WIND-OF-CHANGE'S PERSONAL DATA PROTECTION NOTICE
Wind of Change Total Wellbeing Solutions Ltd Trading as Empeal ("we", "us" or "our") is committed to protecting and respecting your privacy. This Data Protection Notice tells you about your privacy rights and sets out how we, as a Controller, collect, use, process and disclose your personal data relating to your interactions with us. This Data Protection Notice should be read in conjunction with our Cookie-Policy. For personal data that are collected in connection with grant applications, please see our GDPR note.
Information we may collect from you
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect and process any type of personal data you provide to us in the course of your interactions with us. You may have provided some of your personal data directly to us such as when you visited our website by volunteering personal data when subscribing to email alerts or by using our online feedback or other forms.
If you do not provide us with your personal data we may not be able to provide you with our services or respond to any questions or requests you submit to us via our website. We will tell you when we ask for personal data which is a contractual requirement or is needed to perform our functions or to comply with our legal obligations.
How we use personal data we collect
We will only use your personal data for the purposes and legal bases set out in the table below.
| Purpose(s) for Processing | Legal Basis for Processing |
To manage our relationship with you which may include:
To optimize your experience on our website, or to serve you specific content that is relevant to you
To process job applications
Retention of your personal data
We will store your personal data only for as long as necessary for the purpose(s) for which it was obtained. The criteria used to determine our retention periods include (i) the length of time we have an ongoing relationship and/or provide our services; (ii) whether there is a legal requirement to which we are subject; and (iii) whether the retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). Please contact us if you wish to obtain further information concerning our retention periods (see Contact Us below).
Disclosure of your personal data
WoC retains your personal data to deliver service to you individually and/or together with the wellness improvement group you belong to. Your individual data is not disclosed or presented to the group and/or other officers of your organization. This data, however, may be used analysis of relevant trends and patterns which could be beneficial to the legitimate business interests for WoC or our client companies. In specific conditions, WoC may be obliged to disclose personal information, and the conditions are mentioned below:
We may disclose your personal data to third parties who provide a service to us or in the event of changes to the Industrial Development legislative framework, which may impact upon WoC, or in the event of any future mergers/ dissolutions of WoC and/or other related organization, in which case we may disclose your personal data to the applicable successor entity of WoC or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or where necessary for our legitimate business interests to protect the rights, property, or safety of WoC, our client companies, or others or for the purposes of fraud protection, identification of potentially politically-important person and credit risk reduction. Such disclosure may, as appropriate, include exchanging information with other organizations, companies, auditors, Government Departments, Institutes of Technologies, recruiters, Semi State Agencies, universities, and public bodies, where any such body provides a service to Enterprise Ireland and we are satisfied that it complies with the GDPR requirements.
Links to other sites
Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.
You have several rights in relation to your personal data under applicable privacy and data protection law, which may be subject to certain limitations and restrictions. We will respond to any valid requests within one month, unless it is particularly complicated or you have made repeated requests in which case we will respond, at the latest, within three months. We will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. You will not be charged a fee to exercise any of your rights unless your request is clearly unfounded, repetitive or excessive, in which case we will charge a reasonable fee in the circumstances or refuse to act on the request.
If you wish to exercise any of these rights, please contact us. We may request proof of identification to verify your request.
| Your Right | What this Means |
| Right to withdraw consent | If we are processing your personal data on the legal basis of consent, you are entitled to withdraw your consent at any time (see Contact Us). However, the withdrawal of your consent will not invalidate any processing we carried out prior to your withdrawal and based on your consent. |
| Right of Access | You can request a copy of the personal data we hold about you. |
| Right to Rectification | You have the right to request that we correct any inaccuracies in the personal data we hold about you and complete any personal data where this is incomplete. |
| Right to Erasure ('Right to be Forgotten') | You have the right to request that your personal data be deleted in certain circumstances including:
However, this right does not apply where, for example, the processing is necessary:
| Right to Restriction of Processing | You can ask that we restrict your personal data (i.e., keep but not use) where:
We can continue to use your personal data:
| Right to Data Portability | Where you have provided personal data to us, you have a right to receive such personal data back in a structured, commonly used, and machine-readable format, and to have those data transmitted to a third-party data controller without hindrance but in each case only where:
| Right to Object | You have a right to object to the processing of your personal data in those cases where we are processing your personal data in reliance on our legitimate interests, for the performance of a task carried out in business interest or in the exercise of our official authority. In such a case we will stop processing your personal data unless we can demonstrate compelling legitimate grounds which override your interests and you have a right to request information on the balancing test we have carried out. You also have the right to object where we are processing your personal data for direct marketing purposes. |
| Right to Complain | You have the right to lodge a complaint with the Data Protection Authority, place of work, or place of an alleged infringement if you consider that the processing of your personal data infringes the GDPR. |
Security and where we store your personal data
We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We have implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organization. We will continue to revise policies and implement additional security features as new technologies become available. Where we have given you a password which enables you to access certain parts of our website, you are responsible for keeping that password confidential. We ask you not to share your password with anyone.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website. Any transmission of personal data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorized access or disclosure.
Changes to this Data Protection Notice
We reserve the right to change this Data Protection Notice from time to time at our sole discretion. If we make any changes, we will post those changes here and update the "Last Updated" date at the bottom of this Data Protection Notice. However, if we make material changes to this Data Protection Notice we will notify you by means of a prominent notice on the website prior to the change becoming effective. Please review the Data Protection Notice whenever you access or use this website.
Contact us – please view the contact us page on the application or website https://empeal.com