Personal Data Protection Notice
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 register you as a new website user;
To notify you about changes to our Data Protection Notice;
To ask you to take a Questionnaire.
The processing is necessary to perform a contract or enter into a contract with you
The processing is necessary to support our legitimate interests in managing our business (to keep our records updated and to study how website users use our services) provided such interests are not overridden by your interests and rights
To manage our relationship with you which may include:
To facilitate providing wellness programs and online welbeing resources;
To facilitate achieve your personal goals and/or missions through our Irish and overseas expert network;
To participate in health assessment test to enable us design the solution which is right for you;
To work with our technology;
To share information with relevant groups which you are part of.;
The processing is necessary for the performance of a task carried out in the best interest of WoC and your wellbeing as specified by you and authority vested in us
To carry out direct marketing (we use the email address you have used during registration);
To provide you, or permit selected third parties to provide you, with information about events hosted or co-sponsored by us or about events we feel may interest you;
To send you email alerts and newsletters that you have opted-in to receive by filling in our online forms or contacting us by email or by other means;
To contact clients regarding business opportunities.
To contact you regarding the services provided by us.
Where you have given consent to the processing of your personal data for direct marketing – which you may withdraw at any time
Where your consent is not required and you have not objected, the use of the data is necessary for our legitimate interest in managing our business including legal, personnel, administrative and management purposes provided our interests are not overridden by your interests.
To optimise your experience on our website, or to serve you specific content that is relevant to you
The processing is necessary to support our legitimate interests in managing our business (to define types of client companies for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) provided such interests are not overridden by your interests and rights
To process job applications
The processing is necessary to perform a contract or enter into a contract with you
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 retain 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 organisations, 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.
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:
The personal data are no longer needed for the purpose for which they were collected;
You withdraw your consent (where the processing was based on consent);
You object to the processing and there are no overriding legitimate grounds justifying us processing the personal data (see Right to Object below);
The personal data have been unlawfully processed; or
To comply with a legal obligation.
However, this right does not apply where, for example, the processing is necessary:
To comply with a legal obligation; or
For the establishment, exercise or defence of legal claims.
Right to Restriction of Processing
You can ask that we restrict your personal data (i.e., keep but not use) where:
The accuracy of the personal data is contested;
The processing is unlawful but you do not want it erased;
We no longer need the personal data but you require it for the establishment, exercise or defence of legal claims; or
You have objected to the processing and verification as to our overriding legitimate grounds is pending.
We can continue to use your personal data:
Where we have your consent to do so;
For the establishment, exercise or defence of legal claims;
To protect the rights of another; or
For reasons of important public interest.
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:
The processing is based on your consent or on the performance of a contract with you.
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 unauthorised 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 organisation. 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 unauthorised 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 contact us page on the application or website https://empeal.com