Personal Data Protection Policy

Last updated: May 6th 2021

The policy detailed hereafter applies to the processing of personal data carried out by:

Aereco Ireland Limited, registered in the Republic of Ireland as Aereco Limited (452660).

Address : Unit 1, Cherrywood Business Park, Courtstown, Little Island T45 XP70, Co. Cork – Co. Cork. Email : [email protected]. Telephone : + 353 (0)21 429 6030. Our website www.aereco.ie.  

Aereco Limited is part of the Aereco group of companies headquartered in AERECO S.A., 62 rue de Lamirault, 77090 – Collégien, France.

References to “We”, “Us” the “Company” and “Aereco” shall apply to Aereco Limited, the Irish group entity that is processing your data.

Introduction

In order to provide our services and manage our business, we need to process Personal Data. We are committed to protecting the rights and personal data of individuals in accordance with data protection legislation including the General Data Protection Regulation in Europe (the “GDPR”).

This Personal Data Protection Policy describes our approach to data protection and sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be used by us where we are controllers of that personal data for the purposes of the GDPR.  Please read this Personal Data Protection Policy carefully to understand our views and practices regarding the Personal Data we collect and how we will treat it.

The protection of your Personal Data is important to us and we are committed to protecting and safeguarding your rights.

“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.

Who this personal Data Protection Policy applies to?

This Personal Data Protection Policy provides specific information relating to the data subjects whose Personal Data we process:

• business contact details including those of our customers, suppliers, partners, shareholders, and business prospects “Business Contacts” ;
• users/visitors to our Website “Website Users” ; and
• prospective employees /those applying for jobs at Aereco “Candidates” ; and
• members of the public who pass by and/or visit Aereco offices and whose images are captured on CCTV “Visitors”.

Categories of personal data

We process the following categories of Personal Data.  For each category we have included an example of the type of Personal Data that maybe part of that category:

Our legal basis for processing personal data

All processing of Personal Data must be lawful. Processing will only be lawful if we have a legal basis for processing. When the Company processes Personal Data, it is generally on one of the following legal basis :

Contract

We will process Personal Data where necessary to perform our obligations relating to or in accordance with any contract that we may have with you or to take steps at your request prior to entering into that contract.

For instance, when you register for one of our services you will enter a contract with us for the delivery of that service.

Legitimate Interest

At times we will need to process your Personal Data to pursue our legitimate business interests, for example to provide information to you, for administrative purposes, to collect debts owing to us, to operate, evaluate, maintain, develop, and improve our websites and services or to maintain their security and protect intellectual property rights.

We will not process your Personal Data on a legitimate interest basis where the impact of the processing on your interests or fundamental rights and freedoms outweighs our legitimate interests.

Where we carry out marketing activities based on legitimate interests you will always have an option to opt-out of receiving marketing communications.

If do not want us to process your Personal Data on the basis of our legitimate interests, contact us at  [email protected] and we will review our processing activities.

Consent

For certain processing activities we may rely on your consent. For example, we will get your consent if you are not an existing user of any of our services and you sign-up to receive marketing newsletters from us.

Where we are unable to collect consent for a particular processing activity, we will only process the Personal Data if we have another lawful basis for doing so.

You can withdraw consent provided by you at any time by contacting us at [email protected].

Legal Obligation

If we have a legal obligation to process personal data, such as the payment of taxes, we will process personal data on this legal ground.

Special Category Recruitment Data

When we process special category recruitment data such as your health data, we require your explicit consent to do so. We will explain the purpose for processing at the time we collect the data and provide you with suitable information to fully inform your consent.

Our processing activities

We use Personal Data to provide you with our services and to assist us in the operation of the company. Under data protection law, we must ensure that the purpose of processing is clear.

We have set out below the general purpose of processing, the categories of Personal Data processed and the related lawful basis for processing:

Sources of personal data

Business contact personal data

We collect Business Contact Personal Data from our business contacts including – suppliers, partners, consultants, shareholders, and business prospects.

We source Business Contact Personal Data in order to serve the business relationship. We will only ever source Personal Data that is necessary and in a way that would be generally expected.

We receive Personal Data about Business Contacts from a variety of sources, as follows :

• the Personal Data is often provided by the Business Contact as part of the business relationship ;
• the Personal Data may be collected from public sources ;
• the Personal Data may be collected indirectly from another person within the company of the Business Contact ;
• the Personal Data may be collected through our website ;
• the Personal Data may be collected indirectly from a website or from a third party.

Candidate personal data

We will only ever source Personal Data in a way that would be generally expected.

We receive Personal Data relating to Candidates from a variety of sources. The primary source is from Candidates directly. Examples of the sources of Personal Data of Candidates are as follows :

• the Candidate may send their CV to us with the intention of registering with us to be informed of potential job vacancies ;
• the Candidate may apply directly to a position advertised on our website ;
• the Candidates details may be provided by a member of staff or third party by way of referral ; and
• the Candidates details may be provided by a recruitment agency.

Website users personal data

We may collect Website User information from all visitors to our web site www.aereco.ie in order to improve our services and develop the Websites.

This includes :

• Logfiles of service interactions in order to manage our service delivery and progress users through the service offerings ;
• Logfiles of website activity collected for security purposes ;
• Cookies that track website visitors. For more details, please refer to our Cookie Notice.

Social media users personal data

We collect information from you when follow our social media accounts, like, comment or reshare a social media post or when you communicate with us via messaging apps on social media platforms.

Disclosure of personal data

In certain circumstances, we may disclose Personal Data to third parties as follows :

• to business partners and subcontractors for the performance of any contract relating to our services, including email, Skype, Communication Platforms, Customer Relationship Management system, web developers, payment processors, data aggregators, hosting service providers, external consultants, auditors, IT consultants and lawyers ;
• to any recruitment agency who is helping us to recruit Candidates ;
• to analytics and search engine providers that assist us in the improvement and optimisation of the Website ;
• to the HSE (or any health authority) to facilitate any pandemic contact tracing activity ;
• if we or substantially all of our company is merged with another company or acquired by a third party, in which case Personal Data held by us will be one of the transferred assets ;
• to other companies in the Aereco group of companies for the purposes of administration, marketing, recruitment, and provision of our services ;
• if we are under a duty to disclose or share Personal Data in order to comply with any legal obligation (including tax, audit, or other authorities), or in order to enforce or apply any contracts that we have ;
• to protect our rights, property, or safety, or that of our Candidates or Business Contacts or others. This may include exchanging Personal Data with other companies and organisations for the purpose of fraud protection. When we engage another organisation to perform services for us, we may provide them with information including Personal Data, in connection with the performance of those functions. We do not allow third parties to use Personal Data except for the purpose of providing these services.

Security measures

We will take all steps reasonably necessary to ensure that Personal Data is treated securely in accordance with this Personal Data Protection Policy and the relevant law.

In particular, we have put in place appropriate physical, technical, and organisational procedures to safeguard and secure the Personal Data we process.

Transfers outside the EEA

We will only transfer Personal Data outside the EEA if necessary and with appropriate safeguards in place.

Aereco may transfer limited Personal Data to be processed outside the EEA by our processors. In such cases we use processors who provide sufficient guarantees to ensure the security and protection of your Personal Data.

Cookies

Cookies are small text files placed on your computer or mobile device by websites that you visit, and they help us improve the products and services that we offer you. They are used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Cookies may allow a website to remember your activity over a period of time. Cookies are optional and you do not have to accept them.

Further information on the cookies we use on the website and the purpose behind their respective uses are set out in our Cookie Notice.

Third party websites

Our Websites may contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy settings, and these are not endorsed by us.  We do not accept any responsibility or liability for these third-party websites. Please undertake the appropriate due diligence before submitting any Personal Data to these websites.

Retention

We only keep your Personal Data as long as it is necessary for the purposes of processing it or to comply with legal or regulatory requirements.

In some circumstances it is not possible for us to specify in advance the period for which we will retain your Personal Data. In such cases we will determine the appropriate retention period based on balancing your rights against our legitimate business interests.  We may also retain certain Personal Data beyond the periods specified herein in some circumstances such as where required for the purposes of legal claims.

Our retention policy is as follows :

In certain cases, we may retain Personal Data for longer than specified here if required under relevant laws.

Your rights under the GDPR

You have rights under data protection law in relation to how Aereco uses your Personal Data. You may generally access your rights free of charge.

You can ask for access to the Personal Data we hold on you

You have the right to ask for all the Personal Data we have about you. When we receive a request from you in writing, we must give you access to all Personal Data we’ve recorded about you as well as details of the processing, the categories of Personal Data concerned and the recipients of the Personal Data.

We will provide the first copy of your Personal Data free of charge, but we may charge you a reasonable fee for any additional copies.

We cannot give you access to a copy of your Personal Data in some limited cases including where this might adversely affect the rights and freedoms of others.

You can ask to change Personal Data you think is inaccurate

You should let us know if you disagree with something included in your Personal Data.

We may not always be able to change or remove that information, but we’ll correct factual inaccuracies and may include your comments in the record to show that you disagree with it. 

You can ask to delete Personal Data (right to be forgotten)

In some circumstances you can ask for your Personal Data to be deleted, for example, where :

– your Personal Data is no longer needed for the reason that it was collected in the first place ;

– you have removed your consent for us to use your Personal Data (where there is no other lawful basis for us to use it) ;

– there is no lawful basis for the use of your Personal Data ;

– deleting the Personal Data is a legal requirement.

Where your Personal Data has been shared with others, we will do what we can to make sure those using your Personal Data comply with your request for erasure.

Please note that we cannot delete your Personal Data where :

– we are required to have it by law ;

– it is used for freedom of expression ;

– it is used for public health purposes ;

– it is used for scientific or historical research or statistical purposes where deleting the Personal Data would make it difficult or impossible to achieve the objectives of the processing ;

– it is necessary for legal claims.

You can ask us to limit what we use your Personal Data for

You have the right to ask us to restrict what we use your Personal Data for where :

– you have identified inaccurate information, and have told us of it ;

– where we have no legal reason to use that Personal Data, but you want us to restrict what we use it for rather than erase it altogether.

When Personal Data is restricted, it can’t be used other than to securely store the Personal Data and with your consent to handle legal claims and protect others, or where it’s for important public interests.

You can make a complaint

You have the right to lodge a complaint with the local supervisory authority for data protection in the EU member state where you usually reside, where you work or where you think an infringement of data protection law took place.

Amendments to this Personal Data Protection Policy

We will post any changes on our Website and when doing so will change the effective date at the top of this Personal Data Protection Policy.  Please make sure to check the date when you use our services to see if there have been any changes since you last used those services.

In some cases, we may provide you with additional notice of changes to this Personal Data Protection Policy, such as via email. We will always provide you with any notice in advance of the changes taking effect where we consider the changes to be material.

Our contact information

Please contact us if you have any questions about this Personal Data Protection Policy or Personal Data we hold about you :

• by email at: [email protected] ;
• or write to us at : Data Protection, Unit 1, Cherrywood Business Park, Courtstown, Little Island T45 XP70, Co. Cork.

Supervisory authority

The Data Protection Commission in Ireland may be contacted using the contact details below if you have any concerns or questions about the processing of your Personal Data.

IRELAND – CONTACT DETAILS

Online Form :    https://forms.dataprotection.ie/contact

Address :              21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland

Tel :                          +353 578 684 800 or +353 761 104 800