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Privacy Policy and Data Protection Statement

This Data Protection Statement provides information about the ways in which Silver Sky 7 Horizons Limited (the Company) collects, stores and uses personal data relating to individual ls (data subjects). This Data Protection Statement relates to personal data received by the Company where data subjects contact, or request information from, the Company directly, and also personal data received by the Company indirectly, and as set out below.  


Who we are

Our website address is: https://sky7horizons.com. 

The Company was established in 2018 and is registered with the Company Register of Ireland.


General Data Protection Regulation (GDPR)

The GDPR came into force on 25 May 2018 and significantly changed data protection law in Europe, strengthening the rights of individuals and increasing the obligations on organisations.  The GDPR is designed to give individuals more control over their personal data. (A copy of the GDPR is available here).

The key principles relating to the processing of personal data under the GDPR are lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability (Article 5 of the GDPR). 

Although the GDPR is directly applicable as a law in all Member States, it allows for certain issues to be given further effect in national law.  In Ireland, the national law, which amongst other things, gives further effect to the GDPR, is the Data Protection Act 2018 (‘the 2018 Act’). (A copy of the 2018 Act is available here).


Processing of Personal Data By the Company

The Company processes personal data for a number of different purposes, which arise from its functions and services provided.

Some examples of the purposes for which the Company may collect personal data in accordance with its functions are:

  • Provision of offered services – data collected including contact information.  
  • Inquiries and investigations - including personal data received from data subjects directly;
  • Queries and concerns – including personal data received from individuals who have raised queries or concerns with the Company; 
  • Service providers and suppliers – including personal data obtained from service providers or suppliers engaged by the Company;
  • Job applications – including personal data received from persons applying for roles within the Company; and Conferences and events – including personal data relating to attendees at conferences and events organised by the Company.

What Personal Data does the Company Process

Personal data 

As set out above, the Company processes personal data. This includes, as set out above, personal data received by the Company where data subjects contact, or request information from, the Company directly, and personal data received by the Company indirectly.  

The personal data that we process includes (i) basic personal information, such as a data subject’s name / surname; date of birth; the company or organisation a data subject works for; (ii) contact information, such as a data subject’s postal address, email address and phone number(s); and (iii) any other personal data that is provided to the Company during the course of the performance of its functions.

Special category data 

The Company may also processes special category data. This includes, as set out above, special category data received by the Company where data subjects contact, or request information from, the Company directly, and special category data received by the Company indirectly. Such special category data may include personal data relating to racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data for the purpose of uniquely identifying a natural person; data concerning health; and data concerning a natural person's sex life or sexual orientation.

Data relating to criminal convictions and offences

In the course of performing its functions, the Company may also occasionally processes personal data relating to criminal convictions and offences. This includes, as set out above, personal data relating to criminal convictions and offences where data subjects contact, or request information from, the Company directly, and personal data relating to criminal convictions and offences received by the Company indirectly.  


How does the Company Collect Personal Data

Phone Calls To The Company:

The Company does not audio record or retain audio recordings of phone conversations.

Where an individual contacts the Company by phone, caller numbers are automatically stored on the recipient phone in the Company for a limited period of time in a list of inbound and outbound calls, but no further processing of this data (caller numbers) is carried out by the Company.   

During the course of dealing with a query, complaint or other matter, the Company may record personal data received by it during the course of phone calls in the form of notes made on the relevant case file.

Emails:

All emails sent to the Company are recorded, forwarded to the relevant section of the Company and are stored for the purposes of the matter/case file to which the email relates.  The sender’s email address will remain visible to all staff tasked with dealing with the query. 

Please be aware that it is the sender’s responsibility to ensure that the content of their emails does not infringe the law.  Unsolicited unlawful material, together with the details of the sender, may be reported to An Garda Síochána (local Police) and/or other relevant authorities and further emails from such recipients may be blocked.

Post:

All post received by the Company is scanned, forwarded to the relevant section of the Company and stored for the purpose of the matter to which the post item relates.  Original hard copy versions of post items are retained for a period of six weeks and are then confidentially destroyed thereafter. 
In addition to the scanned version of post items retained by the relevant section of the Company, a master scanned copy of all post received is retained for a period of 12 months.

Social Media: 

The Company may also receive personal data through its social media interactions on, for example: Twitter, LinkedIn and Instagram. The Company operates social media accounts in support of its functions (under Article 57, GDPR) to promote its services. Messages or posts received by the Company on these social media platforms are viewed by the Company but the personal data contained in the messages/posts is not logged or stored other than on the relevant social medial platform, and no further processing of such personal data is carried out by the Company. 

CCTV:

We do not operate closed-circuit television on our premises

Should we decide in the future to install any CCTV systems, the purpose for our processing of personal data collected by the CCTV in operation at our offices, as detailed above, is for security and safety.  The legal basis of the processing is Article 6(1)(f),GDPR, which allows us to process personal data on the basis that it is necessary for the Company’s legitimate interests. CCTV footage shall be retained by the Company for a period of 14 days.  

Website:

The Company website (www.sky7horizons.com) uses certain cookies. Our Website and Cookie Policy can be accessed below. 

If you request a password reset, your IP address will be included in the reset email. 


What is the Legal Basis for the Processing of Personal Data By the Company

The legal basis for the processing of personal data by the Company will depend on the legislative framework that applies and the purpose for which the processing is being carried out. 

GDPR 

Under the GDPR, the tasks which the Company may process personal data include,

(i) 

where the data subject has given consent to the processing of his or her personal data for one or more specific purposes (Article 6(1)(a) GDPR).  (An example of where this legal basis may apply is where the Company collects personal data for inclusion in contact lists arising from contact with media practitioners (journalists, PR representatives) and at conferences or events; 

(ii) 

where the processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR).  (An example of where this legal basis may apply is in the case of  the Company’s engagement with third party service providers); and

(iii) 

where the processing is necessary for the purposes of the legitimate interests or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data (Article 6(1)(f) GDPR).  Article 6(1)(f) will only apply to processing by the Company that is not carried out in the performance of its tasks. 


Who are the Recipients Of Personal Data Processed by the Company

Disclosure to third parties

Personal data collected by the Company is held confidentially and is not shared by the Company with any third parties, with the following exceptions: 

Where the sharing of the personal data is necessary for the performance by the Company of its functions.  

This may arise, for example, in the context of complaints handling, where the Company will usually disclose the complainant’s identity and the subject matter of the complaint to a third party against whom the complaint is made. This is required both for practicality (because without disclosing the identity of the complainant in this manner, it will likely be impossible for the Company to investigate the complaint) as well as to ensure procedural fairness.

For the purpose of legal proceedings. 

In the event that the matter or complaint in  question is brought before the Courts (whether the Irish Courts, the Court in the Member State of any other data protection supervisory authority or the Court of Justice of the EU), the materials, including any information, documents or submissions provided by an individual, may be made public in open court.

In the case of service providers or suppliers to the Company. 

The Company uses data processors to provide certain services to the Company. The Company requires such processors to abide by certain terms to protect any personal data which is processed by the service provider/supplier during the course of providing the service, in accordance with the requirements set out at Article 28(3) of the GDPR.     

How Long Does the Company Retain Personal Data

The retention periods for personal data held by the Company are based on the requirements of the data protection legislation set out above at Section 2 of this Data Protection Statement and on the purpose for which the personal data is collected and processed. For example, in the case of complaints, the Company will retain personal data (as contained on its case file) for as long as is necessary for the handling of the complaint and for any subsequent action that is required. 

The retention periods applied by the Company to personal data which it processes are also, in certain circumstances, based on legal and regulatory requirements to retain information for a specified period and on the relevant limitation periods for taking legal action.   

Your Data Protection Rights

Under data protection law, data subjects have certain rights. Subject to certain restrictions, which are set out below, you can exercise these rights in relation to your personal data that is processed by the Company.


The data subject rights have:
The right to be informed about the processing of your personal data;
The right to access your personal data;
The right to rectification of your personal data;
The right to erasure of your personal data;
The right to data portability;
The right to object to processing of your personal data;
The right to restrict processing of your personal data;
Rights in relation to automated decision making, including profiling.

Restriction of data subject rights in certain circumstances

Article 23 of the GDPR allows for data subject rights to be restricted in certain circumstances. In addition, the 2018 Act contains certain provisions dealing with the restriction of rights of data subjects, in particular Sections 59, 60 and 61, which give further effect to the provisions of Article 23.  General guidance in relation to the application of Article 23 and the related provisions of the Data Protection Act 2018 is available here

If you are dissatisfied with how we process your personal data, you have the right to complain to the Data Commissioners.  General guidance can be accessed here. 

Your Right To Complain

If you have any concerns in relation to the manner in which we process your personal data, you can contact us on dpo@sky7horizons.com.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.


Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided if you are using it. 


Cookies

You may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.


If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.


Using Our Website & Cookie Policy

This cookie policy relates to www.sky7horizons.com 

and any of its subdomains.

What is a cookie?

A cookie is a small text file that may be stored on your computer or mobile device that contains data related to a website you visit. It may allow a website “remember” your actions or preferences over a period of time, or it may contain data related to the function or delivery of the site. Cookies can be set by the owner of the website or in some cases by third party services the website owner allows to present other information, run content or provide other functionality such as analytics.


How are they used on this site?

www.sky7horizons.com  and its sub-domains uses cookies only for functionality that is strictly necessary for services that are explicitly requested by the user for their session as per Regulation 5(5), SI 336 of 2011 (the ePrivacy Regulations). 

This website uses session cookies. Session cookies are used to deliver the basic functions of a website i.e. to allow pages to remember technical changes or selections you may make between pages. Session cookies are temporary cookies and are generally erased when you close your browser.

 www.sky7horizons.com 

and its subdomains do not use any third party or persistent cookies.

By clicking on buttons or links to third party sites or services, you will be redirected to an external site, which has its own cookie and privacy policies over which we have no control.

Managing Cookies

Within your browser you can choose whether you wish to accept cookies or not. Different browsers make different controls available to you and so we provide links below to popular manufacturers' instructions on how you can do this. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use ("third party cookies"), or those from specific websites.


Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

This Cookie Policy forms part of our overall Privacy Statement


Changes to Our Privacy Policy and Data Protection Statement

Note: This Data Protection Statement is kept under regular review and is therefore subject to change. 

If you have any comments or queries in relation to this Data Protection Statement, please forward same to DPO on dpo@sky7horizons.com