INTRODUCTION

Welcome to the Aqua Comms DAC (“Aqua Comms”) privacy notice.

Aqua Comms respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or access or provide us your details in connection with the Aqua Comms Focus Portal (“Portal”) and tell you about your privacy rights and how the law protects you.

1. PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Aqua Comms collects and processes your personal data through your use of this website and/or the Portal, including any data you may provide through this website when you elect to contact us to request further information or to subscriber to our newsletter or when you subscribe to or use the Portal.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Aqua Comms is made up of different legal entities which are subsidiaries of Aqua Comms DAC (“Aqua Comms Group”). This privacy notice is issued on behalf of the Aqua Comms Group so when we mention Aqua Comms “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Aqua Comms Group responsible for processing your data. Aqua Comms DAC is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Data Privacy Manager, Aqua Comms DAC, The Exchange Building, Foster Place, Dublin 2, Ireland.

Email address: privacy@aquacomms.com

You have the right to make a complaint at any time to your local supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the local supervisory authority so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 31 May 2024 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website and the Portal may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data is information (including opinions) which relates to an individual and from which he or she can be identified either directly or indirectly through other data which the firm has or is likely to have in its possession. These individuals are sometimes referred to as data subjects.

The type of data we collect and process falls into one of the following categories:-

• personal data relating to subscribers to our Portal, our newsletters and other promotional materials;
• personal data obtained and created in relation to sales enquires for our services or use of the Portal.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Contact Data includes name, company, address, email address and telephone numbers and any other information that you include in your message to us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or the Portal. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• subscribe to our service or publications;
• request marketing to be sent to you; or
• request more information on our services or solutions.
• Automated technologies or interactions. As you interact with our website or Portal, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties sources. This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the U.S. If the IP anonymization is activated, Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. In exceptional cases, the full IP address is sent to and shortened by Google servers in the U.S. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google.

4. HOW WE USE YOUR PERSONAL DATA

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

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity – Subscribers to our newsletters and other promotional material

Types of DataCollectionUseDisclosure Information such as name and business information (email address, job title, who you work for).

Additional information may be processed where it is provided by you, for example in correspondence, in connection with an event or in letting us know what areas you are interested in and when you wish to be contacted by us.
Our websites may also collect your device’s unique identifier, such as an IP address.

Data is collected in our CRM system when you register to receive our newsletters or marketing materials, updates etc or we otherwise receive your contact details.

Data may also be collected in the event that you contact us by email with a similar request.

You can contact us at any time to amend your information or preferences or to provide additional details.

You will also be provided with the option to opt out and/ or be removed from the CRM database with each marketing communication you receive from us.

Personal data will be used to:– complete any request you may make;– contact you with communications about updates, breaking news, newsletters and event invitations which we think are relevant to your interests and in line with your preferences;- make users’ experiences more efficient and understand how we can improve your browsing preferences; and- analyse what subjects are of interest to particular users so that we can improve the content in our newsletters and promotional material.Personal data:

– may be transferred worldwide to our affiliates, and to service providers who support the operation of our business;

– which is shared with service providers will be limited to that which is required for providing the service and will be adequately protected;

– will not be given to other third parties, apart from, in limited circumstances, such as, where we run a joint event and you elect to attend it.

Purpose/Activity – Subscription to and use of the Portal

Types of DataCollectionUseDisclosure Information such as name and business information (email address, job title, telephone, mobile number, who you work for).

Our Portal may also collect your device’s unique identifier, such as an IP address, location of user, time of access and username

Data is collected in our Portal when you register to receive access to the Portal

Additional personal data is collected in the Portal when supplied to us by you when you access and use the Portal.

You can contact us at any time to amend your information or preferences or to provide additional details.

Personal data will be used to:– allow you to access the Portal;- complete any request you may make using the Portal;– contact you with regard to contract management or use of the PortalPersonal data:

– may be transferred worldwide to our affiliates, and to service providers who support the operation of our business and/or the Portal;

– which is shared with service providers will be limited to that which is required for providing the service and will be adequately protected.

Purpose/Activity – Enquiries about our solutions or services

Types of DataCollectionUseDisclosure Information such as name and business information (email address, job title, who you work for).

Information processed for relationship management such as name, business information, financial information.

Our websites may also collect your device’s unique identifier, such as an IP address.

Data is collected in our CRM system when you register to request further information about our services or request a response from our sales team.

Data may also be collected by email in response to a query or through an RFP process.

All additional personal data is collected when supplied to us, or created by us in connection with a particular matter.

You can contact us at any time to amend your information or preferences or to provide additional details.

You will also be provided with the option to opt out and/ or be removed from our database with each marketing communication you receive from us

Personal data will be used to:– complete any request you may make;– contact you with regard to contract management or for the purposes of providing information to you in relation to our services and in connection with the sales lifecycle.Personal data:

– may be transferred worldwide to our affiliates, and to service providers who support the operation of our business;

– which is shared with service providers will be limited to that which is required for providing the service and will be adequately protected.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Aqua Comms Group for marketing purposes. We do not sell personal data about you to unrelated companies for their independent use.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. INTERNATIONAL TRANSFERS

Aqua Comms is incorporated in Ireland. Information collected via our website, through direct interactions with you, or from use of our help services may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and hosting of such information.

7. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting 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.

8. YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact the Data Privacy Manager, Aqua Comms DAC, The Exchange Building, Foster Place, Dublin 2, Ireland. Email address: privacy@aquacomms.com

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

9. DATA BREACHES

Whilst every effort and measure is taken to reduce the risk of data breaches, we have dedicated controls and procedures in place for such situations, along with the procedures that are required to make notification to the relevant supervisory authority and data subjects (where applicable).

10. HOW TO MAKE A COMPLAINT OR QUESTIONS

You should direct all questions or complaints relating to how Aqua Comms has process your personal data to the following:

Data Privacy Manager, Aqua Comms DAC, The Exchange Building, Foster Place, Dublin 2, Ireland.

Email address: privacy@aquacomms.com

31 May 2024

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