1.1. At EML Money DAC (EML Money), your right to privacy is at the forefront of our concerns. Below are guidelines we use for protecting your personal information.
1.2. We are registered in Republic of Ireland under registration number 423276, and our registered office is at 2nd Floor, La Vallee House, Upper Dargle Road, Bray, County Wicklow, Ireland.
1.3. All of the provisions are drafted according to our interpretation of the General Data Protection Regulation (GDPR).
1.4. Subject to the GDPR, you are entitled to request us to send you a copy of all personal data we record. This is in line with the GDPR’s Subject Access Request. How we process our Subject Access Request is governed within our Data Protection Policy.
1.5. EML Money needs to gather and use certain information about individuals.
1.6. These can include customers, suppliers, business contracts, employees and other people the organisation has a relationship with or may need to contact.
1.7. This policy describes how this personal data must be collected, handed and stored to meet the company’s data protection standard and the GDPR requirements.
1.8. Throughout the course of our business we will collect, store and use information for defined business purposes. We use your information to support and enhance our relationship with you, for example, to process your order, provide ongoing service and support. We do not sell your information. We strive to protect your data by use of appropriate measures and processes.
1.9. This policy applies where we are acting as a data controller with respect to the personal data of http://www.perfectpaas.com; in other words, where we determine the purposes and means of the processing of that personal data.
1.10. Our website incorporates privacy controls which affects how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
2. Types of information being collected
2.1. EML Money collects information when you interact with us. Some examples of how we collect information is provided below for your convenience:
Register an account with PerfectPaaS
Request information about one of our products
Place an order with us
Provide us with feedback
When you visit our website after you have accepted our Cookies statement
2.2. The information from you would fall into two categories:
- a). Personally Identifiable Information
- b). Non-personally Identifiable Information
2.3. Personally identifiable Information
2.3.1. This information lets us know the specifics of who you are and enables us to help you manage your profile with us. This information may include your name, address, phone number, date of birth, e-mail address, employer, occupation, credit card number, expiration date, shipping address, job title.
2.3.2. EML Money will process and store this personal information in accordance with the provisions of the GDPR. In order to do so, special training has been provided to all our responsible employees.
2.4. Non-Personally Identifiable Information
2.4.1. This information does not by itself identify itself to a specific individual. This information may include the URL of the website you came from before visiting our site, the Internet Protocol (IP) address, the URL you go to next, which browser or device you used to come to our site, and any search terms entered on our site.
2.4.2. EML Money's main objective when collecting customer information is to provide our service to our customers and to ensure a smooth and efficient experience for all while visiting our site.
2.4.3. Please contact EML Money if you have any questions or concerns. You may also ask to see any personal data you have given us and request amendment or correction or deletion. We endeavour to protect the security of your personal data by use of appropriate measures and processes
2.4.4. Users of this website can contact us:
- a). By post, to 2nd Floor, La Vallee House, Upper Dargle Road, Bray, Co. Wicklow, A98 W2H9, Ireland
- b). By telephone, on +353 1 255 7111, or
- c). By email, using email@example.com
3. How we use your personal data
3.1. In this Section 3 we have set out:
- a). The general categories of personal data that we may process
- b). In case of personal data that we did not obtain directly from you, the course and specific categories of that data
- c). The purposes for which we may process personal data; and
- d). The legal basis of the processing
3.2. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing may be either direct data subject consent or through our legitimate interest as service provider to our customers.
3.3. We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing may be either direct data subject consent or through our legitimate interest as service provider to our customers.
3.4. We may process your information included in your personal profile on our website ("profile data"). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing may be either direct data subject consent or through our legitimate interest as service provider to our customers.
3.5. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.6. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing may be either direct data subject consent or through our legitimate interest as service provider to our customers.
3.7. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.8. Please do not supply any other person's personal data to us, unless you have been given explicit consent from a third party to provide their personal data to us or unless we prompt you to do so.
4. Providing your personal data to others
4.1. We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3. Financial transactions relating to our website and services http://www.perfectpaas.com are or could be handled by our payment services providers such as Mastercard. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.4. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Your rights
5.1. In this Section 5, we have summarised the rights that you have under data protection law and GDPR. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
5.2. Your principal rights under data protection law are:
- a). the right to access;
- b). the right to rectification;
- c). the right to erasure;
- d). the right to restrict processing;
- e). the right to object to processing;
- f). the right to data portability;
- g). the right to complain to a supervisory authority; and
- h). the right to withdraw consent.
5.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
5.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include:
- a). The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- b). You withdraw consent to consent-based processing;
- c). You object to the processing under certain rules of applicable data protection law;
- d). The processing is for direct marketing purposes; and
- e). The personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
5.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are:
- a). You contest the accuracy of the personal data;
- b). Processing is unlawful but you oppose erasure;
- c). We no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and
- d). You have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
5.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
5.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
5.9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
5.10. For the most part the legal basis for our processing of your personal data is:
- a). Consent;
- b). That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
5.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. EML Money lead supervisory authority is the Irish Data Protection Commissioner. You can contact the Data Protection Commissioner using the following details:
Office of the Data Protection Commissioner.
Address: Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland.
Phone +353 (0761) 104 800
LoCall 1890 25 22 31
Fax +353 57 868 4757
5.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6. Retaining and deleting personal data
6.1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3. Please note that we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7.1. We may update this policy from time to time by publishing a new version on our website.
7.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3. We may notify you of changes to this policy [by email or through the private messaging system on our website].
8. Security of Processing
EML Money has implemented technical and organisational measures to ensure personal data processed remains secure however absolute security cannot be guaranteed. Should you have a particular concern about a particular method of data transmission, we will take reasonable steps to provide an alternative method.
It may sometimes be necessary to transfer personal information overseas. When transfers are needed, information may be transferred to countries or territories around the world. Any transfers made will be in full compliance with all aspects of GDPR and in accordance with country-specific legislation applicable to EML Money .
10. Automated decision-making & Profiling
We do not process personal data for automatic decision-making or profiling.
11. Data protection for Employment & Recruitment Procedures
We may collect and process personal data of applicants for the purposes of the processing of the application procedures. The processing may also be carried u electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on the website to EML Money . If EML Money concludes an employment contract with an applicant, the summitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by EML Money , the application documents shall be automatically erased within 6 months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure.
12.1. You may not transfer any of your rights under this privacy notice to any other person. We may transfer our rights under privacy notice where we reasonably believe your rights will not be affected for example as a result of a merger or acquisition.
12.2. There may be instances where we are required to provide personal data in response to a court order or government investigation.
12.3. We also reserve the right to report to law enforcement agencies any activity that we in good faith believe to be unlawful.
12.4. We may release such information that we believe is reasonably necessary to release to enforce our terms and conditions or to protect the rights, property and safety of ourselves and others.
12.5. If any court or competent authority finds that any provision of this privacy notice 9or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this notice will not be affected.
12.6. This notice will be governed and interpreted according to the laws of Republic of Ireland. All disputes arising under this notice will be subject to the exclusive jurisdiction of the Irish courts.
13. Errors and Changes
You can access, review and/or correct all your personal information that we maintain through the “My Account” function. We will use reasonable steps to verify your identity before granting access or making corrections and we do this to prevent unauthorised access to your personal details.
14.1. Our Website uses "cookie" technology.
14.2. A cookie is a little piece of text stored by the browser on your computer, at the request of our server to facilitate ease of communication and use of the Website.
14.3. For further information regarding our approach to Cookies please refer to our Cookies Policy.
15. Contact Us
If you would like to contact us, or have questions regarding our privacy statement, please email us at firstname.lastname@example.org
A data subject may contact our Data Protection Officer directly with any enquires relating to data protection.
EML Money DAC
2nd Floor, La Vallee House
Upper Dargle Road