PRIVACY NOTICE – GENERAL USERS AND CLIENTS
EIIS Management Limited takes your privacy very seriously. This Privacy Notice sets out how we collect and process your personal data, explains your rights and answers any queries you may have about your personal data.
If you have entered into a contract with us or one of our subsidiaries or group companies, the controller of your data will be EIIS Management Limited and its associated companies (collectively and individually, as appropriate, “EIIS Management”, “we”, or “us”).
Our personal information handling policy and procedures have been developed in line with the requirements of the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.
- WHAT INFORMATION DO WE COLLECT AND PROCESS?
We collect and process personal data about you when you engage with EIIS Management either as a client or as a potential client.
We collect and process personal data about you when you interact with us and our products and when you engage us to act on your behalf. The personal data we process may include any or all of the following:
- your name;
- your EIIS Management Online username and password;
- your home or work address, email address and/or phone number;
- utility bills or other forms of address verification;
- your job title;
- your bank details;
- your PPSN number;
- your financial situation information including all forms of income and remuneration;
- your passport or other forms of identity verification;
- information related to the browser or device you use to access our website;
- internet browser and operating system;
- recordings of calls you make to our client representatives; and or
- any other information you provide which is relevant to the service being provided.
We will not seek to gather any personal data which is not relevant for the provision of a service or an ancillary activity that we provide.
- HOW DO WE USE THIS INFORMATION AND WHAT IS THE LEGAL BASIS FOR THIS USE?
We process the personal data listed in paragraph 1 above for the following purposes:
- to establish and fulfil a contract with you, for example, if you make a purchase from us or enter into an agreement to provide or receive services; this may include verifying your identity, taking payments, communicating with you, and providing client services otherwise we would be unable to enter into a contract with you.
- to comply with applicable law and regulation;
- in protecting EIIS Management’s legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
- with your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our website or our products or services;
- we may use information you provide to personalise (i) our communications to you; (ii) our website; and (iii) products or services for you, in accordance with our legitimate interests;
- to monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
- we may monitor any client account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
- in circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
- we may use your information to invite you to take part in market research or surveys.
We may also send you direct marketing in relation to relevant products and services. Electronic direct marketing will only be sent where you have given your consent to receive it, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.
- WITH WHOM AND WHERE WILL WE SHARE YOUR PERSONAL DATA?
Your personal data is highly confidential and will be stored securely with access to it restricted to those who need to use it for legitimate legal and business purposes. In certain circumstances we may be obliged to share your personal information with third parties. These circumstances may include, but are not limited to, circumstances where we use third party service providers to assist us in providing services to you, where it is required by a settlement services provider and other agents of yours or ours, to comply with any legal or regulatory requirement, to carry out our obligations under our Terms and Conditions or any relevant Agreement with you, as well as to protect and defend the rights of property of EIIS Management, our licensors and/or our other clients. In all other circumstances, we will only share information with third parties with your written consent.
Some of the third parties that we may be required to share your personal data with include:
- The Central Bank of Ireland;
- Financial Services and Ombudsman Bureau of Ireland (in the case of a dispute);
- HOW LONG WILL YOU KEEP MY PERSONAL DATA?
We will not keep your personal information for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose for which it was acquired. We are also required to retain certain information under legislation or to meet our regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.
Where you are a client, we will keep your information for the length of any contractual relationship you have with us and after that for a period of 6 years.
Where you are a prospective client and you have expressly consented to us contacting you, we will only retain your data (a) until you unsubscribe from our communications; or, if you have not unsubscribed, (b) while you interact with us and our content; or (c) for 12 months from when you last interacted with us or our content.
We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require EIIS Management to hold certain information for specific periods other than those listed above.
- WHERE IS MY DATA STORED?
The personal data that we collect from you may be transferred to, and stored outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA in which case the third country’s data protection laws will have been approved as adequate by the European Commission or other applicable safeguards are in place. Further information may be obtained from our Privacy Team.
- YOUR RIGHTS
Right of Access
Each person has the right to be advised, on request, whether we process their personal data and, where we do, to access that data. This includes the right to be advised of the purposes and period for which their data are processed and the names of any third parties with whom we share the personal data.
Right of Rectification
Each person has the right to have their data corrected, rectified or updated where they believe it may be inaccurate or incomplete.
Right of Erasure
Each person has the right to have their personal data erased, without undue delay, when the personal data are no longer necessary for the purpose for which it was collected and processed unless it is necessary for complying with a legal obligation.
Right of data portability
Individuals have the right to be provided with a copy of any personal data that we hold on them in a structured, commonly used and machine-readable format. They can request that information be transmitted directly to another party where it is technically feasible.
You may at any time request a copy of any of your personal data that we hold.
If at any time after giving us personal information you decide that you no longer wish us to hold or use this information, or in the case that the information becomes out of date, you should notify us, and we will remove or rectify the information within a reasonable time and in accordance with legislative requirements.
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Changes to our Privacy Statement
EIIS Management Limited may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.
This policy is effective from 1 June 2018.