PRIVACY STATEMENT OF THINKBUSINESS.IE

  1. WHO WE ARE

ThinkBusiness.ie is a business reference website that is owned and managed by Bank of Ireland Group. Bank of Ireland Group whose holding company is Bank of Ireland Group plc which has its registered office at 40 Mespil Road, Dublin 4, Ireland.

We are committed to ensuring the privacy of your information and we understand that as a customer or visitor using the ThinkBusiness.ie website, the privacy and the security of your information is very important to you. The purpose of our Privacy Statement is to outline Bank of Ireland Group’s practices in this area.

PLEASE NOTE that this Privacy Statement is subject to the Terms and Conditions of Use of the ThinkBusiness.ie website. You can read the copy of the Terms and Conditions of Use by clicking here. We recommend that you read the Terms and Conditions of Use. If there is a conflict between the Terms and Conditions of Use and this Privacy Statement, the Terms and Conditions of Use shall prevail. Except as otherwise provided, terms used herein and defined in the Terms and Conditions of Use shall have the same meaning that is given to them in the Terms and Conditions of Use.

  1. THE INFORMATION THAT WE COLLECT ABOUT YOU

Personal Data

There are a number of reasons for collecting information about you. The personal data that we collect about you is:
Contact Data: your name and email address when you contact us through our Contact page, you may also voluntarily provide your telephone number

Identity Data: first name and last name

Technical Data: internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices that you use to access this website

Usage Data: how you use this website

Marketing and Communications Data: your name, email address and consent, through subscribing to our newsletter

The collection of this data is only done if you voluntarily submit it to us when you browse our website, contact us through our Contact page and where you provide your explicit informed consent to the processing of this data.

You may also choose to receive information on our services and up to date news by subscribing to our newsletter by giving us your name and email address. You, therefore, will be opting in to receive this information. Each time that you receive our newsletter by email you may choose to opt out of receiving them by clicking on the “unsubscribe” button.

Non-Personal Data

Like other websites as you browse through our website, our web server collects statistical and other analytical information on an aggregate basis known as aggregated data of all visitors to the website. We use cookies to provide us with this information through the Google Analytics platform (more details about how and why we use cookies are contained in our “Cookies Policy”.

We gather and monitor metadata statistics such as, for example:

  • the number of people who visit the website;
  • the date and time of visits;
  • the number of pages viewed;
  • the amount of time spent on the website;
  • the most popular sections of the website

This information is anonymous and no attempt is or will be made to identify visitors. So, for example, on a specific day, we can identify that our site has forty thousand visitors. However, we know nothing about these visitors in terms of e-mail addresses or any other first person, personal information (e.g. name, email, profession).

Non-personal data by definition cannot identify you and is not considered personal data in law as this data cannot directly or indirectly identify you.

We do not collect any Special Categories of Personal Data about you such as race, ethnicity, sex life, sexual orientation, religious or philosophical beliefs, political opinions, health and genetic or biometric data or any information about criminal convictions or offences.

Personal Data for a Specified Purpose

We only ask and will only ask for first person, personal information from which you can be identified where the information is required for particular purposes e.g. subscribing to the newsletter, registering to use the blog, registering to upload material onto the site e.g. on-line pitches. Examples of details that may be sought include your name, address, e-mail address, etc. (please note in this regard the paragraph headed Internet Fraud below).

  1. WHEN AND HOW WE COLLECT INFORMATION ABOUT YOU

    There are different methods to collect your personal data.

Direct Interactions: your identity and contact details may be given by corresponding with us or completing and sending contact forms. This may be done when:

  • Subscribe to our newsletter
  • Contact us through our Contact page

Automated Interactions: when you browse our website, we may automatically collect technical data about your browsing actions and habits, and equipment. This data is collected by using cookies, server logs and other equivalent technologies (more details about how and why we use cookies are contained in our “Cookies Policy”. Technical data may also be collected about you if you visit other sites which use our cookies. This may occur for example where you download templates from our website or click on a link to one of our Bank of Ireland Group websites. Please note that if you visit any of the Bank of Ireland Group websites that they will be governed by their own Privacy Statements and Cookies Policies and not those of the thinkbusiness.ie website.

Third Parties: personal data may be received from various third parties such as

  • Analytics providers such as Google Analytics
  • Social Media pages such as Twitter, Linkedin, Google + and Facebook and through watching videos on our website through YouTube 
  1. HOW WE USE YOUR INFORMATION AND THE LEGAL BASIS FOR SUCH USE

The use of your personal data will only be done where it is permitted by law- the legal basis for the processing of your personal data. Generally, your personal data will be used:

– where it is required for our legitimate interest and yours in providing our services

– where we are required to comply with a legal or regulatory obligation

– where we obtain your consent for example through subscribing to our newsletter. You may withdraw your consent at any time from receiving our newsletter by opting out on receipt of the newsletter.

Use/Activity

Type of Data

Lawful Basis for Processing

To manage our relationship with you

– Identity

– Contact

– Technical

– Marketing and Communications

– Necessary to comply with legal obligations

– Necessary for our legitimate interest (to keep our records updated and study how customers use our website)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

– Identity

– Contact

– Technical

– Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

– Necessary to comply with legal obligations

To deliver relevant website content to you

– Identity

– Contact

– Technical

– Usage

– Marketing and Communications

Necessary for our legitimate interests (to study how clients use our services, to develop them and for our marketing strategy).
To use data analytics to improve our website, services, marketing, customer relationships and experiences

– Technical

– Usage

Necessary for our legitimate interests (to define visitors to our website, to keep our website updated and relevant and to inform our marketing strategy) and explicit fully informed consent for direct marketing.

Newsletter

If we ask you for personal data for the purpose of subscribing to our newsletter, you will only receive this information if you have given us your explicit consent. The opt-in button is on our request form for those who would like to subscribe. You may opt out at any time from receiving the newsletter every time that we contact you by clicking the unsubscribe button.

Withdrawal of Consent

If you wish to withdraw consent from us processing and holding any personal data under any of the headings above at any time please contact us by email at the following address [include email address] specifying the nature of the processing and holding of personal data for which you want your consent to be withdrawn. This will help us deal with your request more efficiently and quickly.

  1. WHO WE SHARE YOUR INFORMATION WITH

Personal Data 

Your Personal Data is never shared or disclosed to third parties without your permission, except under conditions explained below.

Bank of Ireland Group may send your Personal Data to other companies or people (third parties) under any of the following circumstances:

  • When we have obtained your explicit fully informed prior consent to share and/or disclose the information;
  • When we need to share your information to provide the service you have requested;
  • When you have told us to send the information to other individuals on your behalf, for example, a third party is required to fulfil a request you have made.
  • Sharing and disclosure of personal data will also occur if we believe in good faith that we are required to do so in order to comply with any applicable law, a summons, search warrant, a court or regulatory order or other statutory instrument or to enforce our Terms and Conditions of Use.

Non-Personal Data

We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our site. An example of such data sharing and disclosure could be regarding the number of unique users who visit the site or the activities that visitors to our site engage in while on our website. The companies or persons to whom this information is sent could include service providers, commercial partners, sponsors, researchers, web developers and other similar parties.

Third Party Sites and Social Media 

This website may include certain links to third-party websites, plug-ins and applications. By clicking on those links or enabling those connections will allow these third parties to collect or share data about you; it is likely that they will have their own privacy policies. We have no control over the workings of such third parties. For them, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers as your interaction with them is governed by their own privacy policies and statements and not by ours. Specifically, some of these providers may not be in the same country as you or where the Bank of Ireland Group is based. The result of this is that if you proceed to use the services of a third party provider then your personal and non-personal data may become subject to the laws of a country where such service provider is located. As a consequence, the use of such data may be different from the country in which you are based. Please read carefully the privacy policies and statements of these third-party providers as these are the policies and statements that will now apply to you.

Our website may also contain links to and from other websites such as social media sites or for example Twitter, LinkedIn, Google +, Facebook and YouTube. We have no control over the contents or workings of these sites. These sites (and other sites) may collect information about you if you click on a link and the social media sites may automatically record information about your browsing behaviour every time you visit those sites. Please note that your interaction with these sites is governed by their privacy policies and not by this Privacy Statement. We do not and cannot control what information these websites can collect. Therefore please review your privacy settings on your social media sites and determine carefully before clicking on any of these links.

  1. CHANGE OF PURPOSE 

Your personal data will only be used for the purposes for which it was collected by us unless we consider that we need to use the personal data for another reason and that reason is compatible with the original purpose. We are happy to explain to you how we understand this processing is compatible with the original purpose [Contact us – see below]. 

  1. DATA RETENTION

Your personal data shall only be retained for as long as necessary in order to fulfil the purpose for which it was collected which shall include for the purposes for satisfying any accounting, legal or reporting requirements.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”).
  • Request correction of the personal data that we hold about you.
  • Request erasure of your personal data. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact Us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. All the measures taken by Bank of Ireland Group to facilitate you exercising these rights will be carried out in accordance with EU data privacy law.

9. UPDATING, VERIFYING, DELETING AND REQUEST FOR PERSONAL DATA

You may inform us of any changes in your personal data so that we can amend our records. We will update or delete your personal data as required. If you wish to find out what personal data we hold on you or to have your personal data updated, amended or removed please email us at [contact email address link].

In most circumstances, there is no charge for the supply of this information. Please note that certain data is exempt from disclosure under data protection legislation including certain privileged and confidential information.

If you are not happy with how we implement our Privacy Statement, please contact us and if you have questions about how we use your information, you can reach our Data Protection Officer at www.bankofireland.com/privacy, by mail to Bank of Ireland, PO Box 12940, Dublin 18 or by contacting 01 688 3674.

Or you may 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

Email: info@dataprotection.ie

Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23    

  1. SECURITY OF INFORMATION

At Bank of Ireland Group, we understand how important the security and confidentiality of your information is to you. Keeping customer information secure is a top priority for Bank of Ireland Group. Our goal is to protect your information on the Internet in the same way as we would over the phone, in a branch or at an ATM.

Even so, Bank of Ireland Group cannot guarantee the privacy or confidentiality of information relating to you passing over the Internet. As a result, no data transmission over the Internet can be guaranteed to be 100% secure.

However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data in light of the state of present technological development.

We have put in place appropriate procedures to deal with any suspected personal data breach and will notify you (and the appropriate regulatory body) of a breach where we are legally required to do so.

Internet Fraud

A number of banking organisations and their customers have been the target of hoax e-mails that are aimed at gathering Internet/account details of the customers. Some of these hoax e-mails have encouraged or facilitated contact with hoax websites that purport to be (but are not) the website of the relevant banking organisation. We would always advise you to be cautious as regards disclosing your personal details. In particular, you should note that we will only ever request your personal details if: (i) you are seeking to initiate e-mail contact with us via this website; or (ii) you initiate a request for a particular service via this website and we require certain of your personal details to provide you with the requested service.

Hyperlinks

Some of the pages on this website contain hypertext links to websites not maintained by Bank of Ireland Group. You are reminded that different terms and conditions of use and privacy policies and statements will apply to you as a user of such websites. In addition, such websites may not attain the same privacy standards that Bank of Ireland Group maintains.

  1. CHANGES TO THIS PRIVACY STATEMENT

Bank of Ireland Group may at any time amend or change this Privacy Statement without notice in accordance with data protection legislation, so please review it frequently. Any modification to this Privacy Statement will be posted on this website (www.thinkbusiness.ie) in order that you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

Last updated, December 3, 2018.