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Data Privacy Policy Introduction:

The EU has updated and reformed the rules concerning General Data Protection Regulation [GDPR] from 25 May 2018. Coleman Electronics Ltd collects and processes all personal data in accordance with this Data Privacy Policy document. All appropriate rights and obligations are contained within this data privacy policy along with why, how and when we process your data.

GDPR allows you greater control over your personal data. Personal Data is defined as “data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller”. Under GDPR, Coleman Electronics Ltd is a ‘Data Controller’ of your data. A “data controller is a person / company / other body who either alone or with others controls the contents and use of personal data”.

This policy document outlines how Coleman Electronics Ltd collects, retains and processes all personal data. Your rights under GDPR are also clearly explained within this data privacy policy document. We have a separate data privacy policy for current and previous employees of Coleman Electronics Ltd. The purpose of this Data Privacy Policy notice is to explain how Coleman Electronics Ltd [“Coleman Electronics” “We” and “Our”] process your personal information.

We regularly review and update this Data Privacy Policy document in order to meet our obligations in processing your personal data under the General Data Protection Regulations [GDPR]. Please contact us at any time on info@colemangroup.ie to ensure you have access to the most update version of this policy document.

Who we are

We are Coleman Electronics Ltd. Our registered office is Ardnaree, Ballina Co. Mayo. Our registered company number is 116412. The shares in Coleman Electronics Ltd are owned by its shareholders.

We offer integrated fire & security solution services to customers on the island of Ireland in the following categories : CCTV, Fire Systems, Intruder Systems, Access Control, Door Automation, Barrier & Gate Automation, Emergency Lighting, Gas Alarm and Energy Systems. We licensed by the Private Security Authority and our license number is 00557.

Queries relating to data protection should be sent to the Data Protection Officer:
e: info@colemangroup.ie
In Writing: Coleman Electronics Ltd, Adnaree, Ballina Co. Mayo.
Tel: 096 72858

Data Collected

We collect the following information in order to fulfil our legal requirements pertaining to:

Performance of a contract with our customers
Personal data processing occurs in order to provide you with the products and services we have agreed with you. Such processing includes payments, accounts, contact details, customer history and site details.

Where consent is provided
To supply only relevant data to third parties i.e. monitoring companies as a necessary requirement to provide the service you require. We use your personal information to communicate information relating to products and services which may be of interest to you where you consent has been given to us. Consent will be requested on these specific occasions. **

In order to provide the services you require
We process personal information in our legitimate interests to provide the services we offer you. Coleman Electronics uses name and contact details to communicate with you when you use our services. We use personal data relevant to each specific case to handle customer complaints.

Compliance with our legal obligations
In the administration of our operational requirements to carry out the services we offer to you. To communicate relevant information to you regarding services you require. To maintain records of communications and customer accounts and in order to meet our regulatory and licence requirements.

What Data we collect

• Name
• Address [including Eircode]
• Telephone numbers
• Mobile numbers
• Email addresses
• Technical data relating to your site
• Account history
• Site information
• Bank Details
• Credit information
• Debit information
• Payment records and transactions
• CCTV images captured on our premises for security purposes
• Employee records
• Signatures

How we collect personal data

Persona data is collected from the following sources:

• Collected from you at time of account setup, order processing or account updates that you provide.
• Obtained onsite from our staff when carrying out services you require including signatures, photographs and technical site updates.
• Processing of financial transactions involved with the services we offer.

Sharing your personal information

Coleman Electronics will only share your personal information with our selected trusted third party business partners where necessary to carry out the functions required of providing the services you require. The appropriate safeguards will be in place to ensure the security and confidentiality of your personal data. Under no circumstances will your personal data be transferred to third parties outside the European Economic Area [EEA] as part of any services we offer.

We may share your personal information in accordance with your consent to do so to trusted third parties in accordance with the necessary performance of your contract or request for services delivered. Any personal data disclosed will be in compliance with the terms of the GDPR and Irish Data Protection Law.

Where a duty to disclose or share your personal data requires us to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

In order to ensure the safety and security of your personal data e.g. with our backup providers, IT support providers and other trusted third parties entities concerned with protecting your data who we employ.

How we use personal data for direct marketing purposes.**

On occasions we would like to make you aware of services which may be of special interest to you. This can only be achieved by using specific personal data we hold about you. The right not to receive or request not to receive further information of this type will always be available to you. We will not contact you for direct marketing purposes unless you provided your consent to do so. You will always have the option to change your preferences at any time by contact us on the details provided at the start of this notice.

Personal Information update

Personal information will change from time to time. Please contact us using a method outlined at the start of this policy document if you would like to update any information you have previously provided to us.

Recruitment

CV’s or other personal information submitted as job application data via email, by post or delivered by hand to our offices, will be used for recruitment-related purposes only, which may include contacting you via email, telephone, SMS or post. The processing of your personal data in this circumstance is necessary for our legitimate interests to recruit employees.

Length of time we hold personal data

The length of time your personal data will be kept will be determined by purposes for which it was collected and in accordance in meeting our legal requirements in fulfilling contractual agreements or where services are required by your instruction. [see Data Collected above]. We will remove and destroy personal data where contracts are not renewed, ceased or are cancelled unless specified under your instruction or where this information must be retained in accordance with statutory, regulatory or legal requirements.

Any personal details obtained by us in the performance of a contact or service provide to you will be kept as a record for revenue purposes for seven years after the year of transaction. Retention of quotation information will be kept for two years after the year of quotation to allow for works to be completed. Retention of all recruitment personal data will be held for two years after the year of submission to allow for future opportunities.

Your Rights in Relation to Personal Data under [GDPR]

You have the:

• Right of access and to receive copies of your personal information.
• Right to rectification of inaccurate or incomplete information.
• Right to erasure, deletion or restriction in certain circumstances.
• Right to restrict processing in certain circumstances.
• Right to data portability where you can request your personal data in a structured format and the right to transmit this data to another data controller.
• Right to object to processing based on a legitimate basis e.g. profiling or direct marketing.
• Right to withdraw consent at any time, where processing is based on consent.

Right of access

• If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (subject to applicable exemptions).
• This is known as a “subject access request” (SAR).
• Subject access requests should be made in writing or via email to the addresses proved at the start of this policy document.
• Please provide the information necessary to identify you and to identify the personal data that you’re requesting.
• Unless a SAR is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee will not be charged to cover our administrative costs in responding.
• Under normal circumstances a SAR will be responded to within one month of receiving the request.
• A request for personal data viewed as more complex will therefore require more time to respond. In such circumstances requests can take up to a maximum of three months from the date we receive your request.
• Coleman Electronics will keep you updated with progress relating to complex requests.

Lodging a complaint with the Office of Data Protection Commissioner [O.D.P.C.]

Under Article 80, you may authorise certain third parties to make a complaint on your behalf.
Complaints to the Commission should be made in writing and addressed to:

The Data Protection Commissioner, Canal House, Station Road, Portarlington, Co. Laois

or

via email to: info@dataprotection.ie

or

via Telephone: O.D.P.C. helpdesk function 0761 104 800 or LoCall 1890 252231

Data privacy policy updates

We regularly review and update this Data Privacy Policy document in order to meet our obligations in processing your personal data under the General Data Protection Regulations [GDPR]. Please contact us at any time on info@colemangroup.ie to ensure you have access to the most update version of this policy document. We reserve the right to change, amend and update this policy at any time when required.