In this Policy, unless specified otherwise, words and phrases shall have the same meanings as specified in Our Master Service Agreement which is available as a link in your Quote or can be requested from Mark Hyland at [email protected].
eXpd8 Limited, incorporated in the Republic of Ireland, (Number 351136) and having its Registered Office at Unit 3, Swords Business Park Swords County Dublin understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of Customers and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
means an account required to access and/or use Our Subscription Services;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Subscription Services. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
means the said eXpd8 Limited (as above).
“Thread” or “Thread Legal”
Thread, also known as Thread Legal, is a product of eXpd8 Limited.
2. Information About Us
2.1 Our VAT number is IE6541007C
2.2 Our Data Protection Officer is Mark Hyland and can be contacted by email at [insert address] [email protected], by telephone on +353 01 8900 390, or by post at Unit 3, Swords Business Park Swords County Dublin
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you or your employees and customers (see section 11);
4.1.3 The right to rectification if any personal data We hold about you or your employees and customers is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you or your employees (We only hold personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13). Please note that deletion of certain personal data may prevent the Subscription Services from functioning;
4.1.5 The right to restrict (i.e. prevent) the processing of personal data;
4.1.6 The right to data portability (obtaining a copy of personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the Republic of Ireland’s’s supervisory authority, the Data Protection Commissioner, details of which can be found here www.dataprotection.ie
5. What Data Do We Collect?
We may collect some or all of the following personal and non-personal data:
5.2 business/company name
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences, and interests;
5.7 financial information such as credit / debit card numbers;
5.8 IP address;
5.9 web browser type and version;
5.10 operating system;
5.11 a list of URLs starting with a referring site, your activity on Our Subscription Services, and the site you exit to;
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of personal data (e.g. by subscribing to emails or for delivery of the Subscription Services), or because it is in Our legitimate interests. Specifically, We may use personal data for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to the Subscription Services;
6.2.3 Personalising and tailoring your experience in the Subscription Services;
6.2.4 Supplying Our products and/or Subscription Services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Personalising and tailoring Our products and/or Subscription Services for you; Providing you with helpdesk support and/or training services;
6.2.6 Replying to emails from you;
6.2.7 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the link in the email;
6.2.8 Market research;
6.2.9 Analysing your use of Our Subscription Services and gathering feedback to enable Us to continually improve Our Subscription Services and your user experience;
6.3 With your permission and/or where permitted by law, We may also use your data for customer relationship management and/or marketing purposes which may include contacting you by email and/ or telephone and/ or post with information, news and offers on Our products and/or Subscription Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it; however this may adversely affect the delivery, use and function of the Subscription Services.
6.5 We do not keep personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
Whilst you remain a client with us. However, should your contract terminate and you are no longer a client, data will be retained after your termination date for up to 7 years unless otherwise stated. This data is required for our own company historical records and so that should you choose to return to us, we have your history on file:
6.5.1 Sales Order Information (5 year retention)
6.5.2 User Account Information (1 year retention)
6.5.3 Support Data including Helpdesk Tickets (5 year retention)
6.5.4 Office 365 Data including Hosted Mailbox (Removal on the agreed termination date)
6.5.5 Project Management Information (5 year retention)
6.5.6 Communications including Emails, Calendar & Mailing lists (5 year retention)
6.5.7 Financial Data & Transactions – 7 years or as required by The Revenue Commissioners, Bank & relevant authorities
7. How and Where Do We Store Your Data?
7.1 We only keep personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data.
7.4 Steps We take to secure and protect your data include:
7.4.8 Storage of client data within a Microsoft environment that conforms to ISO 27001:2013 Information Security Management Standards
8.1 We may share your data with other companies in Our group for administrative and internal management. The other company within our group is Branagan Business Supplies Ltd.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of products and services including the Subscription Services including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you or your employees or customers. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 The third party data processors used by Us and listed below are located within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the Republic of Ireland and under the GDPR including:
8.4.1 Microsoft Azure
8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 When you submit personal data to us, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at [email protected], or using the contact details below in section 13.
12. Our Use of Analytics
We use analytics services provided by Google Analytics, Microsoft Azure Application Insights, to collect and analyse anonymous usage information, enabling Us to better understand how our products and services are used. This, in turn, enables Us to improve the products and/or services.
13. Contacting Us
Tell us a little about yourself and we'll be in touch