Privacy Policies

 

1. About VLE

VLE is an innovative virtual learning platform that supports users unique needs and brings virtual on-demand learning courses designed by experienced education practitioners who are committed to providing highest-quality quality training and education services. You may buy, enrol, access and complete a Course on VLE for which we may collect obtain, store and use information about you. VLE platform is owned and operated by Upskill Online Limited trading as Olive Media (referred to as “VLE” “we”, “our” or “us”). We care about your privacy. This Policy, which applies to the VLE platform, vle.olivegroup.io (“Site”), (together with our VLE Terms of Use and any other documents referred to in the Site) explains how we collect and use your information. Please read it carefully. For questions about this Policy, or if you want to enforce your rights: please contact Olive’s Privacy Officer, at compliance@olivegroup.io.

2. Who we are

Upskill Online Limited is a limited company incorporated in Ireland with company number 470792, whose registered office is at Glasshouse 1, Dun Laoghaire, Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland. For the purpose of applicable data protection laws Olive forms part of the data protection regime in the Ireland and the Data Protection Act 2018 (DPA 2018) and EU General Data Protection Regulation 2016/679 applies to the processing of personal data wholly or partly by automated means and to the processing your Personal Information collected through the Site.

2.2 Definitions

2.2.1 “Personal Information” in this Policy means “Personal Data”; as defined in the EU General Data Protection Regulation 2016/679(EU). In summary, it means information that identifies you, whether directly or indirectly, including for example your name, gender, address, email address, phone number and any other information that you may voluntarily submit to us, as well as any online identifiers such as your click stream data or IP address.

2.2.2 “Data Protection Laws” means the data protection and information privacy laws of Ireland and the European Union and includes any legislation in force from time to time which implements Directive 95/46/EC or Directive 2002/58/EC of the European Community, the Data Protection Acts 1988 and 2003 (as amended), and once applicable the General Data Protection Regulation (EU) 2016/679 (the “GDPR”) and/or any corresponding or equivalent Irish laws or regulations, once in force and applicable.

2.2.3 “Data Processing” refers to any action performed on Personal Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, uploading or deleting.

2.2.4 “General Data Protection Regulation” means Regulation (EU) 2016/679, known as the General Data Protection Regulation (the “GDPR”).

2.2.5 “Special Categories of Data” has the meaning as set out in Data Protection Laws.

2.2.6 “‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

3. When do we collect information about you?

We collect Personal Information when you visit our platform or site, when you enrol for a Course and register get access to VLE Platform, when you email, call or write to us, or provide us with information in any other way, including by interacting with us via social media such as Facebook or Twitter. We also collect information when you take a Course or otherwise, use our apps, or if your company has provided your details to us to enable us to provide you with access to and use our courses or apps. All the information collected in the local storage of about you is deleted when you logout from the application.

4. Consent

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us at compliance@olivegroup.io.

5. What types of personal information do we collect and process?

5.1 Each time you visit a Site we may automatically gather the following information:

5.1.1 technical information about your computer such as domain name, browser type and version, operating system and platform, IP address, cookie information and time zone setting; and Following are the information we store in the local storage for logged in user:

• First and Last Name

• Email Address

• User Authentication token from backend servers

• Member ID

• Profile pic url

• mobile number

• Information of client under which user is logged in:

 Client Name

 Client domain

 Client ID

 Client logo url

5.1.2 information about your visit including the full Uniform Resource Locators (URL) clickstream to, through and from the Site (including date and time), what web pages you visited on the Site and how long you spend on each page, page interaction information (such as scrolling, clicks and mouse-overs), page response times, download errors, traffic data, location data, weblogs, history of resources accessed on the Site, methods used to browse away from the page and information on what website you visited before accessing the Site.

5.2 We process the following kinds of personal information if you provide it to us, or if your company provides it to us, or if it comes into existence by virtue of you taking a Course:

5.2.1 Information about you, including your name, job title, address, email and other contact details;

5.2. 2 Information about the company you are associated with;

5.2.3 Information about your use of our mobile applications, including information about which pages you view;

5.2.4 Information concerning your progress in taking a Course including information concerning your performance in assessments and where appropriate, your entitlement to a certificate;

5.2.5 Information you provide to us during communications you have with us and with our staff, for example comments or queries about the courses we provide.

5.2.6 Information about the course or about the content that you provide, such as the location of the person or the date on which you posted a photo or created an event, what you see through features that we provide, so we can do things such as propose masks and filters that you might like, or give you guidelines on using the same.

5.2.7 We also process the following kinds of personal information if you provide it to us, or if your company provides it to us, or if it comes into existence by virtue of you taking a Course: 1) Information about you, including your name, job title, address, email and other contact details; 2) Information about the company you are associated with; 3) Information concerning your progress in taking a Course including information concerning your performance in assessments and where appropriate, your entitlement to a certificate; 4) Information you provide to us during communications you have with us and with our staff, for example comments or queries about the courses we provide. 5) Information about the course or about the content that you provide, such as the location of the person or the date on which you posted a photo or created an event, what you see through features that we provide, so we can do things such as propose masks and filters that you might like, or give you guidelines on using the same. 6) VLE shall have the right to access the outlook calendar of the Teams User who set up a video classroom using VLE.

6. Why do we collect and use your Personal Information, and what are our lawful grounds for doing so?

6.1 We use your Personal Information for the following purposes:

6.1.1 To process and respond to requests, enquiries and complaints received by you, in accordance with our legitimate interest to provide you with a responsive service.

6.1.2 To track your progress through a Course, to assess your performance in assessments and to determine whether you have reached the standard which is required if you are to earn a certificate.

6.1.3 To provide services and products requested by you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.

6.1.4 To communicate with you about services and/or products provided to you. We do this as necessary to carry out our legitimate interest to operate a business which offers training courses.

6.1.5 To update our records and for audit purposes, in accordance with our legitimate interest to operate a business which offers training courses.

6.1.6 To prevent or detect fraud, in accordance with our legitimate interest to do so.

6.1.7 Where legally required or where it is in our legitimate interest to do so, to comply with requests from law enforcement and regulatory authorities.

6.1.8 To analyse trends and profiles, for our legitimate interest to aim, to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.

6.1.9 To carry out customer satisfaction research, for our legitimate interest to aim to enhance, modify, personalise or otherwise improve our services and communications for the benefit of our customers.

6.1.10 If you make enquiries through a Site and agree in the contact form to receive email updates we will send you such updates on the grounds of your consent.

6.1.11 To enable third parties to carry out any of the purposes set out above on our behalf. For this we use our legitimate interest to run our business as efficiently as possible.

6.1.12 To create personalized services with clear recommendations and suggestions that are unique and relevant to users, we use users preferences, interests and activities based on the data that we collect and learn from users.

6.1.13 To communicate with users about our services and let users know about the Policies and Terms as well as to respond to users when the user contacts us.

6.2 The legal basis on which we collect, process and transfer your information in the manner described above are:

(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.

(iv) Our legitimate interest in maintaining a business relationship and communicating with you, as a business contact, about our courses, events and providing you with information about new developments.

6.3 Where we store your Personal Information

The Personal Information we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) as it may be processed by staff or service providers outside the EEA who work for us. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy, and that adequate measures are in place if the country in question is not deemed to provide the same level of protection for your data and rights as you would enjoy within the EEA. Contracts are in place with these service providers, incorporating the European Commission’s approved model clauses, to ensure that any Personal Information involved is safe.

7. Transfers abroad

Where relevant and necessary for Olive’s business, 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 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, 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.

8. How long do we keep your Personal Information?

8.1 We hold your Personal Information for as long as we need to for legitimate legal or business reasons, including complying with any regulatory obligations. Personal Information collected through a application may be kept as follows:

8.1.1 The Analytics Companies keep anonymised information concerning your visits to the application on their servers, in accordance with their respective privacy policies.

8.2 We will keep your information for at least as long as our relationship with you is active, and for any further period as required by our retention policy.

8.3 If you would like more detailed information about our retention policy, please email us at compliance@olivegroup.io or use one of the other methods in the “Contact us” section below.

9. Disclosure of your Personal Information

9.1 We may disclose your Personal Information to companies within our corporate group. We will not share Personal Information collected through our Site with unrelated third parties, except as provided in this Policy.

9.2 We may disclose to your employer details concerning your progress in taking the Course, up to and including the award of a certificate.

9.3 We may disclose your Personal Information to competent regulatory authorities and bodies as requested or required by law.

9.4 If we sell all or any part of our business, the parties which buy it may have access to your Personal Information.

9.5 We also provide information and content to research partners and academies to conduct research and support innovation as well as promote our business and these parties are not authorised to keep or use your Personal Information for any other purpose.

9.6 We may disclose the data to third parties who we engage to provide services to us in connection with this website, such as outsourced service providers, IT services providers, professional advisers, and auditors.

10. Controlling your Personal Information

You have the right to ask us not to process your Personal Information for marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your Personal Information, by clicking “unsubscribe” in any of our marketing emails to you, or by contacting our Privacy Officer at any time at compliance@olivegroup.io.

We at VLE do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the definition of Sensitive Personal Information under clause 2.2 above.

11. Security

We aim to ensure that your Personal Information is secure. In order to prevent unauthorised access or disclosure, we have appropriate physical, technical and organizational measures to safeguard and secure the Personal Information we collect. Our service providers are required to do the same. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information once we receive it, we cannot guarantee the security of your data transmitted to a Site; any transmission is at your own risk. Once we have received your Personal Information, we will use strict procedures and use leading technologies and encryption software to safeguard your data, and keep strict security standards to prevent any unauthorized access.

11.1 While using some third parties services for the purpose of payment processing, research or statistical data analysis, some personal information may be transferred to those third parties. We remain responsible for your information when shared with third parties, and shall instruct such third parties to abide by the GDPR rules.

11.2 All private information like User’s e-mail address, access log-in can be accessed only by providing User’s password.

12. Cookies

Each Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse a Site and also allows us to improve the Site. Providing us with your Personal Information is always your choice. However, your decision not to provide certain information may limit our ability to provide you with our complete services. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy linked at clause 10 above.

13. Links to other Website

A Site may contain links to the website of other companies and organisations which may be of interest (“Third Party Site”). If you decide to leave the Site and access the Third-Party Sites or to use or install any Third-Party Applications, Software or Content, you do so at your own risk and you should be aware that our terms and policies no longer govern. You should review the applicable terms and policies, including privacy and data gathering practices, of any site to which you navigate from the Site or relating to any applications you use or install from the site.

14. 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:

14.1 The right to be informed about the processing of your personal data;

14.2 The right to access your personal data;

14.3 The right to rectification of your personal data;

14.4 The right to erasure of your personal data;

14.5 The right to data portability;

14.6 The right to object to processing of your personal data;

14.7 The right to restrict processing of your personal data.

14.8 The right to request access to your information and information related to our use and processing of your information;

14.9 The right to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.

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 compliance@olivegroup.io or write to us at Glasshouse 1, Dun Laoghaire , Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 County Dublin. 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 Olive Group or email compliance@olivegroup.io with any relevant changes, such as change of address or contact telephone numbers.

15. Access to your Personal Information, deletion, restriction, rectification, and transfer

You have the right to request details and a copy of the Personal Information we hold about you and to ask us to delete, restrict, stop using, correct, rectify or transfer (port) your Personal Information. Our response to your requests may depend on which legal grounds we are using to process the data in question (see section above). For more information about your rights under the EU General Data Protection Regulation 2016/679 &680 please see the EU Directives given effect in Ireland by the Data Protection Act 2018 in Ireland. You can exercise your rights by sending us a written request using our by email at compliance@olivemedia.co; by post at Glasshouse 1, Dun Laoghaire , Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland. With each request please include identification information (a copy of your passport or driving licence and a recent utility bill). Please be as specific as possible in your request about your requirements, so that we can respond to you as quickly as possible.

16. Complaints to the ICO

If you are unhappy with us, our service, or with the way that we treat your Personal Information, please contact us. You also have the right to contact the Irish Data Protection Commission by emailing info@dataprotection.ie or by telephone at 1890 252 231. However, we would appreciate it if you would contact us first so that we can endeavour to resolve any issues that you might have. Our contact details are set out below.

17. Unsubscribe

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 compliance@olivegroup.io.

18. Disclosure of your information to third parties

We disclose your information to third parties, only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights. We will not sell your Personal Information collected through the application with any third party.

19. Data Retention Policy

It is the responsibility of the Olive Group to take all precautions necessary to secure proprietary information and to prevent unauthorised access to the data. The management of OLIVE GROUP is dedicated to mitigating the risks associated with data breaches.

19.1. Data Retention Period

General Data:General Data: We will retain all client-related data for a standard period of 6 months from the date of their exit from our services. After this period, the data will be permanently deleted from all systems and storage media and will not be accessible to anyone.

Contractual Obligations: In instances where the Company has contractual obligations with clients regarding data retention, the data will be preserved for the duration specified in the respective contracts.

19.2. Data Handling and Security

Data Access: Access to client data will be granted only to authorised personnel with a legitimate business need. Strict access controls are being enforced to prevent unauthorised access.

Data Security: We have implemented robust security measures, including encryption and access controls, to protect stored data from unauthorised disclosure, alteration, or destruction.

Data Backup and Recovery: Regular data backups are being conducted to ensure data integrity and facilitate data recovery in the event of accidental loss or system failures.

19.3. Data Disposal

Expiry of Retention Period: At the end of the 6-month retention period, all general client data will be permanently deleted from our databases, archives, and backup systems.

Contractual Data: In case of contractual obligations regarding data retention, data will be disposed of in accordance with the terms specified in the respective agreements.

19.4. Client Data Retrieval

Client Request for Data: If a client requests access to their data within the 6-month retention period, we will provide the data in a timely manner, subject to verification of the client’s identity.

Contractual Obligations: We will adhere to contractual obligations concerning data access and retrieval as outlined in the respective agreements with clients.

20. Changes to this privacy policy

Any changes we may make to our Policy in the future will be posted on this page and, where appropriate and feasible, notified to you by email. Please check these Terms and any Policies periodically for changes. User’s continued use of the application after the changes become effective constitutes the binding acceptance of such changes. Except as stated elsewhere, such amended Terms will automatically be effective upon the earlier of (a) the User’s ongoing use of the application with actual notice of the new terms, or (b) 30 days after we have posted notice of the new terms on this page.

21. Contact us

We are committed to resolving any privacy concerns you may have. If you have any questions or comments about this Policy, or if you wish to exercise your rights, please contact Olive’s Privacy Officer for queries or requests relating to taking a Course: Olive’s Privacy Officer for queries or requests relating to taking Course:

By email: compliance@olivegroup.io

By post: Brendan Kavanagh, Upskill Online Limited, Glasshouse 1, Harbour Court, George’s Place, Dun Laoghaire, A96 P0A4 Co. Dublin, Ireland

PRIVACY POLICY

Last updated December 13, 2023



This privacy notice for SSS Glasshouse Technologies Limited (doing business as MyClub360) ('we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:
  • Download and use our mobile application (MyClub 360), or any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at dpo@myclubireland.com.


SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the privacy notice in full.


TABLE OF CONTENTS



1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
  • names
  • phone numbers
  • email addresses
  • usernames
  • passwords
  • contact preferences
  • billing addresses
  • debit/credit card numbers
Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
  • Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
  • Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:
  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  • Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
  • Data Analytics Services
  • Sales & Marketing Tools
  • Cloud Computing Services
  • Payment Processors

We also may need to share your personal information in the following situations:
  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
  • When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API).

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dpo@myclubireland.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.

We will consider and act upon any request in accordance with applicable data protection laws.
 
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:
  • Log in to your account settings and update your user account.
  • Contact us using the contact information provided.
  • support@myclubireland.com
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at dpo@myclubireland.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at dpo@myclubireland.com, or contact us by post at:

SSS Glasshouse Technologies Limited
Suite 11
Parklands Office Park, Southern Cross Road
Bray, Co. Wicklow
Ireland

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.