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Cliffs of Moher Experience

Website Privacy Statement

1. Important information and who we are

At Cliffs of Moher Experience, we are committed to protecting and respecting your privacy. Cliffs of Moher Centre Designated Activity Company t/a Cliffs of Moher Experience, (a company incorporated in Ireland (registered number 406019) with a registered office at Lislorkan North, Co. Clare (“COME”)) is a wholly owned subsidiary of Clare County Council (with an address at Aras Contae an Chlair, New Road, Ennis, Co. Clare, V95 DXP2) (“CCC”, “us”, “we”, or “our”).

This Privacy Statement will let you know how we, CCC, look after the personal data which we collect from you when you visit our website (regardless of where you visit it from and including any data you may provide through our website) and/or use our products and services. This Privacy Statement also tells you about your privacy rights and how the law protects you. Our website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Statement together with any other privacy statement or fair processing policy/notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Statement supplements other notices and privacy policies and is not intended to override them.

2. Who is responsible for your personal data?

This website is operated by COME, a wholly owned subsidiary of CCC.

For the purposes of the EU General Data Protection Regulations (EU Regulation 679/2016) CCC is the controller and responsible for your personal data. COME acts as a processor of CCC in relation to the operation of this website.

Data Controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed, who/which make independent decisions in relation to personal data and/or who/which otherwise control the personal data.

Data Processors” are the people who or organisations which process personal data for and on behalf of the Data Controller.

CCC has appointed a Data Protection Officer to monitor compliance with our data protection obligations and with this Privacy Statement and related policies. If you have any questions about this policy or about our data protection compliance please Contact Us.

Third-party links. Our 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 policy of every website you visit.

3.The type of information collected

Personal data” means any information relating to an identified or identifiable natural person. Personal data can be factual (for example, a name, address or date of birth) or it can be an opinion about that person, their actions and/or behaviour.

Special categories of personal data” are particularly sensitive personal data which require higher levels of protection. These special categories regroup personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. We do not collect this type of personal data nor do we collect any information about criminal convictions and offences.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, nationality, title, image, audio, likeness and vehicle registration number (collected by automatic number plate recognition cameras or CCTV).
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us including payment and payment methods for the use of our car parking services.
  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, access time, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or when you use our guest wi-fi facilities.
  • Profile Data includes purchases or orders made by you, your interests, preferences and feedback.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 Statement.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

4. How do we collect your personal data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • make a booking on our website;
    • apply for our services;
    • interact with us on social media;
    • subscribe to our service or publications;
    • enter a competition, promotion or survey;
    • use our car parking services;
    • use our guest wi-fi facilities;
    • request marketing to be sent to you; or
    • give us feedback or contact us
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.cliffsofmoher.ie/cookie-policy/ for further details.
  • Third parties. We will receive Technical Data about you from the following third parties:
    • analytics providers such as Google based outside the EU;
    • advertising networks; and
    • search information providers
5. How do we use your information? 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • To contact you, if required, in relation to your communication or order or to respond to any other communication you may send to 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; or
  • Where we need to comply with a legal obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 Purpose/Activity  Type of Data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity Data
(b) Contact Data
Processing is necessary for the performance of our contract with you
Providing products and services which you have requested

To manage our relationship with you which will include:

(a) Registering your bookings

(b) Notifying you about changes to our terms or Privacy Statement

(c) Asking you to leave a review

(a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Technical Data
(f) Usage Data
(g) Marketing and Communications Data
 

Your consent

Processing is necessary for the legitimate interests of COME to grow its business, keep its records updated and study how customers use its products/services and that of our clients to receive COME’s products and services (only where your fundamental rights do not override such interests)

Processing is necessary for the performance of our contract with you

 

Administering billing, processing payments etc. in connection with the products and services we provide (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Usage Data
 

Your consent

Processing is necessary for the legitimate interest of COME to recover debts due to it including non-compliance of contracts between us (e.g., if there has been a non-payment or other breach of contract by you in relation to your use of the car park)

Processing is necessary for the performance of our contract with you

 

 

 Purpose/Activity Type of Data Lawful basis for processing including basis of legitimate interest
To comply with our legal and compliance obligations including with regard to record keeping and tax laws (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
Processing is necessary for compliance with a legal obligation to which we are subject
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity Data
(b) Contact Data
(c) Technical Data
Processing is necessary for compliance with a legal obligation to which we are subject

Processing is necessary for the legitimate interest of COME to run its business, provide network security and prevent fraud

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Usage Data
(e) Marketing and Communications Data
Your consent

Processing is necessary for the legitimate interest of COME to develop its services, grow its business and study how customers use its products/services (only where your fundamental rights do not override such interest)

 

 Purpose/Activity Type of Data Lawful basis for processing including basis of legitimate interest
For any purpose which may arise as necessary during the course of our providing products and services to you (a) Identity Data
(b) Contact Data
(c) Financial Data
(d) Transaction Data
(e) Technical Data
(f) Usage Data
(g) Marketing and Communications Data
Your consent

Processing is necessary for the performance of our contract with you

Processing is necessary for the legitimate interest of COME to manage its relationship with you, develop its services and grow its business (only where your fundamental rights do not override such interest)

Processing is necessary for compliance with a legal obligation to which we are subject

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Processing is 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 Enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(g) Marketing and Communications
Your Consent

Processing is necessary for the performance of our contract with you.

Processing is necessary for our legitimate interests in holding competitions,(to study how customers use our products/services, to develop and grow our business).

For Marketing ,promotional, publicity,editorial,general communication or record keeping Purpose,we may collect your image, audio and likeness(as captured via streaming or film recording made on the premises) (a) Identity
(b) Marketing and Communications
Processing is necessary for our legitimate interests (to promote and market the Cliffs of Moher  and to develop and grow our business)

Where we rely on consent as a legal basis, you may withdraw consent at any time by contacting us.  Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have purchased goods or services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

If you require further detail about the specific legal basis we rely on to process your personal data please do not hesitate to contact us.


6. Who we share your data with

We may share your personal data with the following parties in connection with our processing of your personal data for the purposes set out in the above table. These will include:

  • The Irish Revenue Commissioners, regulators and other authorities based in Ireland who require reporting of processing activities in certain circumstances; or
  • The COME; or
  • Vivaticket Ticketing Ltd, our service provider based in the UK for our visitor management, booking and payment system; or
  • Marketing agencies and platforms such as Dotdigital, Mailchimp and Core Optimisation; or
  • 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. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Statement.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party 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.

Under certain circumstances, COME may be required to disclose your personal data if we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.

7. Keeping your personal data secure

We take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. We limit access to your personal data to those employees, agents and other third parties who are required to have access to your personal data and where they have agreed that they are subject to a duty of confidentiality.

We have put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction.  We have procedures in place to deal with actual and suspected data breaches which include an obligation on us to notify the supervisory authority and/or you, the data subject, where legally required to do so.

8. Transferring personal data out of the EEA

There are circumstances in which we will have to transfer your personal data out of the EEA for the purposes of carrying out the services we provide to you. Where the need for such a transfer arises we will always ensure that there are appropriate safeguards in place to protect your personal data such as:

  • the European Commission has issued a decision confirming that the country to which we transfer the personal data ensures an adequate level of protection for the data subjects’ rights and freedoms. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  • appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism; or
  • you have provided explicit consent to the proposed transfer after being informed of any potential risks.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

9. For how long do we keep your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

 

10. Your data protection rights

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

  • Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
  • Request access to your personal information (commonly known as a “data subject access request“). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that 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 information which override your rights and freedoms.
  • Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
  • 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:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED

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 could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

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.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could 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.

11. Contact us

We have appointed a Data Protection Officer (“DPO”) to monitor compliance with our data protection obligations and with this statement and our related policies.  If you have any questions about this statement or about our data protection compliance, please contact the DPO as follows:

 Contact: Data Protection Officer
 Telephone: 0657086141
 Email:  dpo.flanagan@cliffsofmoher.ie
 Post:  Data Protection Officer
Cliffs of Mother Designated Activity Company
Unit 1
Deerpark west,
Ennistymon Enterprise Centre,
Ennistymon.
County Clare
V95 F2N5

 

In the event that you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority (the Data Protection Commission) who can be contacted via their website www.dataprotection.ie.

12. Updates to this Privacy Statement

Our Privacy Statement may change from time to time, and any changes to this Privacy Statement will be posted on the website and will be effective when posted. We may also notify you in other ways from time to time about the processing of your personal information.