INTRODUCTION
We are Play Services Ireland Ltd, a company incorporated in Northern Ireland with company number: NI601797 and with registered office at 724 Lisburn Enterprise Centre 6 Enterprise Crescent, Ballinderry Road, Lisburn, Northern Ireland, BT28 2BP (we, us, our).
This privacy notice will inform you how we look after your personal data when you visit our website (our Site) or when you use our inspections app and management system (Small World Inspections) and will tell you about your privacy rights in respect of that data. When we refer to our Services in this privacy notice, we mean our Site and/or Small World Inspections.
We may offer other services from time to time such as training or inspection services, which are not covered by this notice. If you would like more information on how we handle personal data in the provision of any such services, please let us know. You can contact our DPO using the details set out at paragraph 3 below.
WHAT IS THIS NOTICE?
1. In the provision of our Services, it is likely that we will need to process personal data: that is, any information which can be linked to an identifiable individual. This notice only deals with our use of personal data.
1.1. If you decide to use our Services to transmit any reports or assignments, the recipients will not be bound by the terms set out in this notice.
1.2. If you click on a link to a third party website or use any third party tools embedded in our Services your use of those services will be governed by the privacy notice of that third party.
In particular, please note that Googlemaps is one such third party service embedded into our Services. If you use Googlemaps, your data will be used by Google in accordance with its then current privacy notice. More information about Google’s privacy notice may be accessed via this link: https://www.google.com/policies/privacy/.
2. We keep our privacy notice under regular review. This version was last updated on 5th January 2021. We might need to change this privacy notice from time to time. If we do, we will let you know by publishing the updated version, but please do keep an eye on our notice before sending us any personal data.
3. It is important that you read this privacy notice together with any other privacy notice or fair processing policy 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 notice supplements other notices and privacy policies and is not intended to override them.
WHO DO WE HOLD INFORMATION ABOUT?
In the provision of our Services, we will hold personal data about the following groups of people:
Client Contact Data: that is any personal data which we receive from our clients or prospective clients for the purposes of finding out about our services and business and to manage any contracts which we may enter into with a client from time to time.
User Data: that is data relating to users which is collected when you use our Services; and PRIVACY NOTICE OF PLAY SERVICES IRELAND LTD WEBSITE AND SMALL WORLD INSPECTIONS
Report Content Data: that is any personal data including in any assignments, assessments or reports (which may include details relating to inspectors and site contacts as well as location data relating to sites and relating to the location of users when they access Small World Inspections) which are transmitting using or stored on Small World Inspections by you or other people when using Small World Inspections.
We act as a Controller in respect of Client Contact Data and Usage Data, which means that we are the party responsible for the data. This privacy notice sets out how we will deal with this data.
We act as a Processor in respect of any Report Content Data. This means that we do not use such data for our own purposes. We process it on your behalf (or on behalf of our client, if you have not entered into a services agreement with us). Our terms of processing are not included in this notice, they are set out in the services agreement which we enter into with our clients.
Our Services are not intended for children and we do not knowingly collect data relating to children.
3. CONTROLLER CONTACT DETAILS
If you have any questions about this privacy notice or our privacy practices, please contact our data protection officer (DPO) in the following ways:
Legal entity: Play Services Ireland Ltd, a company incorporated in Northern Ireland with company number: NI601797.
Email address: info@playservicesireland.co.ukinfo@playservicesireland.co.uk
Postal address: 724 Lisburn Enterprise Centre 6 Enterprise Crescent, Ballinderry Road, Lisburn, Northern Ireland, BT28 2BP
You have the right to make a complaint at any time to the relevant supervisory authority. For users in the UK, that is the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance
WHAT INFORMATION DO WE COLLECT?
We may collect, use, store and transfer different kinds of personal data.
· Identity Data includes first name and last name, job role and user name.
· Contact Data includes work billing address, work email address and work telephone number.
· Service Requirements includes information about your business needs or support requirements.
· Financial Data includes work bank account and payment card details.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
· Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
· Transaction Data includes details about payments to and from clients and other details of products and services you have purchased from us.
· Technical Data includes internet protocol (IP) address, your login data, 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 Services.
· Usage Data includes information about how you use our Services.
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 notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
HOW WE COLLECT 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 Site, by corresponding with us by post, phone, or email or if you provide us with information at an exhibition. This includes personal data you provide when you:
· enter into a contract for our Services;
· create an account on Small World Inspections;
· subscribe to our publications;
· request marketing or quotations to be sent to you;
· contact us with support queries or questions relating to our Services;
· enter a competition, promotion or survey; or
· give us feedback or contact us.
· Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs 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 for further details.
· Third parties. Since Small World Inspections is a paid for service which we make available to permitted users at the request of our clients, it is likely that they will provide us with information relating to their staff for the purpose of facilitating the provision of our Services.
· Publicly available sources. From time to time we may obtain personal data about prospective clients from various public sources.
HOW WE USE PERSONAL DATA
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 (or your employer or contractor). This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
· 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. This means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
· Where we need to comply with a legal obligation. This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 client |
(a) Identity
(b) Contact |
- Performance of a contract with you |
|
To manage the provision of our Services to you:
(a) Manage payments, fees and charges (b) Collect and recover money owed to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
- Performance of a contract with you
- Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey (c) Ensure compliance with our terms and conditions |
(a) Identity
(b) Contact (c) Profile (d) Marketing and Communications (e) Usage Data |
- Performance of a contract with you
- Necessary to comply with a legal obligation - Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) - Necessary for our legitimate interests (to protect our intellectual property rights) |
| To enable you to partake in a prize draw, competition or complete a survey |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
- Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity
(b) Contact (c) Technical (d) Usage |
- 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)
- Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical
(b) Usage |
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 goods or services that may be of interest to you |
a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
From time to time, 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 may receive marketing communications from us if you have consented to receiving the same, or if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us 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. Where you opt out of receiving these marketing messages, this will not affect your ability to use our Services.
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.
DISCLOSURES OF YOUR PERSONAL DATA
Small World Inspections can be used to transfer, store and share Report Content Data. Any such data is controlled by the relevant client (through their designated users). We make no decisions about what data should be disclosed using Small World Inspections. If you have any questions about the functionality of Small World Inspections, please contact our DPO using the contact details set out in paragraph 3 above.
We may share your personal data with the parties set out below for the purposes set out in the table above.
· Internal Third Parties: our employees and contractors who assist us to provide our Services.
· External Third Parties:
o Service providers acting as processors based who provide IT and system administration services.
o Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.
o HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
· 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 notice.
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.
INTERNATIONAL TRANSFERS
Our head office is based in Northern Ireland and our data servers are located in the UK. To the extent that this means that we are transferring any data from the EU to the UK, we will ensure that we implement appropriate measures to ensure the data in question is given the same protection as it has in the EU.
Where we use service providers based outside the EU, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
SECURITY MEASURES
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG DO WE KEEP PERSONAL DATA FOR?
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.
By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients for tax purposes.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You 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 data 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 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 successfully 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.
· 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:
o If you want us to establish the data's accuracy.
o Where our use of the data is unlawful but you do not want us to erase it.
o 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.
o You have objected to our use of your 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. We will 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 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.
If you wish to exercise any of the rights set out above, please contact us using the details set out in paragraph 3 above.
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.
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.
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.
