When we talk about “Smart Ageing Ventures International,” “SAVI,” “we,” “our,” or “us” in this policy, we are referring to Smart Ageing Ventures International, the company which provides the Services.
If you have any questions about how your information gathered, shared, or used, please contact our data protection team via the ‘How To Contact Us’ facility referred to below
We will handle your Personal Data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Data Protection Acts 1988 and 2003 and Directive 95/46/EC, any other applicable law or regulation relating to the processing of personal data and to privacy (including the E-Privacy Directive and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“E-Privacy Regulations”), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and laws implementing or supplementing the GDPR, and laws amending or supplementing the E-Privacy Regulations).
INFORMATION WE COLLECT AND RECEIVE
We fully respect your right to privacy in relation to your interactions with the Services and endeavor to be transparent in our dealings with you as to what information we will collect and how we will use your information. As you use our services, apply for products, make enquiries and engage with us, information is gathered about you. Also, we only collect and use individual’s information where we are legally entitled to do so. Information in relation to Personal Data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commissioner (“DPC”)
1. Customer Data
The customer data we collect can include the following:
Identity & contact information – Name, copies of ID, contact details, cookies, email address, work, and personal phone numbers.
Financial details/circumstances – Bank account details, credit/debit card details, income details, personal guarantees provided, application processing and administration records, employment status and employment details, credit history, credit assessment records, credit data from credit registers, credit agency performance data and authorised signatories details.
We endeavor to keep Customer Data accurate and up to date. As such, you must tell us about any changes to such information that you are aware of as soon as possible.
2. Other information
Smart Ageing Ventures International also collect and receive the following information:
- Billing and other information. For Customers that purchase Services, Smart Ageing Ventures International may collect, and store billing address and we will have appropriate contracts in place with such third parties to safeguard your Customer Data.
- Services usage information. This is information about how you are accessing and using the Services, which may include administrative and support communications with us and information about the Services.
A cookie is a small text file that is placed on your device by a web server which enables a website and/or mobile app to collect data that will allow content improvements and targeted advertising.
The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.
WHY WE NEED CUSTOMER DATA
Smart Ageing Ventures International needs Customer Data in order to provide the Services you have engaged us to provide. If you do not provide the Customer Data, then we will be unable to provide the Services you have requested. We will not collect any Personal Data from you that we do not need in order to provide and oversee the Services we have agreed to provide you with.
HOW WE USE YOUR INFORMATION
We use your information to provide and improve the Services we provide. We will only process your Personal Data where we have a legal basis to do so. In general, our legal basis for processing your Personal Data will be in furtherance of the contract(s) that we have with you and/or where you have provided your consent.
1. Customer Data
Smart Ageing Ventures International may access and use Customer Data as reasonably necessary to (a) provide, maintain, and improve the Services; (b) as required by law and (d) as set forth in our agreement with the Customer or as expressly permitted in writing by the Customer in accordance with Customer’s instructions.
2. Other information
We use other kinds of information in providing the Services. Specifically:
- To understand and improve our Services. We carry out research and analyse trends to better understand how users are using the Services and improve them.
- To communicate with you by:
- Responding to your requests. If you contact us with a problem or question, we will use your information to respond.
- Sending electronic communications. We may send you administrative electronic communications relating to the Services or inform you about changes in our Services. These communications are made in our legitimate interest in accordance with Data Protection Legislation. In addition, we sometimes, with your consent, send electronic communications about new products/services or other news about Smart Ageing Ventures International. You can opt out of these communications at any time by contacting us (see ‘How To Contact Us’) below or by clicking the unsubscribe link in the electronic communication.
- Billing and account management. We use account data to administer accounts and keep track of billing and payments.
- Communicating with you. We often need to contact you for invoicing, account management and similar reasons.
- Protecting Customer Data. We work hard to keep the Services secure and to prevent abuse and fraud, and may contact you in this respect as necessary.
HOW LONG WE KEEP CUSTOMER DATA FOR
The length of time Smart Ageing Ventures International hold your data depends on a number of factors, such as regulatory rules and the type of service we have provided to you.
Those factors include:
- The regulatory rules contained in laws and regulations.
- Whether you and us are in a legal or some other type of dispute.
- Whether you or a regulatory authority asks us to keep it for a valid reason.
As a general rule, we keep your information for a specified period after the date on which a transaction has completed or you cease to be a customer. In most cases Smart Ageing Ventures International will keep Customer Data for seven (7) years, after which time it will be destroyed if it is no longer required for the lawful purpose for which it was obtained.
As a data subject, you have the following rights under Data Protection Legislation and we, as data controller in respect of Customer Data, will comply with such rights in respect of Customer Data:
- the right of access to Personal Data relating to you;
- the right to correct any mistakes in your Personal Data;
- the right to ask us to stop contacting you with direct marketing;
- the right to restrict or prevent your Personal Data being processed;
- the right to have your Personal Data ported to another data controller;
- the right to erasure; and
- the right to complain to the DPC if you believe we have not handled your Personal Data in accordance with Data Protection Legislation.
These rights are explained in more detail in Schedule A to this policy, but if you have any comments, concerns or complaints about our use of your Personal Data, please contact us (see ‘How To Contact Us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.
Withdrawal of consent
SHARING AND DISCLOSURE
1. Customer Data
Smart Ageing Ventures International may share Customer Data in accordance with our agreement with the Customer, including:
- With third party service providers and agents. We engage third party companies or individuals to process Customer Data as follows:
- Third parties we collaborate with to deliver services to you.
- Companies that provide support services for the purposes of delivering the service. These include IT service providers and legal advisors.
- Statutory and regulatory bodies.
2. Other types of disclosure
Smart Ageing Ventures International may share or disclose Customer Data and other information as follows:
- To comply with laws. To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal process.
- To enforce our rights, prevent fraud and for safety. To protect and defend the rights, property, or safety of Smart Ageing Ventures International.
THIRD PARTY WEBSITES
HOW DO WE PROTECT YOUR PERSONAL INFORMATION
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to Customer Data to employees, contractors and agents who need to know such Customer Data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Customer Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Customer Data transmitted, stored, or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Customer Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk.
We will notify serious data breaches in respect of Customer Data to the DPC or the equivalent authority in other jurisdictions, without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
- We have implemented appropriate technical and organisational measures that render the Personal Data unintelligible to anyone not authorised to access it, such as encryption; or
- We have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
- It would involve disproportionate effort, in which case we may make a public communication instead.
HOW TO CONTACT US
Schedule A – Data Subject rights under Data Protection Legislation
Right of access to Personal Data relating to you
You may ask to see what Personal Data we hold about you and be provided with:
- a summary of such Personal Data and the categories of Personal Data held (see Sections 1 and 2 above);
- details of the purpose for which it is being or is to be processed;
- details of the recipients or classes of recipients to whom it is or may be disclosed;
- details of the period for which it is held or the criteria we use to determine how long it is held;
- details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
- any information available about the source of that data;
- whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling; and
- where your Personal Data are transferred out of the EEA, what safeguards are in place.
Requests for your Personal Data must be made to us (see ‘How To Contact Us’ above) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing the Service. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible
There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Date requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your Personal Data or correct any mistakes in your Personal Data
You can require us to correct any mistakes in your Personal Data which we hold free of charge. If you would like to do this, please:
- email or write to us (see ‘How can you contact us’ above);
- let us have enough information to identify you (e.g. name, registration details); and
- let us know the information that is incorrect and what it should be replaced with.
If we are required to update your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How To Contact Us’ above).
Right to ask us to stop contacting you with direct marketing
We have a legitimate interest to send you electronic communications/direct marketing in connection with the Service and related matters (which may include but shall not be limited to newsletters, announcement of new features etc.). We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:
- email or write to us (see ‘How can you contact us’ above). You can also click on the ‘unsubscribe’ button at the bottom of the electronic communication. It may take up to 15 days for this to take place; and
- let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’.
Right to restrict or prevent processing of Personal Data
In accordance with Data Processing Legislation, you may request that we stop processing your Personal Data temporarily if:
- you do not think that your Personal Data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
- the processing is unlawful but you do not want us to erase your Personal Data;
- we no longer need the Personal Data for our processing, but you need the Personal Data to establish, exercise or defend legal claims; or
- you have objected to processing because you believe that your interests should override the basis upon which we process your Personal Data.
If you exercise your right to restrict us from processing your Personal Data, we will continue to process the Personal Data if:
- you consent to such processing;
- the processing is necessary for the exercise or defence of legal claims;
- the processing is necessary for the protection of the rights of other individuals or legal persons; or
- the processing is necessary for public interest reasons.
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:
- the processing is based on your consent or for the performance of a contract; and
- the processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us (please see ‘How To Contact Us’ above) to erase your Personal Data where:
- if you had given us consent to process your Personal Data, you withdraw that consent and we cannot otherwise legally process your Personal Data;
- you object to our processing and we do not have any legal basis for continuing to process your Personal Data;
- your Personal Data has been processed unlawfully or have not been erased when it should have been; or
- the Personal Data have to be erased to comply with law.
We may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e. where we have a legal justification to continue to hold such Personal Data). Where you have requested the erasure of your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC