Data Privacy Notice
We are Savvy with registered number 389382 and our address is 40 Eastmoreland Lane, Ballsbridge, Dublin 4, Ireland. Our Data Protection Lead can be contacted at [email protected]. We have produced this privacy notice to keep you informed of how we and our affiliates handle your personal data when you visit our website and when you become our client.
All handling of your personal data is done in compliance with the Data Protection Act 2018 and, if applicable, the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. “Data Protection Lead” is the title given to the member of staff leading our data protection compliance program in lieu of a requirement for a Data Protection Officer.
What are your rights?
When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:
- The right to be informed of how your Personal Data is used (through this notice);
- The right to access any personal data held about you;
- The right to withdraw consent at any time, by opting out using the options present in communications;
- The right to rectify any inaccurate or incomplete personal data held about you;
- The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
- The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
- The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.
You can gain access to your personal data by emailing at [email protected] with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity. If you have used our website before for submitting an enquiry, but are not our client, please contact us using the email address that you have provided us with initially by sending your enquiry. If you are our client, then please include your phone number for us to contact you to confirm your identity. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Officer deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘Who can you complain to?’.
If you have questions about any of the rights mentioned in this section, please contact us at [email protected]
Who is the Data Controller?
Where we collect your personal data directly from you for our own purposes, we are the Data Controller.
If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are a joint Data Controller. We will contact you to let you know about the acquisition (if we receive it indirectly) and who your point of contact is in relation to our processing before we first start to use your data, or, at the latest, within one month of acquiring it.
If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us at the time they collected your data and within their own privacy notices/standards. For a list of Data Controllers that we process personal data for, the section below ‘Third Party Interests’.
What are the lawful bases for processing personal data?
Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are:
- your consent
- performance of a contract
- compliance with a legal obligation.
- protection of your, or another’s vital interests.
- public interest/official authority.
- our legitimate interests.
What is Savvy’s legitimate interests?
Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Officer. You can object to our processing, and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact [email protected]
About our processing of your data
When you use our website to submit an enquiry or when you become our client, we might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
Identity Data such as names; title.
Contact Data such as addresses; email addresses and telephone numbers.
Transaction Data such as information about payments and details of purchases you have made.
Technical Data such as IP addresses; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.
Usage Data such as analytics relating to how you use the website.
Marketing and Communications Data such as your preferences about receiving communications from us or third parties.
This Website is not directed toward children (as defined by local law), nor does Savvy knowingly collect information from children without parental consent except where in compliance with applicable law.
We may also collect, use, and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity.
What happens if I refuse to give Savvy my personal data?
The information about you that we have collected for the performance of our contracts is required for us to successfully fulfil our obligations to you. If you choose not to provide the personal data requested, we will not be able to enter a contract with you to provide the services we offer. If we are already processing your personal information under a contract, you must end our contractual relationship (as/where permitted) to exercise some of your rights. If we process some personal information as part of a contractual relationship with a Data Controller, then any requests to restrict this type of processing should be forwarded to the Data Controller; they will be responsible for discussing your concerns and making any decisions.
What profiling or automated decision making does Savvy perform?
Savvy does not perform any profiling or automated decision making based on your personal data.
How long will your personal data be kept?
Savvy holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.
- If ‘consent’ is the basis for our lawful processing of your data, we will retain your data so long as both the purpose for which it was collected, and your consent, are still valid. Occasionally, we might identify a legitimate interest in retaining some of your personal data that has been obtained by consent. If we do, we will inform you that we intend to retain it under these conditions and identify the interest specifically.
- If we process your data based on ‘legitimate interests’, we will retain your data for as long as the purpose for which it is processed remains active.
- All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of six years, or as otherwise required under applicable law, for the purposes of exercising or defending legal claims.
Who else will receive your personal data?
Savvy may pass your data to the third parties listed in the section ‘Third Party Interests’ below.
Who can you complain to?
Please send your complaints directly to us at [email protected].