1.
Introduction
1.1
We are committed to safeguarding the privacy of our website visitors and service users.
1.2
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.3
By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.4
Our website incorporates privacy controls which affect 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.
1.5
In this policy, “we”, “us” and “our” refer to Heidi Computers Ltd. For more information about us, see Section 19.
2.
How we use your personal data
2.1In this Section 2 we have set out:
a)
the general categories of personal data that we may process;
b)
in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
c)
the purposes for which we may process personal data; and
d)
the legal bases of the processing.
2.2
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 is our legitimate interests, namely monitoring and improving our website and services.
2.3
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 is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4
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 is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.
2.5
We may process your personal data that are provided in the course of the use of our services (“service data“). The service 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 source of the service data is you or your employer. The service 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 is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.6
We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7
We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.9
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.10
We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.11
We may process personal data. This 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 source of this data is from what you provide and can be augmented from public sources. This data may be processed for the purposes of contact information or identify where your identity may need to be verified to protect our mutual interests. The legal basis for this processing is consent or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.12
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.
2.13
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 is our legitimate interests, namely the proper protection of our business against risks.
2.14
In addition to the specific purposes for which we may process your personal data set out in this Section 2, 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.
2.15
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3.
Automated decision-making
3.1
We will use your personal data for the purposes of automated decision-making in relation to routing to the correct department.
3.2
This automated decision-making will involve simple categorisation based on customer type or selections you have made.
3.3
The significance and possible consequences of this automated decision-making are to ensure we offer the best service to our customers.
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 basis, set out in this policy.
4.2
We may disclose your personal data to our insurers and/or professional adviser 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
We may disclose contact data to our suppliers or subcontractors insofar as reasonably necessary for processing orders or engaging with our services.
4.4
Financial transactions relating to our website and services may be handled by our payment services providers, Stripe, Paypal. 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 refund. You can find information about the payment services providers’ privacy policies and practices on their respective websites.
4.5
We may disclose your enquiry data to one or more of those selected third-party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
4.6
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.
To manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents, we use the consent tool “Real Cookie Banner”. Details on how “Real Cookie Banner” works can be found at https://devowl.io/rcb/data-processing/.
The legal basis for the processing of personal data in this context are Art. 6 (1) lit. c GDPR and Art. 6 (1) lit. f GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we will not be able to manage your consents.
5.
International transfers of your personal data
5.1
In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
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
We will retain your personal data as follows:
(a)
Data you provide will be retained for a minimum period of 90 days following its creation on our systems, and for an unlimited period if there is a legal requirement.
6.4
In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a)
the period of retention of personal contact data will be determined based on legal requirements e.g. tax records.
(b)
Data you yourself store as contact or profile data on our forums, you can delete this your self by updating the user record.
6.5
Notwithstanding the other provisions of this Section 6, 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.
Security of personal data
7.1
We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2
We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
7.3
The following personal data will be stored by us in encrypted form where possible: your name, contact information, password(s) and cardholder data.
7.4
Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
7.5
You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
7.6
You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
8.
Amendments
8.1
We may update this policy from time to time by publishing a new version on our website.
8.2
You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3
We may notify you of changes to this policy by email or through the private messaging system on our website.
9.
Your rights
9.1
In this Section 9, we have summarised the rights that you have under data protection law. 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.
9.2
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.
9.3
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.
9.4
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.
9.5
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and 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.
9.6
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; 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 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.
9.7
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.
9.8
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.
9.9
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.
9.10
To the extent that the legal basis for our processing of your personal data is:
(a)
consent; or
(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,
(d)
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.
9.11
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.
9.12
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.
9.13
You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 9.
9.14
Where you request access to personal information, we are required by law to use reasonable means to verify your identity before doing so. The first copy will be provided free of charge. If your requests for copies are excessive or manifestly unfounded, and in particular if they are of a repetitive nature, we may charge a reasonable fee to cover administrative costs of providing you with such information or communicating with you in regard to that information or taking the action requested by you or refusing to act on your request. This is set out in Article 12 of the GDPR.
10.
Third party websites
10.1
Our website includes hyperlinks to, and details of, third party websites.
10.2
We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11.
Personal data of children
11.1
Our website and services are targeted at persons over the age of 18.
11.2
If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
12.
Updating information
12.1
Please let us know if the personal information that we hold about you needs to be corrected or updated.
13.
Acting as a data processor
13.1
In respect of hosted services we do not act as a data controller; instead, we act as a data processor.
13.2
Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
14.
About cookies
14.1
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
14.2
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
14.3
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
15.
Cookies that we use
15.1
We use cookies for the following purposes:
(a)
authentication – we use cookies to identify you when you visit our website and as you navigate our website;
(b)
status – we use cookies to help us to determine if you are logged into our website;
(c)
shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website;
(d)
personalisation – we use cookies to store information about your preferences and to personalise our website for you;
(e)
security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
(f)
advertising – we use cookies to help us to display advertisements that will be relevant to you;
(g)
analysis – we use cookies to help us to analyse the use and performance of our website and services; and
(h)
cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
16.
Cookies used by our service providers
16.1
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
16.2
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
16.3
We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996 . Please also read https://policies.google.com/technologies/partner-sites
16.4
We use Clicky to analyse web traffic. This service uses cookies for tracking site activity. You can view the privacy policy of this service provider at https://clicky.com/terms
17.
Managing cookies
17.1
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a)
https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b)
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c)
http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d)
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e)
https://support.apple.com/kb/PH21411 (Safari); and
(f)
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
17.2
Blocking all cookies will have a negative impact upon the usability of many websites.
17.3
If you block cookies, you will not be able to use all the features on our website.
18.
Our details
18.1
This website is owned and operated by Heidi Computers Ltd.
18.2
We are registered in the Republic of Ireland under Registration Number: 273384, and our Registered Office is at 3015 Lake Drive,Citywest Business Campus,Dublin,D24 DKP4,Ireland.
18.3
Our principal place of business is at 3015 Lake Drive,Citywest Business Campus,Dublin,D24 DKP4,Ireland.
18.4
You can contact us:
(a)
by post, to the postal address given above;
(b)
using our website contact form;
(c)
by telephone, on the contact number published on our website from time to time; or
(d)
by email, using the email address published on our website from time to time.
19.
Data protection officer
19.1
Our data protection officer can be contacted via the means outlined in 18.4