Identity of the Data Controller and Contact Details
Our Data Protection Coordinator can be contacted as follows:
Purpose and Scope
The purpose of this document is to provide you as our data subject with a statement regarding the Data Protection and Privacy practices and obligations of Integrity Meter, [the Organisation] and an explanation of your rights as a data subject. This Privacy Notice sets out what personal data we collect and process about you in connection with the services and functions of the Organisation. We are not responsible for the content or the privacy notices for any websites to which we provide external links. This Notice applies to our business practices, our website and platform, which is accessible from https://www.integritymeter.com and sub-domains, as well as any associated mobile applications owned and controlled by the Organisation.
The Organisation is established outside of the EU but falls into the scope of the GDPR under Article 3(2). The Organisation is not required to appoint an EU Rep as per Article 27(2) of the GDPR.
Laws that apply to us:
Our practices as described here now may be changed, but any changes will be posted. You are encouraged to review this Notice periodically to make sure that you understand how any personal data you provide will be used. We may also email you to let you know if and when we update this Notice to ensure you are informed.
Why and how do we ensure compliance?
Data Protection and Privacy Law provide rights to individuals with regard to the use of their personal data by organisations, including the Organisation. EU laws on data protection and privacy govern some activities we engage in with regard to our collection, storage, handling, disclosure and other uses of personal data. Apart from compliance being an obligation on us, our compliance with the data protection and privacy law helps individuals to have confidence in dealing with us and helps us to maintain a positive reputation in relation to how we handle personal data.
We need to demonstrate accountability for our data protection and privacy obligations. This means that we must be able to show how we comply with the applicable data protection and privacy law, and that we have in fact complied with the laws. We do this, among other ways, by our written policies and procedures, by building data protection and privacy compliance into our systems and business rules, by internally monitoring our data protection and privacy compliance and keeping it under review, and by acting if our representatives, including employees or contractors, fail to follow the rules. We also have certain obligations in relation to keeping records about our data processing.
Who must comply?
What are the data protection principles and rules?
We aim to comply with the following principles found in Data Protection and Privacy Law:
Lawfulness, fairness and transparency – personal data must be processed lawfully, fairly and in a transparent manner.
Purpose Limitation – personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
Data minimisation – personal data must be adequate, relevant and limited to what is necessary in relation to purposes for which they are processed.
Accuracy – personal data must be accurate and, where necessary, kept up to date. Inaccurate personal data should be corrected or deleted.
Retention – personal data should be kept in an identifiable format for no longer than is necessary.
Integrity and confidentiality – personal data should be kept secure.
Accountability – under the GDPR, we must not only comply with the above six general principles, but we must be able to demonstrate that we comply by documenting and keeping records of all decisions.
What types of personal data will we process?
Regular Personal Data
We will collect personal data with you in accordance with the purposes outlined in this document.
Special Category Personal Data
We will not collect special category data explicitly from you as a data subject based in the EU.
Criminal Conviction Data
We will not collect criminal conviction data from you.
Children’s Personal Data
Who has access to or processes personal data?
Directors and Employees of the Business
Directors and employees of the Organisation who are bound by confidentiality agreements will process personal data on behalf of the Organisation.
We may use trusted service providers who could be considered data processors, sub-processors or third parties. We need to have written agreements in place with all of our data processors and, before we sign each agreement, we need to have vetted and be satisfied with the processor’s data security. The agreements also need to contain specific clauses that deal with data protection. We require all service providers to have appropriate technical and operational security measures in place to protect your personal data, in line with EU laws on data protection. Any such organisation or individual will have access to personal data needed to perform these functions but may not use it for any other purpose.
We use the following service providers in the course of our business:
IntegrityMeter tests data:
Data Centre Service Provider based in Ireland
Data Centre Service Provider based in Israel
Commercial website data:
We may disclose your personal data if we are under a duty to disclose in order to comply with any legal obligation, or in order to enforce or apply any contract with the Data Subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes reporting information about incidents (as appropriate) to the law enforcement authorities and responding to any requirements from law enforcement authorities to provide information and/or personal data to them for the purposes of them detecting, investigating and/or prosecuting offences or in connection with crime sentencing.
Other than the above, we will not disclose personal data to any third party without your consent except in incidences where an individual is potentially at risk or where the law requires it.
Where does your data travel to?
We process the personal data of EU data subjects on our Irish server. Data does not travel outside of Ireland during the regular course of business. For the short-term future, secure, encrypted backups are transferred to our Israeli server for storage while we set up a second location in Ireland. Israel enjoys an adequacy decision from the EU Commission therefore this data transfer is as if it happens within the EU.
Depending on your choice of cookies:
Five statistics cookies send data to the USA – considered adequate.
Fourteen marketing cookies send data to the USA – considered adequate.
If we transfer your personal data out of the EEA, we ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Automated Decision Making and Profiling
According to Article 22(1) of the GDPR, the data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her. Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention. As profiling can use automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
Our platform is designed to create customised reports based on inputs that you provide. Our platform is designed in such a way that a human being is required to analyse and finalise reports. As such, our platform does not fall into the scope of Article 22(1) of the GDPR.
Our ISMS is certified under ISO27001. We may use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run our business. We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. We take appropriate security measures against unlawful or unauthorised processing of personal data, and against accidental loss of, or damage to, personal data. The data you provide to us is protected using modern encryption, intrusion prevention, and account access techniques. 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. Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures themselves. We maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
Confidentiality means that only people who are authorised to use the data can access it.
Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
Availability means that authorised users should be able to access the data if they need it for authorised purposes.
We have a documented data retention schedule. Generally, we will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and for up to three (3) years afterwards or otherwise permitted by applicable laws. We may also retain your information during the period of time needed to complete our legitimate business operations, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
We do not use your test data for marketing purposes.
We may use your personal data from website statistics to form a view on what we think you may want or need, or what may be of interest to you, but this would be more of a general view rather than a personalised, specific view. This is how we decide which products, services and offers may be relevant for you in relation to how other users utilise our products and services.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Where appropriate, you will be asked whether you wish to receive any marketing communications from us.
We will not share your personal data, and especially not any test data, with any third party for marketing purposes. You may object to direct marketing by using the contact details herein to opt-out or make use of the opt-out links on communications.
Cookies and Other Technical personal data
We encourage you to learn about cookies and how to control them in the following site or similar ones: https://www.allaboutcookies.org
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site. Most web browsers automatically accept cookies, but if you wish, you can set your browser to prevent it from accepting cookies. The “help” portion of the toolbar on 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, or how to disable cookies altogether.
Our website service provider serves cookies that are considered to be functionality and strictly necessary cookies. If you wish to block these cookies, please make use of the information above to do so. At this stage we are unable to offer the option of requesting your consent for these cookies due to technological limitations, however, we are monitoring this situation and will update functionality, consent mechanisms and this Notice as the situation changes.
Technical personal data
Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. We may gather technical information for security reasons. We will make no attempt to identify individual visitors, or to associate the technical details listed below with any individual. We will only use the technical information for statistical and other administrative purposes.
We may collect this technical information from you when you visit our website and accept cookies. This information may include standard information from you (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on our website (such as the web pages viewed, and links clicked). We do note that your IP address is considered personal data under the GDPR.
Certain information in relation to web usage is revealed via our internet service provider who records some of the following data. Whilst we do not access this information regularly, the technical information may be used to inform our security measures, to allow us to improve the information we are supplying to our users, to find out how many people are visiting our sites and for statistical purposes. The information we receive depends upon what you do when visiting our site:
The IP address you are using.
The date and time you access our site.
The pages you have accessed, and the documents downloaded.
The previous Internet address from which you linked directly to our site.
The user agent used to access our site.
Sale of Business
Information on Consent
You may withdraw consent at any time by providing an unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify withdrawal of consent to the processing of personal data relating to you. If you have any queries relating to withdrawing your consent, please contact our Data Protection Coordinator using the contact details set out below.
Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.
Details of data processing activities
What rights do you have?
Under certain circumstances, by law you have the right to:
Request information about whether we hold personal data about you, and, if so, what that information is and why we are holding/using it.
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 information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
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. You also have the right to object where we are processing your personal data for direct marketing purposes.
Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal data or profiling of you.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request transfer of your personal data 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.
How do you exercise your rights?
We have appointed a Data Protection Coordinator to monitor compliance with our data protection and privacy obligations and with this policy and our related policies. If you have any questions about this policy or about our data protection compliance, please contact the Data Protection Coordinator.
Data subjects must make a formal request for personal data we hold about them or otherwise to exercise their data protection rights whether to make an access request or otherwise by contacting our Data Protection Coordinator who will respond to the request within 30 days.
We are obliged to comply with exceptions to your requests where laid out in law. Such exceptions relate to health data, disclosures that would be likely to cause serious harm to your physical or mental health or emotional condition and opinions given in confidence.
Our Data Protection Coordinator can be contacted as follows:
Your Right to Lodge a Complaint
You as the Data Subject have the right to complain at any time to your data protection supervisory authority in relation to any issues related to our processing of your personal data.