Privacy Policy – Refresca
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Refresca

Privacy Policy

  1. Introduction

1.1 We are committed to safeguarding the privacy of www.refresca.ie and our website visitors and service users.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of www.refresca.ie and our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.

(“Personal data” is defined in Article 4(1) of the GDPR:

“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

1.3 By using and registering as a user on our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via http:www.refresca.ie.

1.5 In this policy, “we”, “us” and “our” refer to Conor Delgarno.  For more information about us, see Section 13 or the “About” section on our website.

 

  1. Credit

2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).

 

  1. How we use your personal data

3.1 In this Section 3 we have set out:

(a) the general categories of personal data that we may process;

(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];

(c) the purposes for which we may process personal data; and

(d) the legal bases of the processing.

3.2 We may process data about your use of our website, application and services (“usage data“).

The usage data may include identifying your IP address, 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 service use. The source of the usage data is for our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website, application and services. The legal basis for this processing is the users consent and our legitimate interests, namely to monitor and improve our website and services.

3.3 We may process your registered account data (“account data“).

The account data may include your name, identification, user name and email address. The source of the account data is you “the user”.  The account data may be processed for the purposes of operating our website and application, providing our services, ensuring the security of our website, application and services, maintaining back-ups of our databases and communicating with you.  The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website and business.

3.4 We may process your information included in your personal user profile on our website (“user profile data“).

The profile data may include your name, contact address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details.  The profile data may be processed for the purposes of enabling and monitoring your use of our website, application and services. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website and business

3.5 We may process any of your personal data that is provided in the course of the use of our services (“service data“).

The service data may include your site use and preferences, advertisements and search history.  The source of the service data is you. The service data may be processed for the purposes of operating our website, application and providing our services, ensuring the security of our website, application and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website and business.

3.6 We may process advertisement and service information that you post for publication on our website or through our services (“publication data“).

The publication data may be processed for the purposes of enabling such publication and administering our website, application and providing our services. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our website, application and providing our services.

3.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“).

The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.

3.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and others through our website (“transaction data“).

The transaction data may include your contact details, your card details, third party payment companies and the transaction details.  The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you, the user and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website, application and providing our services.

3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] (“notification data“).

The notification data may be processed for the purposes of sending you the relevant notifications, promotions and/or newsletters. The legal basis for this processing is your consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“).

The correspondence data may include the communication of content and metadata associated with the communication.  Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our business, website, application and providing our services and communications with users.

3.11 We may process identification verification.  This data may include Name, address, utility bill, passport or driving licence details, contact number and email address.  The source of this data is you the user and your created profile. This data may be processed for security and trust data on our business, website, application and in providing our services. The legal basis for this processing is your consent and our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract for the purpose of creating a secure user profile.

3.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, or as requested by international police forces. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.13 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.14 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing 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.

3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

 

  1. Providing your personal data to others

4.1 We may disclose your limited personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3 We may disclose your name and email address and your preferences  to our commercial advertisers, advertising on www.refresca.ie  insofar as reasonably necessary for commercial sales and marketing on our business, website, application and in providing our services.

4.4 Financial transactions relating to our website and services are OR may be handled by our payment services providers, www.PayPal.com and credit and debit card companies. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at their websites, www.PayPal.com.

4.5 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to market and / or contact you so that they can offer, market and sell to you relevant goods and/or services.  Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may 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 natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, law enforcement, whether in court proceedings or in an administrative or out-of-court procedure.

 

  1. International transfers of your personal data

5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)].

5.2 We Adora Castillo Ireland Limited and our other group companies have offices and facilities in Ireland, (Other Countries through expansion).  The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries.  Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://www.eugdpr.org the use of binding corporate rules, a copy of which you can obtain from https://www.eugdpr.org.

5.3 The hosting facilities for our website are situated in Ireland (2018).  The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries.  Transfers to Ireland and other European Countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://www.eugdpr.org

5.4 Adora Castillo Holdings Limited situated in Ireland. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to any other country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://www.eugdpr.org/

5.5 You acknowledge that personal data that you submit for publication through our website, application or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

 

  1. Retaining and deleting personal data

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2 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.

6.3 We will retain your personal data as follows:

(a) [personal data category or categories] will be retained for a minimum period of [period] following [date], and for a maximum period of [period] following [date].

[additional list items]

6.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a) the period of retention of [personal data category] will be determined based on [specify criteria].

[additional list items]

6.5 Notwithstanding the other provisions of this Section 6, 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.

  1. Amendments

7.1 We may update this policy from time to time by publishing a new version on our website.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of changes to this policy by email or through the private messaging system on our website.

 

  1. Your rights

8.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a) the payment of a fee (currently fixed at EUR 15); and

(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address, dated within a period of the previous 12 weeks).

8.2 We may withhold personal information that you request to the extent permitted by law.

8.3 You may instruct us at any time not to process your personal information for marketing purposes.

8.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

 

  1. About cookies

9.1 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.

9.2 Cookies may be either “persistent” cookies or “session” cookies: 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, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3 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.

 

  1. Cookies that we use

10.1 We use cookies for the following purposes:

(a) [authentication – we use cookies [to identify you when you visit our website and as you navigate our website][ (cookies used for this purpose are: [identify cookies])]];

(b) [status – we use cookies [to help us to determine if you are logged into our website][ (cookies used for this purpose are: [identify cookies])]];

(c) [personalisation – we use cookies [to store information about your preferences and to personalise the website for you][ (cookies used for this purpose are: [identify cookies])]];

(d) [security – we use cookies [as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally][ (cookies used for this purpose are: [identify cookies])]];

(e) [advertising – we use cookies [to help us to display advertisements that will be relevant to you][ (cookies used for this purpose are: [identify cookies])]];

(f) [analysis – we use cookies [to help us to analyse the use and performance of our website and services][ (cookies used for this purpose are: [identify cookies])]]; and

(g) [cookie consent – we use cookies [to store your preferences in relation to the use of cookies more generally][ (cookies used for this purpose are: [identify cookies])]].

[additional list items]

  1. Cookies used by our service providers

11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.[ The relevant cookies are: [identify cookies].]

11.3 We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.] OR [We publish Google AdSense advertisements on our website. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies. This behaviour tracking allows Google to tailor the advertisements that you see on other websites to reflect your interests (but we do not publish interest-based advertisements on our website).] You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the AdSense partner network cookie using those settings or using the Network Advertising Initiative’s multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.[ The relevant cookies are: [identify cookies].]

11.4 We use [identify service provider] to [specify service]. This service uses cookies for [specify purpose(s)]. You can view the privacy policy of this service provider at [URL].[ The relevant cookies are: [identify cookies].]

 

  1. Managing cookies

12.1 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 however obtain up-to-date information about blocking and deleting cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

 

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

 

  1. Our details

13.1 This website is owned and operated by Adora Castillo Ireland Limited with a registered business name of Refresca.

13.2 We are registered in Ireland under registration number 568961, and our registered office is at TMS Services, 6 Supple Park S.C., Dunshaughlin, Co. Meath, Ireland.

13.3 Our principal place of business is at Office 2, D-House, Finnegans Way, Trim, Co. Meath.

13.4 You can contact us:

(a) by post, to the postal address given above;

(b) using our website contact form;

(c) by telephone, on the contact number published on our website from time to time; or

(d) by email, using the email address published on our website from time to time.

 

  1. Data protection officer

14.1 Our data protection officer’s contact details are: Mr Conor Delgarno, Office 2, D-House, Finnegans Way, Trim, Co. Meath, Ireland.

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