1. CONTROLLER

The Controller pursuant to data protection law is:
HVSM Limited
Unit 3/4 Ashcourt, Ashbourne Industrial Estate,
Ashbourne, Co Meath
A84 FF97
Call: +353 (0) 1 835 0177
Email: info@hvsm.ie | Fax: +353 (0) 1 835 0382

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2. DATA PROTECTION OFFICER

Our Data Protection Officer will be happy to assist you with any concerns regarding data protection.
Michelle Slevin – Data Protection Officer
HVSM Limited
Unit 3/4 Ashcourt, Ashbourne Industrial Estate,
Ashbourne, Co Meath
A84 FF97
Call: +353 (0) 1 835 0177
Email: info@hvsm.ie | Fax: +353 (0) 1 835 0382

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3. PERSONAL DATA

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is a data subject who can be identified, directly or indirectly, in particular by reference to an identifier. Identifiers can include, for example, a name, an identification number, location data, an online identifier, an IP address or one or more factors specific to the physical, physiological, genetic, psychological , economic, cultural or social identity of that natural person (hereafter referred to jointly as “data”).

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4. PURPOSES AND LEGAL BASES OF DATA PROCESSING

4.1 GENERAL

We process your data in accordance with the provisions of the General Data Protection Regulation, the Irish Data Protection Acts and other applicable data protection provisions. Data are processed only insofar as is necessary and permitted under data protection law, for example to enable a visit to the website, to fulfil contractual purposes or to the extent that you consent to data processing.

4.2 USE OF THE WEBSITE FOR INFORMATION PURPOSES

You can visit our website without disclosing any personal details. If you are using our website solely to obtain information, we do not collect any data from you. The exception to this is data transmitted by your browser to enable you to visit the website and information transmitted to us by cookies used.

4.2.1 TECHNICAL FUNCTIONS OF THE WEBSITE

4.2.1.1 SCOPE OF PROCESSING AND PURPOSE

From a technical perspective, in order for us to make this website available, we need to process certain automatically transmitted information about you, so that your browser will display our website and you are able to use the website. This information is automatically recorded each time our website is accessed, and stored in our server log files. This information relates to the computer system of the computer used to access the website.

4.2.1.2 LEGAL BASIS

We process your data in order to make the technical functions of our website available to you on the following legal bases:

• For the performance of a contract or in order to take steps prior to entering into a contract pursuant to Art. 6, para. 1(b) GDPR, if you visit our website to find out about the products we offer or our events or our on our online shop; and
• For the purposes of our legitimate interests pursuant to Art. 6, para. 1(f) GDPR, in order to enable us to make the website technically available to you. It is our legitimate interest to provide you an attractive, user-friendly, technically functioning website of our Homepage.

4.2.2 STATISTICAL ANALYSIS OF THE USE OF THE WEBSITE AND INCREASE OF COVERAGE

4.2.2.1 SCOPE OF PROCESSING AND PURPOSE

For the purpose of statistical analysis of the use of our website, we use Google Analytics and therefore cookies that allow analysis of your surfing habits. This enables us to improve the quality of our website and its content. We learn how the website is used and can continually optimise our service.
The information obtained from the statistical analysis of our website will not be associated with your other data that we obtain on the website.

4.2.2.2 GOOGLE ANALYTICS

This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies”: text files which are stored on your computer and permit analysis of your use of the website. The information about your use of this website generated by the cookie is usually transferred to and stored on a Google server in the USA. However, if IP masking is enabled on this website, Google will first truncate your IP address in member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to and truncated on a Google server in the USA. Google will use this information on behalf of the operator of this website to analyse your use of the website, compile reports on website activities and provide the website operator with other services relating to website use and Internet use. The IP address transferred by your browser for the purposes of Google Analytics will not be associated with other data held by Google.
This website uses Google Analytics with the extension “_anonymize IP()”. This truncates IP addresses before further processing, making it impossible to link them to a specific individual.
You may prevent the storage of cookies by altering the settings in your browser software; however, please be aware that, if you do this, you may not be able to make full use of all the functions of this website.
You may prevent Google from collecting and processing the data generated by the cookie and relating to your use of the website (including your IP address) by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en-GB
As an alternative to the browser plugin, you can click on this link to prevent the collection of your data by Google Analytics on this website in future. Doing this will place an opt-out cookie on your device. If you delete your cookies, you will have to click on the link again.
Further information on terms of use and data protection by/at Google Analytics can be found at https://www.google.com/analytics/terms/gb.html .

4.2.2.3 FACEBOOK, LINKEDIN AND TWITTER SOCIAL PLUGIN

Our website contains social plugins for Facebook, LinkedIn and Twitter. The bookmarks are indicated by the respective logo. To enhance the protection of your data when visiting our website, the respective
INTERNAL USE ONLY
social plugin is not fully incorporated in the site; instead, an HTML link is used. This ensures that, when you access our website, no link is created to the servers of Facebook, LinkedIn or Twitter and your data are not transmitted to them. If you click on the Facebook, LinkedIn or Twitter button, a new window will open in your browser and open the website of Facebook, LinkedIn or Twitter, on which (after entering your login details, if necessary) you can click the like or share button, for example.
If you are already logged in to Facebook, LinkedIn or Twitter, the respective social media platform will be notified that you have accessed the corresponding page on our website and the respective platform may trace your visit to your account. Information about the purpose and scope of data collection and the further processing and use of the data by Facebook, LinkedIn or Twitter, as well as your rights in this regard and the settings you can choose to protect your privacy, can be found in the privacy policies of Facebook, LinkedIn and Twitter at:

• http://www.facebook.com/policy.php
• https://www.linkedin.com/legal/privacy-policy
• http://www.twitter.com/privacy

If you do not want Facebook, LinkedIn or Twitter to gather data about you via our website, before visiting our website you must log out of these sites and delete any cookies they have placed on your PC.

4.2.2.4 LEGAL BASIS

We process your personal data for the purposes of statistical analysis of the use of our website on the following legal bases:

• for the purposes of our legitimate interests pursuant to Art. 6, para. 1(f) GDPR, in conjunction with Section 15, para. 3 TMG; we have a legitimate interest in designing our website to suit users’ needs.
• If you have consented to the processing of data using cookies for analysis purposes, in accordance with Art. 6, para. 1(a) GDPR.

4.2.3 ENQUIRIES

4.2.3.1 SCOPE OF PROCESSING AND PURPOSE

To enable us to process and respond to your enquiries to us, e.g. via the contact form or to our email address, we will process the data you provide to us. The data may include your name, your age and your email address and any additional information you send to us in your communication.

4.2.3.2 LEGAL BASIS

We process your data in order to respond to your enquiries on the following legal basis:

• If you contact us in connection with a contract to which you are a party, or in order to take steps prior to entering into a contract, the legal basis is Art. 6, para. 1(b) GDPR.
• For the purposes of pursuing our legitimate interests pursuant to Art. 6, para. 1(f) GDPR; we have a legitimate interest in responding appropriately to customer enquiries.

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5. LINKS

Some sections of our website contain links to the websites of third-party providers. These websites are subject to their own privacy policies. We are not responsible for their operation, including the handling of data by third-party providers. If you send information to or via such third-party websites, you should check their privacy statements before sending them information that can be traced back to you as an individual.

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6. RECIPIENTS OF THE DATA

Your data will only be shared with the internal departments or organisational units and other companies affiliated with us under company law which have need of it, in order to fulfil our contractual and legal obligations or to the extent that we require the data in order to process and implement our legitimate interests.
Your data will be passed on to external recipients in order to process contracts if we are obliged by legal requirements to:

• provide information,
• report or share data or you have given us your consent to your data being shared with third parties, or
• to external service providers who are acting as processors on our behalf or who perform functions for us (e.g. IT service providers, data centres, courier services etc.).

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7. TRANSFERS TO THIRD COUNTRIES

As part of the use of Google Analytics, we transfer your truncated IP address to the USA. The data transfer is based on Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequacy of the protection provided by the EU-U.S. Privacy Shield.
We do not otherwise transfer your personal data to countries outside the EU or the EEA or to international organisations.

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8. DURATION OF STORAGE

8.1 USE OF THE WEBSITE FOR INFORMATION PURPOSES

When our website is used purely to obtain information, we only store your data for the duration of your visit to our website. Once you have left our website, your data is immediately deleted.

8.2 ACTIVE USE OF THE WEBSITE

When you make active use of our website, we store your data for as long as is necessary for example, to provide the respective service or respond to your enquiry. This includes the initiation of a contract (pre- contractual legal relationship) and the performance of a contract. Provided you have given your consent, we will store your data until consent is withdrawn.
We will also store your personal data until any legal claims arising from the relationship with you have become time-barred, in order that they can be used as evidence if required. The limitation period is usually between 12 and 36 months, but may be up to 30 years.
When the limitation period takes effect, we will delete your personal data unless there is a legal retention requirement under Irish law.

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9. ACTIVE USE OF THE WEBSITE

You may assert your rights listed below against the entity named in Section 1 at any time.

9.1 RIGHT OF ACCESS

You are entitled, pursuant to Art. 15 GDPR, to obtain following information from us at any time and free of charge: your data we process, the purposes of the processing, the categories of recipients, the envisaged period for which the data will be stored or, in the case of transfer to a third country, the appropriate safeguards. You are also entitled to obtain a copy of your data.

9.2 RIGHT TO RECTIFICATION, ERASURE, RESTRICTION OF PROCESSING

Should the data we process of you be inaccurate or incomplete or if their processing is unlawful, you can request that we rectify, supplement or restrict the processing of your data or erase the data to the extent permitted by law, Art. 16, 17 and 18 GDPR.
There is no right to erasure if the processing of the personal data is necessary (i) for the exercise of the right of freedom of expression and information, (ii) for compliance with a legal obligation to which we are subject (e.g. statutory retention periods) or (iii) for the establishment, exercise or defence of legal claims.

9.3 RIGHT TO DATA PORTABILITY

If you have provided us with your data on the basis of your consent or as part of an existing contractual relationship with us, we will, at your request, make the data available to you in a structured, commonly used and machine-readable format or, where technically feasible, will transmit them to a third party named by you.

9.4 RIGHT TO OBJECT

If we process your data in order to pursue a legitimate interest, you may object to this processing on grounds relating to your particular situation, Art. 21 GDPR. The right to object may be exercised only within the confines of Art. 21 GDPR. Moreover, our interests may override the cessation of processing, meaning that, despite your objection, we are entitled to process your personal data.

9.5 RIGHT TO LODGE A COMPLAINT

You are welcome to contact our Data Protection Officer named in Section 2 with questions, suggestions and criticisms.
You are also entitled, subject to Art. 77 GDPR, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. The right to lodge a complaint applies regardless of any other administrative or judicial remedies.
The supervisory authority responsible for us is:
Office of the Data Protection Commissioner.
Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland Phone +353 (0761) 104 800
LoCall 1890 25 22 31
Fax +353 57 868 4757
Email: info@dataprotection.ie

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10. OBLIGATION TO PROVIDE DATA

In principle, you are under no obligation to provide us with data. However, if you do not provide us with data, we cannot make our website available to you without processing your application.

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11. OBLIGATION TO PROVIDE DATACONSENT/RIGHTS OF WITHDRAWAL

In the event that you give or have given us your consent to the collection, processing or use of your data, you can withdraw this consent at any time by notifying the entity named in Section 1. An email is sufficient.
You also have the right, on grounds relating to your particular situation, to object to the processing of data concerning you on the basis of Art. 6, para. 1(e) (performance of a task carried out in the public interest) or Art. 6, para. 1(f) GDPR (legitimate interests pursued by the controller); the same applies to profiling pursuant to those provisions. In this event, we will no longer process the data concerning you, unless we can demonstrate compelling and legitimate grounds for the processing that override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.
If the data concerning you are processed in order to engage in direct marketing, you have the right to object at any time to the processing of this data for the purposes of such marketing. If you object to the processing for direct marketing purposes, the data will no longer be processed for those purposes.

Please send notification of withdrawal to the address indicated in Section 1.

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12. AMENDMENTS

We reserve the right to amend this privacy statement at any time. Any changes will be announced by the publication of the revised privacy statement on our website. Unless specified to the contrary, such amendments take effect immediately. Please therefore regularly check this privacy statement to make sure you are aware of the latest version.
Last updated in June 2023