We will use your data only for the purposes and in the manner set forth below which describes the steps we take to ensure our processing of your data is in compliance with the General Data Protection Regulation ((EU) 2016/679) (GDPR) and any implementing legislation (Data Protection Laws).
Important information and who we are
Purpose of this policy
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: Aerlytix Limited
Email address: firstname.lastname@example.org
Postal address: Embassy House, Herbert Park Lane, Ballsbridge, Dublin 4, Ireland
It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of data about you which we have grouped together as follows:
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data includes information about how you use our website, products and services.
We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service we provide to you, but we will notify you if this is the case at the time.
How is your data collected?
We use different methods to collect data from and about you including through:
- Apply for our services
- Request marketing to be sent to you
- Give us feedback or contact us
Automated technologies or interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies and other similar technologies.
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources
How we use your data
We will only use your personal data when the law allows us to. Most commonly, we will use your data in the following circumstances:
Where we need to perform the contract, we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your data, although we will get your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your data
We have set out below, a description of all the ways we plan to use your data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. In identifying this basis, we have weighed our legitimate interests as a business against your rights and freedoms and determined that it will not unfairly impact your rights.
Please note that you have a right to object to processing of your data where that processing is carried on for our legitimate interest.
Note that we may process your data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of Data||Lawful basis for processing including basis of legitimate interest|
|To use data analytics to improve our website, products/services, marketing , customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To use certain cookies which require your consent. These cookies identify your individual details in order to monitor how our customers use our website—see our Cookies Policy for further details.||(a) Technical
Change of purpose
We will only use your data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of your data
We may share your data with the parties set out below for the purposes set out in the table above.
- Internal third parties, being other companies in the Aerlytix group
- External third parties being service providers who offer IT and administration services
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
- The Revenue Commissioners, regulators and other authorities
We require all third parties to respect the security of your data and to treat it in accordance with the law. We do not allow our third-party service providers to use your data for their own purposes and only permit them to process your data for specified purposes and in accordance with our instructions.
We may share your data within Aerlytix. This may involve transferring your data outside the European Economic Area (EEA), including in particular to the United States and Bermuda.
Whenever we transfer your data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your data to countries that have been deemed to provide an adequate level of protection for data by the European Commission, in accordance with Article 45 of the GDPR.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give data the same protection it has in Europe, in accordance with Article 46(2) of the GDPR.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to data shared between Europe and the US, in accordance with Article 46 (2) GDPR.
Please contact us if you want further information on the specific mechanism used by us when transferring your data out of the EEA.
We limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my data for?
We will only retain your data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for data, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. Further detail in respect of how long we retain data collected through our cookies can be found in our Cookies Policy.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we may anonymise your data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
Under certain circumstances, you have rights under Data Protection Laws in relation to your data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. This right applies unless we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms or where we need to use your information to establish, exercise or defend legal claims.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
We can continue to use personal information in certain circumstances such as where we have your consent, to establish, exercise and defend legal claims, to protect the rights of another, or for reasons of important public interest.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Lodge a complaint with your local supervisory authority, the Irish Data Protection Commission if you consider that the processing of your personal data infringes Data Protection Laws. The contact details for the Data Protection Commission are as follows:
Data Protection Commission Canal House Station Road Portarlington County Laois Phone: 1890 252 231 (Lo Cal rate) or +353 57 8684800 (national rate) Email: email@example.com
You can also make a complaint with another supervisory authority which is based in the Member State where you live, you work or the matter you are complaining about took place.
If you wish to exercise any of the rights set out above, please contact firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.