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    Privacybeleid

    Laatst bijgewerkt: 4 november 2020

    1. About us and our service

    We are Tourism Ireland Company Limited by Guarantee (“we”, “our”, “Tourism Ireland”) whose principal place of business is at 4th Floor Bishop's Square, Redmond's Hill, Dublin, D02 TD99, Ireland. This privacy policy (the “Policy”) refers to any information processed by this website, www.ireland.com (the “Website”) and in-person events which we organise or sponsor.

    Your privacy is of paramount importance to us. This Policy applies to this Website, applications and services related thereto and our in-person events (the “Service”). This Policy is designed to protect you, our users, by informing you what personal data is collected, how we will use the information about you, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of your personal information. Your use of the Website and any micro-sites is subject to your agreement with this Policy.

    In this Policy, the term “Personal Data” means 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, our possession, and includes personal data as described in Data Protection Law (as defined below).

    Any Personal Data that we collect from or process about you for the purposes described in this Policy is hereinafter referred to together as “Your Data”. Your Data is separate from and should be distinguished from User Uploaded Data (as defined below).

    We handle Your Data in accordance with Data Protection Law. “Data Protection Law” means the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and any other applicable law or regulation relating to the processing of Personal Data and to privacy in electronic communications such as the Data Protection Acts 1988 to 2018 and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 in Ireland (as amended and replaced from time to time). Where we offer our Service to users in the United Kingdom, “Data Protection Law” also includes laws and regulations relating to the processing of Personal Data and to privacy in electronic communications in the United Kingdom, including the GDPR as it applies in the United Kingdom (“UK GDPR”).

    We are a controller (as defined in Data Protection Law) in relation to any Personal Data which we collect from you through your or any other user’s use of the Service and the set-up of any account by you on our Website. This Policy sets out the basis on which any such Personal Data will be processed by us.

    You may be a data subject (as defined in Data Protection Law) or you may be a controller. When you are a controller in respect of the Personal Data of other data subjects, then you must comply with all of your controller obligations under Data Protection Law. When you are a controller, we and you act as independent controllers, unless agreed otherwise.

    2. What personal data do we collect?

    We fully respect your right to privacy in relation to your interactions with the Service and endeavour to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual’s information where we are legally entitled to do so. Information in relation to Personal Data collected by Irish entities is available on www.dataprotection.ie, the website of the Data Protection Commission in Ireland.

    Simply put, our function is to facilitate your efforts to find an Irish tourism product or service that suits you so the collection of personal information is limited and always voluntary. As a user of our Website, you may opt-in to receive information from us, in which case we will require certain personal data from you. This will include your name and email address, and we may also ask for your postal address if you request a brochure to be mailed to you. In all cases, you can be assured that we will only seek the most basic details needed to get the information you requested to you in a timely fashion. Website usage information is collected using cookies (see ‘5. Does Tourism Ireland Use Cookies or Other Identifiers?’ below and our Cookies Policy).

    We collect the following information from or about you when you use our Service:

    Account Information information such as your first and last name (including prefix or title), username and password, feedback, competitions and survey responses and your personal interests which you choose to provide, and information to verify your identity or age where necessary, e.g. date of birth, and information about the Service we provide to you.
    Contact Information information such as your home and/or business postal address, email address and phone number(s) and any other address information required to place brochure orders.
    Cookie Data data collected on your interaction with sites and mobile apps, including this Website, from cookies and similar tracking technologies (such as pixels, web beacons and social plugins) which collect user data, such as clicks, language and login preferences, device specifications, location and search history. Please see our Cookies Policy for further information on cookies and other identifiers and how we use them.
    Image Data photographs or film footage that have been taken of you by our photographers or third party photographers on behalf of Tourism Ireland if you are attending an event or similar function.
    Location Data data relating to your location (including real-time geographic location of your device) through your IP address, GPS, Bluetooth signals, nearby Wi-Fi access points, hotspot or telephone masts, if you use location-based features and turn on the location service settings on your device.
    Marketing Data information about you processed by our machine learning model (a computer programme that uses automated processing of data) to recognise patterns and make predictions based on your location and your interaction with our Website, our advertising on other sites and our newsletters (such as your browsing behaviour and when you tend to open newsletters), and also other websites that we do not own.
    Newsletter Information information provided by you when you opt-in to receive our newsletter.
    Social Media Data your handle, name, email address used to sign up from a social media account and other content from your profile that you make publicly available or send or receive through your social media account.
    Technical Information information from your visits to our Website (including internet protocol (IP) and login data, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access the Website or in relation to materials and communications we send to you electronically.
    Other Information information relating to you which you choose to provide to us in the course of the provision of the Service or otherwise such as User Uploaded Data (as defined below).

    Tourism Ireland may ask users for feedback (free text entry, quality ratings or similar) from time to time to help analyse the quality and performance of the Website. Information collected for this purpose is done so anonymously and is used to aid our understanding of customer needs and opinions only. We occasionally highlight specific quotes from individuals but this is done so without personally identifying the users.

    We endeavour to keep Your Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible. You can change your stated interests in respect of whether or not you wish to receive direct marketing from us by clicking ‘unsubscribe’ on any direct marketing electronic communication which you receive from us.

    Applications developed in connection with the Website for mobile devices will operate and capture information as set out above and are subject to this Policy. Applications developed by us but deployed on other platforms such as social media channels provide feedback to us on activity and usage specific to a user.

    Our Website is not intended for children and we do not knowingly collect personal data relating to children. If you are aged under 18, please get your parent/guardian’s permission before you provide Your Data to us/use the Service. If we receive notice or believe that we have been provided with Personal Data on anyone under 18, we will make reasonable efforts to remove such Personal Data from our records. We reserve the right to seek verification of your age where we deem it appropriate to do so.

    3. How and why do we use your data?

    Under Data Protection Law, we only use Your Data where we have a purpose for doing so and on any one or more of the following legal bases:

    (a) where you have given your consent,

    (b) to perform a contract with you,

    (c) to comply with our legal and regulatory obligations,

    (d) to protect the vital interests an individual,

    (e) to perform a task carried out in the public interest for which we are responsible or exercise official authority,

    (f) for our legitimate interests or those of a third party (except where your rights and interests override our legitimate interest).

    A ‘legitimate interest’ is when we have a business or commercial reason to use Your Data, e.g. our business purposes in providing the Service to you. We carry out an assessment when relying on legitimate interests, to balance our interests against your rights and interests. You can find out more information about our legitimate interests and this assessment by contacting us (see ‘14. How to contact us?’ below).

    We have set out below, in a table format, a description of all the ways we plan to use Your Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

    We sometimes process Your Data for more than one legal basis depending on the specific purpose for which we are using Your Data. Please contact us (see ‘14. How to contact us?’ below) for more information about the specific legal basis we are relying on to process Your Data where more than one ground has been set out in the table below.

    We use Your Data for the following activities:-

    Using our Service (including the Website, your My Ireland account or our Community)

    Purpose Categories of data Legal basis for processing and, where relevant, the basis of legitimate interests
    To respond to an enquiry from you. Account Information
    Contact Information
    Necessary for our legitimate interests (to respond to your enquiry at your request).
    To register you as a user of our Service (such as your My Ireland Account, our competitions or Community on our Website) through social networks. Account Information
    Contact Information
    Social Media Data
    Necessary for the performance of a contract with you.
    To contact you for administration reasons related to the Service (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us). Account Information
    Contact Information
    Depending on the circumstances:
    - Necessary for our legitimate interests (to provide you with administrative and security updates for using our Service and Website).
    - Necessary for the performance of a contract with you.
    To provide our Community discussion forum and modify or moderate contents therein in line with our Terms of Use, this Policy and in order to prevent misuse of the Service. Account Information Necessary for our legitimate interests (to deliver our Service).
    Purpose
    To respond to an enquiry from you.
    To register you as a user of our Service (such as your My Ireland Account, our competitions or Community on our Website) through social networks.
    To contact you for administration reasons related to the Service (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us).
    To provide our Community discussion forum and modify or moderate contents therein in line with our Terms of Use, this Policy and in order to prevent misuse of the Service.
    Categories of data
    Account Information
    Contact Information
    Account Information
    Contact Information
    Social Media Data
    Account Information
    Contact Information
    Account Information
    Legal basis for processing and, where relevant, the basis of legitimate interests
    Necessary for our legitimate interests (to respond to your enquiry at your request).
    Necessary for the performance of a contract with you.
    Depending on the circumstances:
    - Necessary for our legitimate interests (to provide you with administrative and security updates for using our Service and Website).
    - Necessary for the performance of a contract with you.
    Necessary for our legitimate interests (to deliver our Service).

    Surveys, events, social networking and our in-person events

    Purpose Categories of data Legal basis for processing and, where relevant, the basis of legitimate interests
    To publicise Tourism Ireland’s activities through our media channels, including social media through photographing/filming event or similar function. Image Data Necessary for our legitimate interests (to promote our business)
    In such instances, Tourism Ireland will, where possible, minimise any potential risk by making clear that photography will be taking place, either verbally or visually, thereby allowing attendees the opportunity of making it known that they do not wish to be photographed.
    To enable you to enter our competitions or complete a survey. Account Information
    Contact Information
    Depending on the circumstances: -
    Necessary for the performance of a contract.
    - Where you have given your consent (to Your Data being shared with our partners where competitions or surveys are jointly run by us and our partners).
    Purpose
    To publicise Tourism Ireland’s activities through our media channels, including social media through photographing/filming event or similar function.
    To enable you to enter our competitions or complete a survey.
    Categories of data
    Image Data
    Account Information
    Contact Information
    Legal basis for processing and, where relevant, the basis of legitimate interests
    Necessary for our legitimate interests (to promote our business)
    In such instances, Tourism Ireland will, where possible, minimise any potential risk by making clear that photography will be taking place, either verbally or visually, thereby allowing attendees the opportunity of making it known that they do not wish to be photographed.
    Depending on the circumstances: -
    Necessary for the performance of a contract.
    - Where you have given your consent (to Your Data being shared with our partners where competitions or surveys are jointly run by us and our partners).

    Providing you with our brochure, newsletter and other marketing based on your preferences and interests

    For more information on our personalised marketing communications, please see ‘6. What about Marketing and Advertising?’ below.

    Purpose Categories of data Legal basis for processing and, where relevant, the basis of legitimate interests
    To send you our brochure by post where requested by you. Contact Information Depending on the circumstances:
    - Your consent where you have requested to receive our brochure.
    - Necessary for the performance of a contract with you.
    To register you to receive, and send you by email, our newsletters. Account Information
    Contact Information
    Your consent to receive our newsletters.
    To provide you personalised content in our Website, newsletter and advertising based on a profile drawn from your location and your previous interactions with our Website, our newsletters or advertising. Account Information
    Contact Information
    Cookie Data
    Location Data
    Marketing Data
    Newsletter Information
    Technical Information
    Your consent:
    - as given through the ‘Manage Cookies’ - Please see our Cookies Policy for further information cookies and other identifiers and how we use them.
    - to receive our newsletters.
    - to advertising and marketing cookies on other sites which show you our advertising.
    Purpose
    To send you our brochure by post where requested by you.
    To register you to receive, and send you by email, our newsletters.
    To provide you personalised content in our Website, newsletter and advertising based on a profile drawn from your location and your previous interactions with our Website, our newsletters or advertising.
    Categories of data
    Contact Information
    Account Information
    Contact Information
    Account Information
    Contact Information
    Cookie Data
    Location Data
    Marketing Data
    Newsletter Information
    Technical Information
    Legal basis for processing and, where relevant, the basis of legitimate interests
    Depending on the circumstances:
    - Your consent where you have requested to receive our brochure.
    - Necessary for the performance of a contract with you.
    Your consent to receive our newsletters.
    Your consent:
    - as given through the ‘Manage Cookies’ - Please see our Cookies Policy for further information cookies and other identifiers and how we use them.
    - to receive our newsletters.
    - to advertising and marketing cookies on other sites which show you our advertising.

    Managing and protecting our business (including provision of the Website and Service)

    Purpose Categories of data Legal basis for processing and, where relevant, the basis of legitimate interests
    To administer, maintain the security of, and protect our business and this Website (including troubleshooting, detection of fraudulent or disruptive use of the Website, fixing errors, data analysis, testing, monitoring our technology tools and services, system maintenance, support, reporting and hosting of data). Account Information
    Contact Information
    Newsletter Information
    Technical Information
    Necessary for our legitimate interests (for running our business, provision of administration, IT services and Website security).
    To maintain the performance of and develop this Website and Service (including auditing and monitoring its use and functionality, providing and improving our Service to you and managing and administering our relationship with you). Account Information
    Contact Information
    Cookie Data
    Marketing Information
    Technical Information
    Location Data
    Necessary for our legitimate interests (to maintain, deliver and improve our Website).
    To meet or enforce legal rights or defend or undertake legal proceedings. Account information
    Contact Information
    Marketing Information
    Technical Information
    Location Data
    Depending on the circumstances:
    - to comply with our legal and regulatory obligations
    - in other cases, for our legitimate interests, such as protecting our business, rights and interests or those of another party
    Anonymisation for statistical/research purposes.
    To fully de-identify Personal Data through anonymisation for use by us for statistical and research purposes and to enhance our business model and in line with the principles of data minimisation.
    Once the anonymisation process is completed by us or our third party service providers who process your Personal Data as set out in this Policy, it is no longer Personal Data and Data Protection Laws do not apply to it.
    Any Personal Data held by us pursuant to this Policy Depending on the circumstances:
    - for our legitimate interests, such as protecting our business, rights and interests or those of another party, including data subjects
    - where compatible with the purposes for which the Personal Data was first collected.
    Purpose
    To administer, maintain the security of, and protect our business and this Website (including troubleshooting, detection of fraudulent or disruptive use of the Website, fixing errors, data analysis, testing, monitoring our technology tools and services, system maintenance, support, reporting and hosting of data).
    To maintain the performance of and develop this Website and Service (including auditing and monitoring its use and functionality, providing and improving our Service to you and managing and administering our relationship with you).
    To meet or enforce legal rights or defend or undertake legal proceedings.
    Anonymisation for statistical/research purposes.
    To fully de-identify Personal Data through anonymisation for use by us for statistical and research purposes and to enhance our business model and in line with the principles of data minimisation.
    Once the anonymisation process is completed by us or our third party service providers who process your Personal Data as set out in this Policy, it is no longer Personal Data and Data Protection Laws do not apply to it.
    Categories of data
    Account Information
    Contact Information
    Newsletter Information
    Technical Information
    Account Information
    Contact Information
    Cookie Data
    Marketing Information
    Technical Information
    Location Data
    Account information
    Contact Information
    Marketing Information
    Technical Information
    Location Data
    Any Personal Data held by us pursuant to this Policy
    Legal basis for processing and, where relevant, the basis of legitimate interests
    Necessary for our legitimate interests (for running our business, provision of administration, IT services and Website security).
    Necessary for our legitimate interests (to maintain, deliver and improve our Website).
    Depending on the circumstances:
    - to comply with our legal and regulatory obligations
    - in other cases, for our legitimate interests, such as protecting our business, rights and interests or those of another party
    Depending on the circumstances:
    - for our legitimate interests, such as protecting our business, rights and interests or those of another party, including data subjects
    - where compatible with the purposes for which the Personal Data was first collected.

    4. What about posts in the Community?

    Your Data is separate from and should be distinguished from User Uploaded Data. “User Uploaded Data” is data uploaded by you or others, for example, (i) through your account in our Community or other use of our Service or (ii) about us or our Service on social media. We strongly recommend that you avoid uploading any Personal Data in any User Uploaded Data. We reserve the sole right to review, edit or delete User Uploaded Data. We also moderate all User Uploaded Data in order to ensure that it does not contain Personal Data. Notwithstanding this, we are a Processor and you are the controller in respect of User Uploaded Data (to the extent that it includes Personal Data).

    If you are a controller in respect of any Personal Data of other data subjects contained in User Uploaded Data, then you must comply with all of your controller obligations under Data Protection Law in that regard. We strongly recommend that you avoid uploading any Personal Data of other data subjects in any User Uploaded Data.

    If Your Data, including User Uploaded Data, contains any material which may reasonably be deemed to be offensive, inappropriate or objectionable or otherwise engage in any disruptive behaviour in relation to the Service, we may remove such content and/or suspend the use of your account. We may also remove any such material from this Website, any micro-sites and any of our social media pages.

    Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, privacy, online safety, defamation or intellectual property, we may disclose Your Data to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Law.

    5. Do we use cookies or other identifiers?

    Our Website and promotional emails use certain cookies, pixels and other identifiers. Please see our Cookies Policy for more information on these cookies and other identifiers and why we use them.

    6. How we personalise our marketing messages for you

    Our core objective is to promote tourism to the island of Ireland. It is therefore very important to us to provide you with content and experiences about the island of Ireland as a holiday destination that are relevant to your interests.

    We do this by providing you with personalised advertising and other marketing messages (such as our competitions or surveys) relevant to your interest in visiting the island of Ireland drawn from a profile of your engagement with our Website, advertising and newsletters and the country in which you are located in circumstances where you have consented to such personalised advertising and other marketing messages.

    For more information on this data and how we collect it, see ‘Marketing Data’ in ‘2. What Personal Data do we collect?’ above.

    If you have registered through ‘My Ireland’, you can update your interests at any time through your ‘My Ireland’ registration, which will allow more accurate content-serving to you. Please also see our Cookies Policy for further information on cookies and other identifiers we use, including first and third party cookies, and how to opt-out and remove them.

    For more information on how we use Your Data for our marketing and advertising activities, the purposes for which process it and the legal basis we rely upon, please see “Providing you our brochure, newsletter and other marketing based on your preferences and interests” in ‘3. How and Why do we use Your Data?‘ above.

    7. What data protection rights so you have?

    As a data subject, you have the following rights under the Data Protection Law and we, as controller in respect of Your Data, will comply with such rights in respect of Your Data:

    • the right of access to Personal Data relating to you;
    • the right to update, or correct any mistakes in, Your Data;
    • the right to erasure (the right to be forgotten);
    • the right to object to our use of Your Data for direct marketing or for tasks carried out in the public interest or for our legitimate interests (including profiling) purposes;
    • rights in relation to automated decision taking;
    • the right to restrict or prevent Your Data being processed;
    • the right to have Your Data ported to another data controller;
    • the right to withdraw your consent; and
    • the right to lodge a complaint with a data protection supervisory authority.

    The rights available to you depend on our reason for processing Your Data. These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of Your Data or if you would like to exercise any of your rights, please contact us (see ‘14. How to contact us?’ below). If contacting us by telephone, post or email to exercise your rights, please:

    • provide enough information for us to identify you (e.g. name and email address); and
    • let us know which right(s) you want to exercise and the Personal Data to which your request relates.

    We will respond to any rights that you exercise within one month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular timeframe pursuant to Data Protection Law, we will respond within that timeframe.

    7.1 Right of access to Personal Data relating to you

    You may ask to see what Personal Data we hold about you and be provided with:

    • a summary of such Personal Data and the categories of Personal Data held (see ‘2. What Personal Data does Tourism Ireland collect?’ and ‘3. How and Why do we use Your Data?‘ above);
    • details of the purpose for which it is being or is to be processed (see ‘3. How and Why do we use Your Data?‘ above);
    • details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers (see ‘8. Who do we share Your Data with? ’ below);
    • details of the period for which it is held or the criteria we use to determine how long it is held (see ’12. How long do we keep Your Data?’ below);
    • details of your rights, including the rights to rectification, erasure, restriction or objection to the processing (set out in this ‘7. What Data Protection Rights do you have?’);
    • any information available about the source of that data (see ‘2. What Personal Data does Tourism Ireland collect?‘ above);
    • whether or not we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling (see ‘7.7 Your rights in relation to automated decision-making, including profiling’ below); and
    • where Your Data are transferred out of the EEA, what safeguards are in place (see ’9. What international transfers do we make with Your Data?’ below).

    Details in respect of the above points are all set out in this Policy; however, if you need further clarification, please contact us (see ‘14. How to contact us?’ below).

    Requests for Your Data should be made to us (see ‘14. How to contact us?’ below) specifying what Personal Data you need access to, and we may keep a copy of such request for our legitimate interests in managing the Service. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.

    There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Law.

    7.2 Right to update, or correct any mistakes in, Your Data

    You can require us to correct any mistakes in Your Data which we hold free of charge. If you would like to do this, please:

    • contact us or our Data Protection Officer (see ‘14. How to contact us?’ below);
    • let us have enough information to identify you (e.g. name, registration details); and
    • let us know the information that is incorrect and what it should be replaced with.

    If we are required to update Your Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.

    It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘14. How to contact us?’ below).

    7.3 Right to erasure (the right to be forgotten)

    You can ask us to erase Your Data where:

    • you do not believe that we need Your Data in order to process it for the purposes set out in this Policy;
    • you have given us your consent to process Your Data, you withdraw that consent and there is no other lawful basis for processing Your Data;
    • you object to our processing and we do not have any legal basis for continuing to process Your Data;
    • Your Data has been processed unlawfully;
    • You Data must be erased to comply with a legal obligation; or
    • the Personal Data have to be erased to comply with law.

    Where you have requested the erasure of Your Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it. Please note that the right to be forgotten will not apply where processing is necessary for:

    • exercising the right of freedom of expression and information;
    • compliance with a legal obligation, the performance of a task carried out in the public interest or in the exercise of official authority;
    • reasons of public interest in the area of public health;
    • archiving purposes in the public interest, scientific or historical research purposes or statistical purposes; or
    • establishment, exercise or defence of legal claims.
    7.4 Right to object to our use of Your Data for direct marketing or for tasks carried out in the public interest or for our legitimate interests (including profiling) purposes

    You have the right to ask us to stop using Your Data:

    • at any time where it is being used for direct marketing (including profiling); or
    • if we process Your Data (including profiling) because it forms part of our public tasks or is in our legitimate interests. We will comply with your objection unless there are compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. We may continue to process Your Data for other purposes that do not relate to performing our public tasks or pursuing our legitimate interests.

    If you would like to exercise your right to object to processing Your Data for direct marketing or any other purposes, you can do so by:

    • clicking on ‘unsubscribe’ in an email or e-newsletter you receive from us (this will be instantaneous); or
    • contacting us (see ‘14. How to contact us?’ below) (this can take up to 5 working days).

    We will provide you with information on action taken on a request to stop direct marketing - this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of Your Account.

    7.5 Right to restrict or prevent processing of Your Data

    In accordance with Data Protection Law, you may request that we stop processing Your Data temporarily if:

    • you do not think that Your Data is accurate (but we may start processing again once we have checked and confirmed that it is accurate);
    • the processing is unlawful but you do not want us to erase Your Data;
    • we no longer need the Personal Data for our processing; or
    • you have objected to processing because you believe that your interests should override the basis upon which we process Your Data.

    If you exercise your right to restrict us from processing Your Data, we will continue to process the Personal Data if:

    • you consent to such processing;
    • the processing is necessary for the exercise or defence of legal claims;
    • the processing is necessary for the protection of the rights of other individuals or legal persons; or
    • the processing is necessary for public interest reasons.
    7.6 Right to data portability

    In accordance with Data Protection Law, you may ask for an electronic copy of Your Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:

    • the processing is based on your consent or for the performance of a contract; and
    • the processing is carried out by automated means.
    7.7 Your rights in relation to automated decision-making, including profiling

    You have the right not to be subject to a decision based solely on automated processing and without human intervention where it produces legal effects or significantly affects you unless you have explicitly consented to such processing or where it is required by law, or is necessary for the performance of a contract between you and us.

    We do not make any such decisions based on Your Data.

    7.8 Right to withdraw consent

    If you have provided us with consent to process Your Data and no longer consent to our processing of Your Data (in respect of any matter referred to in this Policy as requiring your consent). You have the right to right to withdraw your consent at any time. You may request that we cease such processing by:

    • where your consent relates to receiving personalised marketing communications from us, you can opt-out of receiving further emails or e-newsletters by clicking ‘unsubscribe’ in the email or e-newsletter you receive from us (this will be instantaneous);
    • contacting us (see ‘14. How to contact us?’ below); or
    • where your request concerns your consent to cookies, by changing your preferences in ‘Manage Cookies’.

    Please note that if you withdraw your consent to such processing, it may not be possible for us to provide all or part of our Service to you. Withdrawing consent will not affect the lawfulness of our use of Your Data in reliance on that consent before it was withdrawn.

    7.9 Right to lodge a complaint

    If you do not think we have processed Your Data in accordance with this Policy, please contact us in the first instance (see ‘14. How to contact us?’ below). We hope we will be able to resolve any issues you may have. You also have the right to lodge a complaint with:

    • if you are in Ireland, the Data Protection Commission in Ireland (www.dataprotection.ie).
    • if you are in the UK, the Information Commissioner in the UK (https://ico.org.uk/).
    • the supervisory authority under Data Protection Law in the European Economic Area (“EEA”) country of your habitual residence, place of work or alleged infringement of Data Protection Law. For a list of EEA supervisory authorities and their contact details, please see here.

    8. Who do we share your data with?

    We will not share Your Data without your consent or unless required by law (except as set out in this Policy). If we are involved in corporate restructuring, Your Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of Your Data.

    We restrict access to Your Data to employees, contractors, and agents who need such access in order to operate, develop, or improve our Service. These recipients are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations.

    Where you have consented to direct marketing and targeting cookies, we work with third party media agencies and advertising networks, such as advertisers, publishers, social media networks, search engines, and digital content services working on their behalf, to improve the relevance of the marketing we suggest to you

    Where you choose to link your social media account to the Service, we will share Social Media Data with those social media sites.

    Where required to do so by law, we will share Your Data with An Garda Síochána or another law enforcement or judicial or regulatory authority.

    9. What international transfers with your data do we make?

    It is sometimes necessary for us to transfer (including transmission, storage and remote access) Your Data to countries outside the European Economic Area (“EEA”) or the UK. The EEA, UK and other countries outside the EEA have data protection laws that differ from the Data Protection Law, some of which may provide lower levels of protection of Personal Data or privacy rights.

    As we are based in Ireland and the United Kingdom, we will transfer Your Data to:

    • our affiliates located in Ireland, other countries in the EEA, the United Kingdom and other countries outside the EEA.
    • our contractors and service providers located in Ireland, other countries in the EEA, the United Kingdom or other countries outside the EEA. For example:
    • if you consent to our use of targeting cookies, Your Data (a unique identifier associated to you) will be sent to the United States. For more information on these recipients, see our Cookies Policy.
    • the jurisdiction from where you access our Service.

    Unless otherwise permitted by Data Protection Law, we will only transfer Your Data to a territory outside the EEA where an adequate or equivalent degree of data protection is assured. We will take all steps reasonably necessary to ensure that Your Data is treated securely. Such safeguards in place with regard to the transfer of Your Data to third countries include

    in the case of transfers subject to the GDPR:

    (a) the country is subject to an ‘adequacy decision’ which means it has been deemed to provide an adequate level of protection for Personal Data by the European Commission under Article 45 of the GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. For example, we rely on adequacy decisions for transfers to the United Kingdom and the United States

    (b) we enter into appropriate contracts with third parties incorporating standard contractual clauses approved by the European Commission under Article 46(2) of the GDPR together with any supplementary measures required appropriate to any risks in the transfer. For further details, see European Commission: Standard contractual clauses for data transfers between EU and non-EU countries. For example, we rely on standard contractual clauses for transfers to the following countries: United States.

    (c) there are other appropriate safeguards that comply with Chapter V of the GDPR in place, together with enforceable rights and effective legal remedies for you.

    (d) a specific exemption applies that is permitted by Article 49 of the GDPR.

    In the case of transfers subject to the UK GDPR:

    (a) the country is subject to an adequacy regulation which means it has been determined by the government of the United Kingdom to provide an adequate level of data protection under Article 45 of the UK GDPR. A list of countries the United Kingdom currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers from the United Kingdom to Ireland and other EEA member states.

    (b) there are other appropriate safeguards that comply with Article 46 of the UK GDPR in place, together with enforceable rights and effective legal remedies for you.

    (c) a specific exemption applies that is permitted by Article 49 of the UK GDPR.

    All information you provide to us is stored on our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our Service, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Service.

    For more information on transfers of Your Data, please contact us (see ‘14. How to contact us?’ below).

    10. What about linked services, third party websites and content?

    This Policy applies to websites and services that are owned and operated by Tourism Ireland. We do not exercise control over the websites or applications (including articles, videos or blogs) that may be linked from the Service. These other websites or applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Service that we provide may enable or assist you to access the website content of, correspond with, and purchase goods and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of Your Data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Service. We encourage you to familiarize yourself carefully with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

    11. How do we protect your data

    We do our utmost to protect user privacy through the appropriate use of security technology. We are bound by a strict security policy that mandates us to keep Your Data encrypted at all times using SSL and TLS encryption standards. Our servers are security patched monthly and undergo vulnerability scanning by a third party bi-annually, any risks identified are remediated as a priority. We restrict access to Your Data to employees, contractors, and agents who need such access in order to operate, develop, or improve our service. We require industry standard password rules and multi factor authentication to access our systems.

    We ensure that we have appropriate physical and technological security measures to protect Your Data. When we outsource any processes for the Services, we ensure that the service provider has appropriate security measures in place. However, our Service may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

    We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Data transmitted, stored or otherwise processed.

    We will notify you and any applicable supervisory authority (such as the Data Protection Commission or the Information Commissioner’s Office) of a suspected data security breach affecting Your Data where we are legally required to do so.

    12. How long do we keep your data?

    We do not keep Your Data for longer than necessary for the purposes for which we collected it unless we are required by law to do so. We retain Your Data as necessary to administer an account you have with the Service, to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Service.

    We generally keep Your Data for 3 years after you stop engaging with us, e.g. interacting with our newsletters or our Website. We then delete Your Data from our databases.

    For further information on the period for which we retain Your Data or the criteria we use to determine that retention period, please contact us (see ‘14. How to contact us?’ below).

    For more information on how long cookies and other identifiers are stored, please see our Cookies Policy.

    To maintain the performance of and develop this Website and Service (including auditing and monitoring its use, providing and improving our Service to you and managing and administering our relationship with you), we occasionally choose to retain certain information providing insights about the use of our Service in a depersonalised or aggregated form.

    13. Changes to this policy

    We may change this Policy from time to time and at our sole discretion. The date of the most recent revisions will appear on the top of this Policy. If you do not agree to these changes, please do not continue to use the Service to submit Your Data. If material changes are made to this Policy, we will notify you by placing a prominent notice on our Service or by sending you a notification in relation to this. We will not process Your Data in a manner not contemplated by this Policy without your consent.

    14. How to contact us?

    If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to dpo@tourismireland.com.

    You can contact us and our Data Protection Officer by post, email or telephone, if you have any questions about this Policy or Your Data, to exercise a right under Data Protection Law (see further under ‘7. What data protection rights do you have?’ above), or to make a complaint.

    Our Data Protection Officer’s contact details are: