This policy explains how we may process your personal data. This policy may be amended or updated from time to time, so please check it regularly for updates.
This policy is issued by Feelystone Limited, its subsidiaries and its affiliates and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our web sites and other users of our services.
For the purposes of this policy, Feelystone is the Data Controller. This policy covers the information practices relating to our company web sites and services offered now or in the future.
This policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in Irish or European Union law. We encourage you to read this policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this policy.
Collection of Personal Data:
We may collect personal data about you from the following sources:
- Data you provide: We may obtain your personal data when you provide it to us g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card.
- Relationship data: We may collect or obtain your personal data in the ordinary course of our relationship with you g., if you purchase a service from us.
- Data you make public: We may collect or obtain your personal data that you manifestly choose to make public, including via social media g., we may collect information from your social media profile(s), if you make a public post about us.
- Web site data: We may collect or obtain your personal data when you visit our web sites or use any features or resources available on or through a web site.
- Content and advertising information: If you choose to interact with any third-party content or advertising on a web site or in an App, we may receive personal data about you from the relevant third-party.
- Third party information:We may collect or obtain your personal data from third-parties who provide it to us g., credit reference agencies; law enforcement authorities; etc.
Creation of Personal Data:
We may also create personal data about you, such as records of your interactions with us, and details of your purchase history for internal administration purposes and analysis.
Categories of Personal Data we may process:
We may process the following categories of personal data about you:
- given name(s)
- preferred name
- date of birth or age
- job title
- language preferences
- correspondence address
- telephone number(s)
- email address
- details of your public social media profile(s)
- records of any consents you may have given
- the date and time
- the means by which we obtained your consent
- records of purchases
- prices paid
- invoice records
- payment records
- billing address
- payment method
- bank account number
- credit card number
- cardholder or accountholder name o card or account security details
- card ‘valid from’ date
- card expiry date
- BACS details
- IBAN details
- SWIFT details
- payment amount
- payment date
- records of cheques
Data relating to our website:
- device type used
- operating system
- browser type
- browser settings
- IP address
- language settings
- dates and times of connecting to a web site
- aggregate statistical information
- where you interact with us in your capacity as an employee in relation to business correspondence, the contact information of your employer (including name, address, telephone number and email address) to the extent relevant.
Content and advertising data:
- Analytics may record your interactions with our online advertising and content, records of advertising and content displayed on web site pages displayed to you, and any interaction you may have had with such content or advertising, including mouse clicks, any forms you complete and any touchscreen interactions.
Views and opinions:
- any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
Lawful basis for Processing Personal Data:
In processing your personal data in connection with the purposes set out in this policy, we may rely on one or more of the following legal bases, depending on the circumstances:
We may process your personal data where we have obtained your prior, express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for data processing that is necessary, legal or obligatory in any way)
- Contractual necessity:
We may process your personal data where the processing is necessary in connection with any contract that you may enter into with us;
- Compliance with applicable law:
We may process your personal data where the processing is required by applicable law
- Vital interests:
We may process your personal data where the processing is necessary to protect the vital interests of any individual
- Legitimate interests:
We may process your personal data where we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
Sensitive Personal Data:
We do not seek to collect or otherwise process your sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on one of the following legal bases:
Compliance with applicable law:
- We may process your sensitive personal data where the processing is required or permitted by applicable law e.g. to comply with our diversity reporting obligations
Detection and prevention of crime:
- We may process your sensitive personal data where the processing is necessary for the detection or prevention of crime, including the prevention of fraud.
Establishment, exercise or defence of legal rights:
- We may process your sensitive personal data where the processing is necessary for the establishment, exercise or defence of legal rights.
- We may process your sensitive personal data where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your sensitive personal data. This legal basis is only used in relation to processing that is entirely voluntary – it is not used for data processing that is necessary, legal or obligatory in any way.
Purposes for which we may Process your Personal Data
The purposes for which we may process personal data, subject to applicable law, include:
Provision of services to you:
- providing our web site to you
- communicating with you in relation to those services and providing you with promotional items at your request or in connection with those services or similar services.
- operating and managing our website
- providing content to you
- displaying advertising and other information to you
- notifying you of changes to any of our website or our services.
- communicating with you via any means (including via email, telephone, text message, social media, post or in person) for news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law
- maintaining and updating your contact information where appropriate
- obtaining your prior ‘Opt-In’ consent where required.
Communications and IT operations:
- management of our communications systems
- operation of IT security systems
- IT security audits.
Health and safety:
- health and safety assessments
- record keeping
- compliance with related legal obligations
- sales; finance
- corporate audit
- vendor management
- engaging with you for the purposes of obtaining your views on our services
- physical security of our premises
- records of visits to our premises
- CCTV recordings
- electronic security: – including login records and access details
- detecting, investigating and preventing breaches of policy
- criminal offences in accordance with applicable law
- establishing, exercising and defending legal rights
- Legal compliance:compliance with our legal and regulatory obligations under applicable law
Disclosure of Personal data to third parties:
We may disclose your personal data to other entities within the company group, for legitimate business purposes, including operating our web sites, and providing services to you, in accordance with applicable law.
In addition, we may disclose your personal data to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation
- outside professional advisors, accountants, auditors, or lawyers, subject to binding contractual obligations of confidentiality
- third party processors, g. payment services providers, data centres; etc., located anywhere in the world, subject to the requirements noted below.
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security
- any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets, including in the event of a reorganisation, dissolution or liquidation.
If we engage a third-party processor to process your personal data, the processor will be subject to binding contractual obligations to:
- a) only process the personal data in accordance with our prior written instructions;
- b) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable Irish and European Union law.
As the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any personal data that you send to us are sent securely.
We take every reasonable step to ensure that:
- your personal data that we process is accurate and kept up to date
- any of your personal data that we process which you inform us is inaccurate will be erased or rectified as per your instruction
We take every reasonable step to ensure that your personal data which we process is limited to the personal data reasonably necessary in connection with the purposes set out in this policy or as required to provide you services or access to our website.
We take every reasonable step to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this policy.
The criteria for determining the duration for which we will keep your personal data are as follows:
We will retain copies of your personal data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this policy unless applicable law requires a longer retention period. We may retain your personal data for the duration of any period necessary to establish, exercise or defend any legal rights.
Your legal rights:
Subject to applicable law, you may have several rights regarding the processing of your relevant personal data, including:
- the right not to provide your personal data to us. However, please note that we may be unable to provide you with the full benefit of our website.
- if you do not provide us with your personal data, we may not be able to process your orders without the necessary details.
- the right to request access to, or copies of, your relevant personal data, together with information regarding the nature, processing and disclosure of those relevant personal data
- the right to request rectification of any inaccuracies in your relevant personal data
- the right to request, on legitimate grounds: – the erasure of your relevant personal data andrestriction of processing of your relevant personal data
- the right to object, on legitimate grounds, to the processing of your relevant personal data by us or on our behalf
- the right to have certain relevant personal data transferred to another Data Controller, in a structured, commonly used and machine-readable format, to the extent applicable
- where we process your relevant personal data based on your consent, the right to withdraw that consent, noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal data in reliance upon any other available legal bases.
- the right to lodge complaints with the Data Protection Commissioner regarding the processing of your relevant personal data by us or on our behalf.
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this policy, or about our processing of your personal data, please contact us.
Cookies and similar technologies:
When you visit a web site, Cookies may be placed onto your device, or Cookies already on your device may be read. This should always be subject to obtaining your consent, where required, in accordance with applicable law.
When you sign up to receive our newsletter, we ask for your name and your email address.
We will ask for your consent to use your name and email address to email you our company newsletter which contains information about our products and other information which we feel might be of interest to you.
You can withdraw your consent at any time and we will stop sending you the newsletter.
We keep your personal data for as long as we produce and distribute our newsletter. If you withdraw your consent, we will mark your details so that they are not used and delete them after two years.
Your right to complain:
If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the Data Protection Commissioner’s Office via their website at www.dataprotection.ie or write to them at:
Data Protection Commissioner.
Phone: +353 (0761) 104 800