This policy contains important information about your personal rights to privacy. Please read through it carefully to understand how we use your personal data. The provision of your personal data to us is voluntary, however, without providing us with your personal data, use of our services and interaction with us maybe limited.
Contents of this policy:
- How is personal data / information collected?
- Personal data that we use
- How and why we will use your personal data
- Lawful basis
- Communications for marketing / fundraising
- Retention of Personal Data
- Disclosure of Personal Data
- Security & storage of and access to your personal data
- International data transfers
- Exercising your rights
- Links & third parties
- Other Relevant Privacy Policies
- Questions & Complaints
1. How is personal data / information collected?
a. Where information is provided to us directly:
personal data that you submit through our website. This information includes information provided at the time of signing up to our email newsletter; or personal data that you provide to us when you communicate with our Customer Support Channels; email, phone or letter. We may ask you to provide more information when you enter competitions & promotions or when you report an issue with our website.
b. Where information can be gathered publicly:
In some cases personal data may be available to us from external publicly accessible sources. For example, when you choose to interact with us through social media services; Facebook, Twitter, Snapchat.
c. Where information is provided to us online through use of our services:
When you visit our website, we may collect the following types of personal data, either for system administration or to report to our advertisers which includes:
i. Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types & versions and operating systems & platforms.
ii. Information about your visit to our website, including the uniform resource locator (URL) clickstream to, through and from the website (this includes date & time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling & clicks) and methods used to browse away from the website.
We collect and use personal data by using cookies on our website to help us improve our site and to deliver a better, more personalised service. While cookies cannot alone identify an individual we do feel that it is important to be aware of them. We may combine personal data from these different sources (A – C) for the purposes outlined in this policy. Information on how cookies work can be found at Webopedia
2. Personal data that we use
We may collect, store and process the following kinds of personal data:
a. Name and contact details including postal address, telephone number, email address and where applicable, social media identity.
b. Date of birth and gender
c. Information about your computer / mobile device and your visits to and use of this website including your IP address and geographical location
And / or any other personal data we obtain as outlined in section 1 “How we collect personal data about you”.
Special Categories of Data:
We acknowledge that EU General Data Protection Regulation (GDPR) recognises certain categories of personal data as sensitive and are classed as special categories, therefore requiring more protection due in part to their sensitive nature. Information that falls under these categories would be your health status, ethnicity and religious beliefs. Currently we do not collect any of this information and we would only ever process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.
3. How and why we will use your personal data
Your personal data, however provided to us, will be used for the purposes specified in this notice. In particular, we use your personal data:
a. To provide you with services, products or information you have requested
b. To provide further information about our work, services or activities (where necessary, only where you have provided your consent to receive such information)
c. To answer your questions / requests and communicate with you in general
d. To allow you to apply for a job
e. To analyse and improve our work, services, activities, products or information (including our website), or for internal records
f. To run / administer the activities of JC’s Supermarket Swords, including our website, and to ensure that content is presented in the most effective manner for you and for your device
g. To audit / administer our accounts
f. To satisfy legal obligations which are binding on us from regulatory government and / or law enforcement bodies (for example, requirements relating to the payment of tax or anti-money laundering)
g. For the prevention of fraud or misuse or services
h. For the establishment, defence and / or enforcement of legal claims
4. Lawful basis
GDPR requires us to rely on one or more lawful bases to use your personal data. We consider the grounds listed below to be relevant:
a. Where you have provided your consent to us to use your personal data in a certain way (for example, we may ask for your consent to use your personal data to send you email newsletters)
b. Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal data with regulatory bodies which govern our work and services)
c. Where these is a legitimate interest in us doing so
GDPR allows us to collect and process personal data if it is reasonably necessary to achieve our interests as long as that processing is fair, balanced and does not unduly impact your rights as an individual. In broad terms, our “legitimate interests” means the interests of running JC’s Supermarket Swords as a commercial entity and ensuring the best possible customer experience.
When we process your personal data to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and on your rights under Data Protection Acts, 1998 & 2003. We will not use your personal data for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless we are otherwise permitted by law)
5. Communications for marketing / fundraising
We may use your contact details to provide you with information about our work, events, services and / or activities which we consider may be of interest to you. Where we do this via email, we will not do so without your prior consent (unless allowed to do so via applicable law). Where you have provided us with your consent previously but do not wish to be contacted by us about our work, events, services and / or activities in the future, please let us know by email at firstname.lastname@example.org. You can opt out of receiving emails from JC’s Supermarket Swords at any time by clicking the “unsubscribe” link at the bottom of our emails.
6. Retention of Personal Data
In general, unless still required in connection with the purpose(s) for which it was collected and / or processed, we remove your personal data from our records six years after the date it was collected. However, if before that date (i) your personal data is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see section 10 below), we will remove it from our records at the relevant time. If you request to receive no further contact from us, we may keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.
7. Disclosure of Personal Data
We do not share, sell or rent your personal data to third parties for marketing purposes. However, we may disclose some personal data to selected third parties in order to achieve the purposes set out in this policy. These parties may include but are not limited to:
a. Suppliers and sub-contractors for the performance of any contract we enter into with them, for example, IT service providers such as website hosts or cloud storage providers
b. Professional service providers such as accountants and lawyers
c. Parties assisting us with research to monitor the impact / effectiveness of our work, services and activities
d. Regulatory authorities, such as tax authorities
In particular, we reserve the right to disclose your personal data to third parties:
1. In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the (prospective) seller or buyer of such business or assets
2. If substantially all of our assets are acquired by a third party, personal data held by us may be one of the transferred assets
3. If we are under any legal or regulatory duty to do so
4. To protect the rights, property or safety of JC’s Supermarket Swords, its personnel, customers or others
Other than as set out above, we will not disclose any of your personal data without your permission unless we are required to do so by law.
8. Security & storage of and access to your personal data
JC’s Supermarket Swords is committed to keeping your personal data safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information. Your personal data is only accessible by appropriately trained staff and contractors, and is stored on secure servers which have features to prevent unauthorised access.
9. International data transfers
We may also transfer your personal data outside of the European Union in connection with the operation of our business, such as when we use a service provider that is based in another jurisdiction. If we transfer your personal data outside of the European Union please rest assured that we will ensure that appropriate measures are in place to protect your personal data and to comply with our obligations under applicable data protection law. When we transfer your personal data outside of the European Union, if required under data protection law we will either enter into contracts in the form approved by the European Commission with the entity that we transfer data to, or we will ensure that the company to which we transfer your personal data has agreed to abide by an approved transfer mechanism, such as the EU-US Privacy Shield framework. If you would like further details about the measures we have taken in relation to the transfer of your personal data, or copies of the agreements that we have put in place in relation to the transfers, please contact us using the details at the bottom of this notice.
10. Exercising your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right under the Freedom of Information Act 2014 to request access to any / all information held about you at any time by contacting us directly at JC’s Supermarket Swords, Swords Shopping Centre, Rathbeale Rd, Commons West, Swords, Co. Dublin.
JC’s Supermarket Swords reserves the right to update this policy at any time. We will notify you of any significant changes to our policy by contacting you directly where reasonably possible for us to do so and by placing and update notice on our website. This policy was last updated on 23rd May 2018
12. Links & third parties
Our website may, from time to time link directly to and from some websites in our partner networks, advertisers and affiliates. This policy does not cover the external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on those websites.
13. Other Relevant Privacy Policies
Some of our third party advertising partners ask us to make you aware of their privacy policies. These policies are available by following the links below:
14. Questions and Complaints
Please let us know if you have any questions or concerns about this policy or about the way in which JC’s Supermarket Swords processes your personal data by contacting us at the channels below:
Please direct your queries to customer support at one of the following:
TELEPHONE: 01 840 2884
POST: Swords Shopping Centre, Rathbeale Rd, Commons West, Swords, Co. Dublin