GENERAL DATA PROTECTION REGULATIONS (GDPR)

 

The GDPR regulations are due to be implemented on 25th May 2018 and place requirements and responsibilities on both 37 West and its clients.

 

In terms of this legislation 37 West are defined as a ‘data processor’and you the client are a ‘data controller’. Under the legislation 37 West will assume legal obligations as a data processor to maintain records of personally identifiable information. As a data controller you should ensure your contract with us complies with GDPR.

 

The regulations apply to ‘personal data’which is defined as any information that directly or indirectly identifies an individual e.g. names, address, national insurance number and even identifiers such as IP address.

 

Under the legislation you should provide a suitable privacy notice as you are providing the data that is processed by us. Please update your privacy notice accordingly.

 

PRIVACY NOTICE

Introduction

37 West is committed to protecting and respecting your privacy. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us or a 3rd party on our behalf.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).

 

Who are we?

Under the legislation 37 West  is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are:

 

Management Team 

37 West 

37 Lower Newcastle Rd Galway 

Galway, Ireland

 

For data matters the data processor is General Manager 37 West 

 

The  purpose(s) of processing your personal data

We use your personal data for the following purposes:

 

Operate, monitor, evaluate and improve our products, services, websites, mobile applications, other digital assets and business.

Developing new products and services

Managing communications, assess effectiveness and optimisation of advertising

Functionality of our websites, mobile applications other digital assets

The categories of personal data concerned

With reference to the categories of personal data covered under the regulation we process the following categories of your data:

 

Typically  37 West collect :

 

1.    Title           

2.    First Name

3.     Company Address           

4.    Middle Name         

5.     Personal Email

6.     Surname

7 Employer Email        

8 Residential Address

9 Personal Numbers

10Job Title     

11. PPS Number 

12. Bank Details

13. Visa / Passports 

14. Next of kin details 

 

What is our legal basis for processing your personal data?

37 West processes your information under the following

 

Legitimate interests: some information is processed by 37 West as part of its legitimate interests which include: Fraud, risk assessment, due diligence, network and information security, suppressions and managing opting out of communications, profiling, direct marketing, monitoring, web analytics, cloud storage, acquisitions, updating customer details, lettings, sales, financial services and other core products and service provided by the data controller

Public interest: some information is processed in accordance with public interest such as relocations

Consent: where we process information under consent we will seek you clear and unambiguous consent prior to processing your data

Sharing your personal data

Your personal data will be treated as strictly confidential and will be shared only with 3rd parties as necessary for processing and under contract.

 

How long do we keep your personal data?

We will keep information for a reasonable amount of time in order to perform the purposes listed above.

 

We only keep your information for as long as necessary. We generally keep personal information for 7 years after last contact with you.

 

Providing us with your personal data

You are under no statutory or contractual requirement or obligation to provide us with your personal data, but failure to do so will have the following consequences:

 

An inability or severe restriction in providing you with ongoing relevant product and service updates at our restaurant.

 

Your rights and your personal data

Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:

 

The right to request a copy of the personal data which we hold about you;

The right to request that we correct any personal data if it is found to be inaccurate or out of date;

The right to request your personal data is erased where it is no longer necessary to retain such data;

The right to withdraw your consent to the processing at any time.

The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability), (where applicable, i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);

The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).

Automated Decision Making

We do not use any form of automated decision making in our business.

 

Further processing

If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.

 

Changes to our privacy policy

We will update this statement from time to time so we suggest that you review this statement at regular intervals. Where we undergo substantial changes to our privacy statement we will endeavor to inform you directly about these changes.