Privacy Statement

Last Updated: 14 March 2022

1. INTRODUCTION

Welcome to RBESG Ltd’s privacy policy.

RBESG Ltd. respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit from) and tell you about your privacy rights and how the law protects you.

If you have any questions about this privacy policy or the way in which your personal data is being used by us please contact us at info@rbesg.com.

You have the right to make a complaint at any time to the Data Protection Commission (“DPC”), the Irish regulator for data protection issues (https://www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.

2. IMPORTANT INFORMATION AND WHO WE ARE

Controller 

RBESG Ltd. is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

Purpose of this policy

Pursuant to the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), we are required to explain why we process your personal data, how we process it and whether we will share it with anyone else. We must also explain your rights under the GDPR and related data protection law in relation to our processing of your personal data.

Change to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Links

We are not responsible for the content or privacy practices of any linked sites. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. THE DATA WE COLLECT ABOUT YOU

Personal data means any information about a person from which that person can be identified, for example, a name, an identification number, location data, an online identifier. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have group together as follows:

• Identity Data includes first name, last name, username.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating systems and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website and products.
• Marketing and Communication Data includes your preferences in receiving marketing from us and our third party and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of the contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Whose data do we collect

We process personal data about a wide range of people, including:

• Employees
• Customers who purchase our products;
• Users of our website;
• Suppliers;
• Commercial partners and associates;
• Prospective customers;
• Individual who request information from us;
• Individuals who receive marketing communications.

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, email and otherwise. This includes personal data you provide when you

• Apply for our products
• Download resources from our website;
• Request marketing to be sent to you;
• Give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Notice for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties including:

• Technical Data from analytics providers.
• Contact, Financial and Transaction Data from providers of technical and payment services.

5. HOW WE USE YOUR PERSONAL DATA

We process personal data in accordance with the requirements of the law. In general, we will process personal data on one of the following legal basis:

• Contract – we will process your personal data where necessary to perform our obligations in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract.
• Consent – for certain processing activities we may rely on your consent. You can withdraw your consent at any time by contacting us at info@rbesg.com
• Legitimate Interest – we may need to process your personal data to pursue our legitimate interests and your interests and fundamental rights do not override those interests. Examples could arise for administrative purposes, to collect debts owing to us, to provide information to you, to operate our website or to maintain their security and protect intellectual property rights.
• Legal obligation – where we are obliged under law to process personal data.

Where consent is the lawful basis we rely upon to handle your personal data, you may withdraw such consent at any time free of charge.

Purposes for which we will use your personal data

We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful group depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.

Opting Out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase of a product, service, warranty registration, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use please see our Cookie Notice.

6. DATA SECURITY

We will endeavour to take necessary and reasonable steps to ensure the security and integrity of the personal data. We have put in place appropriate technical and organisational procedures to safeguard and secure the personal data which we process.

Once received, we will use strict procedures and security features for the purpose of preventing unauthorised access to personal data and ensuring access is only available to those who need it.

Where you have been given (or where you have chosen) a password which enables you to access our Products, you are responsible for keeping this password confidential. Please do not share your password with anyone.

If, at any stage, you think that there has been any loss or unauthorised access to personal data of any individual, please let us know immediately.

7. DISCLOSURES OF PERSONAL DATA

We may share your personal data in order to provide products to you and in certain circumstances we may disclose your personal data to business partners; tax, audit or other authorities; payment service partners; IT service providers and security service providers; post or courier partners; and/or our email distribution partner and service providers in case of marketing and newsletters.

We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the confidentiality and security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and we only permit them to process your personal data for specified purposes and in accordance with our instructions.

We may share you personal data with organisations and bodies where we are required to do so by law.

8. INTERNATIONAL TRANSFERS

We may transfer your personal data outside the European Economic Area by enabling remote access to your personal data by our service providers for support services, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission.

9. DATA RETENTION

We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this Statement, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

10. YOUR RIGHTS

You have the following rights related to how your personal data is used:

• Remote access – you have the right to ask for all the personal data we hold about you (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request changes – you can request amendments to personal data we hold about you where same is incorrect. We may correct factual errors only.
• Request deletion – in specific circumstances you may be entitled to request that your personal data is deleted by us. This can occur where it is no longer necessary for us to hold the data, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully. This cannot be completed by us where we are required to keep your personal data by law or for another legal basis.
• Object to processing – your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Limit – you can request that your personal data is used for limited purposes.
• Move – you can request that your data is moved to another service provider. This only applies where your personal data is being processed with your consent and where decisions were made automatically and not by a human being. It does not apply where it would adversely affect the rights and freedoms of others.
• Complaint – you have the right to lodge a complaint to the DPC or with the data protection authority in the EU member state where you usually reside, where you believe an infringement of the Data Protection Laws took place.