PRIVACY AND COOKIES POLICY
NATIONAL HUB NETWORK
Effective Date: May 31, 2021
- Who We are
We are the Western Development Commission, (“we”, “our” “us” or “WDC”). WDC were established under the Western Development Commission Acts 1998 and 2007 and promote economic and social development in counties Clare, Donegal, Galway, Leitrim, Mayo, Roscommon and Sligo in Ireland. WDC are also responsible for coordinating the National Hub Network, which aims to establish a community network among the hubs identified throughout Ireland (the “Project”).
This website provides a platform for interconnectivity between hubs and hub clients. Your privacy is of paramount importance to us. This privacy and cookies policy (the “Policy”) applies to this connectedhubs.ie website, and any other of our online domains, applications and services related to the Project (the “Site”). This Policy is designed to protect you, our users, by informing you as to what personal data is collected, how we will use the information about you, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of your personal information. Your use of the Site is subject to your agreement with this Policy.
In this Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Law (as defined below).
This Policy is for any visitor to or user of the Site.
We will handle your Personal Data in accordance with Data Protection Law. “Data Protection Law” means the Data Protection Acts 1988 to 2018, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and any other applicable law or regulation, as shall be amended, supplemented, revised or replaced from time to time, relating to the processing of personal data and to privacy (including the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011) and all applicable guidance and codes of practice issued by a relevant data protection or supervisory authority.
We are a controller (as defined in Data Protection Law) in relation to any Personal Data which we collect from you through your or any other user’s use of the Site and the set-up of Your Account. You may be a data subject (as defined in Data Protection Law) or you may be a controller.
Please read the following carefully. Registering for an account (“Your Account”) on the Site, use of Your Account or the Site or otherwise accepting the terms of this Policy indicates that you have reviewed this Policy and have agreed to be bound by it. If you do not agree to these terms, you must leave the Site immediately. If you no longer consent to our processing of your personal data, you may request that we cease such processing by contacting us via the ‘How to contact Us’ facility referred to below at Section 14.
- Information We gather from You
We fully respect your right to privacy in relation to your interactions with the Project and the Site and endeavour to be transparent in our dealings with you as to what information we will collect and how we will use your information. Information in relation to Personal Data collected by Irish entities is available on www.dataprotection.ie, the website of the Data Protection Commission.
We may collect Personal Data from you in the course of your use of the Site. The information that we process includes:
- basic information, such as your first and last name (including prefix or title), date of birth;
- contact information, such as your billing, home and/or business postal address, email address and phone number(s);
- account information, including your username and password, profile photo, orders made by you, your organisation, and feedback and survey responses;
- occupational information, including title, position and employer;
- social networking information such as LinkedIn, Facebook, Twitter accounts, social network contacts or social network behaviours;
- payment information, including your VAT number, bank account or card details and bank account details for payment processing purposes;
- newsletter information, which is information provided by you when you opt-in to receive our newsletter;
- technical information, such as information from your visits to the Site (including login data, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access the Site or applications) or in relation to materials and communications we send to you electronically;
- location data relating to you such as internet protocol (IP) addresses, cookie identifiers, or website domains; or
- any other information relating to you which you may provide to us by adding it to Your Account, communicating with us, or responding to surveys.
Any Personal Data that we collect from you for these purposes is hereinafter referred to together as “Your Personal Data”. Your Personal Data is separate from and should be distinguished from User Uploaded Data (defined below).
We endeavour to keep Your Personal Data accurate and up to date. As such, you must tell us about any changes to such information that you are aware of as soon as possible.
- Why We Collect/Have Access To Your Information
We may collect information from you as necessary in the course of providing the Site. We may collect your Personal Data while monitoring our technology tools and services, including the Site and email communications sent to and from us. We gather information about you when you provide it to us or interact with us directly.
We may use Your Personal Data on any one or more of the following legal bases: (i) to comply with our legal obligations under the Western Development Commission Acts 1998 and 2007; (ii) to perform a contract with you; or (iii) where you have given us your express consent.
We use Your Personal Data to:
- respond to an enquiry from you.
- register you as a user of the Site.
- facilitate and process your order.
- enable you to communicate with us, other users and participating hubs.
- personalise and customise your experience.
- communicate with you to provide, manage and improve the Project and the Site.
- Inform you about goods or services that may be of interest to you, your hub and he wider network.
- administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- provide and improve the Site, including auditing, evaluating and monitoring its use.
We may use Your Personal Data to contact you:
- for administration reasons related to the Site or the Project (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us.
- to provide you with information about the Project or the Site, activities or online content, including sending e-newsletters or similar correspondence and updates or responding to any contact you have made with us, e.g. on the Site, by email or via the address at ‘How to contact Us’ at Section 14 below.to invite you to participate in surveys about our services (participation is always voluntary).
- for direct marketing purposes.
Please contact us if you need details about the specific legal basis or purpose we are relying on to process Your Personal Data.
Where we wish to use Your Personal Data in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of Your Personal Data for purposes other than those listed in this Policy.
- User Uploaded Data
Your Personal Data is separate from and should be distinguished from User Uploaded Data. “User Uploaded Data” is data uploaded by you or others through Your Account or your use of the Site when you use the comment function and the blog function on the Site. We strongly recommend that you avoid uploading any Personal Data in any User Uploaded Data. We reserve the sole right to review, edit or delete User Uploaded Data. We also moderate all User Uploaded Data in order to ensure that it does not contain Personal Data.
We are a Processor and you are the Controller in respect of User Uploaded Data (to the extent that it includes Personal Data). Notwithstanding this, if we are deemed for any reason to be a Controller of any User Uploaded Data (to the extent that it includes Personal Data) then we will comply with all of our Controller obligations under Data Protection Law in that regard and for the avoidance of doubt the provisions in Section 7 of this Policy will apply.
Where you are a controller in respect of the Personal Data of other data subjects, then you must comply with all of your controller obligations under Data Protection Law.
- Offensive Content
If Your Personal Data contains any material which may reasonably be deemed to be offensive, inappropriate or objectionable or otherwise engage in any disruptive behaviour in relation to the Project or the Site, we may remove such content and/or suspend the use of Your Account. We may also remove any such material from any of our social media pages.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose Your Personal Data to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Law.
- What Rights do You have?
As a data subject, you have the following rights under Data Protection Law and we, as controller in respect of Your Personal Data, will comply with such rights in respect of Your Personal Data:
- the right of access to Your Personal Data;
- the right to correct any mistakes in Your Personal Data;
- the right to ask us to stop contacting you with direct marketing;
- rights in relation to automated decision making
- the right to restrict or prevent Your Personal Data being processed;
- the right to have Your Personal Data ported to another data controller;
- the right to erasure; and
- the right to complain to the Data Protection Commission if you believe we have not handled Your Personal Data in accordance with Data Protection Law.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of Your Personal Data, please contact us (see ‘‘How to contact Us’ at Section 14 below). We will respond to any rights that you exercise within one month of receiving your request, unless the request is particularly complex in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond).
- Right of access to Your Personal Data
You may ask to see what Personal Data we hold about you and be provided with:
- a summary of such Personal Data and the categories of Personal Data held (see Sections 2 and 3 above);
- any information available about the source of that data (see Section 2 above);
- details of the purpose for which it is being or is to be processed (see Section 3 above);
- details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are outside the European Economic Area and what safeguards are in place for those transfers outside the European Economic Area (see Section 7 below);
- details of the period for which it is held or the criteria we use to determine how long it is held (see Section 11 below);
- details of your rights, including the rights to rectification, erasure, restriction or objection to the processing (set out in this Section 6);
- whether or not we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision-making or profiling (see Section 6.4 below); and
Details in respect of the above points are all set out in this Policy; however, if you need further clarification, please contact us (see ‘How to contact Us’ at Section 14 below).
Requests for Your Personal Data must be made to us (see ‘‘How to Contact Us’ at Section 14 below) specifying what Personal Data you need access to. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Law.
- Right to update Your Personal Data or correct any mistakes in Your Personal Data
You can require us to correct any mistakes in Your Personal Data which we hold free of charge. If you would like to do this, please:
- email or write to us (see ‘How to contact Us’ at Section 14 below);
- let us have enough information to identify you (e.g. name, registration details); and
- let us know the information that is incorrect and what it should be replaced with.
If we are required to update Your Personal Data, we will inform recipients to whom that Personal Data has been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact Us’ at Section 14 below).
- Right to ask us to stop contacting you with direct marketing
We may ask you for your consent to send you direct marketing from time to time. You may be able to select your preferences with respect to direct marketing when registering Your Account. We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- Click on ‘unsubscribe’ on an email (this will be instantaneous);
- Respond ‘stop’ on an SMS (this will be instantaneous) to a number notified to you; or
- Send an email via ‘How to contact Us’ at Section 14 below (this can take up to 5 working days).
We will provide you with information on action taken on a request to stop direct marketing - this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of Your Account.
- Rights in relation to automated decision-making
We do not attempt to collect further data without user consent that enables personally identifiable profiling of our users.
- Right to restrict or prevent processing of Your Personal Data
In accordance with Data Processing Legislation, you may request that we stop processing Your Personal Data temporarily if:
- you do not think that Your Personal Data is accurate (but we may start processing again once we have checked and confirmed that it is accurate);
- the processing is unlawful but you do not want us to erase Your Personal Data;
- we no longer need the Personal Data for our processing; or
- you have objected to processing because you believe that your interests should override the basis upon which we process Your Personal Data.
If you exercise your right to restrict us from processing Your Personal Data, we will continue to process the Personal Data if:
- you consent to such processing;
- the processing is necessary for the exercise or defence of legal claims;
- the processing is necessary for the protection of the rights of other individuals or legal persons; or
- the processing is necessary for public interest reasons.
- Right to data portability
In accordance with Data Protection Law, you may ask for an electronic copy of Your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:
- the processing is based on your consent or for the performance of a contract; and
- the processing is carried out by automated means.
- Right to erasure
In accordance with Data Protection Law, you can ask us (please see ‘‘How to contact Us’ at Section 14 below) to erase Your Personal Data where:
- we do not need Your Personal Data in order to process it for the purposes set out in this Policy;
- if you had given us consent to process Your Personal Data, you withdraw that consent and we cannot otherwise legally process Your Personal Data;
- you object to our processing and we do not have any legal basis for continuing to process Your Personal Data;
- Your Personal Data has been processed unlawfully or has not been erased when it should have been; or
- the Personal Data has to be erased to comply with law.
We may continue to process Your Personal Data in certain circumstances in accordance with Data Protection Law. Where you have requested the erasure of Your Personal Data, we will inform recipients to whom that Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
- Right to complain to the Data Protection Commission
If you do not think that we have processed Your Personal Data in accordance with this Policy, please contact us in the first instance (see ‘How to contact Us’ at Section 14 below). If you are not satisfied, you can complain to the Data Protection Commission or exercise any of your other rights pursuant to Data Protection Law. Information about how to do this is available on the Data Protection Commission website at www.dataprotection.ie.
- Withdrawal of Consent
If you no longer consent to our processing of Your Personal Data (in respect of any matter referred to in this Policy as requiring your consent), you may request that we cease such processing by contacting us via ‘‘How to contact Us’ at Section 14 below. Please note that if you withdraw your consent to such processing, it may not be possible for us to provide all/part of the Site to you.
- Who We Share Your Information with
We will not share Your Personal Data without your consent or unless required by law (except as set out in this Policy).
We restrict access to Your Personal Data to employees, contractors, suppliers and agents of WDC or the hubs who need such access in order to operate, develop, or improve our Site. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations. We may also share Your Personal Data with our third-party suppliers who assist us in the provision of the Site. We will share anonymised data with the Department of Rural and Community Development, the CSO and other relevant bodies for the purposes of evidence-based decision-making in the strategic development of the National Hub Network.
Under certain circumstances where required by law, we may be required to disclose Your Personal Data to law enforcement agencies, regulatory or supervisory authorities or judicial bodies.
All information you provide to us is stored on our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Site.
Your Personal Data may be transferred to, stored at, or accessed from a destination outside the European Economic Area (“EEA”) for the purposes of us providing the Site and related services. Prior to sharing Your Personal Data with such third-party service provider, we take steps to ensure an adequate level of data protection as required under Data Protection Law . These include entry by us into appropriate contracts with all transferees of such data, a decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country and/or standard contractual clauses approved by the European Commission or the Data Protection Commission and any relevant supplementary measures. Please contact us for further information on the means to ensure an adequate level of data protection and the transfer mechanism we rely upon for such transfers.
- Third Party Sites
- How do We protect your Personal Data?
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to Your Personal Data to employees, contractors and agents who need to know Your Personal Data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, the Site may contain hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Personal Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Personal Data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Personal Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the Site may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Personal Data arising from such risks.
- Breach Reporting
We will notify serious data breaches in respect of Your Personal Data to the Data Protection Commission without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay. However, it is not necessary to notify the Data Protection Commission where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting Your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Law. We will not be required to notify you of a Personal Data breach where:
- we have implemented appropriate technical and organisational measures that render Your Personal Data unintelligible to anyone not authorised to access it, such as encryption; or
- we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
- it would involve disproportionate effort, in which case we may make a public communication instead.
- Retention of Personal Data
Your Personal Data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Personal Data as necessary to administer Your Account, to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Site.
Where we retain information for Site improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Site, not to specifically analyse personal characteristics about you.
- Tracking Technologies and Cookies
- Strictly necessary cookies. These are required for the operation of the Site. They include, for example, Cookies that enable you to log into secure areas of the Site, use a shopping cart or make use of e-billing services.
- Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around the Site when they are using it. This helps us to improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily and to see how effective and relevant advertising on the Site is.
- Functionality cookies. These are used to recognise you when you return to the Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or location) and remember if we have already asked you for feedback or to complete a survey.
- Targeting cookies. These record your visit to the Site, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Below is a list of first party cookies we use and the purposes for which we use them.
These cookies are essential to provide You with services available through the site and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have requested cannot be provided, and we only use these cookies to provide you with those services.
Session - At the end of the browsing session or shortly thereafter
These cookies allow us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Site.
Persistent cookie - [•]
Third party cookies
You can find below a list of third-party cookies we use and the purposes for which we use them in the tables below.
We use Google Analytics to obtain high-level “audience measurement” data such as the referral web domain, type of operating system/browser used, date and time of visit, and other information relating to activities on the Site to understand its usage better, analyse trends, and optimize the Site experience. To opt out of being tracked by Google Analytics across all websites, visit: tools.google.com/dlpage/gaoptout.
We use Google tracking cookies to understand if you complete certain actions on the Site after you have seen or clicked through one of our adverts served via Google. Based on the content you have engaged with on the Site, Google delivers some targeted advertisements across other Google partner websites. For more information, visit: support.google.com/ads/answer/2662922?hl=en.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-ons settings or visiting the website of its manufacturer.
For more information about cookies and managing them including how to turn them off, please visit www.cookiecentral.com. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to fully experience the interactive features of the Site or other related websites/applications which you visit/use.
- Updates to this Policy
We may change our Policy from time to time and at our sole discretion. The date of the most recent revisions will appear on the top of this Policy. If you do not agree to these changes, please do not continue to use the Site to submit Your Personal Data. If material changes are made to the Policy, we will notify you by placing a prominent notice on the Site or by sending you a notification in relation to this. We will not process Your Personal Data in a manner not contemplated by this Policy without your consent.
- How to contact Us
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to: firstname.lastname@example.org.