Privacy Policy

Overview

As a professional coaching practice, the security, confidentiality and privacy of the personal data you provide or share with us is of utmost importance to Smurfit Team Coaches (STC).  Below you will find our Privacy Policy which tells you about how we will process your personal data and about rights that you have under data protection.   We recommend that you read this Privacy Policy.    By way of introduction, we also provide a quick overview of how we will use your personal data.

We process your personal data for the purposes discussed in detail below, but the  main purposes are to enable us to provide you with services and to comply with our regulatory obligations, specifically:

  • For you to engage us and for us to fulfil our services to you, we will need you to consent for your sponsoring organisation to provide us with your contact details.   Alternatively, you may provide these directly to us.   

  • On a professional aspect, we engage with you through a sharing partnership that is based on a consensual relationship. 

  • When working with you we will maintain the strictest of confidentiality with all your information, and that of your sponsor, unless release of information is required by law.

  • We will store, and dispose of, any of your records regarding, including electronic files and communications, in a manner that promotes confidentiality, security and privacy, and complies with all applicable laws and agreements.

  • We will have a clear agreement with you and your  sponsors about the conditions under which confidentiality will not be maintained (e.g. illegal activity, danger to self or others etc) and gain agreement to that limit of confidentiality where possible.

Introduction

This Privacy Policy applies to our website applications and services that link to this policy.   The purpose of this Privacy Policy is to provide you with information about how we use your personal data.  This Privacy Policy may be updated from time-to-time.  We maintain a last updated date at the bottom of this policy.

Topics:

  • Who is the Controller?

  • How do we collect your personal data?

  • How will we use your personal data?

  • Security - How do we store your personal data?

  • Marketing

  • Social Media Marketing

  • Cookies

  • Retention of your personal data.

  • Updating your personal data.

  • What are your data protection rights?

  • Supervisory Authorities.

  • Contacting us.

Who is the Controller?

The controller (formerly known as data controller) of your personal data is Smurfit Team Coaches (STC), The Ironworks, Ashford, Co. Wicklow, A67 X225, Ireland.  This is who we refer to in this Privacy Policy when saying "STC”, "we", "our" and "us" etc.

Due to the services we provide, we are not obliged to appoint a data protection officer.  However, you can contact us enquiry@smurfitteamcoaches.ie at any stage if you wish to exercise your rights. Please see the 'Your Rights' section below.

How do we collect your personal data?

In order to provide you with our services, you will need to provide basic information to support the services you use.  This will include personal data such as your name, address, email and contact details.   Given the nature of our services, you or your sponsor may also provide such information that relates to your job, for example your job title, function and the role/person to whom you report.

Where you contact us, we will process any personal data you provide in these communications.

Finally, we also use "cookies" and similar technologies which may collect certain information about you, such as your devices' IP addresses and online activity, some of which will constitute your personal data. You can learn more about the cookies we use in the 'Cookies' Policy.

How will we use your personal data?

In accordance with data protection laws, we will only process your personal data when we have a lawful basis for doing so in respect of your personal data. We process your personal data if: (i) it is necessary to provide services to you under the performance of the contract we have with you; (ii) you have given your consent; or, (iii) it is in our legitimate interests to process your personal data, provided that none of these interests prejudice your own rights, freedoms and interests.

With the exception of limited circumstances, we do not process special categories of personal data about you (such as personal data relating to your health, ethnicity, religion, political persuasion, trade union membership or sexuality). For the circumstances in which we process special categories of personal data, we have set out the additional lawful basis required in italics below.

The following is a list of the purposes for which we process your personal data, and the lawful basis on which it carries out such processing:

Purpose

Lawful Basis

To set-up, administer and manage your account 

Necessary for the performance of a contract

To provide you with our services (including consensual diagnostic tools))

Necessary for the performance of a contract

To receive and respond to your communications and requests

Necessary for the performance of a contract if the communication relates specifically to our services, otherwise legitimate interests 

To perform a meaningful engagement and exchange of information pertaining to the service 

Consent

To identify any breach of our terms of use (coaching agreement)

Necessary for the performance of a contract

To carry out marketing campaigns 

Legitimate interests of better understanding the products and services that our clients most enjoy 

To send offers and promotions relating to our services that you may be interested in 

Consent

Sharing: To share your personal information with other members of the Group who assist in providing the services to clients 

Legitimate interests to allow us to provide services

Cookies: To operate our websites and mobile applications, including allowing you to interact with our websites and mobile applications and to recall selections as you move between pages 

Legitimate interest of using a website with at least standard functionality to provide our services

Cookies: To analyse your use of our website, monitor our web audience and populate certain content on our website in line with your usage 

Consent

Cookies: To track your journey to and from our website so we can understand how clients come to and from our website and give effect to any commercial arrangements 

Consent 

Certain conditions under which confidentiality will not be maintained (e.g. illegal activity, danger to self or others etc)

Public interest i.e. to prevent harm

In addition to the purposes set out above, we may also process your personal data for other purposes that we deem compatible with those listed above. We will update this Privacy Policy accordingly, when we do this.

Please note that the lawful bases set out above are those which will primarily apply although it is possible that a change in circumstance may result in a change in lawful basis.

We may also disclose your personal data in the following circumstances:

  • when required by applicable law or regulation (disclosure to a governmental, regulatory or enforcement authority);

  • in order to defend ourselves legally and/or in relation to legal proceedings; and

  • whilst negotiating a takeover, purchase or merger, and pursuant to the same.

Security

Security of your personal data is of the utmost importance for STC.  Accordingly, we will take all appropriate security, technical and organisational measures to ensure that your personal data is kept secure and to prevent the theft, loss or unauthorized access to your personal data.

We will store, and dispose of, any records regarding clients, including electronic files and communications, in a manner that ensures confidentiality, security and privacy, and complies with all applicable laws and agreements.

Marketing

We may perform marketing with organisations that contract with us.  Though, we do not target market to individuals we provide our services to. 

Social Media Marketing

We do not share personal information in social media articles and posts we may deliver (e.g. LinkedIn, Twitter).  In limited circumstances where we request your permission to share personal information, we will only do so with your express consent.   You also have the option to withdraw your consent.  Please see your rights below.

Cookies

Almost all websites and applications you visit, including our websites, will use cookies in order to improve your user experience by enabling that website and/or application to 'remember' you, either for the duration of your visit (using a 'session cookie') or for repeat visits (using a 'persistent cookie').

In this Privacy Policy, we use the expression 'cookie' to refer to cookies and similar technologies we use to store information (such as web beacons). A cookie is a simple text file that is stored on your computer or mobile (or other) device by a website's server, and only that server will be able to retrieve or read the contents of that cookie.

Cookies are used to improve your use of a website or application, for example through letting you navigate between pages efficiently and storing your preferences. Cookies make the interaction between you and the website faster and easier. If a website or application doesn't use cookies, it will think you are a new visitor every time you move to a new page on the website. Cookies can also be used to enable targeted advertising and analyzing your browsing of a website.

For further information, visit www.allaboutcookies.org

How do we use cookies?

Our Company uses cookies in a range of ways to improve your experience on our website, including:

  • Keeping you signed in

  • Understanding how you use our website

How to manage cookies

You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

The Our Company website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.

Retention of your personal data

We retain your personal data for the least amount of time required for our engagement with you as a client and up to a maximum of two years from date of last engagement. Our Company keeps its privacy policy under regular review and places any updates on this web page.

Updating your personal data

You can update your personal data at any time via email at enquiry@smurfitteamcoaches.ie.  We request that when your personal data changes you let us know as soon as possible. 

Your rights

You have the following rights in relation to your personal data:

  • a right to access your personal data. This includes receiving confirmation on whether your personal data is being processed, why it is being processed and the personal data being processed.

  • a right to rectification of inaccurate personal data or updating of incomplete personal data.

·        a right to erasure (also known as the right to be forgotten) of personal data under certain circumstances, including where you (i) withdraw consent previously provided, (ii) objects to STC’s processing for its own legitimate interests or (iii) where STC’s processing of the personal data is unlawful. In the case of unlawful processing, you may request that this processing is restricted rather than the personal data being erased.

 

The below rights are available to you.  However, they are not applicable to the processing we perform;

  • a right to data portability i.e. to receive your personal data in a portable format or, subject to it being technically feasible, have us transfer your personal data directly to a third party. This right applies where processing is taking place based on consent or for the performance of a contract.

  • a right to object to the processing of personal data, where such processing is being conducted for the purpose of (a) direct marketing; (b) establishing, exercising or defending ourselves or others from legal claims; or (c) Our legitimate interests where we cannot demonstrate its interests override your interests and rights. Please note, restriction on processing may be requested while an investigation of legitimate interests takes place. You shall have the right to obtain from the controller restriction of processing in limited circumstances

  • a right not to be subject to decisions taken solely on the basis of automated processing of personal data of an individual (i.e. no human involvement in the decision) which produce legal effects or have similarly significant effects unless permitted by law

 

If you are unsure about your rights or are concerned about how your personal data may be processed, you should contact us on enquiry@smurfitteamcoaches.ie

If you would like to exercise any of your rights then you can do so by contacting us at enquiry@smurfitteamcoaches.ie.  Please be aware that while we will try to accommodate any request you make in respect of your rights, they are not absolute rights. This means that we may have to refuse your request or may only be able to comply with it in part.

When you make a request in respect of your rights, we will require proof of identification. We may also ask that you clarify your request. We will aim to respond to any request within one month of verifying your identity, but it may take longer (we will notify you if this is the case). If we receive repeated requests, or have reason to believe requests are being made unreasonably, we reserve the right not to respond.

Supervisory authorities

If you have any complaints you have the right to contact your own national data protection supervisory authority however we do ask that you contact us in the first instance to allow us the opportunity to address your concerns.

How to contact us

If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that Our Company has not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office.



Policy last revised: 10 December 2021