrity and confidentiality of the personal as maintained at all times.

// Marketing

Our Company would like to send marketing information to you about the products and services which we think will be of relevance to you.   We will always give you an option to unsubscribe from our marketing list, please contact Stephen Wilson Downey at Stephen@speire.ie [1] if you wish to unsubscribe from our marketing list.  You have a right to object to our processing your data for direct marketing purposes at any stage.

[1] You could consider a hyperlink here with an unsubscribe form ?

// Sharing of Personal Data

It may be necessary for us to share your personal data with third parties to enable us to comply with our legal and statutory obligations and to perform the contract between us.   Where such sharing is required, we will ensure that the third parties have in place a sufficient data protection policy to ensure the safety and security of your data.  We will never provide your data to third parties for marketing purposes.  We will need to share your data with our third party hosting partners and service delivery providers to perform the Contract between us. We may also share your data with our professional advisors where necessary including lawyers, bankers, auditors and insurers who provide professional services necessary for the operation of the business of the company.  We do not propose to transfer personal data to any parties not resident within Europe.

// Data Retention

The Company will keep your data for no longer than necessary for the purpose for which the data was provided taking into account the basis for processing the data.   The retention periods are as follows:

 

Data  TypeRetention Period
Customer Contact Information (name, address, email address, telephone number)Two years after the completion of the project or provision of the goods or services (or most recent provision of the goods or services as appropriate) including for the avoidance of doubt maintenance contracts.  In the event that the relationship is a continuing relationship on the basis of a subscription or maintenance contract, then we will retain data for two years  following termination of the relationship between us.
Financial Information (including credit card information)One month after the termination of the relationship or contract between us or one month after receipt of the last payment from you, whichever is the longer.
Personal Injury, accidents, damage, property or other loss sustained by any third party in the course of its relationship with the CompanyThree years following the date of the alleged incident or in the event that the party is a minor, three years after the minor reaches the age of 18 years.  In the event that proceedings are issued or any notification of a claim is made, then the Company may retain the data for as long as may be necessary until the proceedings have been concluded.
Data Law Compliance recordsin relation to our compliance with Data Law and GDPR will be kept for a five year period
Revenue Commissioners, Collector General, Companies Acts legislative provisionsSix years rolling retention of records to enable compliance with legislative provisions.
Breach of Contract related recordsSix years from the date of the alleged breach and in the event that proceedings are issued, the Company may retain the data for so long as may be necessary until the proceedings have been concluded.
Cookie Data6 months

// Rights of Data Subject

You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:

  • Right to access data – you have the right to request a copy of the personal data that we hold about you together with other information about our processing of that personal data.
  • Right to rectification – you have the right to request that any inaccurate data that is held about you is corrected or if we have incomplete information you may request that we request that we update the information such that it is complete.
  • Right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as a right to be forgotten.
  • Right to restrict processing or object to processing – you have the right to request that we no longer process your personal data for particular purposes or object to our processing of your personal data for a particular purpose
  • Right to data portability – you have the right to request us to provide you or a third party with a copy of your personal data in a structured commonly used readable format.
  • Right to object to processing – you have the right to object to processing of data under certain conditions.

If you wish to exercise any of the rights set out above, please contact Stephen Wilson Downey at Stephen@speire.ie

We ask that you ensure that all data which you furnish to us is kept accurate and up-to-date at any stage.  We cannot be held responsible for your failure to provide us with up-to-date information.

If we were processing personal data on the basis of your consent, you may withdraw consent at any time.  This does not affect the lawfulness of processing which should take place prior to its withdrawal. You can object to the processing of your personal data for direct marketing purposes at any stage.

If you are unhappy with how we process your personal data we ask that you contact us so that we can rectify the situation.  You may lodge a complaint with the Supervisory Authority of the Irish Supervisory Authority of the Data Protection Commission.

// Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information.  Please see our Cookie policy here.

// Automated decision-making and profiling

We do not use personal data for the purposes of automated decision-making or profiling.

// Changes to this Privacy Notice

Our privacy notice may change from time to time.   Any change to the Statement we post on this page. Please check back frequently to see how many updates or changes to our private policy have been implemented.  If you do not agree to these changes or any of the terms of this policy, please do not continue to use this website to submit personal information.

Date : 10th June, 2019

 

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