2) Types of Information Collected
The personal data collected depends on how you use our website. You can browse the site, you can fill in forms on the website to contact us / request information or quotes from us, subscribe to our emails, or download documents from us. Our website collect personal data to provide these services.
We collect information about you when you instruct us to provide advice, visit our website, subscribe to our newsletters or to receive our publications, apply for employment with us, and engage in business dealings with us.
Types of information we retain:
- Google Analytics: When someone visits https://www.vinedigital.ie we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website.
- “Personal Data”: This is data that identifies you or can be used to identify or contact you and may include your name, address, email address, user IP addresses in circumstances where they have not been deleted, clipped or anonymised, telephone number, and billing and credit card information. Such information is only collected from you if you voluntarily submit it to us.
- “Non-Personal Data”: Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses where they have been clipped or anonymised, browser types and other anonymous statistical data involving the use of our website.
3) What we do with the information we gather
- Non-Personal Data:
We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website.
- Personal Data:
We will process any Personal Data you provide to us for the following purposes:(a) to provide you with the goods or services you have ordered; (b) to contact you if required in connection with your order or to respond to any communications you might send to us; (c) to contact you by email in relation to news, events, services, products and offers available within Vine Digital Ireland and other related third party offerings where appropriate.
The following table sets out how we handle your personal data and our legal basis for doing so under GDPR and the Data Protection Act 2018.
|What we do||Our legal basis under GDPR|
|Use the personal data that you provide on our web forms||When you provide us with your personal data, for instance to obtain a quote for our services, this is a necessary step to take at the request of the data subject prior to entering into a contract|
|Provide our Pest Control services and products, as well as technical advice||This is necessary for the performance of a contract with you, our data subject|
|To assess the information you have provided and make a decision as to whether we can provide you with a service / product and at what price||Processing is necessary for the performance of a contract and in order to take steps at your request prior to entering into a contract|
|Contact you regarding the services we provide||We need to contact you for our legitimate interests so that we can gather more information for the provision of our services, or to deliver those services most effectively|
|Retain your data under our data retention policy after your contract has expired||We need to retain your personal data for only as long as necessary under the law to protect our legitimate interests|
|Where you require us to make Reasonable Adjustments to enable you to attend a meeting or interview, we may require further information from you.||If this includes information about your physical or mental health, such information (being sensitive personal data, Special Category data), will only be used by us, with your explicit consent, to assess your eligibility for Reasonable Adjustments. We will not share or disclose it to others.You can withdraw your consent as anytime by contacting us. Please note that we may not be able to process your request for Reasonable Adjustments if you do this.|
The following table sets out the categories of personal data that we obtain.
|Name, postal address, email address, website, identification number, location data, online identifier – these are classed as personal data||This data is provided by you on our web forms and questionnaires, either to obtain a quote from us, subscribe to one of our newsletters, request a service from us or as part of the provision of your existing contractual services.This data may be provided if you apply for a job opportunity at Vine Digital Ireland.|
We may collect, hold, use and disclose the information collected to compile statistical data and to; maintain our database; develop/improve our website; respond to any email enquiries; notify you of any upcoming marketing, training or other events that you have opted in to; provide you with publications; manage quality control; manage systems administration; attend to compliance issues; provide you or your organisation with advice and determine suitability for employment.
We will not use or disclose your personal information for any other purpose which is not related (or in the case of sensitive information, directly related) to the above purposes without your consent unless otherwise authorised, required or permitted under the Irish laws. Vine Digital Ireland does not sell your data to third parties.
4) Disclosure of Information to Other Parties
We may provide Non-Personal Data to third parties such as Google, Facebook or Twitter, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of our community users of our website, or the activities that visitors to our website engage in while on our website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.
We will not disclose your Personal Data to third parties unless you have consented to this disclosure or unless the third party is required to fulfill your order (in such circumstances, the third party is bound by similar data protection requirements). We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
7) What are your rights?
Subject to limitations set out in EEA data protection laws, you have certain rights in respect of your Personal Data. In particular, you have a right of access, rectification, restriction, opposition, erasure and data portability. Please contact us in writing if you wish to exercise these rights. If you wish to complete an access request to all personal data that Vine Digital Ireland. holds on you, please note that photo identity will be required for security purposes. We will complete your request within thirty days.
If you wish to learn more about these rights and how they operate, please look at the DPC’s website https://www.dataprotection.ie.
Objecting to processing
Where we process your personal information for purposes we consider to be in our legitimate interest, you have the right to object to this processing. You may exercise this right by writing to us at our address or by emailing us. If you do object, this may affect our ability to provide our products and services to you.
8) Contact us about Data
The data controller is Vine Digital Ireland. You can email us at: firstname.lastname@example.org
In accordance with the General Data Protection Regulation (GDPR), Vine Digital Ireland have implemented this privacy information notice to inform you, our current and former clients (Services, Products online and Trade Counter), of the types of data we process about you. We also include within this notice the reasons for processing your data, the lawful basis that permits us to process it, how long we keep your data for and your rights regarding your data.
We are a Data Controller of the personal data that you supply to us under your contract with us.
1) Principles in Data Protection
Under GDPR, all personal data obtained and held by us must be processed according to a set of core principles. In accordance with these principles, we will ensure that:
- processing is fair, lawful and transparent
- data is collected for specific, explicit, and legitimate purposes
- data collected is adequate, relevant and limited to what is necessary for the purposes of processing
- data is kept accurate and up to date. Data which is found to be inaccurate will be rectified or erased without delay
- data is not kept for longer than is necessary for its given purpose
- data is processed in a manner that ensures appropriate security of personal data including protection against unauthorised or unlawful processing, accidental loss, destruction or damage by using appropriate technical or organisation measures we comply with the relevant GDPR procedures for international transferring of personal data
2) Types of Data we hold
We keep several categories of personal data on and from our customers in order to carry out effective and efficient processes. We hold the data within our computer systems and on paper form.
Specifically, we hold the following types of data:
- personal details such as name, address, phone numbers, job title, email addresses, etc. for the main contact and other contacts for the delivery of the service
- personal details such as name, address, phone numbers, email addresses, property details, etc. provided to us for the delivery of the service
- bank account details and Direct Debit mandates
- IT service use including online service access records.
3) Collection of Your Data
You provide several pieces of data to us directly when the contract is signed, during the onboarding process and during the contract and after the contract has ended. Personal data is kept in files or within the Company’s IT systems.
4) Lawful Basis for Processing
The law on data protection allows us to process your data only for specific reasons. We mainly process your data in order to comply with a legal requirement or in order to effectively manage the service contract we have with you, including ensuring we can deliver the service to you.
The information below categorises the types of data processing we undertake and the lawful basis we rely on.
|Activity requiring your data||Lawful basis|
|Set up your account||Performance of the contract|
|Carry out the delivery of the services / products you have on your account||Performance of the contract|
|Ensuring payments are made under your account||Performance of the contract|
|Ensuring VAT and insurance premium tax is paid||Legal obligation|
|Carrying out checks in relation to your company status and validating the information supplied to us||Legal obligation|
|Making financial decisions in relation to entering both initial and subsequent contracts||Our legitimate interests|
|Making decisions about service / product delivery methods||Our legitimate interests|
|Ensuring efficient administration of contractual services to you||Our legitimate interests|
|Effectively monitoring the service provided including adherence to commitments and service entitlements||Our legitimate interests|
|Maintaining up to date records about you to ensure, among other things, effective correspondence can be achieved and appropriate contact points in place||Our legitimate interests|
|Dealing with legal claims made against us||Our legitimate interests|
|Preventing fraud||Our legitimate interests|
|Ensuring our administrative and IT systems are secure and robust against unauthorised access||Our legitimate interests|
5) “Special Categories” of Data
Special categories of data are data relating to: health; sex life; sexual orientation; race; ethnic origin; political opinion; religion; trade union membership; genetic and biometric data.
We carry out processing activities using special category data for the purposes of delivering services and products. This data will be provided to us or requested by us for the purposes of providing our services & products, to ensure you receive appropriate advice and support. For instance certain pest control products may be more suitable than others if you suffer from respiratory conditions.
Most commonly, we will process special categories of data when the following applies:
- you have given explicit consent to the processing
- we must process the data in order to carry out our legal obligations
- we must process data for reasons of substantial public interest
- you have already made the data public.
6) Failure to Provide Data
Your failure to provide us with data may mean that we are unable to fulfill our requirements for entering into a contract with you. This could include being unable to offer you services or administer existing contractual services.
7) Who we Share Your Data With
All employees within the Business that handle your personal data are trained in ensuring data is processed in line with GDPR.
Your data is not shared with third parties, except for other reasons to comply with a legal obligation placed upon us. We have a data processing contract in place with such third parties to ensure data is not compromised. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
We may share your data with bodies outside of the European Economic Area. These countries are USA,Australia,New Zealand,Philippines,France,Brazil and the United Kingdom. The reason for sharing with these countries is to facilitate our legitimate business interests in providing you with the contracted services where the Business employees responsible for the provision of the service are based outside the EEA. We have put the following measures in place to ensure that your data is transferred securely and that the bodies who receive the data that we have transferred process it in a way required by EU data protection laws: The data processing systems in use at other companies within the Business have comparable levels of security and safety to the systems in operation in countries within the European Economic Area.
8) Protection of Your Data
We are aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
9) Periods of Retention
We only keep your data for as long as we need it for, which will be at least for the duration of your service contract plus 7 years from the date that service contract with us terminates, although in some cases we will keep your data for a longer period after your contract has ended. Some data retention periods are set by the law. Retention periods can vary depending on why we need your data, as set out below:
|Record||Recommended Retention Period|
|Assessments under health and safety regulations and records of consultations with safety representatives and committees||Permanently|
|Money purchase details||6 years after transfer or value taken|
|Health data||30 or 50 years|
|Litigation cases||7 years from the conclusion of the litigation case|
|All other data||7 years from the date the service contract with us terminates|
10) Client Rights
You have the following rights in relation to the personal data we hold on you:
- the right to be informed about the data we hold on you and what we do with it
- the right of access to the data we hold on you. More information on this can be found in the section headed “Access to Data” below and in our separate policy on “Subject Access Requests”
- the right for any inaccuracies in the data we hold on you, however they come to light, to be corrected. This is also known as “rectification”
- the right to have data deleted in certain circumstances. This is also known as “erasure”
- the right to restrict the processing of the data
- the right to transfer the data we hold on you to another party. This is also known as “portability”
- the right to object to the inclusion of any information
- the right to regulate any automated decision-making and profiling of personal data
Where you have provided consent to our use of your data, you also have the right to withdraw that consent at any time. This means that we will stop processing your data.
13) Contact us about Data
The data controller is Vine Digital Ireland. You can email us at: email@example.com