Físín understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:“Account”means an account required to access and/or use certain areas and features of Our Site;“Cookie”means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;“Our Site”means this website, fisin.ie“Ireland and EU Cookie Law”means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and“We/Us/Our”means Físín.
- How Do We Use Your Data?4.1All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.4.2We use your data to provide the best possible products and services to you. This includes:4.2.1Providing and managing your Account;4.2.2Providing and managing your access to Our Site;4.2.3Personalising and tailoring your experience on Our Site;4.2.4Supplying Our products and services to you;4.2.5Personalising and tailoring Our products and services for you;4.2.6Responding to communications from you;4.2.7Market research;4.2.8Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;4.3In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data.4.4With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.4.5Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.4.6Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:a)you have given consent to the processing of your personal data for one or more specific purposes;b)processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;c)processing is necessary for compliance with a legal obligation to which we are subject;d)processing is necessary to protect the vital interests of you or of another natural person;e)processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/orf)processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
- How and Where Do We Store Your Data?5.1We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.In some circumstances you can ask us to delete your data: see under YOUR RIGHT TO ACCESS YOUR PERSONAL INFORMATION AND YOUR OTHER RIGHTS/to request erasure below for further information.In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.We will take all reasonable steps to destroy, or erase from our systems, all the personal information we hold about you when it is no longer required.5.2Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.5.3Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.5.4Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.5.5Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
- Do We Share Your Data?6.1We may share your data with other companies in Our group. We may contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:6.2We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.6.3In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
- How Can You Control Your Data?8.1When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account).8.2You may also wish to sign up to one or more of the preference services operating in Ireland: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- How Can You Access Your Data?You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at email or using the contact details below in section 14.
- Automated Decision-Making and Profiling13.1In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.13.2The right described in section 14.1 does not apply in the following circumstances:a)The decision is necessary for the entry into, or performance of, a contract between the You and Us;b)The decision is authorised by law; orc)You have given you explicit consent.13.3Where We use your personal data for profiling purposes, the following shall apply:a)Clear information explaining the profiling will be provided, including its significance and the likely consequences;b)Appropriate mathematical or statistical procedures will be used;c)Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; andd)All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.