PRIVACY POLICY INTRODUCTION AND SCOPE Cosmic Web Solutions provide a wide range of services including web design, website maintenance and WordPress development. Cosmic Web Solutions was established in 2022 and we are based in Dalkey, Co. Dublin. Processing personal data in a secure, fair, and transparent way is extremely important to us . We know that your privacy is important to you. This notice explains how we collect and use your information, who we share it with and your legal rights. This notice applies to our use of your information in connection with products and services, and all our related website, domains, and apps that may be accessed by our customers, partners and employees (collectively the “Services”). WHO WE ARE Cosmic Web Solutions (“Cosmic Web Solutions”, “we”, “us”, or “our”) is the provider of the Services and is data controller for your information. WHO THIS NOTICE APPLIES TO We collect and process information relating to individuals using the Services, including customers, employees, partners and others. YOUR RESPONSIBILITIES Read this Privacy Statement to understand your rights and how we process your personal data. If you are a customer or partner, please also check the contracts between us: they may contain further details on how we collect and process your data. If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information, you confirm that you have the right to authorise us to process it on your behalf in accordance with this Privacy Statement. INFORMATION WE COLLECT AND HOW WE GET IT In the course of providing the Services, we collect or receive information in different ways and relating to various groups of individuals, including: * Customers We collect and use information relating to you. This information may include information relating to your name, address, email address, and contact number. * Employees We collect and use information relating to you. This information may include your name, job title, email address, registered body / organisation, professional details, medical history, employment history, training records and contact number. * Partners and Suppliers We collect and use information relating to you. This information may include your name, job title, email address, company name, address, and contact details. If you visit any of our websites or use our apps, we will collect certain information relating to you. Generally, unless you submit information to us, such as via an online form, we only collect technical and device-related information from your use of our website and apps. HOW WE USE THIS INFORMATION We use this information for the purposes described below. * Providing the Services: We process your information as necessary to provide the Services requested. For example, we collect information from you in order to provide the Services or process enquiries. We may also send you information relevant to our support service, industry updates, and news on our company. This will be with you consent. Lawful basis: Contract & Consent * Account set up and payment: We process your information in order to set up an account for you which is part of our administrative, financial and operational processes, such as processing queries, taking payment, issuing invoices, etc. where you pay for the Service directly. Lawful basis: Contract * Service improvement and development: We process your information in order to improve our Services and for business planning purposes. For example, we may process information about how you use our Services in order to troubleshoot technical issues, predict service level demands and understand the features of the Services that are most popular. We also process your information in order to develop new products and services. As part of our work with our commercial partners, we may share anonymised data that does not identify you but which reveal trends, patterns or other information about how we provide the Services that is useful to our commercial partners. We may send you out feedback forms to complete post utilising our services by email / SMS. Lawful bases: Contract & legitimate interests * Safety and security: We process your information as necessary to ensure we offer safe and secure Services, including to detect and prevent fraudulent and other illegal behaviour. Lawful bases: Contract & Legitimate Interests * Legal and regulatory: We process your information as required (a) for compliance with our legal and regulatory obligations (b) to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) to protect our rights, property, or safety; (d) to enforce any contracts we have with you; (e) to prevent physical injury or other harm to any person or entity, including you and members of the public. In addition, we may be legally required to share information with public bodies e.g. Revenue, An Garda Siochana, etc. Lawful basis: Legitimate interests * Marketing (with your consent) We may send you updates, invites and marketing materials relating to the Services. If we do so, we will also collect information on your interaction with such communications. Lawful basis: Contract OUR LEGAL BASES In order to collect, use, share, and otherwise process your information for the purposes described in this notice, we rely on a number of legal bases, some of which are mentioned above, including where: * necessary to perform a contract we have with you, and to provide the Services; * you have consented to the processing (in which case you may withdraw your consent at any time; * necessary for us to comply with a legal obligation; * necessary to protect your vital interests, or those of others; * necessary in the public interest; * necessary for the purposes of Cosmic Web Solutions or a third party’s legitimate interests, for example for marketing, improving or developing the Services and keeping the Services safe and secure, provided that those interests are not overridden by your interests or fundamental rights and freedoms. SHARING YOUR INFORMATION In the course of providing the Services, we share information with various third parties such relevant government departments and bodies (including Revenue), our service providers or regulators (where legally required). We do this based upon the legal bases and exceptions mentioned in this notice for the following purposes. * Providing the Services: If you are a customer, we may share the information provided by you with our service providers in order to provide the Services e.g. appointment booking, payment processors, etc. * Keeping our Services safe and secure: We use your information in certain instances as necessary to pursue our and your legitimate interests of keeping some of our Services, such as our domains, websites, apps, offices and events, safe and secure. For example, we collect IP addresses and process log files to ensure our website and apps are not subject to fraudulent access. * Legal and safety reasons: We may share your information with law enforcement, regulators and others if we have a good-faith belief that it is reasonably necessary to (a) respond, based on applicable law, to a legal request (e.g., a subpoena, search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues; (c) protect our rights, property, or safety; (d) enforce any contracts we have with you; (e) prevent physical injury or other harm to any person or entity, including you and members of the public; (f) for regulatory compliance and investigations. * Service providers and professional advisers: We may share your personal information to help us provide our services and communicate with you. Categories of service providers include IT software, hosting providers, and records- storage companies. We may also share your personal information where we need advice and support from our professional advisers, such as accountants, lawyers and insurance providers. Where such third parties are processors, these third parties are contractually required to use it only to provide their service to us and are contractually barred from using it for their own purposes. DATA TRANSFERS In certain cases, we may need to transfer your information to recipients outside the European Economic Area (“EEA”), such as where it is necessary to provide the Services. Where we transfer your information, we do so in accordance with EU data protection law. We only transfer personal information to these countries when it is necessary for the services we provide you, or it is necessary for the establishment, exercise or defence of legal claims or subject to safeguards that assure the protection of your information. When Cosmic Web Solutions engages in such transfers of personal information, it relies on i) Adequacy Decisions as adopted by European Commission on the basis of Article 45 of Regulation (EU) 2016/679 (GDPR), or ii) information, please visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en Cosmic Web Solutions also monitors the circumstances surrounding such transfers in order to ensure that these maintain, in practice, a level of protection that is essentially equivalent to the one guaranteed by the GDPR. Following the Court of Justice of the European Union’s invalidation of the EU-US Privacy Shield Framework in Case C-311/18, Cosmic Web Solutions will no longer rely on the EU-US Privacy Shield as a mechanism of international data transfer until further notice. Cosmic Web Solutions will however remain committed to maintaining its self-certification under the EU-US Privacy Shield Principles and respect its principles, as an additional measure of protection of its users’ privacy, until further notice. Please note that the privacy protections in some of these countries may not be the same as in your home country. We will only transfer information as permitted by law. For further information, including obtaining a copy of the documents used to protect your information, please contact us on info@cosmicwebsolutions.ie. RETENTION We may retain your information for as long as necessary in light of the purposes set out in this notice, including for the purposes of satisfying any legal, accounting, or reporting requirements and, where required for Cosmic Web Solutions to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. For example, we have specific legal obligations to retain medical information in accordance with our statutory requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. YOUR RIGHTS You have a number of rights in relation to your information that we process. To exercise these rights, please contact email info@cosmicwebsolutions.ie. While some of these rights apply generally, certain rights apply only in specific circumstances. We describe these rights below. You have the right to access and obtain the following information from our company: • confirmation that our company is processing your personal data • a copy of your personal data, and • other supplementary information In addition, you have the right to rectify or delete your personal data. In certain circumstances, Cosmic Web Solutions has the right to override your request to be forgotten / erasure in certain circumstances, in accordance with article 17(3) of the GDPR. Below are the reasons cited in the GDPR that override the right to forgotten /erasure. • The data is being used to exercise the right of freedom of expression and information. • The data is being used to comply with a legal ruling or obligation. • The data is being used to perform a task that is being carried out in the public interest or when exercising an organisation’s official authority. • The data represents important information that serves the public interest, scientific research, historical research, or statistical purposes and where erasure of the data would likely to impair or halt progress towards the achievement that was the goal of the processing. • The data is being used for the establishment of a legal defence or in the exercise of other legal claims. • The data being processed is necessary for public health purposes and serves in the public interest. • The data being processed is necessary to perform preventative or occupational medicine. This only applies when the data is being processed by a health professional who is subject to a legal obligation of professional secrecy. In such cases you will be informed promptly and given full reasons for that decision. In order to make a subject access request regarding access to your personal data or for the purpose of erasing or rectifying your personal data, fill in the Subject Access Request Form. Email info@cosmicwebsolutions.ie for a copy of the Subject Access Request form. You have the right to lodge a complaint regarding our use of your data. Please tell us first, so we have a chance to address your concerns. If we fail in this, you can address any complaint to the Data Protection Commission (Ireland). The details are listed below: The Data Protection Commission (Ireland) Commissioner: Helen Dixon Postal Address: Canal House, Station Road, Portarlington, R32 AP23, Co. Laois, Ireland Telephone: +353 57 8684800 or +353 76 1104800 Lo Call Number: 1890 252 231 Fax: +353 57 868 4757 Email: info@dataprotection.ie Website: https://www.dataprotection.ie/ THIRD PARTY SERVICES Our websites, domains and apps may contain links to other websites and services, which are managed and controlled by third parties. Please note that this notice does not apply in those cases and we are not responsible for the privacy practices of such third parties. AMENDING THE NOTICE From time to time, we may amend this notice. This might happen, for example, where we make changes to the Services. If we make material changes to the notice, we will take steps to notify you, such as by posting a notice on our website. The notice was last updated at the date indicated further below. CONTACT US If you want to exercise your rights (described above), or if you have any questions about this notice, please contact us on the below contact details. Cosmic Web Solutions Glenoe, Saval Park Road, Dalkey, Co. Dublin A96 TK46 Email: info@cosmicwebsolutions.ie Telephone: +353 83 0851172 Last updated: 18/09/2023.
