Privacy Policy

1. Intro -Seefin Data Management Limited.
Data privacy is important to us. This means that we process data about identified or identifiable individuals, which is called personal data, with due care and in accordance with applicable data protection law and GDPR.

This Privacy Notice describes how we process personal data we collect from individuals, customers in relation to their use of our website, ordering and use of our services and events (collectively, our “Services). In legal terms, we are the data processor of such personal data and our customers are the data controllers.

This Privacy Notice only covers data processing carried out by Seefin Data Management Limited. The Privacy Notice does not address, and we are not responsible for, the privacy practices of any third parties, also in cases where Services include hyperlinks to third parties’ websites or when cookies are set by third parties.

2. Personal data
The personal data we collect from individuals, and customers using our Services (“Users”) mostly consists of user data, such as name, business function, gender, business address, telephone number, email address and other personal data Users provide to us. The specific kind of user data collected will depend on the Services used.

We may also collect technical data in relation to Users, such as IP address, browser type and version, preferred language, geographic location, operating system and computer platform, the full URL clickstream to, through, and from our Services, including date and time, websites accessed immediately before and after visiting our websites, services Users viewed or searched for while using our Services, and parts of our Services that Users have visited. Although we do not normally use technical data to identify individuals, sometimes individuals can be recognized from it, either alone or when combined or linked with user data. In such situations, technical data can also be considered to be personal data under applicable law and we will treat the combined data as personal data.

We use various technologies to collect and process data in relation to Users, including cookies. Cookies are small text files stored on Users’ computer by the internet browser. Cookies allow us to calculate the aggregate number of people using our Services and monitor the use of our Services. This helps us to improve our Services and better serve our Users. We may also use cookies that make the use of the Services easier, for example by remembering usernames, passwords and preferences. We may use tracking and analytics cookies to see how well our Services are being received by our Users. Some cookies enable our Services to function and inform us whether our Services are functioning properly. Our advertising cookies allow us to deliver targeted advertising to people who visit our website. Users may choose to set their web browser to refuse cookies, or to alert when cookies are being sent. This can usually be done through internet browser’s settings. Information about how to manage cookies can be found online. Some parts of our Services may not function properly if Users prefer not to accept the use of cookies. Our Cookie Notice gives further information on cookies in relation to our Services.

3. Purposes
We process personal data, on behalf of our client for the following purposes:

to allow us to run, maintain and develop our business,
to allow us to offer and provide our Services including research, payroll, marketing, medical, outbound calling, databases clean up and updating.
to allow us to keep Users informed about our Services and special offers that are likely to interest them,
to allow us to perform the contract we have signed with our customers, suppliers or partners,
to allow contract management, e.g. to address our invoices to our customers,
to enhance our Services and the use thereof,
to perform research and analysis relating to our Services,
to perform tracking of the use of our Services,

Should the personal data of the User be provided to us via our prospect, customer, supplier or partner, we shall assume that our prospect, customer, supplier or partner has informed the User of this Privacy Notice.

4. Storage period
We do not store the personal data for longer than is legally permitted and necessary for the related processing purposes. The storage period depends on the type of personal data, the purposes and the applicable law and therefore varies per use.

Typically, we store User’s personal data for as long as the User is using our Services or for as long as we have another purpose to do so and, thereafter, for no longer than is required or permitted by law.
We erase personal data after the above described storage period or when the User requests us to erase his/her personal data.

5. Legitimate grounds for processing
We process personal data to pursue our legitimate interest to run, maintain and develop our business. Furthermore, we process personal data to comply with our legal obligations.

6. Rights of Users
Right to access. Any User may contact us to get confirmation as to whether or not we are processing User’s personal data. Where we do process User’s personal data, we will inform User of what categories of personal data we process regarding him/her, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed and the envisaged storage period or criteria to determine that period.

Right to withdraw consent. In case our processing is based on a consent granted by the User, the User may withdraw the consent at any time by contacting us or by using the functionalities of our Services. Withdrawing a consent may lead to fewer possibilities to use our Services.

Right to rectification. Any User has the right to have inaccurate or incomplete personal data we store about the User rectified or completed.

Right to object. In case our processing is based on our legitimate interest to run, maintain and develop our business, any User has the right to object at any time to our processing. We shall then no longer process User’s personal data unless for the provision of our Services or if we demonstrate other compelling legitimate grounds for our processing that override User’s interests, rights and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, any User has the right to prohibit us from using his/her personal data for direct marketing purposes, by contacting us or by using the functionalities of the Services or unsubscribe possibilities in connection with our direct marketing messages.

Right to restriction of processing. Any User has the right to obtain from us restriction of processing of User’s personal data, as foreseen by applicable data protection law and GDPR, e.g. to allow our verification of accuracy of personal data after User’s contesting of accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for User’s legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use our Services.

Right to data portability. Any User has the right to receive User’s personal data from us in a structured, commonly used and machine-readable format and to independently transmit those data to a third party, in case our processing is based on User’s consent and carried out by automated means.

Right to erasure. Any User has the right to have personal data we process about the User erased from our systems if the personal data are no longer necessary for the related purposes, if we have unlawfully processed the personal data or if the User objects to processing for direct marketing. Any User furthermore has the right to erasure if the User withdraws consent or objects to our processing as meant above, unless we have a legitimate ground to not erase the data. We may not immediately be able to erase all residual copies from our servers and backup systems after the active data have been erased. Such copies shall be erased as soon as reasonably possible.

How to use these rights. To exercise any of the above mentioned rights, User should primarily use the functions offered by our Services. If such functions are however not sufficient for exercising such rights, Customer shall send us a letter or email to the address set out below under Contact, including the following information: name, address, phone number, email address and a copy of a valid proof of identity. We may request additional information necessary to confirm User’s identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

7. Security
We implement and maintain best practice and technical and organizational security measures to protect the personal data we process, from unauthorized access, alteration, disclosure, loss or destruction.

Should despite all of our security measures, a security breach occur that is likely to result in a risk to the data privacy of Users, we will inform the relevant Users and other affected parties, as well as relevant authorities when required by applicable data protection law, about the security breach as soon as reasonably possible.

8. Recipients
We only share personal data within our organization if and as far as necessary for the purposes specified in this Privacy Notice. Our staff members processing personal data are bound to confidentiality.

We do not share personal data with any third party outside of our organization unless one of the following circumstances applies.

For legal reasons. We may share personal data with third parties if we have good-faith belief that their access to and use of the personal data is necessary (i) to meet any applicable law and/or court order, (ii) to detect, prevent or otherwise address fraud, security or technical issues, and/or (iii) to protect the interests, properties or safety of us, our Users or the public, in accordance with the law.
(iv)Gardai and law enforcement to assist with the investigation and prevention of crime (v) the government or our regulators where we are required by law or to assist with their investigations or initiatives, including the Data Protection Commissioner. We will notify Users about such disclosure, as far as reasonably possible.

9. Location and transfer personal data
We will only store or transfer your personal data within Ireland. This means it will be fully protected under the Data Protection Leglisation and GDPR.

10. Lodging a complaint
In case any User considers our processing of his/her personal data to be inconsistent with applicable data protection law, a complaint may be lodged with the Office of the Data Protection Commissioner. We would welcome the opportunity to resolve your concerns ourselves and to contact us using the details in Part 12 below.

11. Changes
This Privacy Notice is dated December, 2018. We may update this Privacy Notice at any time if required in order to reflect changes in our data processing practices, in personal data protection laws or otherwise. For substantial changes to this Privacy Notice, we will use reasonable endeavors to provide notice thereof. The current version can be found on our website.

12. Contact
Any User having any question or request on this Privacy Notice or our privacy practices, can contact us at:

by email at JenniferBoyle@Seefindm.com
by mail at: Seefin DM Head Office, Seefin House, Listowel, Co. Kerry, V31 AK27
by phone at: +353 (0)68 222 18