Updated on 13/11/2023
PART A: PRELIMINARIES
- This policy covers the collection, storage, processing, and other uses of Personal Data and Information under the General Data Protection Regulations (“GDPR”) and Ireland’s Data Protection Act 2018 (“DPA”).
- By using the Site, you consent to this Policy and our lawful collection of your Personal Data and Information under our Services.
PART B: SERVICE PROVIDERS
- Our Services are hosted by and on third-party web services and servers. They provide us with a web service that allows us to offer our products and services to you.
- We shall not share your Personal Data and Information with service providers directly.
- By using our Services, Website, or making payments, you agree and acknowledge that data processing, storage, or collection will be conducted through and using the services of our service provider(s) who may change the region, jurisdiction, or country where data is stored, collected, or processed.
- You also agree and acknowledge that we may not have control of where your data is stored. Your data may be stored in Ireland, a third country in the European Union (“EU”), or outside the EU.
- If there are any conditions, circumstances, or changes in the manner in which our service provider stores, processes, or when data is transferred, and which may affect your data adversely, we may inform you through email or notices.
PART C: COLLECTED INFORMATION
- When you subscribe, register and visit our Services or Website, we collect certain information about your device, your interaction with the Site, and information necessary to process your purchases or provide our Services.
- We may also collect additional information if you contact us for customer support.
- In this Policy, we refer to any data and information that can uniquely identify you as a user (“Personal Data and/or Information”).
- Consult the list below for more information about Personal Data and Information which we will or may collect:
13.1. Device information
13.1.1. Includes the version of the web browser, IP address, time zone and time, cookie information, what sites or products you view, search terms, and how you interact with our Services or Website.
13.1.2. Why we collect: to load our Website accurately for you and to perform analytics on Website usage to optimization.
13.1.3. How we collect: Automatically when you access our Services or Website using cookies, log files, web beacons, tags, or pixels.
13.1.4. This data or information is not shared with any third-parties.
13.2. Purchasing, payment and order information
13.2.1.We collect the name, billing address, shipping address, payment information.
13.2.2.The above includes credit card numbers, bank details, PayPal, Skrill, and other data and information through other payment methods which will be available on our Website or Services.
13.2.3. We will also collect email addresses and phone numbers.
13.2.4. Purpose of collection data above:
188.8.131.52.to provide products or services to you to fulfil our contract
184.108.40.206. to process your payments when paying us
220.127.116.11. arrange for shipping
18.104.22.168.provide you with invoices and/or order confirmations
22.214.171.124. communicate with you
126.96.36.199.screen our orders for potential risk or fraud,
188.8.131.52. and when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
13.2.5. Disclosure for a business purpose: shared with our payment processors only.
13.2.6. Payments will be processed privately and securely by third-party payments’ processors that we have contracted.
13.2.7. We may share or forward your personal data with our payment processors when required by law such as in compliance with Know-Your-Customer (KYC) law, identification requirements under the law, or for purposes of completing relevant payment processing and transactions. Such payment processors are banned from using your Personal Data, except in providing the required payment services to us, and further, are mandated to maintain the privacy and confidentiality of your payment information and personal data.
13.3. Support information
We will also collect customer support information including your feedback, messages, and emails that you share with us.
We may also collect and record data and information from telephone conversations.
13.4. Personal Data
13.4.1. We will collect the personal data which you provide us.
13.4.2. This data and information will include and are not be limited to name, home or work address, email address, telephone number, etc.
13.4.3. The information will be collected after your consent and when you use or sign up with us.
13.4.4. Normally you will be required to provide such details when you sign up or make a subscription.
13.4.5. We may use statistical and analytical tools to monitor information and details of your visit to our Website, your use of our Services. Such information may include location data, traffic data, browser, weblog, and other communication data. This information will not be used to identify you personally.
PART D: MINORS, THEIR DATA AND INFORMATION
- The Site is not intended for individuals under the age of 18 or aged below majority under applicable laws.
- We do not intentionally collect Personal Information from minors or persons of unsound mind.
- If you are the parent or guardian and believe your child has provided us with Personal Information, please contact us at the address below to request deletion.
- We may store or transmit information, data, and records for minors. As a parent or a guardian, any data or information belonging to a minor that you share or store using our Services shall be deemed to have been stored with your lawful consent.
- We will not be responsible when you permit or allow, whether intentionally or recklessly, a minor’s data or information to be stored, shared, or submitted to us.
PART E: USE OF YOUR DATA AND INFORMATION
- We will hold, store and process the Personal Data as per the GDPR and the DPA.
- The information which we collect and the store will be used to offer our Services and meet our contractual obligations to you as per our Terms and Conditions.
- We may also use the data and information as below:
21.1. To notify you of changes to our Website, Services, Terms and Conditions, this Policy and marketing information;
21.2. To notify you of our change in Pricing and Payment Policy and changes in the prices of our Services.
21.3. To send you our e-newsletter from time to time.
- You can unsubscribe from our marketing emails by using the ‘Unsubscribe’ features provided by your email client and service providers.
PART F: DATA TOOLS
- We may use Google Analytics and other related third-party tools to help us understand how our customers use the Site.
- You are advised to conduct your research and familiarize yourself with advertisement services offered by Google, Facebook, Microsoft and others.
PART G: DISCLOSURES
- We may disclose your data or information for purposes of enabling us to comply with the law and in compliance with the court order or warrants.
- You have the opportunity to withhold or withdraw your consent to us by unsubscribing from our Services. Alternatively, you can write to us through our Data Protection Officer whose details we have provided in this Policy.
- We shall not share or disclose information that can be used to identify you to our advertisers or third parties unless allowed by the law, this Policy, or our Terms and Conditions.
PART F: THE USE OF DATA AND INFORMATION
- You consent to us using third-party service providers who host our Services and Website for purposes of providing our Services to you.
- You have the right to revoke or vary your consent at any time upon notifying us.
- Your revoking of your consent may prevent and preclude your access to our Services and we do not guarantee that you will access our Services after you withdraw your consent.
- We may discontinue our Services to you despite your payments when we believe that we will no longer be able to offer our Services to you effectively without your consent or when you exercise your right to be forgotten or the right to be deleted from our Services.
PART G: DATA STORAGE AND TRANSFER
- Data and information which you provide to us may be transferred outside Ireland, the EU, the European Economic Area (“EEA”), or outside your country or jurisdiction.
- We can use remote website servers and hosts to provide our Services and Website. Such remote servers may be located outside the EU, EEA, or your jurisdiction or country.
- Your information may be processed using third-party tools or service providers located within or outside Ireland, the EU, the EEA, your country or jurisdiction.
- The location of storage and processing of data and information will depend on our service providers. The data or information may be transferred outside Ireland, the EU, the EEA, your country or jurisdiction
- If we transfer data outside Ireland, the EU, the EEA, your country or jurisdiction, we shall take steps to ensure there is adequate protection in line with the PDA and the GDPR.
- We do not collect, disclose or use sensitive personal data such as religion, race, sexual orientation, colour, or political affiliation.
- Instances when we may disclose and share your data:
41.1. if the law requires us to do so or when we are following compliance requirements or court orders.
41.2. for lawful purposes as per our Terms and Conditions and this Policy.
41.3. when you make payments to us, we may disclose your information and payment details to payment processing providers.
41.4. To our assignees and successors.
PART F: THE LEGAL BASIS OF COLLECTING AND PROCESSING YOUR DATA
- As per the GDPR and the DPA, we process your personal information for the following lawful purposes and reasons:
42.1. Your consent;
42.2. The performance of the contract between you and the Site;
42.3. Compliance with our legal obligations;
42.4. To protect your vital interests;
42.5. To perform a task carried out in the public interest;
42.6. For our legitimate interests, which do not override your fundamental rights and freedoms.
PART G: INFORMATION AND DATA RETENTION
- When you make a payment on our Website, we may retain your payment details and information for three (3) to six (6) years for purposes of compliance with the law and accounting.
PART H: AUTOMATED PROCESSES
- Residents of the EU and the EEA have the right to object to automated decision making such as profiling when there is a significant effect or legal effect.
- We shall not engage in fully automated decision-making that has significant or legal effects on the information and data provided to us by you.
- We may use automated decision-making to prevent theft or fraud.
- Automated services may include:
47.1. Temporary denylist of IP addresses associated with repeated failed transactions. This denylist persists for a small number of hours.
47.2. Temporary denylist of credit cards associated with denylisted IP addresses. This denylist persists for a small number of days.
PART I: GDPR
- Residents of the EU and the EEA have the right to access the Personal Information which we hold.
- You will be allowed to port it to a new service.
- You will also be allowed to request your data or information to be corrected, updated, or erased.
- If you wish to exercise any of the rights above, please contact us through the contact information provided below in this Policy or through our Data Protection Officer.
- Your Personal Information may be initially processed in Ireland and then will be transferred outside of Europe for storage and further processing, including to Canada and the United States.
PART J: OUR COOKIES
- Cookies include a small amount of information that is downloaded to your computer or from your device when you visit our Services or Website.
- We use several different cookies, including functional, performance, advertising, and social media or content cookies. Cookies make your browsing experience better by allowing the website to remember your actions and preferences (such as login and region selection).
- The cookies also provide information on how people use the website, for instance, whether it’s their first time visiting or if they are a frequent visitor.
- We use the following cookies to optimize your experience on our Site and to provide our services.
- The time a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing while persistent cookies last until they expire or are deleted by you or by your browser. Most of our cookies are persistent and will expire between 7 days to 2 years from the date they are downloaded to your device.
- You can control and manage cookies in various ways. Please keep in mind that removing or blocking cookies can negatively impact your user experience and parts of our website may no longer be fully accessible.
- Most browsers automatically accept cookies, but you can choose whether or not to accept cookies through your browser controls, often found in your browser’s “Tools” or “Preferences” menu.
PART K: SECURITY
- processing, collection, and transmission of information and data are not completely secure or risk-free.
- We will do our best to protect and secure your Personal Data but we shall not guarantee absolute data security.
- Ourselves and our service providers will employ strict procedures and security mechanisms to protect unauthorized access of data and data breaches.
- Where we have provided you, or when you have chosen a password so that you can access our Services or Website, you will remain responsible for keeping the said password confidential. You are advised to choose a password that is secret and which you do not share with any other person.
PART L: THIRD-PARTY LINKS TO OUR WEBSITES
- We will not provide any third-party links on our Website or Services.
PART M: YOUR RIGHTS
- The GDPR and the DPA give you the right to access information held about you by us. To exercise these rights, please write to us or contact us by email through our designated Data Protection Officer.
- The GDPR and the DPA also give you the right to opt-out of marketing programs. You also have the right to have your data deleted by us.
- Exercising some rights under the GDPR and the DPA may bar you from accessing our Site or Services unless you share and consent to our collection and processing of your data.
- We may update these policies to reflect the changes to our Services and Website.
- We will notify you when we make changes to this Policy.
PART O: CONTACTS
Business Name: CrewHR
Business Address: 21 Main St Blackrock Co. Dublin
Business Phone Number: 01 210 0232
Email Address: firstname.lastname@example.org
Contact Information for designated Data Protection Officer
Attn: Data Protection Officer
Address: 21 Main St Blackrock Co. Dublin