We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to our clients in the European Economic Area (EEA).
1. Key Terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our | Sonra Intelligence Limited, a company registered in Ireland under company number 547986 and having its registered office at 6-9 Trinity Street Dublin 2 |
Personal data | Any information relating to an identified or identifiable individual |
Special category personal data | Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership;
Genetic and biometric data (when processed to uniquely identify an individual); and Data concerning health, sex life or sexual orientation |
Data subject | The individual who the personal data relates to |
2. Personal Data We Collect About You
We may collect and use the following personal data about you:
We collect and use this personal data to provide services to you. If you do not provide personal data we ask for, it may delay or prevent us from providing service to you.
3. How Your Personal Data Is Collected
We collect most of this personal data directly from you either in person, by telephone, text or email.
However, we may also collect information from other sources such as:
4. How and Why We Use Your Personal Data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
What we use your personal data for | Our reasons |
Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
Preventing and detecting fraud against you or us | For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for you and/or us |
Conducting checks to identify our customers and verify their identity
Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety law or rules issued by our professional regulator |
To comply with our legal and regulatory obligations |
Operational reasons, such as improving efficiency, training and quality control | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations |
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
Preventing unauthorised access and modifications to systems | For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for you and/or us
To comply with our legal and regulatory obligations |
Updating customer records | To perform our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products |
Statutory returns | To comply with our legal and regulatory obligations |
Ensuring safe working practices, staff administration and assessments | To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you |
Marketing our services to:
—existing and former customers; |
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers |
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, for example:
5. Marketing
We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. However, where consent is needed, we will ask for this separately and clearly. You have the right to opt out of receiving marketing communications at any time.
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
6. Who We Share Your Personal Data With
We routinely share personal data with:
We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We may also need to:
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
7. Where Your Personal Data is Held
Personal data may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the EEA’
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8. How Long Your Personal Data Will Be Kept
We will keep your personal data while we are providing services to you.
Thereafter, we will keep your personal data for as long as is necessary:
We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data. When it is no longer necessary to keep your personal data, we will delete or anonymise it.
9. Transferring Your Personal Data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the EEA, e.g.:
Under data protection law, we can only transfer your personal data to a country or international organisation outside the EEA where:
10. Your Rights
You have the following rights, which you can exercise free of charge:
Access | The right to be provided with a copy of your personal data |
Rectification | The right to require us to correct any mistakes in your personal data |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data, in certain situations |
Restriction of processing | The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations |
To object | The right to object:
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Not to be subject to automated individual decision making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
If you would like to exercise any of those rights, please:
11. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
12. How to complain
Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Data Protection Commissioner.
13. Changes to this privacy policy
This privacy notice was published on 4 May 2022. We may change this privacy notice from time to time—when we do we will inform you via email.
14. How to contact us
You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
[email protected]
Sonra Intelligence Limited
6-9 Trinity Street
Dublin 2
Ireland