1. Definitions used in this Statement
i. Extreme XS Limited, Extreme Sports, Us, We, Our
- Extreme Sports, Us, We & Our all refer to Extreme XS Limited located at 11 Ballytrasna Business Park, Little Island, Co. Cork, with registered company number 518292
- You includes all individuals and organisations that we receive/handle/accept or otherwise process data from. This includes Staff, Clients and Third Parties.
- Clients include all individuals and organisations currently, historically or prospectively engaging in our services, including website visitors.
- Our services include but are not limited to those listed below:
- Gift Experience Vouchers
- Advertising for Adventure Companies
- Our services include but are not limited to those listed below:
v. Website: www.ExtremeSports.ie
vi. Data Protection Officer
- We have appointed the following staff member / external organisation to handle all our data protection related queries: Enguard Security Limited
vii. Criminal records For the purposes of this policy criminal records data means information about an individual’s criminal convictions and offences, and information relating to criminal allegations and proceedings.
viii. Data protection laws For the purposes of this policy Data Protection laws means all applicable laws relating to the processing of Personal Data, including, for the period during which it is in force, the General Data Protection Regulation (Regulation (EU) 2016/679).
ix. Data Subject Data subject means the individual to whom the personal data relates.
x. Personal Data Personal data means any information that relates to an individual who can be identified from that information
xi. Processing Processing means any use that is made of data, including collecting, storing, amending, disclosing, or destroying it.
xii. Special categories Special categories of personal data means information about an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sex life or sexual orientation and biometric data.
2. Scope of this privacy Statement
- This Privacy Statement covers our privacy practices with respect to the collection, use, and disclosure of information obtained that relate to our Staff, Clients and other users of our Services.
- For purposes of the applicable Data Protection Laws, Extreme Sports is the “data controller”. This means that Extreme Sports determines the purposes for which, and the manner in which, your Data is processed.
- This privacy statement describes the information that we collect about you, how we obtain your personal information, and how we may use or disclose that information in connection with the delivery of our services or your employment with us. This Privacy Statement also describes the measures we take to protect the security of your personal information and how you can contact us about our privacy practices, including to exercise your privacy rights.
3. Data we may collect
- We may collect the following Data, which includes personal Data, in each case, in accordance with this privacy Statement from you:
- Date of birth;
- Contact Information such as email addresses and telephone numbers;
- Demographic information such as postcode, preferences and interests;
- Financial information such as credit / debit card numbers / Bank account numbers;
- System Access Credentials
- IP address (may be automatically collected);
- Web browser type and version (may be automatically collected);
- Operating system (may be automatically collected);
- A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (may be automatically collected);
4. How we may collect Data
- We may collect Data in the following ways:
- Data is given to us by you;
- Data is received from other sources; and
- Data may be collected automatically.
5. Data that is given to us by you
- Extreme Sports may collect your Data in a number of ways, in each case, in accordance with this privacy statement, for example:
- When you contact us through the Website, by telephone, post, e-mail or through any other means;
- When you register with us and set up an account to receive our products/services;
- When you complete surveys that we use for research purposes (although you are not obliged to respond to them);
- When you enter a competition or promotion through a social media channel;
- When you make payments to us, through our Website or otherwise;
- When you elect to receive marketing communications from us;
- When you use our services;
6. Data that may be received from third parties and publicly available sources
- Extreme Sports may receive Data about you from third parties and publicly available sources in each case, in accordance with this privacy statement that we require in order to deliver our service to you or offer employment to you.
7. Data that may be collected automatically
- To the extent that you use ours services we may collect your Data automatically, for example:
- We may automatically collect some information about your visit to our Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.
- See our Website Terms & Conditions @ http://www.extremesports.ie/terms-and-conditions
8. Our use of Data
- Any or all of the above Data may be required by us from time to time in order to provide you with the best possible experience when using our Services as a Client or employed by us as a member of our Staff.
- Specifically, Data may be used by us in each case, in accordance with this privacy Statement for the following reasons:
- Internal record keeping;
- Improvement of our products / services;
- Transmission by email of marketing materials that may be of interest to you;
- Contact for market research purposes which may be done using email, telephone, or mail. Such information may be used to customise or update the Website;
- We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
- For the delivery of direct marketing to you via e-mail, we will need your consent, whether via an opt-in or soft-opt-in:
- Soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
- For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting, for example, checking a tick box that we will provide.
- If you are not satisfied about our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
- When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
9. Who we share Data with
- We may share your Data with the following groups of people to deliver, maintain & improve our service in each case, in accordance with this privacy Statement for the following reasons:
- Any of our group companies or affiliates
- Our employees, agents and/or professional advisors
- Third party service providers who provide services to us which require the processing of personal data
- Third party payment providers who process payments made over the Website
- Relevant authorities
10. Keeping Data secure
- We will use technical and organisational measures to safeguard your Data, for example:
- Our staff are governed by a strictly enforced data protection policy.
- Our systems are configured, maintained and monitored to ensure the best possible technical measures we can achieve. These have been implemented to secure your data.
- Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@ExtremeSports.ie.
11. Data retention
- Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy Statement or until you request that the Data be deleted.
- Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.
i. Right to access
- The right to request
- Copies of the information we hold about you at any time, or
- That we modify, update or delete such information.
- If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request.
- If we refuse your request, we will tell you the reasons why.
- The right to request
ii. Right to correct
- The right to have your Data rectified if it is inaccurate or incomplete.
iii. Right to erase
- The right to request that we delete or remove your Data from our systems.
iv. Right to restrict our use of your Data
- The right to “block” us from using your Data or limit the way in which we can use it.
v. Right to data portability
- The right to request that we move, copy or transfer your Data.
vi. Right to object
- The right to object to our use of your Data including where we use it for our legitimate interests.
vii. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@ExtremeSports.ie
viii. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority.
ix. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which it is held.
13. Transfers outside the European Economic Area
- Data which we may collect from you may be stored and processed in and transferred to countries outside of the European Economic Area (EEA).
- For example, this could occur if our servers are located in a country outside the EEA or one of our service providers is situated in a country outside the EEA.
- We also share information with our third party service providers, some of which are located outside the EEA.
- We will only transfer Data outside the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data,
- E.g. by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission, or by signing up to the EU-US Privacy Shield Framework, in the event that the organisation in receipt of the Data is based in the United States of America.
- To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with.
- This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.
14. Changes of business ownership and control
- Extreme Sports may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Extreme Sports.
- Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part. The new owner or newly controlling party will, under the terms of this Privacy Statement, be permitted to use the Data for the purposes for which it was originally supplied to us.
- We may also disclose Data to a prospective purchaser of our business or any part of it.
- In the above instances, we will take steps to ensure your privacy is protected.
- You may not transfer any of your rights under this Privacy Statement to any other person.
- We may transfer our rights under this privacy Statement where we reasonably believe your rights will not be affected.
- If any court or competent authority finds that any provision of this privacy Statement (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy Statement will not be affected.
- Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
- This Agreement will be governed by and interpreted according to Irish Law. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Irish courts.
- In this privacy Statement, unless the context requires a different interpretation:
- The singular includes the plural and vice versa;
- References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy Statement;
- A reference to a person includes firms, companies, government entities, trusts and partnerships;
- “Including” is understood to mean “including without limitation”;
- Reference to any statutory provision includes any modification or amendment of it;
- The headings and sub-headings do not form part of this privacy Statement.
16. Changes to this privacy Statement
- Extreme Sports reserves the right to change this privacy Statement as we may deem necessary from time to time or as may be required by law.
- You may contact Extreme Sports with any queries in relation to this Privacy Statement by email at info@ExtremeSports.ie