Privacy Policy 0518 — CFM Agency

CFM Agency data Privacy Policy

Introduction

Thank you for your interest in CFM Agency. Data protection is of a high priority for the management of our business and we strive to be completely transparent with how we collect and use information we gather about you on this site. Your privacy is important to us and we respect your preferences.

By visiting the website, you are accepting the practices described in this Privacy Policy. If you do not agree to the practices of CFM Agency, please do not access, view, visit, download, or otherwise interact with the website.

The processing of personal data, for example, the name, address, e-mail address, or telephone number of a data subject shall be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to CFM Agency.

By means of this Privacy Policy, our enterprise would like to inform the public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed by means of this policy, of the rights to which they are entitled.

Definitions

The data protection declaration of CFM Agency is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection policy, we use the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry, in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall follow the applicable data protection rules according to the purposes of the processing

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her

Name and address of the controller

The Controller, for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

CFM Agency (“CFM”)

Unit 4a Fingal Bay Business Park

Balbriggan

Co. Dublin

K32 KR44

Ireland.

Phone: 00353 1 906 6419

Email: info@cfm-agency.ie

Website: www.cfm-agency.ie

Access to your CFM Agency account

Access to your account is based on the understanding that this service is provided to allow you to store CVs, Covering Letters and apply for jobs through the CFM Agency website. Users must agree to the Terms and Conditions of use prior to registering with CFM Agency. CFM Agency may terminate access to your account at its own discretion. Inappropriate use of your account will result in access to your account being revoked.

Collection of general data and information

Purpose for collection of personal data

Personal data entered by the data subject is collected and stored exclusively for internal use and for the sole purpose of CFM Agency.

When using general data and information collected via the website, CFM Agency does not draw any conclusions about the data subject. Rather, this information is needed to:

deliver the content of our website correctly,
optimize the content of our website as well as its advertisement,
ensure the long-term viability of our information technology systems and website technology,
provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
By registering on the website, the IP address, which is assigned by the Internet service provider (ISP) and used by the data subject, plus date, and time of the registration are also stored. The storage of this data takes place to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offenses.
This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.
The registration of the data subject, with the voluntary indication of personal data, may be used by the CFM to offer the data subject information on relevant CFM products or services that may only be offered to registered customers.

Telephone Calls

CFM Agency does not collect Calling Landline Identification (CLI) or any other information on the origins of a call. We do not record or retain phone conversations.

Website Browsing

The website of CFM Agency collects a series of general data and information when a data subject or automated system calls up the website.

This general data and information are stored in the server log files. Data collected may include:

the browser types and versions used,
the operating system used by the accessing system,
the website from which an accessing system reaches our website (so-called referrers),
the sub-websites,
the date and time of access to the Internet site,
an Internet protocol address (IP address),
the Internet service provider of the accessing system
any other similar data and information that may be used in the event of attacks on our information technology systems.

CFM Agency analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process.

The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

CFM Agency App

This privacy policy governs your use of software applications, such as the CFM Agency App for mobile devices, which maybe created by CFM Agency or its technology partners.

By downloading the CFM Agency App you agree, and provide your consent, to the use of your data as set out below (subject to the preferences you indicated when registering for the CFM Agency App).

We will respect your right to privacy and treat all of the personal information you give to us as confidential when you register to download the CFM Agency App. This includes your name, email address and any other information you provide us through your account, when you contact us for help.

We may collect technical information in relation to your usage. This may include type of mobile device and operating system you use, a device identifier, IP address, IDFA, identity of your network operator, current location data (if you have enabled this for the CFM Agency App) and sessions (when you have the CFM Agency App open in either the foreground or background) which we may use to generate statistical usage data relating to the CFM Agency App.

We may use your information to:

- inform you of new products, offers or services
- understand your interests based on in-app behaviours to improve our products and services

CFM Agency does not sell, trade or rent your information. We will only share your information with third parties if we have your consent to do so or when they are providing a service for us. For example, a third party developer or an analytics company. Such third parties will only use that information in accordance with our instructions and not for their own purposes. Only aggregated, anonymised data is periodically transmitted to external services to help us improve our service.

When you use the CFM Agency App we may invite you to share content via email or via a social network. If you choose to share content then please be aware that the privacy and cookies policies of such third party sites govern the information you submit to them and we encourage you to read them.

Cookies

From offers and promotions to sound and video, the aim of this site is to be interesting, helpful and informative. We’re keen to find out what you like and dislike – your feedback plays a key role in helping us improve this site. We use many techniques to follow your use of the site and provide you with a customised experience. The main and best-known technique is by using what are known as 'cookies'.

What are cookies?

Cookies are small data files that a website will put on your device, which in turn sends information back to the website. They cannot affect your device, but they do collect information that can be used to enhance the site. For example, a cookie can remember the items that you have placed into a shopping basket, or it can ensure you get the information you requested. These are known as ‘session’ cookies, which expire as soon as you leave the site.

Other cookies can tell us if you come back. These are ‘persistent cookies’, which often expire after a period of time. They will remain on your device until you delete them. We use them to help customise the site – to do things such as display relevant information based on your visit.

Some cookies enable sites to work, while others help us learn about what people are browsing for.

How we use cookies

We use cookies to ensure you get the most from your visit. They improve your experience of the site because certain features work best with cookies. Feedback and information from the cookies can also help make the site better. By visiting this site, you agree to our use of cookies and other technologies.

Rest assured that the cookies we use do not store personal details.

Here are the main types of cookies and what they do:

- Strictly necessary - In brief: These cookies enable you to get the information or service you’ve asked for. They’re essential – without them, some services may not work.
- Performance cookies - In brief: These cookies collect information about the pages you visit, where you go most often and whether you see error messages. The information is only used to ensure a website works well. For example, we gather information to diagnose problems and issues. We then use it to make improvements and fix errors.
- Functional cookies - In brief: These cookies remember choices you’ve made to personalise the site. They may remember where you are so you can get tailored information, or remember changes you have made to help you browse, such as increasing the text size. For example, If you ask for services based on your location, we sometimes store a cookie so that next time you visit you won’t have to tell us again.
- Targeting or advertising cookies - In brief: These cookies collect anonymous information about your browsing habits which are then used to make advertising relevant to you. They remember if you have visited a website and share this information with advertisers. For example, for remarketing purposes, we might use DoubleClick Cookies. They help us tailor the advertisements you see on third party sites by understanding what interests you on our sites, such as the pages you view. We don’t combine this information with other personal information you provide with us. These cookies expire 30 days from when you last click on the advertisement. We limit advertising to certain sections of the website. These services are provided by our carefully selected and monitored partners, and we are committed to ensuring any information is used appropriately.

If cookies are disabled on your device you will still be able to use most of this site. However it may limit what you can do.

How you manage your cookies depends on your browser. To find out which browser you use:

- PC: open your browser and go to the Help menu and then click on the About option.
- Apple Mac: open your browser and go to the Apple menu and then click on the About option.
- Mobile device: check your settings.

If you would like to know more about cookies you can visit All About Cookies which explains in detail how they can work and can be managed.

Enquiries through our website

By inputting their contact details on the electronic contact forms on the website, users are taking to make an enquiry.

If a data subject voluntarily contacts CFM by e-mail or via the contact form on the website, the personal data transmitted by the data subject is automatically stored for relevant processing or contacting the data subject about the specified issue in question.

There is no transfer of this personal data to third parties.

Any emails sent to the company are forwarded to the relevant section or individual employee. 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 is within the bounds of the law. Unsolicited material of a criminal nature will be reported to the relevant authorities and blocked.

Storage of personal data

CFM Agency shall process and store the personal data of the data subject only for the period necessary to achieve the specified purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject.

If the purpose for which the data was originally collected no longer exists, or if a storage period prescribed by the European legislator or Irish legislator expires, the personal data is erased in accordance with legal requirements and as outlined in the company policy on data retention.

Rights of the data subject

Data subject requests for information and access to personal data shall be responded to by CFM free of charge, or, where applicable, in accordance with GDPR fee structure.

a) Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her is being processed.

If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact our Data Protection Officer or another employee of the company via the contact details provided at the end of this document.

b) Right of access

Each data subject shall have the right granted by the European legislator to obtain from CFM Agency confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

the purposes of the processing
the categories of personal data concerned
the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular, recipients in third countries or international organisations.

Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer

where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period
the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing
the existence of the right to lodge a complaint with a supervisory authority
where the personal data are not collected from the data subject, any available information as to their source
the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

If a data subject wishes to avail himself of this right of access, he or she may at any time contact our Data Protection Officer or another employee of the company.

c) Right to rectification

Each data subject shall have the right granted by the European legislator to request from CFM Agency without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact our Data Protection Officer or another employee of the company.

d) Right to erasure (Right to be forgotten)

Each data subject shall have the right granted by the European legislator to request from CFM Agency the erasure of personal data concerning him or her without undue delay, and the company shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

The personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
The personal data has been unlawfully processed.
The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the reasons applies, and a data subject wishes to request the erasure of personal data stored by CFM Agency, he or she may at any time contact our Data Protection Officer or another employee of the company.

The Data Protection Officer of CFM Agency or another designated employee shall promptly ensure that the erasure request is complied with immediately.

e) Right to restriction of processing

Each data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions are met, and a data subject wishes to request the restriction of the processing of personal data stored by CFM Agency, he or she may at any time contact our Data Protection Officer or another employee of the company. The Data Protection Officer of CFM Agency, or another employee, will arrange the restriction of the processing.

f) Right to data portability

Each data subject shall have the right to receive the personal data concerning him or her, which was provided to CFM Agency, in a structured, commonly used and machine-readable format.

He or she shall have the right to transmit that data to another controller without hindrance from CFM, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from CFM to another data controller, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

To assert the right to data portability, the data subject may at any time contact the Data Protection Officer designated by CFM Agency, or another employee of the company.

g) Right to object

Each data subject shall have the right to object, on grounds relating to his or her situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR.

CFM Agency shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.

If the data subject objects to CFM Agency to the processing for direct marketing purposes, CFM Agency will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her situation, to object to processing of personal data concerning him or her by CFM Agency for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may directly contact the Data Protection Officer of CFM Agency or another employee of the company.

h) Automated individual decision-making, including profiling

Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision:

is not is necessary for entering into, or the performance of, a contract between the data subject and CFM Agency, or
is not authorised by Union or Member State law to which CFM Agency is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests,
is not based on the data subject’s explicit consent.

If the decision

(1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or

(2) is based on the data subject’s explicit consent

CFM Agency shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact the Data Protection Officer of CFM Agency or another employee of the company.

i) Right to withdraw consent

Each data subject shall have the right to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact the Data Protection Officer of CFM Agency or another employee of the company.

CFM Agency, as the data controller shall, at any time, provide information upon request to each data subject as to what personal data is stored about the data subject. In addition, CFM Agency shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The data protection officer and employees of CFM Agency are available to the data subject in this respect as contact persons. Contact details are provided at the end of this document.

Legal basis for processing personal data

Art. 6(1)a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. That is to say, the data subject has given consent to the processing of his or her personal data for one or more specific purposes.

If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1)b GDPR.

The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of enquiries concerning our products or services.

If our company is subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1)c GDPR.

In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor was injured in our company and his or her name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1)d GDPR.

Finally, processing operations could be based on Article 6(1)f GDPR. This legal basis is used for processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company 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.

A legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

The legitimate interests pursued by the controller

Where the processing of personal data is based on Article 6(1)f GDPR, our legitimate interest is to carry out our business, which is the provision of IT business management solutions, in favour of the well-being of all our employees and the shareholders, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Period for which personal data will be retained

The criteria used to determine the period of storage of personal data is the respective statutory retention period. Alternatively, the retention period is that designated and documented as legitimate for the specified processing.

After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract.

Provision of personal data as statutory or contractual requirement

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions. Sometimes it may be necessary that to perform a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be performed.

Before personal data is provided by the data subject, the data subject may contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the performance of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

How to contact us

CFM Agency