PRIVACY POLICY Nephin Energy Limited registered in Ireland, No: 614570 This privacy policy explains how we will use any personal information which we collect about you when you use this website or correspond with us. As a company processing your personal data, we are regulated by the General Data Protection Regulation (GDPR). This page is intended to keep you informed about what we do with the personal data we process. ‘Personal data’, for the purposes of the GDPR, means any information from which you can be identified; it includes things like your name, e-mail address, telephone number and IP address. First of all, we’d like to assure you that we are committed to protecting the privacy of all our users. We will endeavour to ensure that the information you provide us with is kept secure and managed within the General Data Protection Regulations. If you are not happy with any aspect of how we collect and use your data, please let us know so we can try and resolve it for you. Should this not be resolved, you have the right to complain to the Information Commissioner’s Office (ICO), the Irish supervisory authority for data protection issues (www.dataprotection.ie). It is important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes by emailing us at info@nephinenergy.com WHAT INFORMATION WE WILL COLLECT ABOUT YOU We may process certain types of personal data about you as follows: Identity Data may include your first name, last name, username, title, date of birth and gender. Contact Data may include your billing address, delivery address, email address and telephone numbers. Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site. Usage Data may include information about how you use our website, products and services. We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data. HOW WE COLLECT YOUR PERSONAL INFORMATION We collect data about you through a variety of different methods including: Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you: request resources or marketing be sent to you; or give us feedback. Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy below for further details. Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below: Technical Data from the following parties: analytics providers such as Google based outside the EU; search information providers such as Google and BING based outside the EU How We Use Your Personal Information We will only use your personal data when legally permitted. The most common uses of your personal data are: Where we need to perform the contract between us. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Purposes for Processing Your Personal Information Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant. We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Purpose/Activity Type of Data Lawful basis for processing Performance of a contract with you To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Contact Necessary to comply with a legal obligation To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage DATA RETENTION 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. YOUR LEGAL RIGHTS Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to: Request access to your personal data. Request correction of your personal data. Request erasure of your personal data. Request transfer of your personal data. Right to withdraw consent. You can see more about these rights at: https://www.dataprotection.ie/docs/Information-for-Individuals/955.htm If you wish to exercise any of the rights set out above, please email us at info@nephinenergy.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 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. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, we cannot absolutely guarantee the security of your personal data. 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. THIRD PARTY LINKS This website 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. GENERAL If you have any questions about this privacy policy, you can contact info@nephinenergy.com or by post at 25-28 North Wall Quay, Dublin 1, Ireland at any time We reserve the right to change this policy at any time. However, we will not change the way we use your personal information without telling you in advance and giving you the chance to opt out of or prevent the new use of your information. Website Terms of Use | Privacy Policy | Cookie Policy Nephin Energy Limited registered in Ireland, No: 614570. Registered Address: 25-28 North Wall Quay, Dublin 1, Ireland. © Nephin Energy Limited, 2018. Website Design by Scapegoat Design. 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