Data Privacy Policy
This document outlines our approach to Data Privacy to fulfil our obligations under the General Data Protection Regulation (2018). We comply with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Irish Data Protection Acts 1998 to 20018 (together “Data Protection Rules”).
This notice applies to all our products and services.
You have a number of rights in relation to your information, including the right to object to processing of your personal information for direct marketing or where the legal basis for our use of your data is not a legitimate business interest or the performance of a task is not in the public interest.
If you have any questions about how your information is gathered, stored, shared or used, please contact us.
1. Who we are
Throughout this document, “we”, “us”, “our” and “ours” refers to devfair. www.devfair.com, (the “Website”) is owned and operated by Developerfair Limited (“devfair”).
Registered Office: 32/33 William Street South, Dublin 2, D02 NC58, Ireland.
Registered Number: 658488
2. The information we collect about you
There are a number of reasons for gathering information about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity and we need to understand your requirements. We need this information so that we can offer you products and services and give you the best possible customer experience. The information we collect falls into various categories.
Identity & contact information
Name, date of birth, copies of ID, contact details, PPS number (or foreign equivalent), online user identities (such as your log on identity, Twitter handle, Facebook profile, internet protocol, addresses, cookie identifiers and radio frequency tags used in contactless cards), security details to protect identity, nationality, home status and address, email address, work and personal phone numbers, marital status, family details, tax residency and tax related information and certain financial details such as bank account details and/or credit/debit card details.
Information you provide us about others or others provide us about you
If you give us information about someone else, or someone gives us information about you, we may add it to any personal information we already hold and we will use it in the ways described in this Data Privacy Notice.
Before you disclose information to us about another person, you should be sure that you have their agreement to do so. You should also show them this Data Privacy Notice. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this Data Privacy Notice.
3. When and how we collect information about you
As you use our services, apply for products, make enquiries execute transactions and engage with us, information is gathered about you. We may also collect information about you from other people and other parties.
When we collect information about you:
• When you use our website and online services provided by us (including mobile applications) and visit our offices.
• When you or others give us information verbally or in writing. This information may be on application forms, online application forms, in records of your transactions with us or if you make a complaint.
• When you use our products or services, including making transactions on your account, we gather details about who you get money from, who you pay money to, how much the payments are for and when the payments are made.
• From information publicly available about you – for example in trade directories, online forums, websites, Facebook, Twitter, YouTube or other social media.
Cookies
“Cookies” are small pieces of information that are stored by your browser on your device. Like most websites, we use cookies to keep track of your activity and enhance your experience. We also use cookies to assist us in the fight against fraud or malice. If you wish to disable these cookies, the “help” section of the toolbar on most browsers will tell you how. However, if you set your browser to disable cookies, you may not be able to access certain areas or features of our Website.
4. How we use your information
Whether we’re using it to confirm your identity, to help in the processing of an application for a product or service or to improve your experiences with us, your information is always handled with care and the principles outlined in this Data Privacy Notice are always applied.
We use your information:
• To provide our products and services to you, and to fulfil our contract with you.
• Process your applications for products and/or services.
• Establish your eligibility for our products and services.
• Establish your identity.
• Manage and administer your accounts, policies, transactions, benefits or other products and services that we or our partners may provide you with.
• Process payments that are paid to you or by you.
• Contact you by post, phone, text message, email, social media, fax, using our online website or other means, but not in a way contrary to your instructions to us or contrary to law.
• Recover debts you may owe us.
• Manage and respond to a complaint or appeal.
• To run, manage, improve and protect our business, reputation, resources and equipment, manage network and information security.
Conduct marketing activities
Where you have given us permission (which you can withdraw at any time) we may:
• Send electronic messages to you about product and service offers from our Group and/or our selected and trusted partners.
• Share your data with third parties so that they may send you electronic messaging about their products and offers.
• Use transaction history/account information from your devfair account to identify your transactional patterns and habits in order to personalise offers that are exclusive and individual to you, based on your account transactions.
• Use special categories of data, or sensitive data.
• Use your location data to send you information regarding special offers from us or our partners close to your location.
• Use information you have made public and combine with this with the activities outlined above.
When we ask for your consent, we will provide you with more information on how we will use your data in reliance on that consent, including in relation to third parties we would like your consent to share your data with.
6. Who we share your information with
We only share your information with a select number of individuals and companies, and only as necessary. Sharing can occur in the following circumstances and/or with the following persons:
• Companies that provide support services for the purposes of protecting our legitimate interests.
• Your personal information remains protected when our service providers use it. We only permit service providers to use your information in accordance with our instructions, and we ensure that they have appropriate measures in place to protect your information.
• Our service providers include marketing and market research companies, analytics companies, banking partners, investment companies, IT and telecommunication service providers, software development contractors, data processors, debit/credit card producers, computer maintenance contractors, printing companies, property contractors, document storage and destruction companies, custodians and providers of administration services, archiving services suppliers, debt collection agencies, budgeting and advice agencies, tracing agencies, receivers, liquidators, examiners, official Assignee for Bankruptcy and equivalent in other jurisdictions, auditors, and consultants, including legal advisors.
• Statutory and regulatory bodies (including central and local government) and law enforcement authorities.
• Third parties in connection with a sale or purchase of assets by devfair.
• Those who are interested in or participating in buying or selling assets of davfair or in connection with a funding arrangement for devfair.
7. How long we hold your information
We hold your information for no longer than is required.
8. Processing your information outside the EEA
Your information is stored on secure systems within Devfair premises and with providers of secure information storage.
We may transfer or allow the transfer of information about you and your products and services with us to our service providers and other organisations outside the European Economic Area (EEA), but only if they agree to act solely on our instructions and protect your information to the same standard that applies in the EEA.
9. How to exercise your information rights (including the right to object)
You have several rights in relation to how we use your information. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise.
You have the right to:
• Find out if we use your information, to access your information and to receive copies of the information we have about you.
• Request that inaccurate information is corrected and incomplete information updated.
• Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests (for example, profiling we carry out for our legitimate business interests) or the performance of a task in the public interest. However, doing so may have an impact on the services and products we can / are willing to provide.
• Object to use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes
• Have your data deleted or its use restricted – you have a right to this under certain circumstances.For example, where you withdraw consent you gave us previously and there is no other legal basis for us to retain it, or where you object to our use of your personal information for particular legitimate business interests.
• Obtain a transferable copy of certain data to which can be transferred to another provider, known as “the right to data portability”.
• This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. You are not able to obtain through the data portability right all of the personal information that you can obtain through the right of access. The right also permits the transfer of data directly to another provider where technically feasible. Therefore, depending on the technology involved, we may not be able to receive personal data transferred to us and we will not be responsible for the accuracy of same.
• Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal. We are obliged to respond without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons why. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise. You have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at:
Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231 Fax: +353 57 868 4757 E-mail: info@dataprotection.ie Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois.
10. How to contact us and/or our Data Protection Officer
If you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact our Data Protection Officer at:
E-mail: dataprotection@devfair.com; Postal Address set out at the top of this document.
11. Changes to this notice
Any updates to this Data Privacy Policy will be made available to you at any time via the website and/or copies can be requested by email.
Dated: 31 August 2020