At exclusion.ie we are committed to safeguard the privacy of our Website visitors, as well as Service users.
This policy applies where we are acting as a data controller with respect to the personal data (in accordance with Article 4 (1) GDPR) collected of our Website visitors and Service users whenever and where we determine the purposes and means of the storing and/ or processing of that personal data to be collected.
In this policy “we”, “us” and “our/s” refer to webmedia.ie.
1. HOW WE USE YOUR PERSONAL DATA
The storing and/ or processing of data through our website and for the purpose of providing our Services, are based on our legitimate interest (in accordance with Article 6(1)(f) GDPR) to monitor and improve both our Website itself and the Services associated with it. With respect thereto, we may store and/ or process personal data following the provisions of Article. 13(1) GDPR:
(1.) data about your use of our website and of our Software, as well as about our services provided with respect thereto (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, length of visit, and website navigation paths, as well as information about the timing, and frequency. The source of the usage data is our analytics tracking system. This usage data may be stored and/ or processed for the purposes of analyzing the use of the website and its services;
(2.) data that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be stored and/ or processed for the purposes of sending you the relevant notifications and/or newsletters;
(4.) Information contained in an enquiry you submit to us regarding our services (“enquiry data”). The enquiry data may be stored and/ or processed for the purposes of offering Software, certain Services related to this Software, as well as to perform marketing.
(5.) Data related to communication you send to us (“correspondence data”) The correspondence data may include any form of communication content and metadata associated with the communication. Correspondence data may be stored and/ or processed for the purpose of record-keeping.
(6.) data that you provide in the course of the use of our services (“service data”). Service data may be stored and/ or used for the purposes of ensuring the quality and proper functioning of our website and our Services, to provide technical support and customer care.
(7.) Information relating to monetary transactions related to our Services, as well as relating to order details (“transaction data”). Transaction data may include personal information such as names, payment information, billing address and other related data. Transaction data may be stored and/ or processed for the purpose of processing payments and/ or detecting incorrect order details.
We do not store and or process any other person’s personal data and thus ask you not to provide such data unless and until we prompt you to do so.
2. PROVIDING PERSONAL DATA TO OTHERS
We may disclose any of the above-mentioned data to any member of our company in accordance with Article 13(1)(e) GDPR insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. We may disclose any of the above-mentioned data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose necessary information of the above-mentioned, to our payment service providers whenever financial transactions relating to our Website and Services are being conducted. We will share transaction data with our payment service providers only to the extent necessary for the purpose of processing your payments, refunding payments and/ or dealing with complaints relating to such payments and/ or refunds.
In addition to the disclosure of data set out herein, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your interests as a natural person or the interests of another natural person. We may also disclose your personal data where such disclosure is necessary with respect to litigation whether in court proceedings or in an administrative or out-of-court procedure.
In any event, in which personal is disclosed, we guarantee to follow all provisions made under Articles 13(1)(e) and 14(1)(e) GDPR.
3. RETAINING AND DELETING OF PERSONAL DATA
All personal data that we store and/ or process for any purpose or purposes mentioned herein shall not be kept for longer than is necessary for that or those purposes.
Your personal data will be retained as follows:
(a) “usage data” – will be retained for a minimum period of two (2) years following the date at which the website and its contents are viewed from your personal computer/ mobile device.
(b) “notification data” – will be retained for a minimum period of two (2) years following the date at which you agree on our website that you wish to receive notifications.
(c) “account data” – will be retained for a minimum period of two (2) years following the date at which you add the account data to our system.
(d) “enquiry data” – will be retained for a minimum period of two (2) years following the date at which you enter an enquiry into our system.
(e) “correspondence data” – will be retained for a minimum period of two (2) years following the date at which you opt to get in touch with us.
(f) “service data” – will be retained for a minimum period of two (2) years following the date at which you make an action to either seek technical support or reach out for customer help in any way.
(g) “transaction data” – will be retained for a minimum period of two (2) years following the date at which the transaction is made.
Irrespectively of the period of two (2) years mentioned above, we retain personal data of long-term customers for as long as the business relation exists with these customers and up to two years after such business relation is terminated. We also recognize that in certain cases (such as in the event of i.e. disclosure due to litigation) it is not possible for us to specify in advance the periods for which your personal data will be retained.
4. INTERNATIONAL DATA TRANSFERS, STORING AND/ OR PROCESSING
Since we commit to outsourcing certain tasks here at exclusion.ie, your data may be transferred to, stored and/ or processed in countries outside of the EEA. The European Commission has made a so called “adequacy decision” with respect to data protection laws of non-EEA countries. Transfers, storing and or processing to and in those countries will be protected by standard data protection clauses adopted or approved by the European Commission. For non-EEA countries to which no “adequacy decision” has yet been made, please find Regulations (EU) 2016/679 and (EU) 2016/680.
Our outsourcing partner 3edgetechnologies.com is located in India. The European Commission has not yet made an “adequacy decision” with respect to the data protection laws of this country. Transfers to this country are made via Simple Mail Transfer Protocol (SMTP), secured by Transport Layer Security (TLS). Although we deploy all necessary measures to make sure your data is protected when transferred internationally, we recognize that circumstances beyond our control may cause your data to be disclosed to third parties at certain points. With respect thereto, you acknowledge that the personal data submitted to us through your proactive act of submission either through our Website or otherwise with respect to our Services, may be available via the Internet, all around the world. We cannot prevent and thus cannot be held liable for the use (or misuse) of such personal data by others.
5. YOUR RIGHTS
You may at any given point in time instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate and sufficient evidence of your identity. As sufficient and appropriate evidence, we accept a copy of your national identity card, or your passport, accompanied by a utility bill stating your current address of residence.
We may withhold personal information that you request to the extent permitted by law.
You may instruct us at any time not to process your personal information for marketing purposes. We will use your personal information for marketing purposes only if expressly agreed to our use of your personal information for marketing purposes.
Your principal rights under data protection law shall remain unaffected by the provisions contained herein. With respect thereto, your principal rights are the following:
(a) the right to access your personal data according to Article 15 GDPR;
(b) the right to rectification of any inaccurate or incomplete personal data about you following Article 16 GDPR;
(c) the right to erasure without undue delay if the data stored and/ or processed is no longer required to be stored and/ or processed given that the purpose as to which the data was stored and/ or processed in the first place is omitted, unless the data to be erased is subject to exclusions of the right to erasure under Article 17 GDPR, and in accordance with Articles 13(2)(b), 14(2)(c) and 15(1)(e) GDPR;
(d) the right to restrict processing in accordance with Article 18(1) GDPR if i.e. the processing of the personal data is unlawful, but the provision of erasure does not apply, or i.e. if the purpose of storing and/ or processing ceased to apply but means of litigation require the data to be stored and/ or processed;
(e) the right to object to processing personal data for marketing purposes and/ or scientific research under Article 21 GDPR read in conjunction with Articles 21(4), 13(2)(b) and 14(2)(c) of the GDPR;
(f) the right to data portability if and unless this right interferes with any rights of third parties set forth in Article 20 GDPR, read in conjunction with Articles 13(2)(b), 14(2)(c);
(g) the right to complain to a supervisory authority if you experience an infringement of data protection laws and you have the legal right to file a complaint with a supervisory authority following Article 77 GDPR, read in conjunction with Articles 13(2)(d), 14(2)(e) and 15(1)(f); and
(h) the right to withdraw consent according to Article 7(3) GDPR, read in conjunction with Articles 13(2)(c), 14(2)(d) and 17(1)(b).
You may exercise any, or all of these rights with respect to the storing and/ or processing of your personal data by written notice to webmedia.ie.
7. ADVERTS AND SPONSORED LINKS
8. SOCIAL MEDIA PLATFORMS
On our website, we may use social media sharing buttons which help share web content directly from web pages to a social media platform. Whenever you use a social sharing button, be advised that you do so on your own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
We may share web links to relevant web pages through our social media accounts. By default, some social media platforms shorten lengthy URL’s (web addresses). Users are advised to take caution and good judgement before clicking any shortened URL’s published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URL’s are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
9. CONTACT AND COMMUNICATION
You can contact us either via Email at email@example.com, via Phone on +353 83 487 2810, or through our Contact form on our website. If you wish to contact us, please keep in mind that you do so at your own discretion and that you provide any personal details requested at your own risk. Your personal information is kept private and stored securely until it is no longer required by law or due to ceasing of purpose. We use any information submitted to provide you with further information about the products/ services we offer or to assist you in answering any questions or queries you may have.
We may update this policy from time to time whenever legal alterations are coming into effect. We therefore encourage you to check this page occasionally to ensure you are happy with any changes to this policy. However, we may notify you of changes to this policy either by means of email or through the private messaging system on our website.