Privacy Policy.

This Privacy Notice provides information about how Fónua Limited, a company registered in Ireland under company registration number 267717 (“Fónua”, “we”, “our”, “us”) collects and processes the personal data of individuals (“you”, “your”) who visit and/or interact with our website and to all subsequent correspondence or communications with those people, whether by email, telephone or by post.

Fónua is a “controller” of your personal data. This means that we are responsible for deciding the purposes and means by which we use the personal data we hold about you. “Personal data” is any information by which you or any living person can be individually identified either directly or indirectly but does not include anonymised data. There are “special categories” of more sensitive personal data which require a higher level of protection.

As a controller, we must provide you with this Privacy Notice in accordance with Irish data protection laws, including the General Data Protection Regulation (EU) 2016/679 and the Data Protection Acts 1988 to 2018, as such laws may be updated from time to time (“Data Protection Laws”). In brief, this Privacy Notice explains:

what personal data of yours we hold and why we process it;
the legal grounds that allow us to process your personal data;
where we obtain your personal data, who gets to see it and how long we keep it;
your data protection rights; and
where to address queries or complaints.

This Privacy Notice does not form part of any contract, or offer to enter into a contract, with us. It may be amended by us at any time. We reserve the right to amend this Privacy Notice at any time, for any reason, without notice to you, other than the posting of the amended Privacy Notice on our website. We recommend that you check the website often, referring to the date of the last modification listed at the top.

It is important that you read this Privacy Notice so that you are aware of how and why we are using your personal data. Please see Section 9 and Section 11 for further information about your rights and how to exercise those rights.

WHAT PERSONAL DATA WE COLLECT ABOUT YOU

The personal data we collect about you depends on how you use our website. For example, we collect different types of personal data depending on whether you create a user account, purchase products or services or only browse the website. Typically, we collect and process the following kinds of personal data:

Identity and Contact Data includes your name, postal address, email address, telephone number and any personal data provided when contacting us;
Profile Data includes your username, password, login and user account details, previous purchases, preferences, feedback, reviews and survey responses;
Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
Technical Data may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
Usage Data includes information about how you use the website such as the services you view or search for, page response times, download errors, length of visits and page interaction information (such as scrolling, clicks and mouse-overs); and
Marketing and Communications Data includes your preferences in receiving marketing communications from us and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for various purposes. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Where we need to collect personal data by law, or under our Terms and Conditions, and you do not provide that personal data when requested, you may not be able to purchase products or services from us through our website. We will let you know at the time of collecting personal data from you whether you must provide the personal data to use the website or any of our services, and whether the provision of personal data requested by us is optional.

HOW WE COLLECT YOUR PERSONAL DATA

We may receive your personal data through various means including:

Direct interactions: You may give us your Identity and Contact Data, Profile Data and Transaction Data by creating and managing your user account, purchasing our products or services, selecting preferences, providing product reviews or other comments, filling in website forms, sharing product or service details or by corresponding with us by post, phone, email, SMS, social media or otherwise. This includes personal data you provide when you enter a competition, promotion or survey, give us feedback or contact us.

Automated technologies or interactions: As you interact with our website, we collect Technical Data and Usage Data including details of your device, browsing actions and patterns, searches, traffic data, web logs and other communication data and the resources that you access. We collect this personal data by using cookies, tacking codes, server logs and other similar technologies. Please see our Cookies Policy for further details.

Third party sources: We may also receive personal data about you from third parties, as set out below:

Technical Data from the following parties: analytics providers such as Google Analytics; SEMrush and others;
Identity and Contact Data and Transaction Data from providers of payment services such as Realex

HOW WE USE YOUR PERSONAL DATA

We have set out below a description of the ways we typically process your personal data and the legal grounds we rely on to do so.

Purpose / activity	Type of Data	Grounds for processing
To allow you to create and manage a user account on our website, including managing your profile, preferences, previous purchases, feedback, product/services reviews and survey responses, and so we can conduct profiling based on the preferences you choose in your user account to ensure you receive relevant content.	· Identity and Contact Data · Profile Data · Transaction Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary for our legitimate interests of enabling users to create and develop personalised accounts, to facilitate purchases and recording of product and service preferences, for running our business and to develop new business.
To deliver your orders to you, to send you delivery updates by email or SMS, to contact you by email, telephone and/or SMS to arrange or rearrange delivery, to manage product returns in accordance with our Terms and Conditions and other policies and to provide customer service and support.	· Identity and Contact Data · Transaction Data	Necessary for the performance of a contract with you. Necessary for our legitimate interests of providing you a good purchase experience.
Depending on your selected method of payment, to acknowledge payments from you, provide refunds and to keep a record of payments and transactions with us.	· Identity and Contact Data · Transaction Data	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation.
To respond to queries submitted through our websites, telephone, social media or other means and to manage our relationship with you including: (i) notification of changes to our services, Terms and Conditions, Cookies Policy, Privacy Notice or other policies; (ii) customer feedback, product review and survey facilities; (iii) complaints and disputes; (iv) administering your marketing and communication preferences; (v) administering your data protection, privacy and other rights.	· Identity and Contact Data · Profile Data · Transaction Data · Technical Data · Usage Data · Marketing and Communications Data	Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract. Necessary to comply with a legal obligation. Necessary for our legitimate interests for responding to queries, attracting new users and customers, running our business and to develop new business, keeping our records updated and to gauge consumer satisfaction with our services and/or the products they purchase.
To administer and protect our business, products, services, networks, systems, the website and data and property hosted on or made available through the website including implementing and monitoring security measures, troubleshooting, data and usage analysis, testing, system maintenance, support, reporting and hosting of data. To anonymise personal data for statistical purposes.	· Identity and Contact Data · Profile Data · Transaction Data · Technical Data · Usage Data · Marketing and Communications Data	Necessary for the performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests for running our business, network security, to identify and/or prevent fraud, to collate statistical information to enhance our services and business, and in the context of a business reorganisation or group restructuring exercise.
To use data analytics and similar technologies to monitor usage of the website, to measure the performance of the website and to optimise the website, to improve our services, marketing strategy and output, user interactions, relationships and experiences. We may also process information collected when you browse and use our website to set default options for you (such as language and currency).	· Technical Data · Usage Data	Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.
To make suggestions and recommendations to you about products that may be of interest to you, to deliver relevant content and ads to you on our website and third party websites and apps and to measure and understand the effectiveness of this. We may also observe the readership of our newsletters, blog postings and other publications.	· Identity and Contact Data · Technical Data · Usage Data · Marketing and Communications Data	Necessary for our legitimate interests to develop and improve our products and services, to grow our business, to inform our marketing and advertising strategy and output and to conduct marketing and advertising.
If you post comments about us, tag us or post photos to our social media pages we may process this information to highlight our products and branding or to respond to you.	· Identity and Contact Data · Profile Data	Necessary for our legitimate interests to develop our products and services and to gauge and react to consumer sentiment which helps us improve our products and services.

Generally, we do not rely on consent as a legal ground for processing your personal data although we will request your consent before (i) sending direct marketing communications to you by electronic means (e.g. via email); and (ii) before setting non-essential cookies or similar technologies on your device.

Marketing: We would like to send you information about our products, services, insights and offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by email and/or SMS. We will only ask whether you would like us to send you marketing messages when you subscribe to our mailing list on our website. You can unsubscribe at any time by using the ‘unsubscribe’ link in our marketing emails or the ‘STOP’ number in SMS. If you tell us you do not want to receive marketing messages it might take a few days for all our systems to be updated to reflect this. Please note that opting out of marketing messages will not stop service communications, such as order updates.

If you agree as part of our cookies framework, we will use certain technologies that allow us to see whether news updates and other communications we send to you have been viewed and read. As explained in the table above, we use this information for our legitimate interests to develop our products and services, direct market and grow our business.

Advertising: If you agree, we may use cookies and similar technologies that allow us to include ads for our products and services on other websites and apps, such as social media. The ads you see are based on information we hold about you or your previous use of our website (e.g. your search history and the content you read on our website) or on adverts you have previously clicked on. For more information on our use of advertising technologies and cookies, please see our Cookies Policy.

DISCLOSURE OF YOUR PERSONAL DATA

Except as set out in this Privacy Notice, we do not disclose to any third party personal data that we collect from you or you provide to us. We may have to share personal data with the parties set out below for the purposes set out in the table in section 4.

External third parties: Companies that provide us products and services. This includes companies that help us to deliver and fulfil your orders; marketing agencies and advertising partners; analytics companies; IT service providers (e.g. website hosting and support) and other professional service providers.
Public and Government Authorities: Entities that regulate or have jurisdiction over us. We will disclose personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities or in order to enforce a contract with you or to protect our rights, property or safety and/or that of our staff, website users and others.

Corporate activity: Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.

We require all service providers who we disclose personal data which we collect under this Privacy Notice to respect the security of personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

TRANSFERS OF YOUR PERSONAL DATA

In connection with our business and for administrative, management and legal purposes, we may transfer your personal data to jurisdictions outside of the European Economic Area. Where we need to transfer your personal data, we shall ensure that the transfer is lawful and that there are appropriate security arrangements. Please contact us if you would like further information about how we protect your transferred information.

SECURITY OF YOUR PERSONAL DATA

We have appropriate security measures in place to prevent personal data from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal data to those who have a genuine business need to know it. Those processing your personal data will do so only in an authorised manner and are subject to obligations of confidentiality. You recognise that no entity can keep data fully secure. If you have reason to believe that any of your personal data is no longer secure, please tell us immediately by contacting us using the information provided in contact us section.

RETENTION OF YOUR PERSONAL DATA

We endeavour to ensure that personal data is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. We generally retain personal data for as long as is required to satisfy the purpose for which it was collected. We are required to keep certain types of information for a specific period of time in order to comply with legal requirements. Some of your personal data may need to be retained because of circumstances such as a legal dispute or regulatory investigation, which would not normally be subject to retention.

YOUR DATA PROTECTION RIGHTS

Under certain circumstances, by law you may have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. This enables you to ask us to provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the personal data to perform a contract with you.
Right to withdraw consent. If you provided your consent to the processing of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you wish to withdraw your consent, we will take steps to ensure we no longer process your personal data for the purpose(s) you originally agreed to, unless we have another legitimate basis for doing so in law. Withdrawal of consent will not affect the lawfulness of processing based on consent before withdrawal.

In order to exercise one or more of your rights in respect of your personal data, please contact us in writing using the information provided in section 11 We will need you to provide us with information to identify you on our records, we will also need proof of your identity and address, and the information to which your request relates.

You have the right to make a complaint at any time to the Data Protection Commission, the Irish supervisory authority for data protection issues (dataprotection.ie). However, we would appreciate the chance to deal with your concerns before you contact the supervisory authority and therefore ask you please contact us in the first instance.

UPDATING YOUR PERSONAL DATA

You are responsible for notifying us of any changes to your personal data that you provide to us.

CONTACT US

If you have any questions about this Privacy Notice or wish to exercise any of your rights please contact us by emailing DataProtectionCommittee@Fonua.com