Data Protection and Privacy Notice ( https://enware.cloud )
Version Number: 1.01
Revision Date: 13/2/23
Identity of the Data Controller and Contact Details
Verde Led Limited (the “Organisation”) is the data controller for this instance of Enware and with regard to the Personal Data described in this Data Protection and Privacy Notice. This Data Protection and Privacy Notice applies to our Enware portal/App.
Our Data Protection Coordinator can be contacted as follows:
Email: dataprotection@enware.team
Supervisory Authority and Applicable Law
As we are established in the Republic of Ireland, this document is written in the vein of Irish Data Protection Law and we fall under the jurisdiction of the Irish Data Protection Commission. This Data Protection and Privacy Notice sets out what Personal Data we collect and process about you in connection with the Enware app. We are not responsible for the content or the privacy notices for any websites to which we provide external links. Laws that apply to us:
| State and/or Country of Incorporation | Applicable Law |
| Ireland |
|
Updates
Our practices as described here now may be changed, but any changes will be posted, and changes will only apply to activities and information on a going forward, not retroactive basis. You are encouraged to review this Data Protection and Privacy Notice periodically to make sure that you understand how any personal information you provide will be used. We may also email you in certain circumstances to let you know if and when we update this Data Protection and Privacy Notice to ensure you are informed.
Any changes to this Data Protection and Privacy Notice will be posted on this website/app so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Data Protection and Privacy Notice, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice, if permissible under the applicable law, as to whether or not we use your Personal Data in the new manner.
What types of personal data will we process?
Regular Personal Data
We will collect personal data with you in accordance with the purposes outlined in this document. This will be basic personal data used to facilitate an account and interactions on the platform.
User behaviour data
Behavioural data is collected to record actions such as engaging with training modules and carbon footprinting.
Special Category Personal Data
We will not collect special category data from you.
Criminal Conviction Data
We will not collect criminal conviction data from you.
Children’s Personal Data
If we are notified or learn that a child has submitted Personal Data to us through this portal without the correct permissions or consents, we will delete such Personal Data.
Who has access to or processes personal data?
Directors and Employees of the Organisation
Directors and employees of the Organisation who are bound by confidentiality agreements will process personal data on behalf of the Organisation.
All information provided to employers by way of reports from the platform are aggregated and anonymised
Service Providers
We may use trusted service providers who could be considered data processors, sub-processors or third parties. We need to have written agreements in place with all of our service providers and, before we sign each agreement, we need to have vetted and be satisfied with the service provider’s data security. The agreements also need to contain specific clauses that deal with data protection. We require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with Irish and EU laws on data protection. Any such organisation or individual will have access to Personal Data needed to perform these functions but may not use it for any other purpose.
We use the following categories of service providers:
- Cloud Web and App Hosting Service
- Email Service Provider
- API Provider
- Helpdesk Provider
- One or More Contract Developers
This list may be updated from time to time so for an updated list of service providers you should check this Data Protection and Privacy Notice periodically.
We may pass on your details if we are
- under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or
- in order to enforce or apply any contract or other agreements with you, or
- to protect our rights, property, or safety of our employees, customers, or others.
This includes reporting information about incidents (as appropriate) to the law enforcement authorities and responding to any requirements from law enforcement authorities to provide information and/or Personal Data to them for the purposes of them detecting, investigating and/or prosecuting offences or in connection with crime sentencing.
Other than the above, or captured herein or in another agreement with you, we will not disclose personal information to any third party without your consent or prior knowledge except in incidences where an individual is potentially at risk or where the law requires it.
Where does your data travel to?
Our hosting provider’s data centre is located in the Netherlands. The Netherlands currently enjoys adequate status.
International Transfers
If we transfer your Personal Data out of the EEA, we ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
Automated Decision Making and Profiling
Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention. As Profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
We do not use automatic decision-making or profiling.
Security
We follow strict security procedures in the storage and disclosure of your Personal Data, and to protect it against accidental loss, destruction or damage. We take appropriate security measures against unlawful or unauthorised processing of Personal Data, and against the accidental loss of, or damage to, Personal Data. The data you provide to us is protected using modern encryption, intrusion prevention, and account access techniques as appropriate and required. We have put in place procedures and technologies to maintain the security of all Personal Data from the point of collection to the point of destruction. We maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:
Confidentiality means that only people who are authorised to use the data can access it.
Integrity means that Personal Data should be accurate and suitable for the purpose for which it is processed.
Availability means that authorised users should be able to access the data if they need it for authorised purposes.
Data Retention
Generally, we will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for and for up to seven (7) years afterwards (for purposes related to Revenue requirements) or otherwise permitted by applicable laws. We may also retain your information during the period of time needed to complete our legitimate business operations, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where your employer terminates our services, your Personal Data will be deleted within 30 days of termination.
Marketing
We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. Where appropriate, you will be asked whether you wish to receive any marketing communications from us.
We will not share your Personal Data with any third party for marketing purposes. You may object to direct marketing by using the provided links or the contact details herein to opt-out or make use of the opt-out links on communications.
Cookies, Tracking, and Other Technical Personal Data
Cookies
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site. Most web browsers automatically accept cookies, but, if you wish, you can set your browser to prevent it from accepting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
Technical Personal Data
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. We may gather technical information for security reasons. We will make no attempt to identify individual visitors, or to associate the technical details listed below with any individual. We will only use the technical information for statistical and other administrative purposes.
We may collect this technical information from you when you visit our website and accept cookies. This information may include standard information from you (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our website (such as the web pages viewed and links clicked). We do note that your IP address is considered personal data under the GDPR.
Certain information in relation to web usage is revealed via our internet service provider who records some of the following data. Whilst we do not access this information regularly, the technical information may be used to inform our security measures, to allow us improve the information we are supplying to our users, to find out how many people are visiting our sites and for statistical purposes. The information we receive depends upon what you do when visiting our site:
- The IP address you are using.
- The date and time you access our site.
- The pages you have accessed and the documents downloaded.
- The previous Internet address from which you linked directly to our site.
- The user agent used to accessed our site.
Information on Consent
By consenting, where this is the appropriate and identified grounds for processing, to our processing your Personal Data in line with this Data Protection and Privacy Notice you are giving us permission to process your Personal Data specifically for the purposes identified.
You may withdraw consent at any time by providing an unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify withdrawal of consent to the processing of Personal Data relating to you. If you have any queries relating to withdrawing your consent, please contact our Data Protection Coordinator using the contact details set out below.
Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.
Summary of Data Processing Activities
| Categories of Data | Purpose/Activity | Possible Lawful Basis for Processing |
| Name and Contact Details (optional photograph) | Electronic account creation and/or management |
|
| Name and Contact Details | Notifying you about changes to our terms or this policy |
|
| Name and Contact Details | Asking you to leave a review or take a survey |
|
| Name and Contact Details; IP Address | To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
|
| Behavioural actions | To track progress with learning modules and record relevant information such as carbon footprinting |
|
| Name and Contact Details | To respond to your enquiry, feedback or complaint |
|
What rights do you have?
Under certain circumstances, and dependent on legal basis under which your personal data is processed, by law you have the right to:
- Request information about whether we hold Personal Data about you, and, if so, what that Personal Data is and why we are holding/using it.
- Request access to your Personal Data (commonly known as a “Data Subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
- Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
- Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your Personal Data or profiling of you.
- Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your Personal Data in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
How do you exercise your rights?
We have appointed a Data Protection Coordinator to monitor compliance with our data protection obligations and with this policy and our related policies. If you have any questions about this policy or about our data protection compliance, please contact the Data Protection Coordinator.
If you wish to exercise your rights please contact our Data Protection Coordinator who will respond to the request and attempt to resolve it within one calendar month.
Our Data Protection Coordinator can be contacted as follows:-
Email: dataprotection@enware.team
Your Right to Lodge a Complaint
You as the Data Subject have the right to complain at any time to a supervisory authority in relation to any issues related to our processing of your Personal Data. As our organisation is located in Ireland and we conduct our data processing here, we are regulated for data protection purposes by the Irish Data Protection Commission.
You can contact the Data Protection Commission as follows:
Website: www.dataprotection.ie
Phone: +353 57 8684800 or +353 (0)761 104 800
Email: info@dataprotection.ie
Address: Data Protection Office – Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. Or 21 Fitzwilliam Square Dublin 2. D02 RD28 Ireland
Notice Approval
This Notice has been approved and authorised by:
NAME: John Keohane
POSITION: Director
DATE: 13/2/23