Privacy Policy

Introduction
1. Vistatec Limited, a company incorporated under the laws of Ireland with registered number 268483 and registered address at 693-705 South Circular Road, Dublin 8 D08 H30H, Ireland (“Vistatec” or, in this privacy notice, “we”, “us”, “our”) is strongly committed to protecting your Personal Data (as defined below). This Privacy Notice sets out how we collect, use and protect your Personal Data through your use of www.vistatec.com (the “Website”).
2. This privacy notice (“Notice”) applies to all current and former website users (“Website Users”). Please read the following carefully to understand our practices regarding your Personal Data and how we treat and safeguard it.
3. The Notice has been developed to ensure our Website Users whose Personal Data is processed under the control of Vistatec feel confident about the privacy and security of Personal Data, and to meet our obligations under EU Regulation 679/2016 General Data Protection Regulation (“GDPR”) and the Data Protection Acts 1988-2018 of Ireland (together “Data Protection Law”);
4. For the purposes of this Notice, Personal Data is information that identifies you as an individual or is capable of doing so (“Personal Data”).
5. We must comply with the data protection principles set down in Data Protection Law and this Notice applies to all Personal Data collected via the Website, processed and stored by us that is subject to the laws described above. By providing us with information, you acknowledge and agree to the practices described in this Notice.
6. For the purposes of Data Protection Law, Vistatec is the Data Controller of your Personal Data. You will find our contact details in the “Contact us” section below.
7. The terms “Data Subjects”, “Data Controller”, “Data Processor” and “process”, when used in this Notice, have the meanings given to them in Data Protection Law, unless otherwise indicated.
8. This Notice does not form part of any contract of employment or any contract to provide services. We may update this notice at any time in our sole discretion.
9. The Website is not intended for children and we do not knowingly collect data relating to children.
10. It is important that you read and retain this Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing Personal Data about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
What kinds of Personal Data do we hold on Website Users?
1. We may collect the following types of Personal Data:
  1. identity and contact details: including name, signature, alias, nickname, maiden name, government ID, date of birth, current address, title, position, business phone number, business email address;
  2. financial and credit card information and transaction data;
  3. employment history and education;
  4. technical information: profile data and usage data such as IP address, login information, browser type and version, time zone, products viewed; and
  5. marketing and communications data: your preferences in receiving marketing from us and your communication preferences.
How we Collect data and Personal Data
1. We collect Personal Data about Website Users when you interact with the Website or when transacting with us via the Website, and in the course of business correspondence via the Website. This includes personal data you provide when you:
  1. submit contact forms for sales enquiries, general enquiries, freelance and agency applications;
  2. place an order via the Website;
  3. create an account on the Website;
  4. apply to work with us via the Website;
  5. subscribe to our newsletter;
  6. request marketing to be sent to you;
  7. give us feedback or contact us;
2. As you interact with the Website, we will automatically collect technical information about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and/or other similar technologies. We may also receive technical information about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
3. Contact, financial and transaction data may also be collected from providers of technical, payment and delivery services.
4. We may receive information about you if you use any other websites we operate or other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive personal data about you from them. We may combine this personal data with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out below (depending on the types of information we receive). When you apply to work with us, we might engage a background check agency to carry out background checks on you.
Why do we collect Personal Data?
1. We collect Personal Data in order to provide you with our services/products, to market our services, to improve the Website and to recruit staff, and more specifically to:
  1. deliver information about our products and services, where you have subscribed to receive same;
  2. provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
  3. ensure that content from the Site is presented in the most effective manner for you and for your computer;
  4. allow you to participate in interactive features of our service, when you choose to do so;
  5. create a candidate proﬁle for you if you are a prospective employee;
  6. process employment applications, including by assessing qualiﬁcations, verifying information, conducting reference or other employment-related checks, and notifying you of future opportunities that might be of interest to you;
  7. create a proﬁle for you if you are a prospective freelance or agency applicant;
  8. process applications, including by assessing qualiﬁcations, verifying information, conducting reference or other background-related checks, and notifying you of future opportunities that might be of interest to you;
  9. administer and improve our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  10. keep the Website safe and secure; and
  11. make suggestions and recommendations to you and other users of the Website about services that may interest you or them.
Legal basis for processing
1. The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
  1. Performance of a contract with you: where we need to perform the contract we are about to enter into or have entered into with you.;
  2. Legitimate interests: we may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure website experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); and
  3. Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  4. Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
How we may use your Personal Data
1. We may use your Personal Data in the conduct of our business with you, for example, in order to fulfil our contract with you, upon your consent for the purposes of contacting you regarding our or your services and business.
2. We also use data (including Personal Data) to administer, operate, and improve the Website.
Do we disclose YOUR PERSONAL DATA to anyone else?
1. We shall disclose your Personal Data to third parties only when it is necessary as part of our contract with you, for the conduct of business or when there is a legal or statutory obligation to do so. Whenever we disclose your Personal Data to third parties, we will only disclose that amount of your Personal Data necessary to meet such business need or legal requirement. Third parties that receive your Personal Data from us must satisfy us as to the measures taken to protect the Personal Data such parties receive, in accordance with Data Protection Law and as stated in this Notice. Appropriate measures will be taken to ensure that all such disclosures or transfers of your Personal Data to third parties will be completed in a secure manner and pursuant to contractual safeguards.
2. We may employ other companies and individuals to perform functions on our behalf, including professional advisors, outsourced services providers and contractors in order to fulfil our contract with you. These third-party service providers are authorised to use Personal Data only as needed to perform their functions on our behalf and are required to maintain the security of your Personal Data.
3. The following is a list of categories of third parties to which Vistatec may disclose your data in the manner described at section 7.1 above:
  1. external contractors assisting Vistatec in the provision of our services;
  2. organisations and other entities providing services to Vistatec, including financial, legal, IT, organisational, etc.;
  3. companies within Vistatec’s group.
4. We may transfer your Personal Data to another company with which we have merged, or which has acquired all or some of our assets. We will advise you if such a change of ownership or change of corporate structure takes place and we will update this Notice accordingly.
5. We may provide your Personal Data when obliged to do so under relevant Data Protection Law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. In the case of any such disclosure, we will do so only in accordance with the relevant Data Protection Law.
6. We may also provide your Personal Data when required to do so by law, for example under a court order, and may transfer data to legal counsel where same is necessary for the defence of legal claims.
Transfers outside of the EEA
1. Your Personal Data may be processed by Vistatec, companies within Vistatec’s group or its trusted third-party partners outside the European Economic Area (“EEA”). Data privacy laws in the countries to which your personal data is transferred may not be equivalent to, or as protective as, the laws in the EEA.
2. We will implement appropriate measures to ensure that your Personal Data remains protected and secure when it is transferred outside of the EEA, in accordance with applicable Data Protection Law. Because many countries to which Personal Data may be transferred have not received an “adequacy finding” regarding their privacy laws from the European Commission, Vistatec will either rely on Standard Contractual Clauses or derogations in Article 49 of the GDPR to transfer your Personal Data to such countries.
3. Vistatec continues to monitor all developments regarding the legal bases for the international transfer of Personal Data and shall update its processes as necessary.
How long do we keep Personal Data?
1. The period for which we retain Personal Data varies according to the use of that information. In some cases, there are legal requirements to keep Personal Data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will retain Personal Data no longer than is necessary for the purposes for which the Personal Data were collected and processed (as described above).
2. We will retain your Personal Data for as long as we continue to provide our services to you. Following termination of the provision of the services to you, your Personal Data shall be retained for as long as is necessary and permissible in accordance with statutory limitation periods.
Security of your Personal Data
1. We are committed to ensuring that all of your information, including Personal Data, is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical and organisational measures to safeguard and secure your Personal Data.
2. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.
3. The transmission of information electronically is not completely secure. Although we will do our best to protect your Personal Data and apply appropriate safeguards, we cannot guarantee the security of your data transmitted electronically and any such transmission is at your own risk.
How to exercise your rights in respect of Personal Data we hold about you?

Your rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to request that we:
1. provide you with information as to whether we process your data and details relating to our processing, and that we provide you with a copy of your data (‘access right’);
2. rectify and/or update any inaccurate data we might have about you without undue delay (‘right to rectification’);
3. under certain circumstances, the right to object to processing of data relating to you (‘right to object’);
4. under certain circumstances, be restricted from processing your data (‘right to restriction’);
5. under certain circumstances, erase your personal data without undue delay (i.e. the “right to erasure”); and
6. under certain circumstances, furnish you with the personal data which you provided us with in a structured, commonly used and machine readable format (‘right to data portability’).

Exercising your rights and managing Personal Data

You can exercise any of your rights by making a request to us at the contact information provided below. If, for some reason, these rights are denied, we will provide an explanation of why this is the case.
We will process your request within 30 days of receipt.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

How can you make a complaint about the Use of Personal Data?
1. Complaints on the use, retention and disposal of Personal Data can be submitted via email to our Data Protection Representative at privacy@vistatec.com.
2. Under Data Protection Law, you also have the right to lodge a complaint with the Data Protection Commission.
Review
1. We keep our privacy policy under regular review. We encourage you to periodically review this Notice to stay informed about how we collect, use, and disclose Personal Data.
2. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.
Contact information
1. If you have questions about this Notice or our treatment of the Personal Data provided to us, please contact us at:

Name: Vistatec Limited

ATTN: Patrick Kelly, Vistatec Privacy Officer

Address: 700 South Circular Road, Kilmainham, Dublin 8, D08 H30H, Ireland

Phone: +353 1 416 8000

E-mail: privacy@vistatec.com

Historic versions can be obtained by contacting us.

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