Privacy Policy

 

  1. Introduction

The privacy and security of our existing customers and future clients are of paramount importance. FCDM is fully committed to protecting the data you share with us. Our privacy policy below will explain how we processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of our website.

For the purposes of this policy, FCDM defines the term “client” as an entity with which FCDM has an established relationship, the term “potential client” as any individual who has contacted us for services and the term “Visitor” as an individual that visits our front-end website www.fcdm.com.

We implement and maintain appropriate technical, security and organisational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

If you have any questions or concerns that are not adequately answered by the information provided here, or if you wish to have us amend or delete data we have on our system that relates to you personally, then you will find various ways to contact us in the ‘contact us’ section at the end.

This statement (together with our Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following statement carefully to understand our views and practices regarding your personal information and how we will treat it, including what type of information is collected and tracked on the Website, how the information is used, and with whom the information is shared. All of the ways in which you can communicate with us are contained in the contact us section.

Your Rights

We have a legal obligation to ensure that the personal information we have in our systems about you is kept accurate and up to date. Please assist us to comply with this obligation by informing us of any changes to your personal information.

For processing activities for which we rely on consent as a basis for processing your data, you have the right to withdraw your consent at any time.

For processing activities which are based on a statutory or contractual requirement, you may request your data not be processed for that purpose. However, this is not an absolute right and may be over-ridden by our statutory obligations. In other cases, requesting that data should not be processed for a particular purpose may prevent us from executing a contract or delivering a service to you

Subject Access Request.

If you would like a copy of the data that we hold on file for you, or if you wish to have us amend delete or restrict the use of the data we have on our system that relates to you personally, you have a legal right to submit what is referred to as a subject access request(‘SAR’).

You can send a SAR to: paul@fcdm.ie

or by post to FCDM Athlone | Unit 50, Blyry Business & Commercial Park, Athlone, Co. Westmeath.

Although, a SAR should, ideally, be submitted in writing, you will find all other methods of communicating with us detailed in the ‘contact us’ section at the end of this document.  We will meet any such requests within 30 calendar days of the receipt of a valid request.  We reserve the right to request you to provide additional information in order to enable us to identify your personal data and/or to verify your identity.

 

  1. Collection and use

2.1 General

The following sections cover the specifics of each of the three groups from which data are collected.

2.2 Website Visitors

If you are a Visitor to our website and are not a ‘Client’ or a ‘potential client’ that has contacted us directly then this section is relevant for you.

By visiting the www.fcdm.com website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website. Any personal information which you volunteer to FCDM will be treated strictly in accordance Irish Data Protection Law and with the EU General Data Protection Regulation (Regulation (EU) 2016/679) to become known as the Data Protection Acts 1988-2018.  If you do not agree with the terms set out herein, please discontinue use of the website. If required by applicable law, we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website is not possible. We reserve the right to modify this Privacy Notice at any time. Each time you use this website you shall be bound by the then current Privacy Notice and accordingly you should review the Privacy Notice each time you use this website.

FCDM may collect, record and analyse information of Visitors to its website.

We record your IP address and use cookies. We may add information collected by way of pageview activity. We collect and process any Personal Data that you volunteer to us in our website’s forms. If you provide us with your social media details, we may retrieve publicly available information about you from social media.

Such Personal Data may comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, data for social networks, your areas of interest, interest in FCDM services and certain information about the company you are working for (company name and address), as well as information as to the type of relationship that exists between FCDM and yourself.

FCDM gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or where Visitors have come from. We use Google Analytics for this purpose to learn how you and other users use our services and how well they perform

In addition to the above we also collect Non-Personal data such as details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data, and the resources that you access; If you contact us, we may keep a record of that correspondence.

 

2.2.1 Purpose of processing personal data

FCDM uses the collected data to communicate with Visitors, to customize content for Visitors, to show ads on other websites to Visitors, and to improve its website by analysing how Visitors navigate its website.

 

2.2.2 Sharing personal data

FCDM will not share your information with any third-parties other than as set out in this Policy.

We may share your information in the following circumstances:

  • Service providers: We may need to share personal information with our service providers, such as where necessary to provide our services to you. If there has been a breach of our Terms of Use, we may also share personal information with our legal advisors. All of our service providers will be obliged to keep your personal information safe and secure.
  • Consent: We will share your information with a third party where you have allowed us to do so.
  • Business [Transfer]: Where some or all of our company and/or its assets may potentially be or have been acquired, we may need to transfer your personal information to the new or prospective owners.
  • Legal and safety: In certain instances, we may share information where we reasonably believe that it is necessary for legal reasons, to defend our legal rights, to enforce our Terms of Use or to protect our rights, property, users, customers or the safety of any person. For example, we may provide personal information where ordered by a court to do so.

Transfers of your Personal Information Abroad

The personal information we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, provision of support or other services.

It is important to be aware that the privacy protections in certain jurisdictions may not be equivalent to those in Europe. We only transfer your information outside the EEA where permitted by law and ensuring that it is subject to appropriate protections.

By submitting your personal information, you agree to this transfer, storing or processing.

2.2.3 Cookies

Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, you should either (a) immediately stop using our services or (b) use the settings described in www.allaboutcookies.org below, to reject cookies.  By choosing not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. We may also place cookies from third parties for functional and marketing purposes. The use of cookies is widespread and benefits the website user. Please refer to your Cookie Policy for additional information.

The information collected in this way can be used to identify you unless you modify your browser to prevent this happening – guidance for which is set out below. We also aggregate this data to perform statistical analyses of the characteristics and behaviour of our Website Visitors. Cookies are also used as a further means of ensuring private and secure purchase sessions are operated within the Website.

We may use third-party advertising companies to serve advertisements on our behalf. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. Your browser can be modified to not accept cookies – guidance for which is provided in the paragraph below.

For more information about cookies, including how to set your internet browser to reject cookies, please go to www.allaboutcookies.org. (Please note: FCDM.com does not own the website allaboutcookies and accepts no responsibility whatsoever for its content or activity)

We are currently developing the ability for you to select which cookies you are happy for us to use during your time on our site and hope to have this available soon. The cookies we use on our site are as follows:

  • Cookie Type
  • Cookies for analytics, Google Analytics– to learn how you and users use our services and how they perform.
  • Cookies for marketing, Google AdWords – to track and improve the effectiveness of our marketing emails.

2.2.4 Links to other sites

Please be aware that while visiting our site, Visitors can follow links to other sites that are beyond our scope of influence. FCDM is not responsible for the content or privacy policy of these other sites.

 

2.4 Users

2.4.1. General

In order to provide services to our clients and provide information to our potential clients we collect certain types of data from them. This section will describe how these types of data are collected and used by us as well as geographical differences that effect this policy.

2.4.2 Collection of client and potential client data

During a potential client’s registration, they provide information such as name, company name, email, address, telephone and other relevant data. This information is used by FCDM to identify the person/company and provide them with information on our services.

FCDM will not retain this data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations.

2.4.3. Geographical location

FCDM’s “Data Region” is a set of data centres located within a defined geographical area where data are stored. Personal Data are not transmitted between Data Regions. For FCDM clients with accounts located in European Data Region, all Personal Data are processed in the EEA.

2.4.3.1 Processing in the European Economic Area (EEA)

For clients with accounts located in European Data Region, all processing of Personal Data is  performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and FCDM’s processing will take place in accordance with the GDPR.

2.4.3.2. Controller

FCDM processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:

The FCDM entity which you as a User entered an agreement with when using our services, will be the Controller for User data, as outlined above in “Collection of User data” section.

All data collected by FCDM will be stored exclusively in secure hosting facilities provided by Nexcess. We have a data processing agreement in place with this provider, ensuring compliance with the Directive. All hosting is performed in accordance with the highest security regulations. All transfers of data internally in the EEA is done in accordance with this data processing agreement.

  1. Retention and deletion

FCDM will not retain data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations. For potential clients, the purpose for collecting data, and the duration for which the Personal Data may be kept will be no longer than 6 months. Our clients with an active account will therefore have the right to request to delete data when required and when requested by them. When a client’s account is terminated all Personal Data collected will be deleted, as required by applicable law.

  1. Acceptance of these Conditions

We assume that all Visitors of our website, clients and potential clients have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our website and requesting services from FCDM. We reserve the right to change our privacy policy as necessity dictates. Continued use of our website after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. This privacy policy is an integral part of FCDM’s terms of use.

  1. Our Legal Obligation to Disclose Personal Information

We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to FCDM or to others who could be harmed by the user’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.  See section 2.2.2 above for further details.

  1. FCDMs Data Protection Queries

Data Protection queries can be reached at the following address: Attn: Paul Fox

paul@fcdm.ie

FCDM Athlone | Unit 50, Blyry Business & Commercial Park, Athlone, Co. Westmeath. +353 90 6493740

  1. For Further Information

If you have any further questions regarding the data FCDM collects, or how we use it, then please contact us by emailing Paul Fox at paul@fcdm.ie or in writing to: FCDM Athlone | Unit 50, Blyry Business & Commercial Park, Athlone, Co. Westmeath. +353 90 6493740.

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