This policy applies to all processing of personal data carried out by Kavanagh Group and has the objective of informing the user regarding the way in which Kavanagh Group carries out the processing of personal data (including details of the type of personal data collected and the purpose of processing) and regarding the rights of the user in relation to their personal data.
Contact – How can I contact?
- Headquarters are located at: Shop Street, Westport, Co. Mayo
- Contact phone number is: 00353(0)9826300
The user may establish direct and effective communication with Kavanagh Group by written communication sent to any of the indicated addresses or also by sending an email to the address: email@example.com
In addition, information of the officer in charge of processing your personal data is listed below:
- Trade name: Kavanagh Group
- Identity of the controller: Kavanagh Group
- Address: Shop Street, Westport, Co. Mayo
- Email: firstname.lastname@example.org
Processing identification – How do we collect personal data?
In compliance with current regulations on the protection of personal data, especially,
- Regulation (EU) 2016/679 of the European Parliament and Council, dated April 27, 2016 on the protection of natural persons regarding the processing of personal data and the free circulation of these data (hereinafter, the “GDPR”),
Kavanagh Group collects personal data in its possession when the user:
- (i). completes the forms of www.kavanaghgroup.ie (“Site”);
- (ii). subscribes to the newsletter;
- (iii). answers a poll or completes a web form;
- (iv). completes a printed form;
- (v). sends an email or communicates by phone, which are then loaded in the corresponding forms;
Personal Data Collected – What personal data do we collect?
Kavanagh Group collects information when visiting their web page, and mainly by completing its registration forms.
The following data is collected: full name, email, phone number, gender, date of birth, nationality, address and emergency contact.
As a rule, when personal data is requested to use a service or access certain content, its delivery will not be mandatory, except for those cases where it is specifically indicated that it is data required for the provision of the service. In this case, the user may freely choose not to register and/or not to contract the services.
The user declares and guarantees that all the data provided by him are true and correct and undertakes to keep them updated. The changes may be communicated to the Data Protection Delegate or to the address indicated in Section 2 hereof.
Likewise, the user acknowledges that the data required by Kavanagh Group are necessary, adequate, and not excessive to carry out the purposes expressed in Section 5 hereof, which would be impossible to fulfill if said data are not provided.
Any false or inaccurate statement that occurs as a result of the information and data given, as well as the damages that such information may cause, will be the responsibility of the user.
Purpose – What do we use personal data for?
The personal data requested to the user will be used for the following purposes:
- In the event of contracting services offered through the Site, to create and maintain the commercial relationship, and to carry out the activities and provide the services of Kavanagh Group (including, without limitation, the management, administration, provision and improvement of services).
- Send newsletters, as well as commercial communications, promotions and/or advertisements of Kavanagh Group, either occasionally or periodically. Accordingly, the email address that the user provides when completing the form on the Site may be used to send information and updates on the request for services, as well as news about Kavanagh Group (either occasionally or periodically), updates, information on related products or services, among others. This treatment is based on our legitimate interest in promoting our products and services.
- Conduct a survey or run a contest
- Personalize the user experience, increasing our ability to respond to their needs.
- Improve the Site and the service offer of Kavanagh Group, based on the legitimate interest of Kavanagh Group in constantly improving its products and services.
- Process transactions and comply with the legal obligations to which Kavanagh Group is subject, such as tax obligations. The data subject to treatment will not be used for purposes other than or incompatible with those mentioned above and that motivated its collection. Notwithstanding the foregoing, it is stated that the recorded data may be used, in addition to the purposes for which it was expressly collected, for the purpose of carrying out statistics, managing incidents or conducting market studies. However, in the event that personal data is processed for a purpose other than that initially specified when collecting said data, a compatibility analysis will be carried out by Kavanagh Group in accordance with applicable regulations. The processing will only be authorized if the original purpose is compatible with the new purpose or allowed in accordance with an independent legal basis. In these cases, the user will be informed of the changes in purpose or legal justification for the processing of their data.
We remind the user that they can oppose the sending of commercial communications (unsubscribe) and stop receiving emails from Kavanagh Group, reliably notifying Kavanagh Group, which will proceed to interrupt in the shortest possible time after receiving such communication. For this purpose, it may send an email to the address indicated in Section 2, a postal mail addressed to the address indicated in Section 2 hereof, or directly follow the unsubscribe instructions detailed at the end of each email of Kavanagh Group.
How we use your information?
We will use the information that we collect about you for the following purposes:
- Administration info
- Customer feedback collection
- Enforce T&C
- Targeted advertising
- Administration info
- Site protection
- Dispute resolution
If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.
By providing personal data to Kavanagh Group, the user declares to accept their processing fully and unreservedly by Kavanagh Group. The user hereby grants his free, express, and informed consent for Kavanagh Group to use the data collected for the purposes indicated in Section 5 hereof, as well as its incorporation into a Kavanagh Group database.
Expiration – How long do we store them?
The data will be destroyed or archived when it is no longer strictly necessary or relevant for the purposes detailed in Section 5 above. In particular, personal data will be kept as long as the business relationship is in force (and to the extent that the user has not previously requested its deletion) and during the period during which obligations, indemnities and/or responsibilities may arise under the business relationship or for the services provided.
Confidentiality / Assignment / International Transfer – Do we disclose data to third parties?
Kavanagh Group will keep the personal data collected private and confidential, and will not use them for purposes other than those established in Section 5 hereof. Kavanagh Group requires the signing of confidentiality agreements and personal data processing by its employees and third parties that provide services that access the content of the databases (or include such obligations within the service agreements that it signs with such providers as indicated in the next paragraph).
The personal data of the user collected by Kavanagh Group will not be transferred, sold, exchanged, transmitted and/or communicated to any third party outside of Kavanagh Group without the consent of the user, except legal obligation and/or for the purpose of providing the services to the user. This does not include certain employees and service providers that allow Kavanagh Group to keep the Site operational, comply with the purposes established in Section 5 hereof and/or provide services to the user, who have assumed the obligation to maintain the confidentiality of the data provided and commit to compliance with the applicable regulations on the protection of personal data, at the time of hiring. The contracts with the service providers stipulate the objective, scope, content, duration, nature and purpose of the data processing, the type of personal data, the categories of data owners and the obligations and responsibilities of Kavanagh Group and of the contracted third parties.
In particular: Kavanagh Group may share the personal information provided with controlling companies, affiliates, subsidiaries, related companies and/or intermediaries related to Kavanagh Group.
Kavanagh Group may share certain personal information provided by the user internally within Kavanagh Group, with certain departments, such as administration, marketing, or IT.
Security – How do we ensure data security?
Kavanagh Group declares its intention to adopt the technical and organizational measures necessary to guarantee the security, integrity, and confidentiality of the data in accordance with the provisions of the RGPD in order to avoid its adulteration, loss, consultation or unauthorized processing.
Kavanagh Group does not guarantee absolute privacy in the use of the Site since the possibility that unauthorized third parties may have knowledge of it should not be ruled out. The user acknowledges that the existing technical means that provide security are not impregnable and that even when all reasonable security precautions are adopted, it is possible to suffer manipulation, destruction and / or loss of information. In the event that a security incident is detected and that it implies a significant risk for the owner of the data, such event will be communicated without delay to the competent control authority, together with the corrective and palliative measures implemented and / or to be implemented.
Kavanagh Group is not responsible for the loss or deletion of data by users. Likewise, Kavanagh Group does not accept any responsibility for possible damages caused by computer viruses.
Finally, the user must also take measures to protect their information. Kavanagh Group insists that you take every precaution to protect your personal information while on the Internet. At least, you are advised to change your password periodically, using a combination of letters and numbers, and make sure you are using a secure browser.
Rights of the owner of the data and procedures to respond to their exercise – What rights do I have as the owner of the data?
The user who owns the data may at any time exercise the rights of access, rectification, cancellation, opposition, limitation of processing, portability, confidentiality and deletion regarding their personal data, in accordance with the provisions of articles 15 and following of the RGPD, as appropriate.
The exercise of these rights can be carried out by the user himself through an email addressed to email@example.com, or by any of the methods provided for in the applicable regulations referenced above. Kavanagh Group may request the necessary data to validate the identification of the owner of the data.
The deletion of some data will not proceed when it could cause damage to the legitimate rights or interests of third parties, or when there is a legal obligation to keep the data.
Training – Do we train?
The Kavanagh Group staff whose functions are related to the processing of personal data are trained in order to guarantee better protection of personal data and the rights of its holders.
Links to third parties – Does our Site contain links to other sites?
The Site may contain links to third party sites, with or without advertising content, whose privacy policies are foreign to Kavanagh Group. The linked sites are not related to Kavanagh Group and, their existence in no way presupposes that there is any kind of suggestion, invitation, or recommendation for the visit of the destination places or any kind of link or association between Kavanagh Group and such sites. Kavanagh Group is not responsible or liable for the content, use and activities of these linked websites, or for damages, whether current or eventual, material or moral, direct or indirect, suffered by users and derived from the information contained in such sites or of the relationship that users may establish with third parties whose services have been published on the Site. Notwithstanding the foregoing, any comment on these linked websites will be useful to Kavanagh Group in order to improve services and/or ensure the integrity of the Site. Kavanagh Group undertakes to do everything possible to prevent the existence on its Site of links to sites with illegal content.
The user should know that to navigate the Site, it is not necessary for the user to allow the installation of cookies sent by the Site. This may only be required in relation to certain services. The user can erase cookies from the hard drive of his/her computer, prevent access to his/her computer either through his/her browser or by choosing the corresponding option when asked about the possibility of using cookies for these purposes and in compliance with the Cookies Policy of Kavanagh Group.
Cookies are information files that a website or the provider of certain services of the site transfers to the hard drive of the user’s computer through the browser program. Cookies by themselves cannot personally identify the user (although they can contain the user’s IP address) but they allow them to recognize the user’s browser, and capture and store certain data (user’s operating system, domain name of the website from which the Site was linked, among others). Kavanagh Group reserves the right to contract the services of third parties to analyze and understand the users of the Site, who may not use the information collected for purposes other than to improve Kavanagh Group services.
Modifications – Is this the most current version?