Privacy Policy Turmec

We are committed to safeguarding the privacy of our website visitors, service users and other
individuals with whom we deal. This policy sets out information about how we use, store and
transfer personal data relating to those individuals. We are a data controller in relation to that
personal data, which means we determine the purposes and means of the processing of that
personal data. Turmec has a responsibility to ensure that your personal data is protected,
which we take very seriously, and we’re committed to keeping your information safe and
secure.

Information we collect about you:

a) Usage data: To ensure that our website is useful to all visitors and continues to improve, we
may process data about your use of the site. This may include your geographical location,
browser type and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency and pattern of
your use. This data, obtained through Google Analytics, is aggregated and anonymised such
that it contains no information pertaining to any identifiable individual; as such, it is not
personal data per se, but we address it here for completeness’s sake.
b) Correspondence data: we may process information contained in or relating to any
communication that you send to us, whether through the site, by email, through social media,
or otherwise. This may include the communication content and metadata associated with the
communication, as well as any contact details you provide to us, such as your name, email
address, phone number, job title, address or social media username. We process
correspondence data for the purposes of communicating with you and record-keeping.
c) Enquiry data: we may process information contained in any enquiry you submit to us
indicating your interest in our services or business, such as the contents of your enquiry and
any contact details you provide to us, such as your name, email address, phone number, job
title or address. We process such data for the purposes of addressing your enquiry and
providing you with occasional news about our services and operations. If you no longer wish to
receive news from us then you can unsubscribe at any time.
d) Project data: where we are commissioned to undertake a particular piece of work or
project, we process information for the purposes of setting up that project in our systems, such
as your name and contact details. We may also process personal information contained within
project-related correspondence and documents, including in relation to your customers,
whether created by us or provided to us. All such data is processed for the purposes of
providing our professional services and for record-keeping purposes.
e) Transaction data: we may process information relating to transactions, such as bank
account details, contact details, or transaction data in relation to payments made by us to you
or by you to us. This may include your contact details, or any bank account or sort code
information provided for the purposes of making payment, as well as transaction details (such
as POs or invoices). The transaction data may be processed for the purpose of supplying or receiving and administering the relevant services and keeping proper records of those
transactions, and for making and receiving payments.
f) Personal data we obtain from others: our personal data may be provided to us by
someone other than you—for example, by your employer, by an organisation with whom you
and we are both dealing, or by someone who wishes to refer you to us or vice versa. Normally
this data will be correspondence data, enquiry data, or project data as described above, and
will be processed by us for the purposes described above.
We process personal data on lawful bases only. In particular, we process personal data on the
following lawful bases identified in Article 6 of the General Data Protection Regulation:
a) for the performance of a contract with you, or to take steps at your request prior to entering
into a contract with you (Article 6(1)(b) GDPR). This may be our basis for processing
correspondence data, enquiry data, matter data and transaction data;
b) for our legitimate interests (Article 6(1)(f) GDPR). This may be our basis for processing:
i) correspondence and matter data (as we have an interest in properly administering our
business and communications);
ii) enquiry data (as we have an interest in developing our business with interested parties);
iii) transaction data (as we have an interest in making and receiving payments promptly and in
recovering debts);
iv) any personal data identified in the other provisions of this Notice where necessary in
connection with legal claims (as we have an interest in the protection and assertion of our legal
rights, your legal rights and the legal rights of others);
v) any of the personal data identified in the other provisions of this Notice in connection with
backups of any element of our IT systems or databases containing that personal data (as we
have an interest in ensuring the resilience of our IT systems and the integrity and recoverability
of our data).
In addition to the specific purposes for which we may process your personal data set out
above, we may process any of your personal data where such processing is necessary for
compliance with a legal obligation to which we are subject (Article 6(c) GDPR), or in order to
protect your vital interests or the vital interests of another individual (Article 6(d) GDPR).

Your rights

The rights you have under data protection law are summarised below. Some of these are
complex, and not all of the details have been included here. Further guidance can be obtained
from your data protection authority—e.g. in Ireland, the Data Protection Commissioner
(www.dataprotection.ie)

Your principal rights under data protection law are the right to:
a) access;
b) rectification;
c) erasure;
d) restrict processing;
e) object to processing;
f) data portability;
g) complain to a supervisory authority.

Access: You have the right to confirmation as to whether or not we process your personal data
and, where we do, to access to the personal data, together with certain additional information.
That additional information includes details of the purposes of the processing, the categories
of personal data concerned and the recipients of the personal data. Providing the rights and
freedoms of others are not affected, we will supply to you a copy of your personal data. The
first copy will be provided free of charge, but additional copies may be subject to a reasonable
fee.
Rectification: You have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete personal data
about you completed.
Erasure: In some circumstances you have the right to the erasure of your personal data. These
might include if:
a) the personal data are no longer necessary for the purposes for which they were collected or
otherwise processed; or
b) the processing is for direct marketing purposes.
However, there are certain general exclusions of the right to erasure, for example where
processing is necessary for compliance with a legal obligation or in connection with legal
claims.
Restriction: In some circumstances you have the right to restrict the processing of your
personal data. Where processing has been restricted on this basis, we may continue to store
your personal data and will observe the restrictions on processing except in the case of
processing permitted by applicable law (for example, in connection with legal claims or for
reasons of public interest).
Objection: You have the right to object to our processing of your personal data on the basis of
the legitimate interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate compelling
legitimate grounds for the processing which override your interests, rights and freedoms, or
unless the processing is for legal claims.
You have the right to object to our processing of your personal data for direct marketing
purposes (including profiling for direct marketing purposes). If you make such an objection, we
will cease to process your personal data for this purpose.

Portability: To the extent that the legal basis for our processing of your personal data is
consent, or the performance of a contract with you, and such processing is carried out by
automated means, you have the right to receive your personal data from us in a structured,
commonly used and machine-readable format. However, this right does not apply where it
would adversely affect the rights and freedoms of others.
Complaints: If you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your habitual
residence, your place of work or the place of the alleged infringement.
You may exercise any of your rights in relation to your personal data by written notice to us.

Providing your personal data to others

We may disclose your personal data to our insurers and/or professional advisers as necessary
for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining
professional advice and managing legal disputes.
We may disclose personal data to our suppliers or subcontractors in connection with the uses
described above. For example, we may disclose:
a) any personal data in our possession to suppliers that host the servers on which our data is
stored.
b) correspondence data to suppliers which host email campaigns or send or receive
correspondence on our behalf (such as Mailchimp or Microsoft, in relation to enquiries
received through our site);
c) transaction data and billing contact details to our accountants and in accounting packages;
and
d) transaction data and other relevant personal data to third parties for the purposes of fraud
protection, credit risk reduction and debt recovery.
We do not allow our third-party service providers to use your personal data for their own
purposes and only permit them to process your personal data for specified purposes and in
accordance with our instructions and applicable law.
In addition to the specific disclosures of personal data set out in this section, we may also
disclose your personal data where such disclosure is necessary for compliance with a legal
obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another person.
If any part of our business or operations is sold or transferred to, or integrated with, another
organisation, your personal data may be disclosed to that organisation.

Data security

We have in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition,
we limit access to your personal data to those officers, employees and freelancers who have a
business need to know. They will process your personal data only on our instructions and they
are subject to a duty of confidentiality.
We have in place procedures to deal with any suspected personal data breach and will notify
you and any applicable regulator of a breach where we are legally required to do so.

Retaining and deleting personal data

Personal data that we process for any purpose or purposes shall not be kept for longer than is
necessary for that purpose or those purposes.
We will retain and delete your personal data as follows:
a) usage data (which is anonymised, and not personal data) may be retained by us indefinitely;
b) enquiry and correspondence data which does not relate to a business relationship with us
will be retained for the period of the enquiry or chain of correspondence and then deleted after
24 months;
c) project and transaction data, and enquiry and correspondence data which relate to a
business relationship with us will be retained for six years after delivery of the relevant service
or transaction or the end of the relationship.
We may retain your personal data where such retention is necessary for compliance with a
legal obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person. For example, certain project and transaction data will be
retained for longer than six years in order to comply with Revenue or other tax reporting
obligations.

Amendments

We may update this Notice from time to time by publishing a new version on the site. We will
notify you of material changes to this Notice using the contact details you have given us, but
also recommend that you check occasionally to ensure you are happy with any changes to this
Notice.

About cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web
server to a web browser and is stored by the browser. The identifier is then sent back to the
server each time the browser requests a page from the server. A ‘persistent’ cookie will be
stored by a web browser and will remain valid until its set expiry date, unless deleted by the
user before the expiry date; a ‘session’ cookie will expire at the end of the user session, when
the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal
information that we store about you may be linked to the information stored in and obtained
from cookies.
Our Site uses category one and category two cookies. Category one cookies are essential in
order to enable you to move around the website and use its features. Category two cookies
collect information about how visitors use our Site—for instance, which pages visitors go to
most often. All information these cookies collect is aggregated and therefore anonymous.
Category two cookies enable us to use Google Analytics for analysing the use of and improving
the Site. Google Analytics gathers information about website use by means of cookies. The
information gathered relating to the Site is used to create reports about the use of the Site.
Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for
doing so vary from browser to browser, and from version to version. You can obtain up-to-date
information about blocking and deleting cookies via the support pages made available by your
browser operator.
You can at any time change or withdraw your consent from the Cookie Declaration on our
website.

Third parties and security

The site contains links to third-party websites and refers to third-party service providers and
other entities. If you follow a link to any third-party website or deal with any third party entity
referred to on the site, then you should note that these third parties may have their own
privacy and cookie policies, and that we are not responsible for their use of any personal data
which you may provide to them. You should ensure that you have read and understood any
relevant policies.
Although we do our best to ensure the security of personal data provided to us (and to use only
reputable service providers), any transmission of data via the Internet is by its nature insecure
and we cannot guarantee the security of any personal data you provide to us.
Turmec, is a limited liability company, registered in Ireland no. 75338, registered
office: Rathcairn, Athboy, Co. Meath, Ireland.

How to contact us

Any questions concerning this privacy policy or data protection can be sent marked for the
attention of the Data Officer to:
Turmec
Rathcairn, Athboy,
Co. Meath
Ireland
Tel: +353 (0)46 943 2243
Email: info@turmec.com
Effective: 23rd May 2018