PRIVACY POLICY

Personal Data
This is any information we collect in the course of the provision of services or which you provide through our applications, devices, websites or services, such as your name, job title, contact information, location, health data, and other information relevant to client enquiries, support requests and surveys. 8 West will also store any information that is freely provided as part of any contact forms. Confidential information should not be included in these forms.

It may be possible to directly or indirectly personally identify you from the information collected.

Non-Personal Data
This is information that cannot be used to identify or contact you, for example, demographic information regarding browser types, devices, network and other anonymous statistical data involving the use of our applications, devices, websites or services. We collect this information to measure the popularity our applications, devices, websites or services and our performance in providing services to you, we use this data to enhance your user experience using our applications, devices, websites or services.

Contractual Relationship
We may use your personal information in the course of the provision of services arising from our contractual relationship. Such use will be limited to the minimum required to perform said services. It may be necessary for us to share your personal information with trusted third parties as part of our provision of services to you. We will through relevant agreements, bind those third parties to similar levels of data privacy and protection.

Legitimate Interests
Through your interactions with our applications, devices, websites or services, we believe you may be interested in our products or services and that the content we choose to send to you will be helpful for your business success. Where we process your information on the basis that there is legitimate interest, we do after having carefully considered how you would expect us to process your data and whether you would consider it reasonable for us to do so.

Legal Obligation
On occasion, we may have to process your information in order to comply with a statutory obligation. We may be legally bound to give information to legal authorities if they so request it or if they serve us with a warrant or court order.

We may use your information to:

• Provide services to which you have subscribed or been enrolled.
• Provide SafeTrx product support.
• Contact you in response to a specific enquiry from you.
• Carry out any contractual obligations arising from contracts between you & us.
• Notify you of changes to our products & services.
• Improve the products and services we provide. For example, we may conduct analysis and research on our users' behaviour, including performing statistical analysis of our users, their use of our applications, devices, websites or services. We do this to optimise and improve our products and services.
• Contact you via email, telephone or mail for market research reasons.

We review our retention periods for personal information on a regular basis. Personal data which you provide to us via our applications, devices, websites or services will be retained for no longer than is necessary for the purpose for which it was obtained or as long as is set out in any relevant contract you hold with us. In some cases, we may be legally required to retain your data for regulatory reasons and fraud prevention.

If you unsubscribe from our newsletter, we may retain your data on a suppression list to ensure you do not receive future email communications.

We will always hold your information securely.

To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards. We also follow stringent procedures to ensure we work with all personal data in line with:
(i) the Data Protection Act 1998, 2003 and 2018
(ii) the General Data Protection Regulation (EU) 2016/679.

Third Party Service Providers working on our behalf may have access to your personal information: We may pass your information to our third party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf.
When we use third party service providers, we disclose the minimum amount of personal information that is necessary to deliver the service and we will have a contract in place that requires them to keep your information secure and precludes them from using it for their own direct marketing or other purposes unrelated to the provision of our services to you.

We will not release your information to third parties for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law.

Our websites and online services may use "cookies."

What is a cookie?
A cookie is a small file placed on your computer's hard drive. It enables our website to identify your computer as you view different pages on our website. Cookies allow websites and applications to store your preferences in order to present content, options or functions that are specific to you. They also enable us to see information like how many people use the website and what pages they tend to visit.
For more details on our use of cookies and to adjust your cookie preferences, please see our:
Cookie Preference Center

You have several rights in relation to your personal data under applicable privacy and data protection law as required by the General Data Protection Regulation (GDPR) 2018, which may be subject to certain limitations and restrictions. We will respond to any valid requests within one month, unless it is particularly complicated or you have made repeated requests in which case we will respond, at the latest, within three months. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. You will not be charged a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive, in which case we will charge a reasonable fee in the circumstances or refuse to act on the request.

To exercise your rights, please email us at DataProtection@8west.ie
or write to us at:

8 West Consulting,
Building 1,
University Technology Centre,
Curraheen Road,
Cork, T12 AY18,
Ireland

Right of Access
You can request a copy of the personal data we hold about you.

Right to Rectification
You have the right to request that we correct any inaccuracies in the personal data we hold about you and complete any personal data where this is incomplete.

Right to Erasure ("Right to be Forgotten")
You have the right to request that your personal data be deleted in certain circumstances including:

• The personal data is no longer needed for the purpose for which they were collected.
• You withdraw your consent (where the processing was based on consent).
• You object to the processing and there are no overriding legitimate grounds justifying us processing the personal data (see Right to Object below).
• The personal data have been unlawfully processed.
• To comply with a legal obligation.

However, this right does not apply where, for example, the processing is necessary:

• To comply with a legal obligation; or
• For the establishment, exercise or defence of legal claims.

Right to Restriction of Processing
You can ask that we restrict your personal data (i.e., keep but not use) where:

• The accuracy of the personal data is contested.
• The processing is unlawful, but you do not want it erased.
• We no longer need the personal data but you require it for the establishment, exercise or defence of legal claims.
• You have objected to the processing and verification as to our overriding legitimate grounds is pending.

We can continue to use your personal data:

• Where we have a contractual relationship
• For the establishment, exercise or defence of legal claims.
• To protect the rights of another.
• For reasons of important public interest.

Right to Data Portability
Where you have provided personal data to us, you have a right to receive such personal data back in a structured, commonly-used and machine-readable format, and to have those data transmitted to a third-party data controller without hindrance but in only where both the following are true:

• The processing is carried out by automated means.
• The processing is based on your consent or on the performance of a contract with you.

Right to object
You have a right to object to the processing of your personal data in those cases where we are processing your personal data in reliance on our legitimate interests, for the performance of a task carried out in the public interest or in the exercise of our official authority. In such a case we will stop processing your personal data unless we can demonstrate compelling legitimate grounds which override your interests and you have a right to request information on the balancing test we have carried out. You also have the right to object where we are processing your personal data for direct marketing purposes.

Automated Decision-Making
You have a right not to be subjected to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affects you other than where the decision is:

• Necessary for entering into a contract, or for performing a contract with you.
• Based on your explicit consent - which you may withdraw at any time.
• Is authorised by EU or Member State law.

Where we base a decision solely on automated decision-making, you will always be entitled to have a person review the decision so that you can contest it and put your point of view and circumstances forward.

Right to Complain
You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

Our privacy policy has been developed to comply with the laws of every country or legal jurisdiction in which we aim to do business. If you feel it fails to satisfy the law of your jurisdiction, please contact us.

However, it remains your choice as to whether you wish to use our website.

We may make changes to this privacy notice from time to time as necessary to address changes in the law or our business practices. The terms and conditions that apply to you are those available on our website(s) on the day you use our website.

If you have any question regarding our privacy policy, please contact us at: DataProtection@8west.ie