BRENNAN & COMPANY

PRIVACY NOTICE

1. IMPORTANT NOTICE

  • 1.1 This is the Privacy Notice of P.J Brennan and Company Limited t/a Brennan and Company (company number 24218) whose address is 61 Birch Avenue, Stillorgan Industrial Park, Stillorgan, Co Dublin A94 XW68 (“we”, “us” or “our”) and sets out how we collect and process your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal
  • 1.2 We take our data protection responsibilities very seriously and we comply with all applicable Data Protection Legislation in force from time to time. For the purposes of this Privacy Notice, “Data Protection Legislation” means: the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) (“GDPR”) and any laws in Ireland giving effect to its provisions.
  • 1.3 This Privacy Notice relates to personal information that identifies you. We refer to this information throughout this Privacy Notice as “personal data” and section 2 sets out further detail of what this Please read this Privacy Notice to understand how we may use your personal data. This Privacy Notice may vary from time to time so please check it regularly.

2. THE PERSONAL DATA WE COLLECT ON YOU

  • 2.1 We may obtain the following personal data about you:
    • personal data you provide to us in person, via our website or by telephone, including the personal and contact details you supply when establishing a profile on our website or requesting that we contact you in relation to a query. For example:
      1. your first and last name;
      2. demographic data such as your gender, age, country and preferred language;
      3. your marketing preferences; and
      4. log-in and account information for authentication purposes and account
    • personal data in the form of images or video footage that is taken at one of our locations;
    • personal data gathered using cookies;
    • details of your visits to our website including but not limited to traffic data, location data, weblogs and other communication data;
    • information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual;
    • personal data you provide when:
      1. you apply for a job advertised or submit a speculative job application and/or your CV;
      2. you purchase our solutions and/or services, or we process orders and payment transactions;
      3. you provide feedback about our solutions and/or services;
      4. you register for our events, workshops or seminars;
      5. we conduct our administrative and business functions;
      6. you enter into a competition or promotion;
      7. when you request our marketing material or email newsletter; and
      8. you submit a query to us or which is collected via social media, or when there are communications between you and our representatives.
  • 2.2 We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint or ask a question, then we may make a written record of key details of the conversation so that we can take steps to address the complaint or the
  • 2.3 We also obtain your personal data from an external lead generation platform, which may include your name, job title and company. This information is obtained using IP lookup, a publicly accessible

KEY INFORMATION ABOUT YOUR PERSONAL DATA

  • 2.4 Data controller and contact details
    • For the purposes of the Data Protection Legislation, we are the controller of the personal data you provide to us (in the DPA this is referred to as a “data controller”) and as a controller we use (or ‘process’) the personal data we hold on you in accordance with this Privacy
    • If you need to contact us in connection with our processing of your personal data, then you can do so at dpo@brennanco.ie
  • 2.5 Legal grounds for processing
    • We collect and process your personal data for a variety of different purposes, which are set out in further detail
    • In some cases, we will ask for your consent in order that we can process your personal data. However, in certain circumstances Data Protection Legislation allows us to process your personal data, without needing to obtain your consent. As examples, this may be because we need to use your personal data in order to provide you with the services or goods you have elected to receive from us (i.e. in the ordinary course of our business), to operate our site or for legitimate business or legal purposes.

3. HOW WE USE YOUR PERSONAL DATA & OUR BASIS FOR USING IT

  • 3.1 Where we are relying on a basis other than consentWe may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data:
How we use your personal dataThe legal basis on which we can do
this (this is what the law allows)
In order to perform our contractual obligations to you. This would include our fulfilling orders you have placed for goods or services, contacting you in relation to any issues with your order or where we need to provide your personal data to our service
providers (e.g. the company which processes our payments).
The processing is necessary for the performance of a contract which you have entered into, or where you request us to process your data prior to entering into a contract
In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (e.g. from the police).The processing is necessary for compliance with a legal obligation to which we are subject
In order to use your personal data in life or death situations and there is no time to gain your consent (e.g. in the event of an accident and we have to give your personal details to medical
personnel).
The processing is necessary in order to protect your vital interests or the vital interests of another individual
In order to use your personal data to operate our business, but otherwise than in performing our contractual obligations to you. These would be our ‘legitimate interests’ for the purposes of Data Protection Legislation and are as follows:

  • to send you important notices such as communications about changes to our terms and conditions and policies;
  • to deal with any misuse of our website;
  • to provide you with important real-time information about products or services you have ordered from us (e.g. a change of time or location due to unforeseen circumstances);
  • to send you information you have requested;
  • to deal with your enquiries;
  • where you have submitted a job application we may for a reasonable period keep your details on file for future reference should a suitable position subsequently become available and we may send you information about job opportunities;
  • to develop, deliver and improve our goods or services;
  • to help us develop our website to be more useful to you;
  • for internal purposes for research, analysis, testing, monitoring, customer communication, risk management and administrative purposes;
  • to protect and defend our rights or property;
  • to notify winners of online competitions;
  • to send you surveys in connection with our solutions and/or services;
  • to assist in the investigation of suspected illegal or wrongful activity. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  • to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers; or
  • in order to enforce or apply our website terms of use, terms and conditions of supply and other agreements with third parties
Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data which require protection of personal data, in particular where the data subject is a child

In addition, we may obtain certain special categories of your data (“Special Categories of Data”), and this Privacy Notice specifically sets out how we may process these types of personal data. The Special Categories of Data are: (i) personal data revealing racial or ethnic origin, and (ii) the processing of genetic data, biometric data for the purposes of uniquely identifying a natural person and data concerning health.

  • 3.2 Where we may rely on consentWe would like to use your personal data for a variety of different purposes. For certain of these purposes it is appropriate for us to obtain your prior consent. These are as follows:
    • where, in the provision of our products and services to you, we need to use the Special Categories of Data that you provide
    • where we would like to use photos or images taken of you in promotional materials; or
    • where we or our carefully selected third parties have new products and services which we think you will be interested in

    The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way. You may at any time withdraw the specific consent you give to our processing your personal data. Please contact us using the contact email address dpo@brennanco.ie to withdraw your consent.

    Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other bases to process your personal data for other purposes.

  • 3.3 Who receives the personal data you provide to us
    • Save as set out in this Privacy Notice, we do not share your personal data with any third party that is not connected to
  • 3.4 We may share your personal data with the following recipients:
    • Our PR agency and customer feedback;
    • Revenue, legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
    • external professional advisers such as accountants, bankers, insurers, auditors and lawyers;
    • law enforcement agencies, courts or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
    • third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
    • third parties which are considering or have decided to acquire some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);
    • third parties operating plugins or content (such as Facebook, Twitter, Instagram) on our website which you choose to interact with;
    • In addition, we may disclose the personal data you provide to us to our group companies and affiliates or third party data processers who may process data on our behalf to enable us to carry out our usual business practices. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice.
  • 3.5 Transfers of your personal data to other countriesIt is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area.In connection with such transfers:
    • the relevant safeguard in place is the standard data protection contractual clauses between us and the recipient and can be obtained by contacting us using the contact details set out in paragraph 4; or
    • this is made on the basis of an adequacy decision, namely:
      1. the European Commission has decided that the relevant non-EU country ensures an adequate level of
  • 3.6 How long we will hold your personal data for
    • We will only hold your personal data for so long as is necessary for us to do so, however because this depends in each case on how each of our customers interact with us, we keep the length of time that we hold your personal data for under continual review. These reviews take place annually.
    • Where we no longer need to process your personal data for the purposes set out in this Privacy Notice then we will delete your personal data from our
  • 3.7 Why should you provide us with personal data?Providing your personal data to us may be a requirement of entering into your contract with us for the provision of goods and services. Your personal data belongs to you and it is your choice as to whether you provide us with your personal data. However, because we may require your personal data in order to perform our contractual obligations to you, please be aware that if you do not provide all of the personal data we request from you then we may not be able to perform to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so. Please see our terms and conditions for further details.

4. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data (see paragraph 3.2), you may have a number of rights in connection with the processing of your personal data, including:

  • the right to request access to your personal data that we process or control;
  • the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
  • the right to request, on legitimate grounds as specified in law:
    • erasure of your personal data that we process or control; or
    • restriction of processing of your personal data that we process or control;
  • the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
  • the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
  • the right to lodge complaints regarding the processing of your personal data with the Information Commissioner’s Office or other relevant supervisory body. Please see for how to do this;
    https://www.dataprotection.ie/en/organisations/law-enforcement-directive

If you would like to exercise any of the rights set out above, please contact us using the contact details set out in paragraph 2.4.

5. LINKS TO OTHER WEBSITES

This policy only applies to P.J Brennan and Company Limited. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We are not responsible for any use of your personal data that is made by unconnected third party websites.

6. COOKIE POLICY

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu . Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

  • 6.1 Which cookies are used on this web site
    • Targeting or Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
    • Strictly necessary cookies: These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies, services you have asked for cannot be provided.
    • Performance cookies; These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
    • Functional cookies; These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
  • 6.2 Google AnalyticsThese cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site.
    The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they
    visited. For further details visit:
    http://www.google.com/analytics/learn/privacy.html
  • 6.3 How can Cookies be removedYou may refuse to accept cookies by activating the setting on your internet browser which allows you to refuse the setting of cookies. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org