1.4 Please note that we may disclose individuals’ information to trusted third parties for the purposes set out and explained in this document. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Irish and EU laws on data protection.
1.5 We are not responsible for the content or the privacy policies for any websites that we provide external links to.
2. Data Controller
2.1 Data protection provides rights to individuals with regard to the use of their personal data by organisations, including Skilly. Irish and EU laws on data protection govern all activities we engage in with regard to our collection, storage, handling, disclosure and other uses of personal data.
2.2 Compliance with the data protection rules is a legal obligation. In addition, our compliance with the data protection rules helps individuals to have confidence in dealing with us and helps us to maintain a positive reputation in relation to how we handle personal information.
2.3 The data protection rules that apply to us are currently contained in the Data Protection Acts 1988 and 2003, in the ePrivacy Regulations 2011 and in related legislation (together the “DPAs”). As and from 25 May 2018, the applicable rules will be contained in the EU General Data Protection Regulation (EU Regulation 679/2016) (the “GDPR”) and in related Irish data protection legislation which gives effect to the GDPR.
2.4 “Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed, who/which make independent decisions in relation to the personal data and/or who/which otherwise control that personal data.
3. Type of Information Collected
3.1 We collect two types of information:
3.1.1 “Personal data” means any information relating to an identified or identifiable natural person.
220.127.116.11 Information that you provide when expressing an interest in obtaining additional information about our service, registering to use our service or registering for an event, such as name, company name, email address, phone number, and other contact details.
18.104.22.168 Information that you provide when applying for a job with our company such as a resume or cover letter containing other details about your employment history.
22.214.171.124 Information that you provide when purchasing the service such as billing name and address, and other financial information provided by you when completing a transaction through the website.
126.96.36.199 Optional information that you may provide when asked by Skilly, for example, a request to partake in a survey.
188.8.131.52 Information about your location when you access the Site.
3.1.2 “Non-personal data”. Like most websites, we gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This non-personal data comprises information that cannot be used to identify or contact you.
4. Use of Information Collected
4.1 We collect and use your information for the following purposes:
4.1.1 To perform the services requested, for example, if you fill out the “How can we help you?” Web form, we will use the information provided to contact you about your request. This data processing is necessary to provide or fulfill a service requested by or for you.
4.1.2 To perform marketing purposes, for example, we may use information you provide to contact you to further discuss your interest in the service and to send you information regarding the company such as our products, services, or events. This data processing for marketing purposes is a legitimate business interest.
4.1.3 To operate and improve our Website, for example, we may analyze and process information for the purpose of improving the customer experience. Information collected may include your browser type and language, or the city or region or country from which you accessed the Website, as well as the ways you interact with the Website, such as pages visited, time spent on pages, the number of clicks and the domain names. We may use third-party analytic providers and technologies, including cookies and similar tools, to assist. We process this information given our legitimate business interest to improve the Skilly Website and our customer’s experience with it.
4.1.4 For payment purposes, for example, to collect payment from you where applicable. This data processing is necessary to provide or fulfil a service requested by or for you.
5. Data retention
5.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for and for up to seven (7) 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.
5.2 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.
6.2 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 Skilly’s Data Protection Officer using the contact details set out below.
6.3 Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.
7. What are the data protection rules?
7.1 The eight data protection rules (also known as the data protection principles) that apply to our organisation are that:-
7.1.1 We must process personal data fairly, lawfully and transparently. This obligation includes that we must have a valid legal basis for our processing of personal data (whether the consent of the person, or that the processing is necessary for our legitimate interests (as long as these interests do not outweigh the rights of data subjects) or some other legal basis set out under the DPAs or (when applicable) the GDPR). It also means that we must be transparent with individuals about our processing of their personal data.
7.1.2 We can only collect personal data for specified, identified and legitimate purposes.
7.1.3 We can only then process the personal data that we have collected for the purposes which we have identified or for purposes that are compatible with the purposes that we have identified.
7.1.4 The personal data that we collect and process must be adequate, relevant and limited to what is necessary for the purposes.
7.1.5 The personal data that we collect and process must be accurate and (where necessary) kept up-to-date.
7.1.6 We must not keep personal data any longer than is necessary, bearing the purpose for which we collected it. This includes that we should keep personal data in a form which permits identification of the data subject for no longer than is necessary.
7.1.7 We must keep personal data safe and secure from unauthorised access, deletion, disclosure or other unauthorised uses. This includes not just keeping data safe and secure from persons outside our organisation, but also from people within our organisation who have no need to access or use the personal data. We must also be careful when transferring personal data outside the European Economic Area (“EEA”, being the EU plus Norway, Liechtenstein and Iceland), and make sure that we have a valid legal basis on which to transfer that data. Transfer can include using a cloud server that is located outside the EU or allowing people who are located outside the EEA access to personal data that is stored within the EEA.
7.1.8 We must comply with data subjects’ rights of information about, and (separately) access to, their personal data and with their other data protection rights, including the rights to correct or erase their personal data, rights “to be forgotten”, rights to object to processing (including profiling), rights against automated decision-making and (under the GDPR) rights to data portability.
8. Security of your personal data
8.1 We take appropriate security measures against unlawful or unauthorised processing of personal data and against accidental loss of, or damage to, personal data.
8.2 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 he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself. In addition, we have appropriate written agreements in place with all of our data processors.
8.3 We maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:
8.3.1 Confidentiality means that only people who are authorised to use the data can access it.
8.3.2 Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
8.3.3 Availability means that authorised users should be able to access the data if they need it for authorised purposes.
8.4 We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. Skilly uses third party vendors and hosting partners to provide the necessary hardware, software-networking, storage, and related technology required to run. The data you provide to us is protected using modern encryption, intrusion prevention, and account access techniques.
9. International Transfers
9.1 When 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:
9.2 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
9.3 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
9.4 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
10. Technical information we collect when you visit our websites
10.2 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. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your reservation. 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. The cookies we use do not detect any information stored on your computers.
10.4 Certain information in relation to web usage is revealed via our internet service provider who records some of the following data. The information we receive depends upon what you do when visiting our site:
- a) The logical address of the server you are using.
- b) The date and time you access our site.
- c) The pages you have accessed and documents downloaded.
- d) The previous Internet address from which you linked directly to our site.
- e) Some of the search criteria you are using
11. How we may use this technical information
11.1 Aggregate cookie and tracking information may be shared with third parties.
11.2 The technical information is used 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.
11.3 Some of the above information is used to create summary statistics which allow us to assess the number of visitors to the different sections of our site, discover what information is most and least used, inform us on future design and layout specifications, and help us make our site more user-friendly.
11.4 We will make no attempt to identify individual visitors, or to associate the technical details listed above with any individual. We will only use the technical information for statistical and other administrative purposes. You should note that technical details, which we cannot associate with any identifiable individual, are not “personal data” within the meaning of the GDPR.
12. Will we share your information with anyone else?
12.1 We may disclose your information to trusted third parties set out in Section 4. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Irish and EU laws on data protection. Any such company or individual will have access to personal information needed to perform these functions but may not use it for any other purpose.
12.2 Specifically, 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.
12.3 We use the following categories of data processors in the course of our business:
12.3.1 Cloud Service Provider, Cloud-based Support Services, Cloud-based Email Notification Services.
12.5 We may pass on your details if we are under a duty to disclose or share a data subject’s personal data 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.
12.6 We need to demonstrate accountability for our data protection obligations. This means that we must be able to show how we comply with the data protection rules, and that we have in fact complied with the rules. We do this, among other ways, by our written policies and procedures, by building data protection compliance into our systems and business rules, by internally monitoring our data protection compliance and keeping it under review, and by taking action if our employees or contractors fail to follow the rules. We also have certain obligations in relation to keeping records about our data processing.
13.1 We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. At the point at which you provide us with your personal data you will be asked whether you wish to receive any marketing communications from us.
13.2 We may use your personal 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).
13.3 We will not share your personal data with any third party for marketing purposes.
14. Sale of Business
15. Your data protection rights
15.1 Under certain circumstances, by law you have the right to:
15.1.1 Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
15.1.2 Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
15.1.3 Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
15.1.4 Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
15.1.5 Object to processing of your personal information 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 information for direct marketing purposes.
15.1.6 Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
15.1.7 Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
15.1.8 Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
16. Requests by data subjects to exercise their rights
16.1 We have appointed a Data Protection Officer to monitor compliance with our data protection 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 Officer.
16.2 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 Officer who will respond to the request within 30 days.
16.3 Our Data Protection Officer can be contacted as follows:
Mail: Data Protection Officer - Skilly Limited, 33 Hyde Park Avenue, Blackrock, Co. Dublin, Ireland
16.4 Note also that data subjects have the right to complain at any time to a data protection supervisory authority in relation to any issues related to our processing of their personal data. As our organisation is located in Ireland and we conduct our data processing here, we are regulated for data protection purposes by the Irish Data Protection Commissioner.
16.5 You can contact the Data Protection Commissioner as follows:
Go to their website www.dataprotection.ie
Phone on +353 57 8684800 or +353 (0)761 104 800
Address: Data Protection Office – Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. Or 21 Fitzwilliam Square Dublin 2, D02 RD28 Ireland.
18. UK Data Representative
18.1 Skilly hereby designates Imagine Education Ltd Crossmead, Denver Road Exeter, Devon, EX3 0BS as its Representative in the United Kingdom, as required by Article 27 of the GDPR for controllers based within the United Kingdom. The UK Representative shall represent the Controller in all matters related to the personal information of data subjects and supervisory authorities within the United Kingdom.