1. WHAT IS A PRIVACY STATEMENT AND WHY IS IT IMPORTANT
- We know your personal information is important to you and it is also important to I Wish Stem Company Limited by Guarantee (“I Wish”, “we”, “us”).This Privacy Statement has been developed to inform you about the privacy and security of personal data and to meet our obligations under the Data Protection Acts 1988 to 2018 and the General Data Protection Regulation (the “Data Protection Law”). Under Data Protection Law, personal data is information that identifies you as an individual or is capable of doing so (“Personal Data”).
- WHO CONTROLS YOUR PERSONAL DATA
For the purposes of the applicable data protection legislation, I Wish is the data controller. You will find our contact details in the “Contact us” section below.
- HOW WE GATHER PERSONAL DATA
We gather Personal Data when you:
- use iwish.ie(the “Website”) to sign our charter;
- have provided us with Personal Data for example by contacting us via email or through the Website;
- register to attend one of our events;
- sign our photography consent form;
- download and use the I Wish mobile application (the “App”).
- PERSONAL DATA WE MAY COLLECT AND PROCESS
We receive and store information you enter on the Website or give us in any other way. We may collect and process the following categories of Personal Data:
Information you give us
- full name;
- phone number;
- job title/ position;
- school number, name and address, roll number;
- your photograph and film footage if you attend our events;
- full name;
- phone number;
- e-mail address;
- job title/ position;
- your photograph;
- full name;
- e-mail address;
For more information on cookies, please read our Cookies Policy.
We may also process other information, which is not Personal Data within the meaning of Data Protection Law.
- HOW WE MAY PROCESS YOUR INFORMATION AND LEGAL BASIS
Except as disclosed in this Privacy Statement, we will not disclose Personal Data that we collect to any parties other than those with whom we partner or are affiliated with, without your consent. Except as disclosed below, we will not sell, share, trade, rent, or give away your Personal Data.
We may use your Personal Data to process any requests made by you for example, to sign the charter. We may also use information you provide to communicate with you about your interest in our events, to sign you up for our Alumni Network, to help us improve, operate and enhance your experience on the Website and in the App, to promote our events (including on our Website and social media accounts), for administrative purposes, and to enable third-parties to carry out technical or other functions on our behalf as well as any other purpose that we may disclose to you at the point at which we request your Personal Data.
When you contact us, we may request your affirmative, positive consent to use your contact information for marketing or other promotional purposes. In the event you do not consent to the use of your contact information for marketing or other promotional purposes, your data will not be used for those purposes. If you provide your consent but subsequently do not wish to receive notifications about related events or activities, you will be able to modify your preferences by following the instructions on any marketing correspondence.
Photographs and film footage are uploaded to the I WISH social media pages. As a result of this, it is possible that social media websites may take the images and film footage that we upload and use them for their own purpose in accordance with their respective terms and conditions of use. We have no control over the information that other websites or social media websites or plugins collect, store, or use.
We analyse precise and/or approximate location information from app users mobile device’s if they enable us to do so via their device settings. We use this data to determine if they are at the event location and allow the user to submit comments against each segment within the event.
We rely on the following legal bases under Data Protection Law in processing your Personal Data:
Legal Basis Example Compliance with legal obligations We may need to disclose Personal Data to comply with a request from law enforcement, or other government agencies or court order. Consent Where you have signed our charter, photography consent form, enrolled in our Alumni Network, downloaded the App, subscribed to our newsletter or opted in to receive information from I WISH.
- WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We disclose information to third parties only when it is necessary as part of activities or when there is a legal or statutory obligation to do so.
Governmental, regulatory, etc.
We may disclose your Personal Data to a governmental or regulatory body (including tax authorities and law enforcement agencies) in order to comply with a legal obligation or to any person pursuant to an order of a court or tribunal.
Professional Advisors and Experts
We may also disclose your information to our solicitors, auditors, insurance advisors and financial services advisors.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them.
- From time to time, we may also share Personal Data or non-personally identifiable information with third-parties that we have engaged to perform certain services in connection with the operation of certain aspects of the Website or the App, including to customise, deliver, measure, analyse, improve and support our Website or the App, content, advertising and layout, your interaction with those aspects, and to deliver more relevant messages to you. These third-party service providers are authorised to use Personal Data only if needed to perform their functions on our behalf and are required to maintain the security of your personal information.
We may disclose your personal information to third parties:
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation and agreements; or to protect the rights, property, or safety of I Wish or others.
- DATA RETENTION PERIODS
It is our aim to only hold your data for as long as this is necessary. The period for which we retain information varies according to the use of that information. In some cases, there are legal requirements to keep data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will retain information no longer than is necessary for the purposes for which the data were collected and processed (as described above).
Images and film footage of all students are retained for two years following their participation in an event.
The personal data we collect from you in the context of the Alumni Network is retained for as long as you remain a member of the Alumni Network.
We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access and use.
As effective as modern security practices are, no physical or electronic security system is entirely secure. The transmission of information via the internet is also not completely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the internet. We will continue to revise policies and implement additional security features as new technologies become available.
Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us. Any transmission of data is at your own risk. Once we receive your personal data, we use appropriate security measures to seek to prevent unauthorised access.
- TRANSFERS OF YOUR INFORMATION OUTSIDE OF THE EUROPEAN ECONOMIC AREA
We do not transfer any Personal Data outside of the EEA. However, certain third parties providing services to our Website may transfer data outside of the EEA for example, for storage purposes. If this changes at any point in the future, this Privacy Statement will be updated to take account of this change. We only engage reputable third parties that provide appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available.
- YOUR RIGHTS
As an individual, under EU law you have the right to request that we:
- provide you with information as to whether we process your data and details relating to our processing, and that we provide you with a copy of your data (‘access right’).
- rectify and/ or update any inaccurate data we might have about your without undue delay (‘right to rectification’).;
- the right to object to processing of data relating to you (‘right to object’).
- under certain circumstances, be restricted from processing your data (‘right to restriction’).
- under certain circumstances, erase your personal data without undue delay (i.e. the “right to erasure”). and
- under certain circumstances, furnish you with the personal data which you provided us with in a structured, commonly used and machine readable format (‘right to data portability’).
Where we process your data solely on the basis of your consent, you are entitled to withdraw your consent at any time. This will not affect the lawfulness of our processing before the withdrawal.
You also have the right to lodge a complaint with the Data Protection Commission at any time.
The exercise of your rights might be subject to certain conditions and we might require further information from you before we can respond to your request.
You may exercise your rights by contacting our Data Protection Champion at the address or e-mail address provided below.
- CHANGES TO THIS STATEMENT
We reserve the right to change this Statement from time to time in our sole discretion. If we make any changes, we will publish those changes on our website. At the bottom of this document you will find the date on which this Statement was last updated.
- CONTACT US
Questions, comments, requests and complaints regarding this Statement and the information we hold should be addressed to us at:
Data Protection Champion
Email address: email@example.com
Telephone number: 353 87 1722555
We endeavour to deal with all requests promptly and efficiently.
Last updated: [20/05/2020]