Privacy
& Cookie Policy
Revision
1.3
2nd June 2021
Stephen
Moreau
This privacy policy tells you about the
information we collect from you when you use our websites. In collecting this
information, we are acting as a data controller and, by law, we are required to
provide you with information about us, about why and how we use your data, and
about the rights you have over your data.
Any external links to other websites are
clearly identifiable as such and Dataway is not responsible for the content or
the privacy statements of these websites. If you have any issues or queries
relating to such websites, please contact the providers directly.
Who are we?
We are Dataway and we have office in
Ireland, 25-26 Westland Square,
Dublin 2, D02 N403 (and USA, 2443 Fillmore St, #380-17561, San Francisco California 94115). You can contact us by post at the above
addresses, by email at privacy@dataway.com or by telephone on +353 1 676 0307. Our
Company Registration Number is 277015.
We currently are not required to have a
data protection officer, so any enquiries about our use of your personal data
should be addressed to the contact details above.
This Privacy and Cookie Policy applies
to the websites operated by Dataway, accessible via www.dataway.com and any mobile applications or other
online and/or mobile applications or websites operated by us that are related
to us (collectively, the "Websites").
This policy (together with our terms and our Data Protection Policy)
sets out how we may or will use any personal data which you provide through our
websites. Please read it carefully before you proceed. By visiting our websites,
and/or using the services offered on or through our websites, you acknowledge
you have read and understood the terms of this Privacy and Cookie Policy, and
that it may be amended from time to time.
1. Information we may collect from you
1.1. We may collect and process the following data about you:
1.1.1. Information that you provide by filling in forms on our websites. This
includes information provided at the time of registering to use our websites,
subscribing to our service, posting material or requesting further services
including, for example, name, business address, job title, job function, email
address, telephone number, demographic information and/or other information
that may identify you as an individual. We may also ask you for information
when you enter a competition or promotion sponsored by us (or close associated
but always directly associated with our core business), sign-up for email
newsletters and when you report a problem with our websites. You can choose not
to provide us with some of this information, but doing so may affect your
ability to use our websites and our services.
1.1.2. If you contact us, we may keep a record of that correspondence.
1.1.3. We may also ask you to complete surveys that we use for research
purposes, although you do not have to respond to them.
1.1.4. Subject to your expressed marketing preferences, to send you marketing
information about goods and services which may be of interest to you by post,
telephone, email or other means. You have the right to "opt in� and
"opt out� of certain uses of your personal data for these purposes.
1.1.5. Details of your visits to our websites including, but not limited to,
traffic data, location data, weblogs and other communication data, whether this
is required for our own purposes or otherwise and the resources that you
access.
1.1.6. Information we may receive about you if you use any of the other
websites we operate or the other services we provide. This may include
information sent to us from other parties operating those services on our
behalf, including, for example, sub-contractors in technical, payment and
delivery services, advertising networks and analytics providers or vendors. We
will notify you when we receive information about you from them and the
purposes for which we intend to use that information.
2. IP addresses and cookies
2.1. We may collect information about your computer, mobile phone, personal
electronic device, and all other similar electronic or mobile devices,
including where available your IP address, operating system and browser type,
for system administration and to report aggregate information to our
advertisers. This is statistical data about our users' browsing actions and
patterns, and does not show personal details that identify you.
2.2. For the same reason, we may obtain information about your general internet
usage by using a cookie file which is stored on the hard drive of your
computer. Cookies are small pieces of information (e.g., cookies, web beacons,
pixels, gifs tags or other similar technologies) sent by a web server to a web
browser which allow the web server to recognize the web browser. This operates
as a piece of data stored on your browser or device, or may identify, compile,
aggregate and/or collect information through other means. They help us to
improve our websites and to deliver a better and more personalized service.
They enable us:
2.2.1. To estimate our audience size and usage pattern.
2.2.2. To store information about your preferences, and so allow us to
customize our websites according to your individual interests.
2.2.3. To speed up your searches.
2.2.4. To recognize you when you return to our websites.
2.3. You can control how your browser handles cookies received from website.
You can choose to refuse all cookies, or to be prompted before a cookie is
saved to your hard drive, or to only accept cookies from certain website that
you designate. Information on deleting or controlling cookies is available at www.AboutCookies.org. By refusing to accept cookies from us,
you may not be able to use some of the features and functionality available on
our websites.
3. Advertising and online tracking
3.1. We do not allow allow third-party companies to serve ads when you visit
the Dataway websites.
4. Uses Made Of The Information
4.1. We use information provided by you and/or held about you (including your
personal data) in the following ways:
4.1.1. To ensure that content from our websites is presented in the most
effective manner for you and for your computer.
4.1.2. To carry out our obligations arising from any contracts or transactions
entered or contemplated to be entered into between you and us or to provide you
with the websites and any services requested by you.
4.1.3. For any specific purpose for which it was provided or volunteered.
4.1.4. To develop, market, sell or provide products and services.
4.1.5. To keep you apprised of information and developments that you may find
of interest.
4.1.6. To inform you of our, or our business partner's products or services.
4.1.7. To perform analysis and research in relation to transactions, including
without limitation, analyzing and conducting research on our user's
demographics and interests, information about your browsing and viewing
preferences.
4.1.8. To allow you to participate in interactive features of our websites
including services provided by our affiliated companies including companies
that, directly or indirectly: control us; or are controlled by us; or are under
common control with us, when you choose to do so. Please see Section 8 for
further information.
4.1.9. To notify you about changes to our service.
4.1.10. If you review or download information, we track the visit to give us
information about which part of the websites is frequented.
4.1.11. To send you notices (for example, in the form of e-mails, SMS,
mailings, and the like), and otherwise correspond with you, about products,
services, companies and events, sponsored by us and others, that we think might
interest you, where you have consented to be contacted for such purposes.
4.2. We do so on the basis that such use of your information is necessary: (i)
to fulfil a contract that we have in place with you, (ii) for the purposes of
our or a third party�s legitimate interests (including our legitimate
commercial and related interests, such as understanding our customers and
potential customers and providing you with information on our products and
services); or (iii) for compliance with a legal obligation to which we are
subject, or where you have given us your consent.
5. Where we store your personal data
5.1. The data that we collect from you may be transferred to, and stored at, or
processed from a destination outside the European Economic Area where the laws
applicable to your personal data offer the same level of protection. Those
processing your personal data may be engaged in, among other things, provision
of support services. We will adopt appropriate safeguards necessary to ensure
that your data is treated securely and in accordance with this policy and
applicable laws. This is applicable mainly in relation to our US branch office
and we have ensure and appropriate contract is in place between our 2
organisations to ensure compliance in relation to this activity. For further
information on such safeguards, please contact us.
6. Security
6.1. While we have implemented reasonable technical and organisational
precautions to protect the security and integrity of personal data provided to
our websites, due to the inherent nature of the internet as an open global
communications vehicle, We cannot guarantee that information, during
transmission through the internet or while stored on our system or otherwise in
our care, will be absolutely safe from intrusion by others, such as hackers. We
maintain physical, electronic and procedural safeguards to protect your personal
data. We strive to protect information transmitted on or through the websites
or services, however, we cannot and do not guarantee the security of any
information you transmit on or through the websites, and you do so at your own
risk. We cannot and do not guarantee the security of your data and information.
But we can assure you that we only operate at the very highest standards of
data security and only engage ourselves with partners and suppliers who also
are at the very top of the ladder when it come to Data protection Technologies
7. Service Providers
7.1. We may use third-party partners, carefully selected by us, to help operate
our websites and deliver our products and services, and may share your
information with our service providers and other third parties that provide
products or services for or through these websites or for our business (such as
website or database hosting companies, address list hosting companies, e-mail
service providers, research, analytics and customer experience and survey
companies, distribution companies, fulfilment companies, marketing and
promotional companies, and other similar service providers that use such
information on our behalf).
7.2. We may disclose aggregate statistics regarding user behaviour as a measure
of interest in, and use of, our websites and e-mails to third parties in the
form of aggregate data, such as overall patterns or demographic reports that do
not describe or identify any individual user.
8. Third parties
8.1. Some of the content, advertising, and functionality on our websites may be
provided by third parties that are not affiliated with us. For example, we
enable you to share certain materials with others through social networking
services such as Facebook, Twitter, Google +, and LinkedIn. These third-parties
may collect or receive certain information about your use of the websites,
including through the use of cookies, beacons, and similar technologies, and
this information may be collected over time and combined with information
collected across different websites and online services. Dataway does not
control the data collection and use practices of these companies and you should
check the relevant privacy notices and policies before using the services
provided by these companies.
9. Disclosure of your information
9.1. We may disclose your personal data to any member of our group, which means
our subsidiaries, our ultimate holding company and its subsidiaries (both
direct and indirect).
9.2. We may also use your personal data to maintain our internal record keeping
and/or share it with our affiliates for internal marketing or other purposes.
9.3. We may disclose your personal data to third parties:
a. In the event that we sell or buy any business or assets, in which case we
may disclose your personal data to the prospective seller or buyer of such
business or assets.
b. If Dataway or substantially all of its assets are acquired by a third party,
in which case personal data held by it about its customers will be one of the
transferred assets.
c. If we are under a duty to disclose or share your personal data in order to
comply with any legal obligation, or in order to enforce or apply our terms and
other agreements; or to protect the rights, property, or safety of Dataway, our
customers, or others. This includes exchanging information with other companies
and organisations for the purposes of fraud protection and credit risk
reduction.
d. We may disclose user information to government authorities, and to other
third parties when compelled to do so by government authorities or otherwise as
required or permitted by law, including but not limited to in response to court
orders and subpoenas. We also may disclose user information when we have reason
to believe that someone is causing injury to or interference with our rights or
property, other users of our websites, or anyone else that could be harmed by
such activities. Additionally, we cooperate with law enforcement inquiries and
other third parties to enforce laws, intellectual property rights and other
rights.
10. Retention
10.1. Your personal data will be retained for as long is reasonably necessary
for the purposes listed above or as required by applicable local law. Please
contact us for further details of applicable retention periods.
10.2. We may keep an anonymized form of your personal data, which will no
longer refer to you, for statistical purposes without time limits, to the
extent that we have a legitimate and lawful interest in doing so.
11. Your rights
11.1. You have the right to:
(i) request information on and access to all the personal data We hold
about you;
(ii) request that any inaccurate personal data we hold be corrected;
(iii) to object to certain types of processing of your personal data We
carry out (including the right to opt-out of any direct marketing);
(iv) request that we delete the personal data we hold about you; and
(v) to request a copy of your personal data in
a machine readable, commonly used format (or to request we transfer your
personal data in such a format to a third party service provider).
11.2. In order to exercise these rights, you will need to contact us at privacy@dataway.com. We will consider such responses and make
every reasonable effort to complete your request within 30 days. We will
require verification of your identity for providing a copy of your information
as permitted by law.
12. Changes to our privacy and cookie policy
12.1. Any changes we may make to our privacy policy in the future will be
posted on this page and will be effective upon posting and as reflected in the
�last revised� date shown in the revised policy. Your continued use of our websites
after any such changes are posted will be considered acknowledgment by you of
such changes. Under certain circumstances, we may also elect to have such
changes notified to you by e-mail or by posting a notice on the front page of
our websites. You should regularly check back to this page from time to time.
13. Contact
13.1. Questions, comments and requests regarding this Privacy and Cookie Policy
are welcomed and should be addressed to privacy@dataway.com. You also have a right to lodge a
complaint with your local data protection authority,
www.dataprotection.ie
E-Mail dpcbreaches@dataprotection.ie
Phone - 1890
252231(lo-call); 00 353 (0) 57 8684800
Fax- 00 353 (0) 57
8684757
We do recommend you contact us in the first instance as we may be able
to resolve any issues with you directly in a more efficient manner.
That�s it
Thank you so much for your time
Stephen Moreau