INTRODUCTION
This is a notice to inform you of our policy regarding the information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the legislation and this notice, “process” means collect, store, transfer, use or otherwise act on information.
Our policy complies with the Data Protection Act 2018. By visiting the website of the Data Controller, the Data Subject (“visitor”, “you”) accepts the terms of this privacy policy.
We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them.
The law requires us to tell you about your rights and our obligations to you regarding the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.dataprotection.ie
PERSONAL INFORMATION WE COLLECT ABOUT YOU
We currently collect and process the following information:
- Personal identifiers, contacts and characteristics (for example, name, address, email and contact number, IP addresses)
- Payment information: financial information such as bank account or revenue information in order to facilitate the processing of payments
- Any information provided to us on your behalf to allow us to carry out our service to you
We do not collect special categories of personal data about you. Special categories of personal data are as follows:
Racial origins, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data, criminal convictions, or offenses.
WHEN YOU VISIT OUR WEBSITE
We use a third-party server to host our website called Siteground, the privacy policy of which is available here; Siteground Privacy Policy.
Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (eg the website or URL link) which referred you to our website), and your browser version and operating system.
USE OF WEBSITE SERVER LOG INFORMATION FOR IT SECURITY PURPOSES
We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make nor do we allow our hosting provider to make, any attempt to identify you from the information collected via our server logs.
COOKIES
A cookie is a text file containing information that can be remembered by a web browser between pages. When an individual uses a web browser to access the internet their browser can create cookies which are stored on the users computer or whatever device they are using. Cookies are not programs and therefore cannot contain viruses or other malicious software. They are purely a string of text and numbers.
HOW DO WE USE COOKIES
Unemployable Promotions use cookies to record how our visitors use and browse around our website; unemployablepromotions.com. Cookies help us determine popular and unpopular pages and lets us know where we need to improve our service offering.
Google Analytics is a system used by many websites to record information about visits to their website. Google set six different cookies with expiry dates ranging from 30 minutes to 2 year. These cookies are used mainly to differentiate between first-time visitors to a website and repeat visitors. They also allow us to ensure our website performs as well as possible for our users. The cookies are able to collect an anonymous customer number when a user is logged into the website, allowing our backend systems to ensure accuracy of Google Analytics Data and help us ensure your website experience remains relevant across devices. They do not contain any personally identifiable information. You can find out more about how Google use cookies at http://www.google.co.uk/policies/privacy/ These cookies may be used to help us target advertising on platform providers such as Google and Facebook.
HOW WE GET THE INFORMATION AND WHY WE HAVE IT
DIRECT INTERACTIONS
You may provide us with your personal information when you;
- Fill in the query form on our website
- Correspond with us via email, phone or otherwise
- Meet with us on a one-to-one and provide us with your business card, for example.
Most of the personal information we process is provided to us directly by you, however we also receive personal information indirectly, from the following sources in the following scenarios:
Facebook, Linkedin, Twitter, google analytics
From visiting these pages, or interacting with us, you are passing information on to us via the above platforms, these are known as cookies. This type of information is technical data about your computer equipment, browsing actions and preferences.
We also may have access to your publicly available details from these sources.
We are required to determine the legal basis for which we process different categories of your personal information, and to notify you of the basis for each category. If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Most of the personal information we process is provided to us directly by you for one of the following reasons:
INFORMATION WE PROCESS BECAUSE WE HAVE A CONTRACTUAL OBLIGATION WITH YOU
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- Set up your account as a client with us
- Liaising with you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We may share this information with third parties in order to process the purchasing transaction of our services. These companies must also adhere to the same data protection legislation. If you would like further information about the identities of our service providers please contact us directly by email.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
INFORMATION WE PROCESS FOR THE PURPOSES OF LEGITIMATE INTERESTS
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do so after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would consider it reasonable to do so
For example, we may process your data on this basis for the purpose of;
- necessary administration of our business – for example, creating your client account
- responding to unsolicited communication from you which we believe you would expect a response
- Where you have enquired about service and we are following up on the information provided
- Processing payments and invoices
INFORMATION WE PROCESS BECAUSE WE HAVE A LEGAL OBLIGATION
We may be required to give information to legal authorities if they so request and subject to the correct authorisation.
We also may be required to process your data in order to comply with common or statutory law.
What we do with the information;
- verify your identity for security purposes
- process financial transaction
- sell products to you
- provide you with our services
- keep our website safe and secure
If there are any regulatory requirements to process your personal data whilst carrying out any of the above, we are obliged to do so.
SHARING YOUR DATA
We may pass your personal data on to third-party service providers contracted to Unemployable Promotions in the course of dealing with you in order to provide our services to you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with the General Data Protection Regulation.
The third parties we pass your personal data to are:
Web hosting provider,
IT Cloud Service Providers
Selected business providers, suppliers and contractors to provide you with our services.
We have issued all our third-party processors with a Data Processor agreement and/or checklist to ensure they are GDPR compliant.
In the event that we buy or sell any business or assets, it may be necessary to disclose personal data to the prospective buyer or seller.
DATA TRANSFERS
In some circumstances, it may be necessary for us to transfer your data outside the European Economic Area (EEA). We will only transfer data to receivers that are in countries approved by the EU Commission, or where there are the appropriate safeguards in place to protect your personal data. For further information on these appropriate safeguards, please email unemployableltd@gmail.com
SECURITY
There are appropriate security measures in place to protect your data in the event of being accidentally lost or accessed without authorisation including;
- Your data is also limited to only the necessary parties that need to process your data for business purposes.
- Using secure servers to store your information
- Verifying the identity of any individual who requests access to information prior to granting them access to information
- Using secure sockets layer (SSL) software to encrypt any payment transactions you make on or via our website;
- Using encryption to secure personal data
- Only transferring your information via closed system or encrypted data transfers*
*transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
YOUR DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information
- Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances
- Your right to object – You have the right to ask us to stop processing your personal data for profiling or direct marketing
- Your right to restriction of processing – You have the right to object to the processing of your personal data in certain circumstances
- Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at unemployableltd@gmail.com if you wish to make a request.
HOW TO COMPLAIN
You can also complain to the Data Protection Commission if you are unhappy with how we have used your data.
The Data Protection Commission address:
21 Fitzwilliam Square South
Dublin 2
D02 RD28