Privacy and Cookies Policy

1. WHO WE ARE

We are Circet Networks (Ireland) Limited, incorporated and registered in Ireland with company number 303841, whose registered office is at GHQ, Cloverhill Industrial Estate, Clondalkin, Dublin 22 (hereinafter referred to as Circet, we, us or our, and which terms shall also include our Affiliates. Affiliates means any entity that directly or indirectly controls, is controlled by, or is under common control with us. Control, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity). We are leading providers to the telecommunications, transport infrastructure and power sectors in Ireland and the UK (the Business).

Your privacy is of paramount importance to us. This privacy and cookies policy (the Policy) applies to the Business, the www.circet.ie website (the Website) and services related thereto (the Service). This Policy is designed to protect you, our users, by informing you what Personal Data is collected, how we will use Your Personal Data, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of Your Personal Data. Your use of the Website is subject to your agreement with this Policy.

In this Policy, the term Personal Data means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes Personal Data as described in Data Protection Laws (as defined below).

Please read the following carefully. Use of our Website or otherwise accepting the terms of this Policy indicates that you have reviewed this Policy and have agreed to be bound by it. If you do not agree to these terms you must leave our Website immediately. If you no longer consent to our processing of Your Personal Data, you may request that we cease such processing by contacting us. See ‘How to Contact Us’ below.

We will handle Your Personal Data in accordance with Data Protection Laws. Data Protection Laws means all applicable laws concerning data protection and privacy in electronic communications including (1) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “GDPR”); (2) the Data Protection Acts 1988 to 2018 and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 in Ireland; (3) the Data Protection Act 2018 (“UK DPA”) and the GDPR (as retained by section 3(10) (as supplemented by section 205(4)) of the UK DPA) (“UK GDPR”), as such legislation shall be supplemented, amended, revised or replaced from time to time and all guidance and codes of practice issued by a relevant supervisory authority, such as the Irish Data Protection Commission (“DPC”) and/or the Information Commissioners Office (“ICO”), from time to time and which are applicable to a party.

We are a controller (as defined in Data Protection Laws) in relation to any Personal Data which we collect from you through your or any other user’s use of the Service. This Policy sets out the basis on which any such Personal Data will be processed by us.

You may be a data subject (as defined in Data Protection Laws) or you may be a controller. When you are a controller in respect of the Personal Data of other data subjects, then you must comply with all of your controller obligations under Data Protection Laws. When you are a controller, we and you act as independent controllers, unless agreed otherwise.

­

2. INFORMATION WE GATHER FROM YOU

We fully respect your right to privacy in relation to your interactions with the Website or the Service and endeavour to be transparent in our dealings with you as to what Personal Data we will collect and how we will use Your Personal Data. We only collect and use Personal Data 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 DPC. Information in relation to Personal Data collected by UK entities is available on www.ico.org.uk, the website of the ICO.

We may collect Personal Data from you in the course of your use of the Website or the Service. This may be through email or online forms. The information that we process includes the following:

Basic Information: such as your first and last name (including prefix or title);

Contact Information: such as your home and/or business postal address, email address and phone number(s);

Technical Information: such as information from your visits to our Website or applications (including internet protocol (IP) address and login data, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access the Website or applications) or in relation to materials and communications we send to you electronically;

Any Other Information: relating to you which you may provide to us in the course of the provision of the Service or otherwise.

Any Personal Data that we collect from you for the above purposes is referred to in this Policy as Your Personal Data.

If you are aged under 18, please get your parent/guardian’s permission before you provide Your Personal Data to us/use the Service. We do not knowingly collect Personal Data from people under the age of 18. If we become aware we have inadvertently received Personal Data from a person under the age of 18, we will delete such information from our records.

3. WHY WE COLLECT/HAVE ACCESS TO YOUR INFOMATION

We may collect information from you as necessary in the course of providing our Service. We may collect your Personal Data while monitoring our technology tools and services, including our Website and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly.

We may use Your Personal Data on any one or more of the following legal bases: (i) to perform a contract with you; (ii) for our legitimate business purposes in providing the Service to you (in which case, our legitimate interests will not override your fundamental privacy rights); and/or (iii) in limited circumstances, where you have given us your express consent. We may also use or disclose your Personal Data to comply with a legal obligation to which we are subject.

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 legal basis, depending on the specific purpose(s) for which we are using Your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to process Your Personal Data where more than one ground has been set out in the table below. See ‘How to Contact Us’ below.

­­­

Purpose: To respond to an enquiry from you/provide customer support where you send us a message via the contact form on our Website.

Categories of data:

• Basic information
• Contact information

Legal basis for processing and, where necessary, the basis of legitimate interest: Necessary for our legitimate interests (for responding to you)

Purpose: To respond to an enquiry from you where you apply for a job in response to an advertisement.

Categories of data:

• Basic information
• Contact information
• CV/cover letter information

Legal basis for processing and, where necessary, the basis of legitimate interest: Necessary for our legitimate interests (for responding to you and potentially entering into a contract with you)

Purpose: To respond to an enquiry from you where you send in an unsolicited job application.

Categories of data:

• Basic information
• Contact information
• CV/cover letter information

Legal basis for processing and, where necessary, the basis of legitimate interest: Necessary for our legitimate interests (for responding to you)

Purpose: To deal with a complaint which you make through the website.

Categories of data:

• Basic information
• Contact information

Legal basis for processing and, where necessary, the basis of legitimate interest: Necessary for our legitimate interests (for responding to you)

Purpose: To deal with a whistleblowing report which you make through the whistleblowing platform accessible via our website.

Categories of data:

• Basic information
• Contact information

Legal basis for processing and, where necessary, the basis of legitimate interest: Necessary for our legitimate interests (for responding to you)

Purpose: To process and deliver your order.

Categories of data:

• Basic information
• Contact information
• Profile information

Legal basis for processing and, where necessary, the basis of legitimate interest: Performance of a contract with you and/or the relevant service provider.

Purpose: To administer and protect our business and improve our Website and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Categories of data:

• Basic information
• Contact information
• Profile information
• Newsletter information
• Technical information

Legal basis for processing and, where necessary, the basis of legitimate interest: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

Purpose: To provide and improve our Website, including auditing and monitoring its use, providing and improving our Service to you and managing and administering our relationship with you.

Categories of data:

• Basic information
• Contact information
• Marketing information
• Technical information
• Location data

Legal basis for processing and, where necessary, the basis of legitimate interest:

• Necessary for our legitimate interests to provide and improve our Website, including auditing and monitoring its use; providing and improving our Service to you; or managing and administering our relationship with you.
• Necessary to fulfil our legal, regulatory and risk management obligations.

4. COOKIES POLICY

A cookie is a small text file that is placed on your device by a web server, which we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a better experience when you browse our Website and also allows us to improve the Website. Cookies also help us to improve our Service and to deliver many of the functions that make your browser experience more user-friendly. 

We use the following types of cookies:

Strictly necessary cookies

These cookies are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services

Analytical or performance cookies

These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily and to see how effective and relevant advertising on our Website is.

First and Third Party Cookies:

Cookie: tarteaucitron

• Source: First Party
• Purpose: Storing cookie acceptance preferences for the main site
• Duration: 6 months

Cookie: __Host-_krakatoa_session

• Source: First Party
• Purpose: Navigation aid for careers site
• Duration: Session

Cookie: cookieconsent_dismissed

• Source: First Party
• Purpose: Storing cookie acceptance preference for the careers site
• Duration: 12 months

Cookie: __utma

• Source: Third Party (Google Analytics) – for more information, see Google Cookies
• Purpose: Used to define the number of unique visitors to the site
• Duration: 2 years

Cookie: __utmt

• Source: Third Party (Google Analytics) – for more information, see Google Cookies
• Purpose: Used to limit the volume of data saved
• Duration: 10 minutes

Cookie: __utmb

• Source: Third Party (Google Analytics) – for more information, see Google Cookies
• Purpose: Works with __umtc to calculate the average time each user spends on the site
• Duration: 30 minutes

Cookie: __utmc

• Source: Third Party (Google Analytics) – for more information, see Google Cookies
• Purpose: Works with __utmb to determine when the user closes their browser
• Duration: Session

Cookie: __utmz

• Source: Third Party (Google Analytics) – for more information, see Google Cookies
• Purpose: Identifies how the user arrives at the site (e.g., from another website or a search engine)
• Duration: 6 months

Cookie: _ga

• Source: Third Party (Google Analytics) – for more information, see Google Cookies
• Purpose: Used to differentiate users
• Duration: 2 years

Cookie: _gat

• Source: Third Party (Google Analytics) – for more information, see Google Cookies
• Purpose: Used to limit the volume of data saved
• Duration: 1 minute

We use Google Analytics to obtain high-level “audience measurement” data such as the referral web domain, type of operating system/browser used, date and time of visit, and other information relating to activities on our Website to understand its usage better, analyse trends, and optimize the Website experience. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

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-ons settings or visiting the website of its manufacturer.

Further information about browser privacy settings, and cookies and how to disable them can be found at www.allaboutcookies.org or ico.org.uk/your-data-matters/online/cookies.

­

5. CASES WHERE WE MAY USE YOUR INFORMATION TO CONTACT YOU

We may contact you (i) for administration reasons related to the Service (e.g. in response to a question that you ask us) or (ii) to provide you with information about our Service, activities or online content including responding to any contact you have made with us, e.g. on our Website, by email or via the ‘How To Contact Us’ below.

6. YOUR RIGHTS

As a data subject, you have the following rights under Data Protection Laws and we, as controller in respect of Your Personal Data, will comply with such rights in respect of Your Personal Data. These rights are explained in more detail below, 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 one month of receiving your request, unless the request is particularly complex, 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).

Right of Access (Article 15 GDPR):
You have the right to request a copy of Your Personal Data. Requests for Your Personal Data must be made to us (see ‘How to Contact Us’ below) 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.

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 Data 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 Laws.

For security reasons, we will take reasonable steps to confirm your identity before providing you with any Personal Data we may hold about you.

Right of Rectification (Article 16 GDPR):
You have the right to request that we amend any inaccurate or incomplete Personal Data that we have about you. If you would like to do this, please (i) email or write to us (see ‘How to Contact Us’ below); (ii) let us have enough information to identify you (e.g. name, registration details); and (iii) 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 has 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’ below).

Right to Object (Article 21 GDPR):
You have the right to ask us to stop using Your Personal Data, and we will comply unless there is a legal basis for us to continue using it, which we will explain to you.

Right to Erasure (Article 17 GDPR):
You can ask us to erase Your Personal Data (i) where we do not need Your Personal Data to process it for the purposes set out in this Policy; (ii) if you had given us consent to process Your Personal Data, you withdraw that consent and we cannot otherwise legally process Your Personal Data; (iii) you object to our processing and we do not have any legal basis for continuing to process Your Personal Data; (iv) Your Personal Data has been processed unlawfully or have not been erased when it should have been; or (v) the Personal Data has to be erased to comply with law.

We may continue to process Your Personal Data in certain circumstances in accordance with Data Protection Laws. Where you have requested the erasure of Your Personal Data, we will inform recipients to whom that Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.

Right to Restriction of Processing (Article 18 GDPR):
You may request that we stop processing Your Personal Data temporarily if (i) you do not think that Your Personal Data is accurate (but we may start processing again once we have checked and confirmed that it is accurate); (ii) the processing is unlawful but you do not want us to erase Your Personal Data; (iii) we no longer need the Personal Data for our processing; or (iv) 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: (i) you consent to such processing; (ii) the processing is necessary for the exercise or defense of legal claims; (iii) the processing is necessary for the protection of the rights of other individuals or legal persons; or (iv) the processing is necessary for public interest reasons.

Right to Data Portability (Article 20 GDPR):
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 (i) the processing is based on your consent or for the performance of a contract; and (ii) the processing is carried out by automated means.

Right to be informed:
You have the right to clear, transparent, and easily understandable information about your rights and about how we use Your Personal Data. We use this Policy to inform you of your rights. If you have any queries.

Right to Withdraw Consent:
Where processing is based on your consent, you have the right to withdraw your consent at any time with future effect by contacting us. However, if you do withdraw your consent, we may not be able to continue to provide the service we offer to you.

Rights in relation to automated decision-making:
We do not attempt to collect further data without user consent that enables personally identifiable profiling of our users.

Right to Complain to the DPC:
If you do not think that we have processed Your Personal Data in accordance with this Policy, please contact us in the first instance (see ‘How to Contact Us’ below). If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Laws. Information about how to do this is available on the DPC website at https://www.dataprotection.ie.

­

7. WHO WE SHARE YOUR INFOMATION WITH

Your Personal Data are intended for Circet.  It may be necessary for us to share Your Personal Data with our Affiliates and with our service partners in order to respond to your inquiries or to requests concerning our services. Your Personal Data may also be shared with the Circet DPO and any external advisors and auditors. In addition, we may use third parties acting as processors in order to provide you with our services and manage your data. This includes processors located outside the European Union or the European Economic Area, in which case we will ensure that adequate measures are in place to protect your personal data, in line with Section 9 of this Policy.

If our Business is acquired or merged with another company, Your Personal Data may be transferred to the new owners so that we may continue to sell products and Services to you. If we become involved in a merger, acquisition, or any form of sale of some of all of its assets, Your Personal Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of Your Personal Data.

We restrict access to Your Personal  Data to employees, contractors, and agents who need such access in order to operate, develop, or improve our Service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations. [We may also share Your Personal Data with our third party suppliers who assist us in the provision of the Service (subject to having appropriate contracts in place with such third parties).

Your Personal Data may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding in Ireland or abroad.

8. NON-EEA PERSONAL DATA TRANSFERS

Your Personal Data may be transferred to, stored at, or accessed from a destination outside the EEA (a ‘third country’) for the purposes of us providing the Service. It may also be processed by staff operating outside the EEA who work for us, another corporate entity within our group, or any of our suppliers. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and to an acceptable EU standard. The safeguards in place with regard to the transfer of your personal data to third countries shall include (but shall not be limited to) reliance by us on a decision of the European Commission confirming an adequate level of data protection in the respective third country, the entry by us into appropriate contracts with third parties incorporating standard contractual clauses approved by the European Commission where required or reliance other appropriate safeguards and the carrying out of risk assessments and adoption of supplementary and/or mitigating measures to ensure compliance with Data Protection Laws.

9. THIRD PARTY WEBSITES

This Policy applies to websites and services that are owned and operated by us. We do not exercise control over the sites/applications that may be linked from the Service. You may see ‘social buttons’ during your use of the Website, including but not limited to Twitter, Facebook, LinkedIn and Instagram which enable you to share or bookmark certain web pages. These websites and social platforms have their own cookies and privacy practices, which are controlled by them. These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Service may enable or assist you to access the Website content of, correspond with, and purchase goods and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of Your Personal Data.  We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Service. We encourage you to carefully familiarize yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

­

10. HOW WE PROTECT YOUR PERSONAL DATA

We do our utmost to protect user privacy through the appropriate use of security technology. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Personal Data. In particular, we consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Personal Data transmitted, stored or otherwise processed.

We restrict access to Your Personal Data to employees, contractors and agents who need to know Your Personal Data in order to operate, develop or improve the Services. 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. However, our Website may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Personal Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our Service may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of Your Personal Data arising from such risks.

All information you provide to us is stored on our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our Service, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Service.

11. PERSONAL DATA BREACH REPORTING

We will notify serious Personal Data Breaches in respect of Your Personal Data to the DPC or the ICO, as relevant 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 or the ICO, as relevant, 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 Personal Data Breaches, including their effects and the remedial action taken, and will notify you of any Personal Data Breach affecting Your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Laws. We are not required to notify you of a Personal Data Breach where (i) we have implemented appropriate technical and organisational measures that render Your Personal Data unintelligible to anyone not authorised to access it, such as encryption; (ii) we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or (iii) it would involve disproportionate effort, in which case we may make a public communication instead.

12. RETENTION OF PERSONAL DATA

Your Personal Data will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Personal Data as necessary to administer Your Account, comply with our legal obligations, resolve disputes, enforce our agreements, support business operations, and continue to develop and improve our Service.

Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Service, not to specifically analyse personal characteristics about you.

13. AMENDMENTS TO POLICY

We may change our Policy from time to time and at our sole discretion. If you do not agree to these changes, please do not continue to use the Service to submit Your Personal Data.

14. HOW TO CONTACT US

If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to DPO@circet.ie.