Privacy & Data Protection Procedures
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please get in touch with us by e-mail at info@lensmen.ie | accoun
Please ring Susan Kennedy on 000353 01 819 7738 | 00353 087 258 4388
This is the privacy notice of S.K.P & Associates Ltd t/a Lensmen & Associates.
We are committed to safeguarding the privacy of our website visitors, service users and other individuals we deal with. This policy sets out information about how we use, store and transfer personal data relating to those individuals. We are a data controller in relation to that personal data, which means we determine the purposes and means of processing that personal data. S.K.P & Associates Ltd t/a Lensmen & Associates is responsible for ensuring that your personal data is protected, which we take very seriously, and we’re committed to keeping your information safe and secure.
In this document, “we”, “our”, or “us” refers to S.K.P & Associates Ltd t/a Lensmen & Associates.
S.K.P & Associates Ltd t/a Lensmen & Associate CRO Number 231702 registered in Ireland.
S.K.P & Associates Ltd t/a Lensmen & Associates registered office is at 17 Nottingham Street, North Strand, Dublin 3, D03 C654. Ireland
00353 01 819 7738 | 00353 087 258 4388
info@lensmen.ie | accounts@
S.K.P & Associates Ltd t/a Lensmen & Associates VAT Registration IE 8231702R
S.K.P & Associates Ltd t/a Lensmen & Associates Registration IE 8231702R
Tax Clearance Certificate Issued Access Number: 442714
https://lensmen.photoshelter.
Introduction
- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately.
- We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. We do this now by requesting that you read the information provided at knowyourprivacyrights.org
- Except as set out below, we do not share, sell, or disclose to a third party any information collected through our website.
The basis on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your personal information and to notify you of the basis for each category.
If the basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes, we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information if required by law.
1. Information we process because we have a contractual obligation to you
When you create an account on our website, buy a product from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
- verify your identity for security purposes
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services, and how to obtain the most from using our website
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example, to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
Information we collect about you:
a) Usage data: To ensure that our website is useful to all visitors and continues to improve, we may process data about your use of the site. This may include your 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 use. This data, obtained through Google Analytics, is aggregated and anonymised such that it contains no information pertaining to any identifiable individual; as such, it is not personal data per se, but we address it here for completeness’s sake.
b) Correspondence data: we may process information contained in or relating to any communication that you send to us, whether through the site, by email, through social media, or otherwise. This may include the communication content and metadata associated with the communication, as well as any contact details you provide to us, such as your name, email address, phone number, job title, address or social media username. We process correspondence data for the purposes of communicating with you and record-keeping.
c) Enquiry data: we may process information contained in any enquiry you submit to us indicating your interest in our services or business, such as the contents of your enquiry and any contact details you provide to us, such as your name, email address, phone number, job title or address. We process such data for the purposes of addressing your enquiry and providing you with occasional news about our services and operations. If you no longer wish to receive news from us then you can unsubscribe at any time.
d) Project data: where we are commissioned to undertake a particular piece of work or project, we process information for the purposes of setting up that project in our systems, such as your name and contact details. We may also process personal information contained within project-related correspondence and documents, including in relation to your customers, whether created by us or provided to us. All such data is processed for the purposes of providing our professional services and for record-keeping purposes.
e) Transaction data: We may process information relating to transactions, such as bank account details, contact details, or transaction data in relation to payments made by us to you or by you to us. This may include your contact details, or any bank account or sort code information provided for the purposes of making payment, as well as transaction details (such as POs or invoices). The transaction data may be processed for the purpose of supplying or receiving and administering the relevant services, keeping proper records of those transactions, and making and receiving payments.
f) Personal data we obtain from others: our personal data may be provided to us by someone other than you—for example, by your employer, by an organisation with whom you and we are both dealing or by someone who wishes to refer you to us or vice versa. Normally this data will be correspondence data, enquiry data, or project data as described above, and will be processed by us for the purposes described above.
We process personal data on lawful bases only. In particular, we process personal data on the following lawful bases identified in Article 6 of the General Data Protection Regulation:
a) for the performance of a contract with you, or to take steps at your request prior to entering into a contract with you (Article 6(1)(b) GDPR). This may be our basis for processing correspondence data, enquiry data, matter data and transaction data;
b) for our legitimate interests (Article 6(1)(f) GDPR). This may be our basis for processing:
i) correspondence and matter data (as we have an interest in properly administering our business and communications);
ii) enquiry data (as we have an interest in developing our business with interested parties);
iii) transaction data (as we have an interest in making and receiving payments promptly and in recovering debts);
iv) any personal data identified in the other provisions of this Notice where necessary in connection with legal claims (as we have an interest in the protection and assertion of our legal rights, your legal rights and the legal rights of others);
v) any of the personal data identified in the other provisions of this Notice in connection with backups of any element of our IT systems or databases containing that personal data (as we have an interest in ensuring the resilience of our IT systems and the integrity and recoverability of our data).
In addition to the specific purposes for which we may process your personal data set out above, we may process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject (Article 6(c) GDPR), or in order to protect your vital interests or the vital interests of another individual (Article 6(d) GDPR).
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example, to monitor the performance of a particular page on our website. https://lensmen.
If you have given us explicit permission to do so, we may, from time to time, pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us info@lensmen.ie, if you do so, you may not be able to use our website or our services further.
3. Information we process for legitimate interests
We may process the information on the basis there is a legitimate interest, either to you or to us, in doing so.
Where we process your information on this basis, we do so after having given careful consideration to:
- whether the same objective could be achieved through other means.
- whether processing (or not processing) might cause you harm.
- whether you would expect us to process your data and whether you would, in the round, consider it reasonable to do so.
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of our business.
- responding to unsolicited communication from you to which we believe you would expect a response.
- protecting and asserting the legal rights of any party.
- insuring against or obtaining professional advice that is required to manage business
- protecting your interests where we believe we must do so.
4. Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
5. Information provided on the understanding that it will be shared with a third-party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by others.
Examples include:
Place a review of a product on our product page.
https://g.page/r/
https://g.page/r/
https://g.page/r/
https://lensmen.photoshelter.
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We store it and reserve the right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, we may, at our discretion, agree to delete the personal information that you have posted. You can make a request by contacting us at info@lensmen.ie | accoun
Complaints regarding content on our website
Our website is a publishing medium. Anyone may register and then publish information about himself, herself, or some other person.
We do not moderate or control what is posted.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we must judge which right will be obstructed: yours or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
7. Information relating to your method of payment
We never take payment information or transfer it to ourselves, either through our website or otherwise. Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on Stripe | Paypal’s website or paid via bank transfer to our bank account. That page may be branded to look like a page on our website, but it is not controlled by us.
8. Sending a message to our support team
When you contact us, whether by telephone, through our Lensmen website, or by e-mail, we collect the data you have given to us in order to reply with the information you need.
00353 01 819 7738 | 00353 087 258 4388 | info@lensmen.ie | ac
We record your request in our https://www.onepagecrm.com
We keep personally identifiable information associated with your message, such as your name and email address to be able to track our communications with you to provide a high-quality service.
9. Complaining
When we receive a complaint, Susan Kennedy will call or email you back to resolve any problem or complaint.
00353 01 819 7738 | 00353 087 258 4388 | info@lensmen.ie | ac
We record all the information you have given us on our https://www.onepagecrm.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter of our sole discretion as to whether we give information and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
Use of information we collect through automated systems when you visit our websites
https://lensmen.photoshelter.
10. Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose and prevent or limit their use.
Our https://www.lensmen.ie
When you first visit our websites, https://lensmen.
https://360virtualworld we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or prevent their use through your browser settings, you will not be able to use all the functionality of our website.
We use cookies in the following ways on our websites https://lensmen.
- to track how you use our website.
- to record whether you have seen specific messages we display on our website.
- to keep you signed on to our site.
- to record your answers to surveys and questionnaires on our site while you complete them.
- to record the conversation thread during a live chat with our support team.
11. Personal identifiers from your browsing activity https://lensmen.
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, Internet service provider, and IP address. We also record information about the software you use to browse our Lensmen’s websites, such as the type of computer or device and the screen resolution.
We use this information in the aggregate to assess the popularity of our website’s web pages and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data could be used to identify you personally, even if you are not signed in to our website.
12. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse our websites https://lensmen.
We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.
Disclosure and sharing of your information
13. Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up of your personal information from third parties whose services we use.
14. Credit reference
To assist in combating fraud, we share information with credit reference agencies regarding clients or customers who instruct their credit card issuer to cancel payment to us without first providing an acceptable reason and giving us the opportunity to refund their money.
15. Data may be processed outside the European Union
Our website is hosted in Ireland.
We may also occasionally use outsourced services in countries outside the European Union in other aspects of our business.
Accordingly, data obtained within Ireland or any other country could be processed outside the European Union.
We use the following safeguards with respect to data transferred outside the European Union:
- the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
- the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union.
- we comply with a code of conduct approved by a supervisory authority in the European Union.
- we are certified under an approved certification mechanism as provided for in the Act.
- both our organisation and the processor are public authorities between whom there are either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to the protection of your information
Access to your information
16. Access to your personal information
At any time, you may review or update personally identifiable information that we hold about you, by signing in to your account at our websites https://lensmen.
To obtain a copy of any information that is not provided on our website you may send us a request at info@lensmen.ie | accoun
After receiving the request, we will tell you when we expect to provide you with the information and whether we charge a fee for it.
17. Removal of your information
If you wish us to remove personally identifiable information from our website photographs, videos, or reviews, you may contact us at info@lensmen.ie | accou
This may limit the service we can provide to you.
18. Verification of your information
When we receive any request to access, edit or delete personally identifiable information, photographs, video, or reviews, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
19. Use of the site by children on our websites https://lensmen.
We do not sell products or provide services for purchase by children, nor do we market to children.
If you are under 18, you may use our Lensmen website only with consent from a parent or guardian
CHILDREN
SKP associates t/a Lensmen will not knowingly collect any personal data from children under the age of 16. If an individual under the age of 16 has provided any personal information on www.lensmen.ie or through any of its features. We will delete that information.
If any minors are on any Lensmen shoot, we will ask for their parent/guardian to sign a model release form. Lensmen is not responsible for the distribution of model release forms, the client must take this responsibility unless otherwise discussed in writing between the client and a member of management.
Data Protection – Privacy Policy
Data protection is of a particularly high priority for the management of SKP associates t/a Lensmen. The use of the Internet pages of SKP associates t/a Lensmen is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to SKP associates t/a Lensmen. By means of this data protection declaration, our enterprise would like to inform the general public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.
As the controller, SKP associates t/a Lensmen has implemented numerous technical and organisational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
- Definitions
The data protection declaration of SKP associates t/a Lensmen is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:
- a) Personal data
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.
- b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
- c) Processing
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
- e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
- f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
- h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
- Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
SKP associates t/a Lensmen
- Subscription to our newsletters
On the website of SKP associates t/a Lensmen, www.lensmen.ie, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.
SKP associates t/a Lensmen informs its customers and business partners regularly by means of a newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter shipping. A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorised to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third parties. The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller, or to communicate this to the controller in a different way.
- Newsletter-Tracking
The newsletter of SKP associates t/a Lensmen contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, SKP associates t/a Lensmen may see if and when an e-mail was opened by a data subject, and which links in the e-mail were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimise the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller. The SKP associates t/a Lensmen automatically regards a withdrawal from the receipt of the newsletter as a revocation.
- Contact possibility via the website
The website of SKP associates t/a Lensmen contains information that enables a quick electronic contact to our enterprise, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. There is no transfer of this personal data to third parties.
- Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
- Rights of the data subject
- a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
- b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
the purposes of the processing; the categories of personal data concerned;
the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
- c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
- d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data have been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by SKP associates t/a Lensmen, he or she may, at any time, contact any employee of the controller. An employee of SKP associates t/a Lensmen shall promptly ensure that the erasure request is complied with immediately. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employee of SKP associates t/a Lensmen will arrange the necessary measures in individual cases.
- e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by SKP associates t/a Lensmen, he or she may at any time contact any employee of the controller. The employee of SKP associates t/a Lensmen will arrange the restriction of the processing.
- f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of SKP associates t/a Lensmen.
- g) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. SKP associates t/a Lensmen shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims. If SKP associates t/a Lensmen processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to SKP associates t/a Lensmen to the processing for direct marketing purposes, SKP associates t/a Lensmen will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by SKP associates t/a Lensmen for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, the data subject may contact any employee of SKP associates t/a Lensmen. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
- h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, SKP associates t/a Lensmen shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of SKP associates t/a Lensmen.
- i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of SKP associates t/a Lensmen.
- Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above-mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
- The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.
- Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.
- Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.
- Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
- Exceptions
Based on GDPR Art. 85, SKP associates t/a Lensmen may be involved with Processing of personal data solely for journalistic purposes or for the purposes of academic, artistic or literary expression where that data has been obtained for those purposes. SKP associates t/a Lensmen does not process highly sensitive personal information e.g. medical, ethnic, political or financial data under any circumstances.
17. Updates to our Data Protection Notice
We keep this notice under regular review and from time to time will look to amend it to reflect changes to the way in which we are processing personal information. The most recent version will always be available at request or via our website. We will inform you of material changes to the content of the Data Protection Notice through a notification posted on our website or other communication channels.
- Contacting the Data Protection Commissioner (DPC)
The Data Protection Commission can be contacted in two ways:
Option 1
Post: Data Protection Commission (DPC), Canal House, Station House, Portarlington, Co. Louth.
Telephone: +353 (0) 57 8684800
Telephone: +353 (0) 76 1104800
Lo-Call Number: 1890 252 231
E-mail: info@dataprotection.ie
Option 2
Data Commissioners Office,
21 Fitzwilliam Square South,
Dublin 2.
Tel No: +353 578684800
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