Data Protection Notice of Currency Media Limited (the “Company”)
Personal information is data that can be used to identify or contact a single person. You, the User, may be asked to provide your personal information anytime you are in contact with the Company (“Personal Data”). We will use your Personal Data to administer your account including to enable you to access the content and services of the Company, to collect subscription payments from you and for all purposes which are reasonably incidental to your relationship with the Company. We will not ask you to provide any Sensitive Personal Data, as that term is defined in the EU General Data Protection Regulation 2016/679 of the European Parliament and of the Council (“GDPR”). The Company and its affiliates may share this personal information with each other and use it consistent with this Policy. You are not required to provide the personal information that we have requested but if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have. We may also contact you for marketing purposes, subject to any preferences expressed by you.
The Personal Data we collect may include your name, contact details, work address, profession, billing address, IP address, payment details, bank card payment information, phone number and email address. When you sign up for newsletters, we will collect information to enable us to provide you with a tailored newsletter including your email address, name, newsletter topics which you are interested in and links which you can follow from the newsletter.
We obtain your consent to the use your Personal Information for the provision of the Services, access to the website and collection of the Subscription Fees as those terms are defined in our Terms and Conditions.
From time to time, we may use your Personal Data to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. We may also use personal information for internal purposes such as auditing, data analysis, and research.
We will retain your Personal Data until either you close your account or you unsubscribe from the email newsletter, whichever is the earlier. Up until this point, we will require the Personal Data in order to provide you with the services. We may keep your details for a reasonable period following a termination of your relationship with the Company but shall not keep it for any longer than is necessary (generally no longer three years in accordance with the statute of limitations) for use for the purposes mentioned above and will at all times comply with any statutory provisions, order or court order compelling erasure or amendment of your Personal Data.
You are entitled to withdraw your consent to the use of your Personal Data at any time; please write to us at [email protected] or in a form prescribed by the Company from time to time.
You are entitled to access a copy of your personal data and to have any inaccurate or misleading data amended or erased. If you would like to avail of these rights please write to us at [email protected]. The Company takes reasonable steps to ensure that the Data it processes is accurate, complete and current, however we would also encourage you to let us know if any of your details change (e.g. address, phone, e-mail, etc). Users who are registered members can update their Personal Data or change their settings once logged in. If registered members of the website wish to cancel their registration, they can do so by contacting the Company at the email address provided below: [email protected].
We may disclose personal information to our agents, service providers and professional advisers, and to such other third parties as may be reasonably required or permitted by applicable law. This may involve the transfer of your personal information outside of the European Economic Area where appropriate.
Our website uses two different types of cookies. Subscription cookies or sessional cookies are used only for session management. The data is not shared, in encrypted and expires when the session is completed.
We also use persistent cookies or analytical cookies, which are used on most websites across the web. These cookies are used primarily for analytical and statistical purposes. They typically persist for a period between 2 months to 4 months. If you wish to opt out of analytics tracking and analytical cookies you must do so on these third party sites or by changing your browser settings. The type of data we collect is:
- Your IP address – in order to track your activity;
- Anonymous data about your device – your operating system (e.g. iOS11), device type (e.g. tablet);
- Anonymous aggregated demographics – for example your current city and other anonymous data;
- Anonymous data about your browsing – content you read and browsing patterns.
- Device information – Currency Media also collect information from and about the devices you use to access the Site and the Services. This includes things like IP addresses, the type of browser and device you use and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Site and Services. For example, Currency Media use device information to detect abuse, identify, number of devices connected with your account and troubleshooting.
We collect and process this data as part of our drive to ensure the highest level of customer satisfaction. The Company may review details of your account history and usage patterns in aggregated and anonymous form to assist in identifying overall customer trends and preferences. We may also look at your specific usage patterns so that we can provide you with marketing information which is more tailored to your individual preferences.
This data helps us optimise the way the site is structured and how content is arranged on the site. It also allows us to show interested parties how many people access the different parts of our site and on average how often they visit. This allows understanding of how many people look at our content at different times of the day etc. These statistics are always calculated on an aggregated basis – never individually.
Our third-party service providers, Google Analytics and Intercom, may process anonymised data in a manner consistent with their respective privacy policies and the GDPR in order to provide certain services and features. The services and features include analytical services in respect of the people accessing the Services, automated interactive assistance technology and payment services. Copies of the privacy policies of Google Analytics, Intercom and Crazyegg can be accessed from the following links:
Any external links to other websites are clearly identifiable as such and are provided for information purposes only. We are not responsible for the content, accuracy or the privacy practices of other websites.
Taking into account the costs of implementation and the nature, scope, context and purposes of collecting Personal Data as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, we shall implement appropriate technical and organizational measures for ensuring the security of the Processing as would be expected from a reasonably prudent Data Controller.
In assessing the appropriate level of security, we shall take account of the risks that are presented in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to the stored Personal Data. We store your data within the EU.
Your Rights Under Data Protection Law
You have several rights under data-protection law in relation to the personal information that Currency Media holds about you. If you choose to exercise any of these rights, we will ask you to verify your identity. We will consider your request and provide a response within one month. These rights are described in detail on the Data Commissioner’s website and summarised below:
- Right of Access: You are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”). Typically, there is no fee for this, however, we have the right to apply a reasonable fee in exceptional circumstances.
- Right of Portability: You can request a copy of the personal information we hold about you in a structured, commonly used and machine-readable format and if technically feasible, have your personal information transmitted to another data controller in a machine-readable format.
- Right to rectify: If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.
- Right to withdraw consent: You have the right to withdraw your consent to any future processing for which you have previously given that consent. There are also options to unsubscribe accessible from a link contained in each newsletter, available from the account section of our website or you can write to us at the address below.
- Right to Erasure: Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”).
- Right to Restriction: Restrict processing of your personal information in certain circumstances
- Right to object to processing: You are entitled to object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes.
- Rights relating to automated decision making including profiling: You are entitled to not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature.
- Right to complain: You are entitled to lodge a complaint with the Data Protection Commissioner if you have concerns about how we process your personal data. You can complain directly to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois, by telephone at +353 1890 25 2231 and/or by email to [email protected]. You can also make a complaint directly to the relevant data protection authorities in the country where you are ordinarily resident.
“We” means the Company and any subsidiaries or holding company or any subsidiary of such holding company and their respective legal successors or assigns from time to time.
The terms Data Controller, Data Processor, Data Subject, Process/Processing and Special Categories of Personal Data shall have the same meaning as described in the GDPR.
If you have any questions or concerns about this Policy or our data processing or if you would like to make a complaint about a possible breach of please write to us. Our Data Protection Officer is: Edel Robinson at [email protected].