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Our Privacy Policy

Effective July 2024

SeaChange takes privacy and the protection of client data very seriously and commits to upholding individual rights regarding personal information as set out in the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. These privacy notices underscore our commitment to protect your personal data as.

Changes

Our Privacy Policy will always indicate the date when it was last changed. We encourage you to visit this page regularly to be aware of our current terms.

We may modify or supplement this Privacy Policy from time to time for any reason.

If we make any material changes to this Privacy Policy, we will post the updated Privacy Policy here, along with its effective date, to notify users as required by applicable law. You should review this page regularly to look for changes in this Website Privacy Policy.

Your continued use of this Website after we have posted changes to this Privacy Policy on this page with a new effective date will indicate that you agree to be bound by such changes.

Security

We seek to use reasonable technical, organizational, and administrative measures to protect data collected through this Website against unauthorized or unlawful processing and against accidental loss, destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody. However, because no security system can be 100% effective, we cannot guarantee the security of any information we may have collected from or about our users.

When the circumstances require, we use encryption technology (data scrambling) and authentication tools to protect information that you may provide through our Website. In addition, our employees are instructed that such information is to be used only in accordance with the principles of this Website Privacy Policy, or other information security policies and procedures we may adopt from time to time, and the laws applicable to each specific business.

We will not ask you for any information such as your social security number, a bank or credit card account number, through the Website. If you need to send us confidential information and are concerned about the security of the Website, then you should consider sending it via another secure connection or method.

If you believe that your interaction with our Website is no longer secure, please immediately notify us of the problem in accordance with the “How to Contact Us” section below.

Information We Collect

Information Collected Directly

  • Preferences and settings: time zone, language, and character size
  • Identifiers: computer IP address; unique mobile device identifier
  • Technical information: type of device, operating system, or platform (Mac, Windows), browser information (type, version)
  • Connection: Internet provider or mobile carrier name, connection speed and connection type; Internet service provider (ISP)
  • URL of the last Web page visited before visiting our Service; exit page.
  • Information about your use of the website: data stamp, pages viewed, time spent on a page, click through, clickstream data, queries made, search results selected, history, comments made.
  • Location: general geographic location

Information You Provide to Us

We collect personal data about you for several reasons. For example, we need your contact information to reach you, your details to set you up in our systems, and the necessary information for our Accounts department to process transactions. This helps us provide you with the best customer service and experience. The types of personal data we collect may include.

  • Contact Information: Name, employer’s address, email address, Contact numbers (landline & mobile), job title.
  • Financial Accounts Details: Business bank account details, including account number, sort code, IBAN, currency reference as relevant; VAT exemption status; contact details for your Accounts department.
  • Information you provide us about others or others provide us about you: If you give us information about someone else, e.g. the work contact number for a colleague, or someone else gives us similar information about you, we will add it to or update any personal information we already hold and will use it in the ways described in this Data Privacy Policy.
  • Information which you have consented to us using.
  • Your contact details to allow us to inform you of new products or services we believe you may be interested in.
  • Sensitive Data
  • Where you have requested our Personality Profiling Service, an individual report is created based on results generated by the online assessment completed by an individual. Where you elect to upload same, identifiable images are stored relating to your site or your employees.
  • Other Personal Information

Reports and results generated by delivery of our services and attributed to client businesses, e.g. Audit reports, Risk Assessment reports, Gaps Analysis reports.

Reports and results generated by your activity on our Client Portal or Applications, e.g. JSA© eLearning, CAYGO© Digital.

How we Collect Information

As you use our services, make enquiries, and engage with us, information is gathered about you as follows:

  • When you contact us with an enquiry or request; this is logged to ensure it is followed through.
  • When you enter into a contract with us for specified service(s) and deliverable(s) and you are set up as a client on our internal operating systems and our Client Portal.
  • When you provide us with information pertaining to your organisation, whether in soft or hard copy, for the purposes of supporting the work we are carrying out on your behalf, and this may contain PII.
  • When you or others give us information or updates verbally or in writing, e.g. new contact details for a manager.
  • When you use our Portal to upload information, e.g. progress reports.
  • When you use any of our digital solutions, e.g. our CAYGO Digital device, where your usage is logged on our cloud application.
  • When we deliver contracted services and prepare relevant reports for you.
  • When we carry out our Personality Profiling Service for the purposes of recruitment of staff/ professional development of staff/ company profiling:

Use of your Information

  • We use your information to deliver our products and services and to fulfil our contract with you.
  • Manage your account daily.
  • Process invoicing and payments.
  • Contact you by phone, email, text message, WhatsApp or post but not in a way contrary to your instructions to us or contrary to law.
  • Contact you for feedback regarding service/ quality assurance purposes.
  • Contact you to support you as you roll out our risk management systems and solutions in your place of work.
  • Manage and respond to any complaint or query.
  • Compile and process your information for a range of service purposes, e.g. risk assessment, audit, survey, analysis, personality profiling, coaching, as per your contract with us.
  • Comply with our own legal and regulatory obligations, e.g. the preparation and submission of annual financial accounts.
  • Use your data in anonymised (non-PII) format as generated by e.g. CAYGO© Digital use and/ or Portal use and stored on the server, for the purposes of research and development.
  • Share your data with third parties as per your agreement with us and where we have your permission, e.g. where your contract with us is part of an insurance scheme and your insurer requests your audit report.

Sharing and Disclosure of Information

We share user information with the following entities or in the following circumstances:

  • Service providers – We share information with our service providers, suppliers, subcontractors and similar third parties who provide services to us or act on our behalf so that they can assist us with the provision, upkeep and maintenance of the Website and other related activities, such as the organization of conferences and webinars, email delivery or auditing, or with the selection of applicants to job openings at our company. We require these service providers to refrain from using or sharing with others, for other purposes than as directed by us, the information that we provide to them, or that they collect directly from our users.
  • Analytics – We use automated tools and applications, such as Google Analytics, to evaluate the use of our Website. These third-party services use cookies and other tracking technologies to perform their services.
  • Affiliates – We share information with entities that are under common ownership or control of our parent company (“affiliates”) for the purposes described in the Privacy Policy. Subject to local requirements, this information may be used to provide legal and related services offered by our affiliates and for the purposes described in this Privacy Policy.
  • Sale, merger, and corporate reorganization – We may transfer users’ information to a third party in case of the reorganization, sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, asset, or stocks, including in the event of corporate restructuring of our company or its affiliated entities.
  • Social networking – Your information may be disclosed to anyone to whom you send a message through this Website (e.g., when you forward an article). You may disclose it when you post or transmit information or material through our social networking buttons (e.g., a Facebook button). Please note that any information that you post or disclose through these social networking services may be available to us, or to other users of that service or the public. We urge you to be careful when using these features.

Cookies and Web Beacons

We use cookies to recognize your device and browser. The next time you visit our Website, we may use information stored in your cookie file to facilitate your use of our Website. For example, we may use your cookie file to store a password so that you do not have to input it every time you move to a different section of a password-protected portion of our Website. A cookie does not tell us your individual identity unless you have chosen to provide it to us.

Most cookies expire after a defined period, or you can delete your cookie file at any time you choose. In addition, you can set your browser to notify you when you receive a cookie so that you can decide whether to accept or reject it. Please note that these actions apply to a specific browser.

You can always choose whether to accept cookies by changing the settings on your browser. Most browsers contain information on how to control or delete cookies. These settings will typically be found in the “Options” or “Preferences” menu of a browser. You may wish to refer to http://www.allaboutcookies.org/manage-cookies/. Further, you can use the cookie icon in the lower left-hand side of the screen to change your cookie preferences with regards to our site at any time.

If you choose to delete or disable cookies, your experience at our Website may be diminished and some features may not work as they were intended. Some cookies cannot be turned off using the cookie preferences menu because they are essential to the function of the Website.

We use Web beacons. A Web beacon can help us track your activity on the Website, such as which page you are viewing or how long you are staying on that page. Some technologies will notify you of the presence of Web beacons, but browsers typically do not notify you of them.

Third Parties’ Cookies and Beacons

Third parties’ cookies and beacons are used for functionality, performance, and analytic purposes. These cookies and beacons collect and store automatically information about a user’s computer or mobile device, and the use of the Service. This information is used in aggregate form only.

The practices of these third parties are subject to the third parties’ privacy policies, some of which we have no control over. We encourage you to read their privacy policies.

Data Retention

We will hold your information for as long as it is needed for the service, or for as long as we are permitted to do so by the applicable regulations. Our business is governed by the General Data protection Regulation (GDPR) and this data will benefit from the protections afforded by the GDPR. This means that data we no longer deem necessary will be regularly deleted in line with our regulatory requirements.

Your Rights

Each user has the right to review, change, suppress or erase personal information that can reasonably be linked to, and that we have collected from that user. You may exercise this right by contacting us as indicated in the “How to Contact Us” section. For your protection, we may need to verify your identity before implementing your request. We will try to implement your request as soon as reasonably practicable, but in any event, we will carry out this request within 30 days. If we cannot fully comply with your request within 30 days, we will notify you to inform you of this, provide our reasons and inform you of what other rights you have available to you.

However, please note that we reserve the right to refuse to act on a request that is manifestly unfounded or excessive (e.g., because it is repetitive) and/or to charge a fee that takes into account the administrative costs for providing the information or the communication or taking the action requested. If you have a question, comment, or request, please contact us as explained in the “How to Contact Us” section below.

  1. provide a copy of the personal information we hold (once requested, we have a maximum of one month to give an individual such information).
  2. Provide you with details of the collection and use of the data they collect about you.
  3. rectify information if it is inaccurate or incomplete.
  4. delete or remove your personal data where there is no compelling reason for its continued processing.
  5. suppress processing of your personal data, when processing is restricted, we are permitted to store the personal data, but not carry out further processes. We will retain sufficient information about the individual to ensure that the restriction is respected in future.
  6. object to certain uses of your personal information.
  7. under specific conditions to provide personal information to you or another designated controller in a commonly acceptable and easily readable digital format. However, this is applicable only when the processing of said information relies on either (i) your consent or (ii) the execution of a contract to which you are a party.
  8. include you in decisions made entirely by automated processes i.e., without any human involvement in which case you have a right to object to such processing.

Additional Rights

Applicable laws may give you additional rights that are not described in this Website Privacy Policy. Which may include:

  1. withdraw any permission you may have previously provided; and
  2. complain to the Information Commissioner’s Office at any time if you are not satisfied with our use of such information (please see “registering a complaint” for more information).

How To Contact Us.

To write to us regarding this Privacy Policy and our personal information handling practices, please Email: dataprivacy@nfpireland.ie

Address: Monread Leisure & Commercial Centre, Unit 4 Monread Ave, Monread South, Naas, Co. Kildare, W91 YWX3, Ireland

Regarding email communications: note that email communications are not always secure. Thus, please do not include any confidential or sensitive information in any emails. We subscribe to some secure data transfer services. Please ask us about this if you would like to transfer data to us securely.

Regarding postal communications be aware that it may take us longer to route and process your request if it is made on paper than we would take with an electronic message.

Registering a complaint

If you have a complaint about the way your personal data is processed, we ask that you reach out to us about this in the first instance.

In addition to reaching out to us, you also have the right to lodge a complaint with the supervisory authority for data protection if you are unhappy with how your personal data is being processed. In the UK, the relevant supervisory authority is:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland

Tel: (01) 765 01 00 or 1800 437 737 (calls are charged at local rates)