DTMarketing with the registered address of 13 Main Street, Drominahilla, Millstreet, Co. Cork P51XY2A and the business registration number of 589936, (also referred to as “we,” “our,” “us”) is the Data Controller when you provide information to us.
This Privacy Statement defines how we collect, use, share, store, our legal basis, how long we keep your data and your rights. Any information that we process will be held in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act, 2018 and other Irish or EU Data Protection legislation.
LEGAL BASIS FOR USING YOUR INFORMATION +
All businesses must have a legal reason to use your personal information; if they do not have one, they cannot use your data. Several legal grounds enable data processing. Outlined below are the most relevant grounds you should be aware of.
WHEN YOU ARE A CLIENT OR A POTENTIAL CLIENT +
When you are a potential client or a client, we will process the following personal data about you:
- Name, address, phone number, email;
- A record of the information that you provide to us;
- Conversations you have when you call us;
- Payment and financial information;
- Self-completing an online survey;
- Marketing profiles, including what events and communications we think you might be interested in.
- When you complete a feedback form, either manually or online;
Where you provide information to us about other people, you need to make sure you have their permission to do so.
Lawful basis relied upon: The processing is necessary for the performance of a contract, consent or legitimate interest.
A contract is where we either have a contract with you or you wish to enter into a contract with us. For example, when you order services from us, we will process your information to administer that transaction.
There may be situations where we need to use your information to comply with legal obligations. We are required by law to keep your information on file for the purposes of complying with the Revenue Commissioner, Health and Safety legislation and for Professional Indemnity Insurance purposes.
We process the following data because we have a legitimate interest:
- Keeping your data in our system to keep it secure;
- Your email and telephone number in a suppression list so that we do not email or telephone you again by accident;
- The date on which you started using our services;
- The date on which you ceased to use our services;
- We may receive your business contact information directly from you, as a client or from business cards, or we may get your information from third party sources, such as your website or professional network profile.
- A record of any complaints or compliments made by you and the action taken in respect of any such complaint or compliments; and
- The IP address and the MAC address when you visit our website enables us to keep our website secure.
We process the following data because we have your consent:
- Training Feedback Form
On the completion of a course, all participants are requested to complete a feedback form. The purpose of this is to evaluate the training delivered and to make improvements to course delivery if necessary. On occasion, we may use quotations from our courses on our promotional materials. Such use is always anonymized. If we require a direct quotation, we will always contact you for your permission. We retain this information for a year following completion of a course.
SENSITIVE DATA +
In the course of providing our services, we may process specific sensitive data, for instance, your dietary requirements. We rely on exceptions contained in Article 9 of the GDPR and the Data Protection Act 2018 to process this information.
WHY DO WE NEED YOUR DATA? +
DTMarketing needs to process personal data about our clients to provide effective and high-quality service and to satisfy our legal obligations. We will process your data to:
- Provide you with the services or information that you have asked for;
- Keep a record of your relationship with us;
- Send your correspondence and communicate with you;
- Meet our legal obligations;
- Respond to or complete any requests, complaints or queries that you may have; and
- Understand how we can improve our services or information;
WHEN AND HOW WE COLLECT YOUR INFORMATION +
We may collect information you provide to us directly and indirectly when interacting with our products and services. This may include such interactions as:
- Make an initial approach to us by email or on the phone;
- Interact with us by email, text, or on social media; and
- Complete our market research/customer surveys;
CHILDRENS’ DATA +
DTMarketingis a business-to-business service directed to and intended for use only by those who are 18 years of age or over. We do not aim our services at children, and we do not knowingly collect any personal data from any person under 16 years of age.
STUDENTS ON WORK EXPERIENCE +
We process the following data because we have a legal obligationsuch as Employment Law and Taxation laws. Processing is necessary for the performance of a contractto which the data subject is a party or to take steps at the request of the data subject before entering into a contract. Legitimate interest: processing is necessary to ensure DTMarketing is effective and efficient in its regular business activities.
Contact details (first name, surname, postal address, email, phone number), CVs, medical certificates, bank details and PPSN for students.
The information you provide will be held securely by us and our Book-Keeper whether the data is in electronic or physical format. We will use the contact details you provide to us to contact you to progress your application. We will use the other information you provide to assess your suitability for work experience.
We are required to confirm the identity of the students on work experience, their right to work in Ireland and seek assurance as to their trustworthiness, integrity and reliability. You will, therefore, be required to provide, proof of your identity, you will be asked to attend our office with original documents and we will make copies. We will also ask you for your emergency contact details, so we know whom to contact in case you have an emergency at work.
YOUR BUSINESS FINANCE INFORMATION +
Processing is necessary for compliance with a legal obligationsuch as Taxation laws. We collect financial data required to comply with Irish Tax law such as VAT numbers, PPSN, account details to pay and sending invoices.
USE OF OUR WEBSITE +
We process the following data because we have a legitimate interest:
We have a legitimate interestin understanding how our clients and potential clients use our website. This assists us in providing more relevant services and communicating value to our clients.
See the Cookie Notice on our website for more details.
CONTACT FORM +
We collect personal information relating to you when you contact us through the contact forms on this website. This information may include your name, email and your phone number. We will only use this information to respond to your request. We will never use this information to market to you unless you have specifically requested us to reach out to you through the contact form.
We use a third-party provider, MailChimp to deliver our newsletter. As part of MailChimp’s services, it collects statistics around email opening and clicks using industry-standard technologies. If you no longer wish to receive marketing emails or newsletters from us, you have the right to ask us to stop processing your data for direct marketing purposes. Please send an email to email@example.com with ‘UNSUBSCRIBE’ in the subject line or click the ‘Unsubscribe’ link in the newsletter email you received from us.
There are some activities where we process personal information with your permission, which you can withdraw at any time, although if you do, we may not be able to provide the product or service you have requested. An example is where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. We will indicate in this Privacy Statement where we rely on consent.
WITHDRAWING CONSENT +
Where we may rely on consent to use your information, you have the right to revoke that consent for that processing activity at any time. However, we may have the right to rely on an alternative legal basis for the processing activity and will inform you of that.
A withdrawal of consent may still allow the processing of your data if:
- Processing is necessary for the performance of a contract with you.
- Processing is necessary for compliance with a legal obligation.
- Processing is necessary to protect your vital interest or that of another person.
- Processing is necessary for the performance of a task carried out in the public interest.
- Processing is necessary for the legitimate interests pursued by the controller or a third party; except where such interests are overridden by your interests or fundamental rights and freedoms.
DIRECT MARKETING +
We want to send you information about our services, training and events from time to time which may be of interest to you. If you have consented to receive such marketing information, you may opt-out at a later date. You have a right at any time to ask us not to contact you for marketing purposes.
In addition to sending you information about the services you use, and where we have your permission, we may send you direct marketing communications about our services, events and offers.
Direct marketing communications may be sent by post, e-mail, telephone, social media (such as Facebook, Instagram, LinkedIn and Twitter), messages including push notifications to your mobile devices, and via other electronic means such as when you visit our website.
We may send you direct marketing while you have an ongoing relationship with us and for a reasonable time after you have used one of our services.
You will be able to opt-out of direct marketing by following the instructions in the communications you receive or changing your device settings.
LINKED SERVICES, THIRD-PARTY SITES AND CONTENT +
In some of our articles and blogs, we may reference other websites and provide links which are outside of our control. This Privacy Statement does not cover these other websites and links. DTMarketing does not accept any responsibility or liability for other sites’ Privacy Notices/Statements or Privacy Policies. If you access other websites using the links provided, please read their policies before submitting any personal information.
Our website uses interfaces with social media sites such as LinkedIn, Twitter and others. If you choose to “like” or share information from the DTMarketing website through these services, you should review the Privacy Statement/Notice of that service. If you are a member of a social media site, the interfaces may allow the social media site to connect your site visit to your personal data.
DISCLOSURES REQUIRED BY LAW +
Your information will be disclosed where we are obliged by law to do so. We may also disclose your information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
When we have answered your query and there is no opportunity for a follow-up – you may not want training services, so we will hold onto your email for six calendar months, just in case you have forgotten something and come back to us.
RETAINING YOUR DATA +
We shall keep your information per our Data Retention & Erasure Policy, or for as long as necessary for the uses set out in this Privacy Statement or while there is a legitimate business reason for doing so.
We hold your data:
- For enquires – 6 months.
- For marketing – until you withdraw consent or until we see that you are no longer opening the emails. We review our consents every year.
- After ceasing to be a client – 7 years.
- QQI – the result sheets along with participant marking sheets – 7 years.
If you ask us to delete your information before this time, we may not be able to do so for technical, legal, regulatory or contractual constraints. As an example, where you wish to be suppressed from direct marketing, we would need to retain your information for this purpose.
Where you ask for your account to be closed, we will do this as soon as possible subject to any terms and conditions relating to the account. Your information will be retained to comply with legal and regulatory obligations as well as for analysis, to prevent fraud, collect any monies owed, and to resolve disputes.
YOUR RIGHTS UNDER THE GDPR & THE DATA PROTECTION ACT, 2018 +
You have rights in respect of our processing of your personal data which are:
- To access your personal data and information about our handling of it. You also have the right to request a copy of your personal data (but we will need to remove information about other people).
- To rectify incorrect personal data that we are processing.
- To request that we erase your personal data if:
- We no longer need it;
- If we are processing your personal data by consent and you withdraw that consent;
- If we no longer have a legitimate ground to process your personal data; or
- We are processing your personal data unlawfully
- To object to our processing if it is by a legitimate interest.
- To restrict our processing if it was by a legitimate interest.
- To request that your personal data be transferred from us to another company if we were processing your data under a contract or with your consent and the processing is carried out automated means.
If you want to exercise any of these rights, please contact us at firstname.lastname@example.org.
WHO DO WE SHARE YOUR INFORMATION WITH? +
We share your information with third parties and we require all third parties to have appropriate technical and operational security measures in place to protect your data.
DATA TRANSFERS OUTSIDE OF THE EU OR EEA +
When we transfer your personal data out of the European Economic Area (EEA), we ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
CHANGES TO OUR PRIVACY STATEMENT +
We reserve the right to modify this Privacy Statement at any time. Each time you use this website, you shall be bound by the then current Privacy Statement and accordingly you should review the Privacy Statement each time you use this website. This is a live document, under regular review. This policy was last updated on November 2018.
COMPLAINTS, QUESTIONS AND ASSISTANCE +
If you have any comments, concerns or complaints about our uses of your information, we would ask that you contact us first, so that we can try and resolve the matter.
You are encouraged to raise any issues with Director Sarah McSweeney:
Post: DTMarketing, 13 Main Street, Drominahilla, Millstreet, Co. Cork P51XY2A
Telephone:+ 353 (0) 2970200
COMPLAINING TO THE DATA PROTECTION COMMISSION (DPC) +
Where we are unable to help, you can complain to the Data Protection Commission (DPC) in Ireland or the Statutory Authority in your country of residence, who will be able to liaise with the Data Protection Commission.
The Data Protection Commission (DPC) can be contacted at:
Post: Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, Ireland, R32 AP23.
Telephone:+353 (0) 57 8684800
Telephone:+353 (0)761 104 800
Lo-Call Number:1890 252 231