Last Modified: 29 July 2020
Vivid Edge, as a company with its principal place of business at NovaUCD, Belfield Innovation Park, UCD Belfield, Dublin 4, Ireland, including its affiliates, takes its responsibilities under applicable data protection law, including the General Data Protection Regulation (EU) 2016/679 and implementing legislation (“Data Protection Law”) very seriously. The purpose of this notice is to inform you of the data relating to you that we may collect and the use (including disclosures to third parties) we may make of your data. This includes the provision of business services and sending you briefings and invitations to events, training programmes and lectures.
Vivid Edge is the controller in respect of the data we collect and we take all reasonable steps to ensure the safety and privacy of all information and, where appropriate, enter into contracts with any third party processors to protect the privacy of any personal data processed by us.
1. What information do we collect
We collect personal data that you voluntarily provide to us, for example when you communicate with us via email, when you sign up for or ask us to send you newsletters, briefings, or other materials and when you sign up for an event.
Such data may include:
1.1 your contact details, including your home address (where you have provided this to us), business address, email address and telephone number;
1.2 records of invitations and briefings sent to you and of your attendance at Vivid Edge events;
1.3 special dietary requirements and the name of your spouse or partner (in limited circumstances); and
1.4 information relating to particular areas that may be of interest to you.
1.5 We also collect some inferred data which is generated when you visit our website. This includes, for example, your IP address, the type of device you use to log in to our website, your browser type, and operating system.
If we are in regular contact with you, we may collect more information about our relationship with you.
2. Purpose of processing and legal bases
We use this information to help us make our site more useful to visitors and to learn about the number of visitors to our site. We do not track or record information about individuals on their visits. We may compile and report aggregate statistics about our users in terms of numbers, traffic patterns and related site information. Any such statistics will not include any personally identifying information.
Vivid Edge will not use the information you provide us with for purposes other than those for which the information was sent.
We will not sell, share or transfer your information with anyone outside of Vivid Edge. This does not include trusted third parties who assist us in managing our website, conducting our business, or providing services to you, where we are confident that they are compliant with Data Protection legislation and have agreed to keep this information confidential.
Your personal data is used by us and by third party service providers acting on our behalf for the following purposes:
2.1 providing you with business services;
2.2 for administration and billing purposes and for other purposes which are reasonably incidental to the services being provided;
2.3 sending or providing you with access to business information, invitations to events, training programmes and lectures; and
2.4 maintaining our list of contacts.
The legal bases on which we collect, process and transfer your information in the manner described above are:
(a) For 2.1 and 2.2
- (i) your consent (where we have sought it and you have provided it to us), and in which case, you can withdraw your consent at any time;
- (ii) where any such processing is necessary for the performance of a contract with us; and
- (iii) our legitimate interests in conducting our business in a responsible and commercially prudent manner.
(b) For 2.3 and 2.4
- (i) Our legitimate interest in maintaining a business relationship and communicating with you, as a business contact, about our events and providing you with information about new legal developments.
We may process special categories of data, such as accommodating any special dietary requirements you may have for any events that you register to attend. Any use of such information is based on your consent.
3. Sources of data
As well as collecting information from you or other professional services advisors, in some cases your personal data has been supplemented by information obtained from publicly available sources, including LinkedIn and your employer’s website, for the purpose of confirming your current professional position.
4. Sharing your data
We may disclose your personal data to third party recipients acting on your or our behalf, for the purposes of providing business services to you and for providing you with information which we believe you may be interested in.
We will retain your personal data for as long as it is reasonably necessary for us to provide you with legal advice and business services. If you are a business contact, we will retain your personal data for as long as we consider you to be a business contact and we will give you the opportunity to unsubscribe if you no longer wish to receive communications and invitations from us.
Even if we delete your Personal Data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.
6. Security measures to keep your personal data safe
We employ appropriate technical and organisational security measures to help protect your personal data against loss and to guard against access by unauthorised persons. We regularly review our security policies and procedures to ensure our systems are secure and protected.
In addition, where an agent or processor is being retained to process personal data, there will be a sound contractual basis for this, with appropriate security safeguards in place.
7. Necessity of provision of certain information and consequences
You may be required to provide us with certain information in order for us to verify your identity and carry out anti-money laundering or other checks which are required by law. This information consists of identification and verification documentation for individuals. If you do not provide us with such information, we will be unable to provide you with business services.
Apart from the details mentioned above, you are not under a statutory or contractual duty to provide us with any personal data.
8. Transfers abroad
Where relevant and necessary for the company’s business including our representation of you, we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing 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, which may include (i) entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or (ii) seeking and obtaining your explicit consent to the transfer or (iii) where the transfer is necessary for the establishment, exercise or defence of legal claims.
9. Your rights and how to update your information
You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:
9.1 the right to be provided with a copy of your personal data;
9.2 the right to request access to or ask us to correct, update or delete any Personal Data that we process about you by contacting us directly by email at email@example.com;
9.3 the right to restrict the use of your personal data;
9.4 the right to object to the processing of your personal data, where we are processing it based on this being necessary for the purposes of our or of a third party’s, legitimate interests; and
9.5 the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller, where we are processing the data based on your consent or that this is necessary for the performance of a contract with you.
In order to exercise any of the rights set out above, or if you have any questions about how we process your personal data, you can email us at firstname.lastname@example.org or write to us at Vivid Edge, Belfield Innovation Park, UCD Belfield, Dublin 4, Ireland. Please note that the limitation or deletion of your personal data may mean that we will be unable to provide you with the communications and/or invitations described above.
We are required to keep all personal data accurate and up to date. To assist us in doing so, we ask you to contact your usual business contact at Vivid Edge or email email@example.com with any relevant changes, such as change of address or contact telephone numbers.
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
We take a high level of care in how your personal data is handled to ensure that it is safeguarded and our legal obligations are met. If you are not happy with the way we have used your information or addressed your rights, you may contact us at firstname.lastname@example.org. You also have the right to make a complaint to the Irish Data Protection Commission by emailing email@example.com.By using this website, you are accepting the terms of this policy. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of those websites.
If you no longer wish to receive further marketing communications and/or invitations from us, you can unsubscribe at any time by emailing us at firstname.lastname@example.org