Last Updated: 6 December 2023
We, KPTRS Investments Ltd, a company duly incorporated in Ireland under company number 496147, having its registered office at CleverCards Suite 4, The Mall, Beacon Court, Sandyford, Dublin D18 TN80 (“CleverCards/Us/We”), together with our affiliates, take privacy very seriously. This policy sets out how we, as a data controller, collect and process personal data about:
- Visitors to our websites
- Subscribers to or users of our online products and services
- Individuals who apply for jobs
- Individuals who we communicate or interact with in the course of our business
- Individuals whose personal data is provided to us in connection with the provision of our products and services
- Individuals who attend events which we organise or sponsor
- Individuals who are employed or engaged by suppliers of goods or services or parties tendering to provide goods or services
Our "websites" includes this website, all our associated sites, and our social media pages. This policy also sets out information about data subject rights and our obligations under data protection law.
1. INFORMATION THAT WE COLLECT
There are instances where we invite or request individuals to provide us with their personal data, including through our websites or at events which we organise or sponsor. In addition, individuals may volunteer their personal data to us by various means of communication, e.g. by telephone, email, at events or via our websites.
In providing our products and services, we may also receive personal data directly or indirectly, including from publicly accessible sources. Categories of such personal data include: names, addresses, contact information and other information that is relevant to the provision of our products and services.
At any events which we organise or sponsor, directly or with other third parties, we may have a photographer or a videographer present and we may capture your image. We may use or make any images available on our websites, social media sites or in printed material. If you have any objection to this, you can inform the photographer or videographer or notify any of our staff at the event.
We may also receive your personal data directly or indirectly where you work for or represent one of our suppliers or a party tendering to provide goods or services to us, in connection with services or goods we receive from that supplier. Categories of such personal data include: names, addresses, contact information, your job title, your IP address, our correspondence with you or with the supplier you represent or are engaged by, about you, financial information and other information that is relevant to the receipt of those services or goods. Where we need to provide or allow you to have access to our systems or premises, for security reasons, we may monitor and record that access and retain your identification photograph.
Information communicated in connection with the provision of our products or services is subject to client confidentiality obligations.
2. HOW WE USE PERSONAL DATA
The purposes for which we use personal data and the legal basis for why that processing is necessary or permitted are:
We will retain personal data only for as long as necessary for the purposes for which it was collected; as required by law or regulatory guidance to which we are subject; and for the exercise or defence of legal claims that may be brought by or against us.
We will retain personal data about job applicant candidates for no more than one year. Our retention practices may be reviewed and updated from time to time in line with legal requirements and best practice.
3. DISCLOSURE OF YOUR INFORMATION
We may disclose personal data to:
- Third parties, including cloud service providers, who provide a service to us
- A public authority in the event that we are required to do so by law
- A third party where we are under a legal obligation to transfer it to that third party or where we provide it on behalf of a customer for regulatory purposes
- A prospective seller or buyer of any of our assets or business
- A third party where it is necessary to protect the vital interests of the data subject or another natural person
- Third parties who we partner with to organise or sponsor events
- Third parties who tender to or provide services or goods to us
To the limited extent that it is necessary to transfer personal data outside of the EEA, we will ensure appropriate safeguards are in place to protect the privacy and integrity of such personal data, including standard contractual clauses under Article 46.2 of the GDPR. Please contact us if you wish to obtain information concerning such safeguards at firstname.lastname@example.org.
4. LINKS TO OTHER SITES
Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
5. DATA SUBJECT RIGHTS
To the extent that we are a controller of your personal data you may request access to, rectification, or erasure of your personal data, or restriction of processing or object to processing of your personal data, as well as the right to data portability. In each case, these rights are subject to restrictions as laid down by law. The following is a summary of your rights:
- The right of access enables you to receive a copy of your personal data
- The right to rectification enables you to correct any inaccurate or incomplete personal data we hold about you
- The right to erasure enables you to ask us to delete your personal data in certain circumstances
- The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances,
- The right to object enables you to object to us processing your personal data on the basis of our legitimate interests (or those of a third party)
- The right to data portability enables you to request us to transmit personal data that you have provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible
You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR.
If you wish to exercise any of these rights, please contact us (email@example.com). We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse your request where there is a basis to do so in law, or if your request is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.
6. SECURITY AND WHERE WE STORE YOUR PERSONAL DATA
We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organisation. We will continue to revise policies and implement additional security features as new technologies become available. Where we have given you a password which enables you to access certain parts of our Site, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorised access or disclosure.
We reserve the right to change this policy from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the top of this policy. However, if we make material changes to this policy, we will notify you by means of a prominent notice on the website prior to the change becoming effective. Please review this policy periodically for updates.
8. CONTACT US
Questions, comments, requests and complaints regarding this policy and the personal data we hold are welcome and should be addressed to firstname.lastname@example.org or by writing to CleverCards at Suite 4, The Mall, Beacon Court, Sandyford, Dublin D18 TN80. All requests will be dealt with promptly and efficiently. You also have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues.