Introduction
This policy outlines how we handle and use your personal information and informs you of your rights in relation to that information. Under the General Data Protection Regulation (GDPR) of May 2018 & The Data Protection Act 2018, Thorntons Recycling is the controller of the personal data we collect.
Thorntons Recycling ("we," "our," or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains why and how we use the personal information we obtain from you or others, who we share it with, and the rights you have in connection with how we use your information. Please read this policy carefully to understand our practices.
If you have any questions about how your data is processed, please reach out to our Data Protection Team at GDPR@thorntons-recycling.ie.
Personal Information We Collect About You
We at Thorntons Recycling collect information that you provide us with directly and information we gather from your visits to our website through cookies (please visit out cookie policy for more information on this).
In reference to information we collect directly from you, this includes:
• Name
• Address
• E-Mail Address
• Telephone Number
• Transaction records you have undertaken with us
• Your marketing preferences
• Payment & card details
How We Use Your Personal Information
We use your personal data for various purposes during your customer relationship with us.
These include:
Purpose |
Categories of Data Subject |
Personal Data Types |
Legal Basis |
To register you
for Thorntons services at your own request
|
Customer |
Name Email address Phone
number Payment details |
Performance
of a Contract |
To provide a product
or service purchased by you
|
Customer |
Name Address Email Address |
Performance
of a Contract |
Processing
payments and transaction |
Customer |
Name Email Financial Information
|
Performance
of a Contract |
Contact you
regarding Thorntons’ products and services which we believe could be on
interest to you
|
Customer |
Name Email Address Phone Number |
Consent |
Contact you
regarding service-related updates & reminders
|
Customer |
Name Email Phone Number |
Legitimate
interest |
New customer
welcome pack |
Name,
email, account number |
Name Email |
Legitimate
interest |
Where You Have Provided Consent
We will only ever contact you with marketing information if you have provided your consent (opted in). At any stage you can amend your marketing preferences with us by reaching out to GDPR@thorntons-recycling.ie.
You can also choose to receive communications from us via SMS text message and/or email.
Third Party Disclosure of Your Personal Data
We only share your personal information outside of our organisation in specific circumstances. When we do so, we will establish a contract that obliges recipients to protect your personal information, unless we are legally compelled to disclose such information. Any contractors or recipients engaged by us will be required to adhere to our instructions. We do not sell your personal information to third parties.
We may disclose your information to our third-party service providers (referred to as "Suppliers") for the purpose of delivering services to us or directly to you on our behalf. This includes for administration, financial, accounts, communication and App hosting purposes.
Transfers of Your Personal Data outside of Europe
We do not currently transfer your personal information outside of Europe. Should this change in the future, we will inform you and implement measures to safeguard your personal information.
Retention Periods
We have implemented a Retention Schedule that ensures your personal data is not retained for longer than necessary to fulfil its original purpose. For more information on our compliance with Storage Limitation please reach out to GDPR@thorntons-recycling.ie.
Your Rights as a Data Subject
Under the General Data Protection Regulation, you have specific rights as a Data Subject. We at Thorntons Recycling have developed a process to ensure you can exercise these rights at any stage. These Rights include;
• The Right of Access
• The Right to Rectification
• The Right to Erasure
• The Right to Restriction of Processing
• The Right to Object to Processing
• The Right to Data Portability
• The Right to Complain to the Supervisory Authority
To submit a request for Access, Rectification, Erasure, Restriction, Objection or Portability please submit a form through the following link.
Or email our Data Protection Team at GDPR@thorntons-recycling.ie
.
To lodge a complaint with the Data Protection
Commission Ireland please visit their website at www.dataprotection.ie
for more information.
Unsubscribing / Opting Out
From time to time, we may contact you with details about special promotional offers or products that we believe may interest you via email and/or SMS. If you do not wish to receive these communications, you can opt out in the following ways:
Please contact GDPR@thorntons-recycling.ie
Changes to Our Privacy Policy
Please check this page regularly for any changes to this policy.
You can contact us with any queries related to this policy or for any other reason by email, or phone.
Please email us at GDPR@thorntons-recycling.ie or call us on (01) 623 5133.
(We are currently updating our website's Privacy Policy)
This privacy policy and statement (“Privacy Policy”) describes the
information Thorntons Recycling (the “Company”) will collect from time to time
in order to accommodate the provision of our services to you, related
information requests and our intended use of that information.
The Company respects your right to privacy and will not collect any
personal information about you without your consent.
By viewing or using this website you accept and agree to all of the provisions
of this Privacy Policy.
Data Collection
For the purpose of ensuring the smooth operation of the Company’s waste
collection service (the “Service”), the processing of your payments for that
Service as well as any queries and/or other information requests you may have,
we will require and collect from you such personal data as your name, address,
telephone number, e-mail address and other contact and billing information.
Purpose
The personal data you provide to us will be used for the following
general purposes:
Disclosure
We may share your personal information with any member of our group,
which means any subsidiaries, any holding company and its subsidiaries, as
defined in the Companies Act 2014.
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; or in order to enforce or apply our terms and conditions
of the Service and other agreements; or to protect the rights, property, or
safety of the Company, our customers, or others. This includes exchanging
information with other companies and organisations for the purposes of fraud
protection and credit risk reduction.
We may also share aggregated, non-personally identifiable information
and de-identified data with our partners or others.
Transfers Abroad
We may transfer and maintain your data on servers located outside of the
European Economic Area (EEA) but only in or to such countries outside of the
EEA which have been approved by the European Union as providing adequate levels
of data protection.
Security
We will take commercially reasonably efforts to ensure that your data is
held on secure servers and that it has appropriate security measures in place
to prevent unauthorised access to, or unauthorised alteration, disclosure or
destruction of, your data and against their accidental loss or destruction.
We will never ask you for financial or sensitive information. Please be
aware, however, that despite our efforts, no security measures are perfect or
impenetrable and no method of data transmission can be guaranteed as entirely
securely.
We make no representations or warranties as to the security of any
information transmitted to or by us over the Internet.
Access, Update or Delete Your Data
If you wish to access, update or delete the personal data we hold on
file about you, please contact us by e-mail at info@thorntons-recycling.ie. A request to access or obtain
details or copies of such personal data may be subject to a prescribed fee.
If your account is closed or becomes inactive or suspended, we may maintain certain information for record-keeping and analysis purposes. While we may retain information for these purposes, we may, at our sole discretion, delete it for any reason at any time and are under no obligation to maintain it.
Withdrawal of Consent
We may use and process your personal information for the following purposes where you have consented for us to do so:
To contact you via email, online or by post (as you have indicated) with marketing information about our products, events, product launches, exciting offers and services.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see the ‘Access, Update or Delete your data’ section below for further details.
Right to Rectification
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified.
If you believe that we hold inaccurate personal data about you, then you can either update this information directly by emailing info@thorntons-recycling.ie Depending on the type of personal data you believe is inaccurate, we may ask you for further proof to ensure that the personal data is being corrected properly. If we are satisfied that the personal data is inaccurate, we will make the necessary changes.
Right to Restriction
You have a right to request that processing of personal data is restricted in certain circumstances. However, we shall still continue to process the personal data for storage purposes, for the establishment, exercise or defence of legal claims or with your consent.
Right to Objection
Where we are relying on legitimate interests as a legal basis to process your data, you have a right to object to such processing on grounds relating to your particular situation.
Cookies
This website uses cookies, [web beacons] and similar technologies. These
allow us to better understand the usage and traffic pattern of visitors and use
on our website and to enable certain functionality in our Service.
For more information about our use of cookies and how you can manage or
disable them, please see our Cookie Policy.
Third Party Material
We accept no liability howsoever arising for the content, accuracy or
reliability of any third party materials or websites, or any part thereof,
which may be referenced from time to time by link or other means at this
website or for the data collection and use practices or security measures
exercised by such third parties.
Assignment
We may assign or transfer information (including your personal data) to
a third party in the event of a sale, merger, insolvency, termination of
business operations, or transfer of all or substantially all of the assets
and/or liabilities of the Company. In each case, such third party shall be
obliged to undertake to use your personal data in accordance with the terms of
this Privacy Policy or on such other terms as may be separately agreed between
you and that third party. All commercially reasonably efforts will be made to
notify you in the event of such a transfer and provide you with an opportunity
to opt-out.
Changes to this Privacy Policy
Any changes made to this Privacy Policy from time to time will be
published at this website.
In the event any change to this Privacy Policy results in your personal
data being used in a way which is substantially different from that disclosed
to you at the time it was collected, we will use commercially reasonable
efforts to notify you to determine whether or not we may use your personal data
in this new way.
Contact Us
Any questions or complaints relating to this Privacy Policy should be
directed to:
Thorntons Recycling,
Unit S3B Henry Road, Parkwest Business Park, Dublin 12.
D12 AC2X
Email: info@thorntons-recycling.ie
Thorntons Recycling respects the privacy of all visitors to our website.
This cookie policy (the “Cookie Policy”) outlines our policy concerning the use
of cookies, [web beacons] and similar technologies.
We may update this Cookie Policy from time to time to reflect any
changes in technology or legislation or our data usage policies which may
affect the way in which cookies and similar technologies are used by us and how
you as a user, can manage them.
WHAT ARE COOKIES?
Cookies, [web beacons], and similar technologies are small text files
placed in your computer, tablet, mobile, or another device. They may collect
information such as your device identifier (IDFA) or IP address. This
information may be used to recognize when your device visits a particular
website or clicks on a particular link or website or when you open emails we
send you or links in them.
Cookie technology is customarily used to gather statistical information
and to analyze trends of use or access to a website. Typically, the information
generated by using cookie technology does not and cannot be used to identify
you as an individual, just the device you are using.
More information about cookies and how you can manage them can be found
at www.aboutcookies.org.
WHY WE USE COOKIES?
Cookies, web beacons, and similar technologies allow us to better
understand the usage and traffic pattern of visitors and use on our website and
to enable certain functionality on our services. Cookies also help us make your
experience on our website more efficient and more enjoyable.
WHICH COOKIES DO WE USE?
The cookies, [web beacons] and similar technologies that are used in
connection with our website can be categorized as follows:
Strictly necessary cookies
Strictly necessary cookies enable services that you have specifically
requested from us. We use a number of cookies that are essential to the
operation of certain services available via our website. For example, certain
Cookies enable you to log in to certain areas of our website or help ensure the
content of the pages you request loads quickly. Without these cookies, services
that you have asked for cannot be properly provided. We want you to understand
these are necessary cookies and why we use them; but, we do not need to get
your consent to use them on our website as we use these cookies only to provide
you with services that you have requested.
Functionality cookies
Functionality cookies allow our website to remember choices you make
while on our website such as:
The aim of functionality cookies is to provide you with a more personal
experience so that you do not have to reset your preferences each time you
visit our website.
We may also use functionality cookies to enable you to comment on an
article or provide enhanced services such as enabling you to view a video on
our website. You may disable any of these functionality cookies, but if you do
so, then various functions of our website may be unavailable to you or may not
work the way they were meant to work.
Performance analytics cookies
Performance analytics cookies collect information about how visitors use
our website, for example, which pages our visitors go to most often, and if
they get error messages on those pages. Performance cookies do not collect
information that identifies you as an individual; all information they collect
is aggregated and anonymous. The information gathered is only used to improve
how our website works.]
No targeted advertising
We do not use cookies to:
THIRD PARTY COOKIES
Third parties (including providers of external services like web traffic
analysis services) may also use cookies on our website, over which we have no
control. For example, we use Google Analytics to help us analyze how our
website is used. You can find out more about this website analytics tool here:
http://www.google.com/analytics/index.html. Google Analytics uses performance
cookies to track visitor interactions. By using cookies, Google Analytics can
tell us which pages our user's view, which are most popular, what time of day
our websites are visited, whether visitors have been to our websites before,
what website referred the visitor to our websites, and other similar
information. You can find out more about how Google protects your data in
Google’s privacy policy at https://policies.google.com/privacy.]
WEB BEACONS AND PIXELS
We may also use web beacons, pixels, or similar technology in our email
communications with you to determine if an email has been opened and acted
upon.
HOW YOU CAN MANAGE OR DISABLE COOKIES
[The first time you visit our website you will see a banner that asks
you to review our Cookie Policy, provides a link to this Cookie Policy and
explains that by using our website you are deemed to consent to the use of
cookies as described in this Cookie Policy.]
You can disable and/or delete all types of cookies by using your browser
settings. Cookies are generally easy to disable and/or delete but how you do so
varies from browser to browser. The "help" function within your
browser should tell you how to do it. The best way may be to close your browser
and then search for "cookie folder" or "cookie manager" or
simply "cookie".