How we process your information

We are required by law to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category.

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then—if required by law—we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you

   When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

   In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

   We may use it in order to:

   • verify your identity for security purposes
   • sell products to you
   • provide you with our services
   • provide you with suggestions and advice on products, services and how to obtain the most from using our website.
   
   

   We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

   Additionally, we may aggregate this information in a general way and use it to provide class information, e.g. to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

   We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

2. Information we process with your consent

   Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

   Wherever possible, we aim to obtain your explicit consent to process this information, e.g. by asking you to agree to our use of cookies.

   Sometimes you may give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

   Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, e.g. to monitor the performance of a particular page on our website.

   If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

   We may continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

   You may withdraw your consent at any time by instructing us gdpr@headsupclare.ie. However, if you do so, you may not be able to use our website or services further.

3. Information we process for the purposes of legitimate interests

   We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

   Where we process your information on this basis, we do after having given careful consideration to:

   • whether the same objective could be achieved through other means
   • whether processing (or not processing) might cause you harm
   • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so.
   
   

   For example, we may process your data on this basis for the purposes of:

   • record-keeping for the proper and necessary administration of our business
   • responding to unsolicited communication from you to which we believe you would expect a response
   • protecting and asserting the legal rights of any party
   • insuring against or obtaining professional advice that is required to manage our business risk
   • protecting your interests where we believe we have a duty to do so.


4. Information we process because we have a legal obligation

   We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

   For example, we may be required to give information to legal authorities if they so request, or if they have the proper authorisation—such as a search warrant or court order.

   This may include your personal information.

Specific uses of information you provide to us

5. Information provided on the understanding that it will be shared with a third party

   Our website may allow you to post information with a view to that information being read, copied, downloaded, or used by other people.

   Examples include:

   • posting a comment on our blog
   • tagging an image
   • sharing our blog posts to a social media site
   • clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks.
   
   

   In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

   While we do not specifically use this information except to allow it to be displayed or shared, we do store it, and we reserve a right to use it in the future in any way we decide.

   Once your information enters the public domain, we have no control over what any individual third party may do with it.

   We accept no responsibility for their actions at any time.

   Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at gdpr@headsupclare.ie.

6. Complaints regarding content on our website

   We attempt to moderate user-generated content, but we are not always able to do so as soon as that content is published.

   If you complain about any of the content on our website, we shall investigate your complaint.

   If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

   Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

   If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

7. Sending a message to us

   When you contact us, whether by telephone, through our website, or by email, we collect the data you have given to us in order to reply with the information you need.

   We record your request and our reply in order to increase the efficiency of our business.

   We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

8. Complaints

   When we receive a complaint, we shall record all the information you give to us. We shall use that information to resolve your complaint.

   If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

   We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

Use of information we collect through automated systems when you visit our website

9. Cookies
   

   Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience, and the website owner with statistics about how you use the website, so that it can be improved.

   Some cookies may last for a defined period of time, such as 1 day or until you close your browser. Others last indefinitely.

   Your web browser should allow you to delete any cookie you choose. It also should allow you to prevent or limit their use.

   Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

   When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we regret that you must cease use of our website and leave it immediately.

   If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

   We use cookies in the following ways:

   • to track how you use our website
   • to record whether you have seen specific messages we display on our website
   • to keep you signed in our site (if and when comments are enabled)
   • to record your answers to surveys and questionnaires on our site while you complete them
   
   
10. Personal identifiers from your browsing activity

    Requests by your web browser to our servers for web pages and other content on our website are recorded.

    We record information such as your geographical location, your Internet service provider (ISP) and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

    We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

11. Our use of re-marketing

    Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

    We do not currently re-market, and we do not place a cookie on your system for this purpose.

    However, we may use a third party to provide us with re-marketing services at some time in the future. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites. We shall advise you here if and when we begin to use re-marketing services.

Disclosure and sharing of your information

12. Information we obtain from third parties
    

    Although we do not disclose your personal information to any third party (except as set out on this page), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.

    No such information is personally identifiable to you.

13. Data is processed within the European Union

    Our website and associated services is hosted in the EU.

Access to your own information

14. Access to your personal information
    

    If and when commenting is enabled on this site, you may review or update personally identifiable information that we hold about you, by signing in to your account on our website at any time.

    To obtain a copy of any information pertaining to your activities on the website that is not provided on our website you may send us a request at gdpr@headsupclare.ie.

    After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

15. Removal of your information
    

    If and when commenting is enabled on this site, if you wish us to remove personally identifiable information from our website, you may contact us at gdpr@headsupclare.ie. This may limit the service we can provide to you.

16. Verification of your information

    If and when commenting is enabled on this site, when we receive any request to access, edit or delete personally identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Other matters

17. Use of site by children
    

    We do not sell products or provide services for purchase by children, nor do we market to children. If you are under 18, you may use our website only with consent from a parent or guardian.

18. Encryption of data sent between us
    

    We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

    Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

    The presence of the padlock merely shows that the communication between your browser and our server is encrypted. It does not mean that your connection to our server is secret or hidden from records.

19. Retention period for personal data
    

    Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

    • to provide you with the services you have requested
    • to comply with other law, including for the period demanded by our tax authorities
    • to support a claim or defence in court.
    
    
20. How you can complain
    

    If you are not happy with our privacy policy, or have any complaint with our website, then you should tell us by email. Our address is gdpr@headsupclare.ie.

    If you are not happy with our products or services, then you should email our team at info@headsupclare.ie.

    If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

    If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Data Protection Commissioner.

21. Compliance with the law
    

    As we only provide services within Ireland our privacy policy has been compiled so as to comply with the laws of Ireland.

22. Review of this privacy policy
    

    We may update this privacy notice from time to time as necessary. The terms that apply to you are specifically those posted here on our website on the day you use our website. We advise you to print a copy for your records.

    If you have any question regarding our privacy policy, please contact us.

    This document was last updated on October 1, 2019.