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This Notice sets out the basis on which any Personal Data we at Greencross Publishing Group of First Floor, Ebony House, Main Street, Wicklow Town, A67R272 collect from you, or from others, will be processed by us. Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.
This Notice is divided into several sections – if you click on a heading in the Table of Contents, you will be taken directly to that section. More detailed information is available in several sections, or on request in some instances.
“We” are Greencross Publishing Ltd and all associated companies defacto within the Greencross Group structure and all affiliates ( “Greencross Group”).
This Notice applies to Greencross Group as the DATA CONTROLLER for the purposes of the General Data Protection Regulation EU2016/679, and the Data Protection Acts 1988 – 2018 .
This Privacy Notice (“Notice”) applies to Personal Data collected by the Greencross Group through its websites, services and mobile applications (collectively, the “services”). This Privacy Notice describes in detail the types of Personal Data we collect about you; how we use your Personal Data (the purposes for processing your Personal Data) and with whom we share it; the choices and rights you have with regard to your Personal Data; how we protect your data; and how you can contact us about our privacy practices and data protection issues.
For data protection issues, please email our Privacy Champion at dermot@greenx.ie
“ Personal Data” is data that can identify you, either directly or indirectly, as an identified or identifiable individual.”
We obtain Personal Data about you from a variety of sources. This includes Personal Data you provide to us directly and data we obtain from other sources.
Personal Data you provide to Greencross Group. When you register for or participate in certain services, seek access to certain content or features, or directly correspond with us, we may collect certain types of Personal Data from you:
Contact information (such as name, postal address, email address and telephone and/or mobile numbers).
Certain professional qualification Personal Data and product preference information that you elect to provide, such as your doctor/nurse id number, and/or reading preferences, to customise our service for you;
Financial information (such as credit card or banking information required to pay for our products or services);
Username and password when you register through our services.
Survey responses, reviews and/or comments; and
Other information you may provide to us, such as through our “Submit a Request” or “Contact Us” feature; and
Personal Data obtained from other sources. We may obtain Personal Data about you in connection with the services from publicly and commercially available sources and from our affiliates and/or business partners
We may also process other data, which is not Personal Data.
When you access our website your device’s browser provides us with information such as your IP address, browser type, access time and referring URL which is collected and used to compile statistical data. This information may be used to help us to improve our website and the services we offer, and to offer services to you.
Children’s Personal Data: We do collect and manage information about children. Where possible and appropriate we will seek consent from a parent or guardian before collecting information about children.
We, or service providers acting on our behalf, may use the information collected from and about you to:
Provide our products and services, including authorising a purchase, or completing a transaction that you requested.
Create and manage online accounts.
Send promotional materials, alerts regarding available offers and other communications,
Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;
Respond to enquiries from you and other third-parties, including enquiries from law enforcement agencies;
Provide technical support for our membership platform.
Generate suggestions about the type of content you may enjoy.
Operate, evaluate and improve our business (including developing, enhancing, analysing and improving our services; managing our communications; reviewing and processing employment applications, performing data and statistical analytics; and performing accounting, auditing and other internal functions);
Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our terms of service and other policies; and
In other ways for which we provide specific notice at the time of collection.
Special Category Data and the lawful basis for that processing activity.
The processing of your Personal Data may include Personal Data relating to your socio-economic background such as your ethnic or cultural background and/or living circumstances, your health and wellbeing or otherwise which is regarded as Special category of Personal Data under the GDPR.
The legal bases for the processing of your special category data or sensitive data are:
That you have explicitly provided consent.
Processing necessary for compliance with a legal obligation to which we are subject.
Where Personal Data collected and processed explicit and informed consent is gained at the point of the collection which can be withdrawn at any point by contacting our Privacy Champion on dermot@greenx.ie
We may share your Personal Data with provide you with our services. For example, our web hosting provider and our IT service providers.
In addition, we may disclose your personal information to third parties If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We may share your information with selected third parties including:
Business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you.
Third parties with whom: (i) we need to share your information to facilitate transactions you have requested, and (ii)you ask us to share your information.
Statutory and regulatory bodies (including central and local government) and law enforcement authorities in order to comply with any applicable laws, grant applications and / or court orders
Service providers who provide us with marketing services/CRM platform ,Wi Fi services, website and online platforms, and subcontractors who provide a service to us, and sub processors.
We will, from time to time, make use of services provided by 3rd parties for the delivery of our services which may necessitate the transfer of Personal Data outside the EU/EEA. For example, we use a variety of cloud-based tools such as Google for Business/Send it in blue and others. Where Personal Data needs to be transferred or processed outside the EU/EEA, we chose providers who process Personal Data on the basis of
Standard Contractual Clause (s)(SCC’s)
An Adequacy Decision from the European Commission.
Irish and EU law sets out the grounds upon which data controllers such as Greencross Group can rely on to lawfully process Personal Data.
The legal bases for the processing of your Personal Data are:
Processing necessary for the performance of a contract which you have entered into with us or to take steps at your request prior to entering into a contract.
That you have provided consent for the processing for one of more specified purposes such as marketing for example when you fill out consent to receiving marketing material.
Processing necessary for compliance with a legal obligation to which we are subject.
Processing necessary for the purposes of the legitimate interest which we pursue in providing you with quotes and proposals about our services prior to contract where such interests are not overridden by your interests or fundamental rights or freedoms which require the protection of your information.
The legal bases for the processing of your special category Personal Data or sensitive Personal Data are:
That you have explicitly provided consent.
Processing necessary for compliance with a legal obligation to which we are subject.
Where our processing of your Personal Data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.
If you are receiving marketing from us, you may opt out. If you no longer wish to be contacted for marketing purposes, please contact us as set out in this Notice to request to “opt out” of marketing.
As an individual, under EU law you have certain rights to apply to us to provide information or make amendments to how we process your Personal Data. These rights apply in certain circumstances and are set out below:
The right to access Personal Data relating to you (‘access right’).
The right to rectify/correct Personal Data relating to you (‘right to rectification’).
The right to object to processing of Personal Data relating to you (‘right to object’).
The right to restrict the processing of Personal Data relating to you (‘right to restriction’).
The right to erase/delete Personal Data relating to you (i.e., the ‘right to erasure’).
The right to ‘port’ certain Personal Data relating to you from one organisation to another (‘right to Personal Data portability’).
These rights are not absolute and only apply in certain circumstances. You may exercise any of the above rights by contacting us accompanied by all necessary information via: an e-mail to dermot@greenx.ie
You may lodge a complaint with your local supervisory authority with respect to our processing of your Personal Data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie
We would ask that you contact us first at dermot@greenx.ie to enable us to try to deal with the matter to your satisfaction.
The exercise of Data Subjects’ rights as some other “interactions” requires the univocal identification of the person submitting such request as being, in fact, the Data Subject to whom such Personal Data pertains to, hence we may have to set in place a process or mechanism that allows it to document having undergone such assertive identification.
If you no longer wish us to contact you in a particular way, for example, to no longer send you text messages, just advise us of that and we will respect your wishes.
It may be necessary for us to contact you from time to time in connection with services, for example to ensure your Personal Data is correct.
MARKETING
If you no longer wish to receive marketing communications by electronic means, just use the opt-out facility in any of our communications, OR advise us at dermot@greenx.ie
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 databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We will continue to revise policies and implement additional security features as new technologies become available.
The transmission of information via the internet is not completely secure and may involve the transfer of Personal Data to countries outside of the European Economic Area (EEA). This occurs typically through use of cloud solutions for web hosting, email hosting or proprietary software solutions delivered to us through the Cloud. We do not however authorise any third party to use your Personal Data for their own purposes. Non-EEA countries may not provide an adequate level of protection in relation to processing your Personal Data. By submitting your Personal Data, you agree to this transfer, storing and processing. The sharing, storage and processing of your Personal Data/ information will predominantly take place within the EEA.
Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to us. 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.
The time periods for which we retain your information depends on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted.
We keep your Personal Data for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your Personal Data to provide this service to you, you can request that we erase your Personal Data. Please note that if you request the erasure of your Personal Data:
We may retain some of your Personal Data as necessary for our legitimate interests, such as fraud detection and prevention and enhancing safety
We may retain and use your Personal Data to the extent necessary to comply with our legal obligations.
Because we maintain our records to protect from accidental or malicious loss and destruction, residual copies of your Personal Data may not be removed from our backup systems for a limited period of time.
You have the right to complain to the Data Protection Commission if you feel that we are in breach of any of your rights. Full contact details are provided below.
We would ask that you contact us first, to enable us to try to deal with the matter to your satisfaction. Please contact us at dermot@greenx.ie
If you wish to exercise any of the rights you have in respect of your data, please contact us.
Where we process your Personal Data based only on your consent, you may withdraw your consent.
You have the right to bring a complaint to a supervisory authority if you have any complaints about the processing of your Personal Data. In Ireland the Personal Data Protection Commission is the supervisory authority.
In circumstances where the provision of your Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, we will advise you at the point of collecting your Personal Data whether the Personal Data is a required field, and the consequences of not providing the Personal Data.
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/notices and that we do not accept any responsibility or liability for those policies/notices. Please check those policies/notices before you submit any Personal Data to those websites,
We maintain active social network accounts. We embed widgets from these networks to provide follow buttons, like boxes and stream embeds. This will involve cookies being set by these networks while using our site. You may choose to refuse these cookies. Your use of these social media platforms remains subject to your own user agreements with the platform providers.
This notice may change from time to time, and any changes will be posted on our website and will be effective when posted. Please review this notice each time you use our website or our services. This notice was last updated on 18th October 2021.
