https:\/\/erp-recycling.org\/ie\/<\/a>\u00a0when you contact us, or when you correspond or communicate with us (including by telephone) in connection with our business.\u00a0 If you are an employee or an agent of a member, your employer may provide us with your information.<\/p>\n3. How we will use information about you and the basis for that use<\/strong><\/p>\nWe gather and process your personal information for a variety of reasons and rely on a number of different legal bases to use that information.\u00a0 For example, we use your personal information to process membership benefits and obligations, to manage your requirements in relation to collection points, when auditing members, processing payments, to give you information about your participation in our scheme, to prevent unauthorised access to your information and to meet our legal and regulatory obligations.<\/p>\n
We need all the categories of information in the list above (in section 1) primarily to enable us to carry out the following actions with your personal data:<\/p>\n
\n\n\nUse of your personal data by ERP<\/strong><\/td>\nERP\u2019s Bases for Processing<\/strong><\/td>\n<\/tr>\n\nTo determine how best to perform our roles, and to take decisions about your membership<\/td>\n | For each of the situations listed in which your personal data is processed, one, several, or all of the following grounds justify this use of your personal data:<\/p>\n\n- processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to your entering into our recycling scheme;<\/li>\n
- processing is necessary to comply with our legal obligations, including those contained in waste recycling laws; and\/or<\/li>\n
- to pursue legitimate interests of our own or those of third parties, such as for the proper operation and administration of the scheme, provided your interests and fundamental rights do not override our legitimate interests.<\/li>\n<\/ul>\n<\/td>\n<\/tr>\n
\nTo provide services to you or others, including the destruction and recycling of data-containing devices or the provision of battery boxes<\/td>\n<\/tr>\n | \nTo verify the personal information provided to us, to determine your eligibility to join the scheme and to continue to benefit from the scheme, and to comply with anti-money laundering, anti-terrorist financing and fraud prevention rules<\/td>\n<\/tr>\n | \nTo comply with applicable data protection laws, tax and regulatory reporting obligations<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n Some of these grounds for processing will overlap, and there may be several grounds which justify our use of your personal data.<\/p>\n 4. What happens if you do not give us personal data or tell us when it changes?<\/strong><\/p>\nIt is important that the personal data we hold about you is accurate and current. You agree to notify us without delay in the event of any change in the personal data that we hold about you, to enable us to comply with our obligations, including to keep information up to date. If you fail to provide certain information when requested by us, or by our processor(s) on our behalf, we will not be able to accept you into the scheme and\/or will not be able to give you the full benefit of our services.\u00a0 In addition, we may be prevented from complying with our obligations to you as we require your personal data to perform our obligations, or we may be prevented from complying with our legal obligations or applicable laws.\u00a0 This may also be the case if you exercise your rights to erasure or restriction of processing, or object to our processing of your personal data (as described in section 9).<\/p>\n You can contact us at any time using the details set out in section 11.<\/p>\n 5. Third Party Information<\/strong><\/p>\nWhere you provide us with personal data relating to other people, you represent and warrant that you will only do so in accordance with applicable laws. You will ensure that before doing so, the individuals in question are made aware of the fact that we will hold information relating to them and that we may use it for any of the purposes set out in this privacy statement and the relevant terms and conditions, and where necessary you will obtain their consent to our use of their information.\u00a0 You will provide anyone that you provide us with personal data about with a copy of this privacy statement.\u00a0 \u00a0We may notify those individuals that you have provided their details to us and provide them with a copy of this privacy statement (however we are under no obligation to do so).<\/p>\n 6. Sharing your personal data<\/strong><\/p>\nWe may share your personal data with third parties, including third-party service providers.\u00a0 We require third parties to respect the security of your personal data and to treat it in accordance with applicable laws, including data protection laws.<\/p>\n We will only ever share your personal data with third parties for your benefit as a member or in connection with our obligations to you.\u00a0 We will share your personal data with third parties where required by law or where we have a legitimate interest in doing so, such as where it is necessary to the proper operation and administration of our recycling scheme and compliance with our legal obligations.<\/p>\n We may need to share your data with An Post for the purposes of the operation of services on\u00a0www.licences.ie<\/a>, for both retailers and members as part of our legal and regulatory obligations. You should refer to the terms and conditions (and privacy statements) of An Post in respect of that data sharing.<\/p>\nWe envisage sharing the following personal data with the following entities for the following purposes:<\/p>\n \n\n\nThird Party to whom your personal data may be given<\/strong><\/td>\nData shared by ERP<\/strong><\/td>\nPurposes for which the data is shared<\/strong><\/td>\n<\/tr>\n<\/thead>\n\n\nRecycling operators and sub-contractors<\/td>\n | Contact details, such as names, titles, work details, telephone numbers and email addresses.<\/td>\n | To ensure that you receive the full benefit of services that we provide to you<\/td>\n<\/tr>\n | \nMarketing and support service providers<\/td>\n | Contact details, such as names, titles, work details, telephone numbers and email addresses.<\/td>\n | To ensure that you receive the full benefit of services that we provide to you<\/td>\n<\/tr>\n | \nAuditors<\/td>\n | Your personal contact details such as your name, title, address(es), telephone numbers and email addresses; your employer and your location of employment or workplace.<\/td>\n | To carry out the year-end audit and any control or governance work we deem necessary in connection with our operations<\/td>\n<\/tr>\n | \nLegal advisors<\/td>\n | Your personal contact details such as your name, title, address(es), telephone numbers and email addresses; your employer and your location of employment or workplace.<\/td>\n | To obtain legal advice about our rights and obligations<\/td>\n<\/tr>\n | \nRegulators and other government authorities<\/td>\n | Your personal contact details such as your name, title, address(es), telephone numbers and email addresses; your employer and your location of employment or workplace.<\/td>\n | To comply with our legal obligations or other lawful requests for information<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n 7. Data security<\/strong><\/p>\nWe 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.\u00a0 In addition, we limit access to your personal data to ERP, its agents, contractors and other third parties who have a business need to know about the information in connection with our scheme.\u00a0 They will only process your personal data on our instructions and they are subject to a duty of confidentiality.<\/p>\n Although we cannot guarantee against any loss, misuse, unauthorised disclosure, alteration or destruction of data, we take reasonable steps to prevent this from happening.\u00a0 We have put in place measures to protect the security of your personal data.<\/p>\n Third parties which process your personal data on our behalf are required to agree to only process your personal data on our instructions, and to treat the information as confidential and to keep it secure.\u00a0 We only authorise these service providers to use your personal data for specified purposes to provide services and in accordance with our instructions, or in order to comply with applicable laws.\u00a0 We disclose only the personal data about you that is necessary for the third party to perform a service for ERP, or to carry out the actions described in this privacy statement.\u00a0 We have a contract in place that requires these third parties to keep your information secure and not to use it for their own purposes.<\/p>\n Please note however that where you are transmitting information to us or to our service provider over the internet or another telecommunications network this can never be guaranteed to be 100% secure.\u00a0 For any payments which we take from you or pay to you online we will use a recognised third party online secure payment system, and we are not responsible for the security of this system.\u00a0 You should contact these third parties for information about the security of these internet, telecommunications systems or payment systems if you need further information.<\/p>\n 8. How long will we hold and use your personal data for?<\/strong><\/p>\nWe will hold some personal data about you for as long as you are a member of our scheme, or are otherwise involved in a business relationship with us.\u00a0 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for; see section 3 of this privacy statement.\u00a0 Your personal data will be retained by us for any period required by law.\u00a0 Some of your personal data may need to be retained because of circumstances such as a legal dispute or regulatory investigation, which would not normally be subject to retention.<\/p>\n In general, we will hold your personal data for a period of seven years after you (or the organisation you work for) cease being a member or otherwise stop your involvement with us, unless we are obliged to hold it for a longer period of time under applicable law or regulations, or in connection with a legal dispute or regulatory investigation.\u00a0 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.<\/p>\n We review our retention of personal data regularly, to establish whether we are still entitled to process it.\u00a0 If we decide that we are not entitled to do so, we will stop processing your personal data except that we will retain your personal data in an archived form in order to be able to comply with future legal obligations.<\/p>\n When it is no longer necessary for us to hold your personal data, we will securely destroy it in accordance with applicable laws and regulations.<\/p>\n 9. Your rights in connection with the personal data we hold about you<\/strong><\/p>\nYou have the right, subject to some conditions and limited exceptions contained in the data protection laws (such as those set out below), to:<\/p>\n \n- Request access to your personal data that we hold about you. This right enables you to receive a copy of this personal data from us;<\/li>\n
- Request correction of the personal data that we hold about you. This right enables you to have any incomplete or inaccurate information we hold about you corrected;<\/li>\n
- Request erasure of your personal data. This right 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);<\/li>\n
- Where we hold and process your personal data in order to comply with legal obligations, such as compliance with tax requirements and exemptions, or for the establishment exercise or defence of legal claims, your right to ask us to delete or remove your personal data is limited;<\/li>\n
- Object to our processing your personal data where we are relying on a legitimate interest (or those of a third party) in order to justify the basis for our processing your personal data and there is something about your particular situation which makes you wish to object to processing on this ground;<\/li>\n
- Request that we restrict processing of your personal data. This right enables you to ask us to suspend the processing of your personal data,\u00a0g.,<\/em>\u00a0if you want us to establish its accuracy or the reason for processing it; and<\/li>\n
- Request the transfer of your personal data to another party where you provided that information to us.<\/li>\n<\/ul>\n
We are not under an obligation to rectify or delete your personal information where to do so would prevent us from meeting our contractual obligations to you, or where we are required or permitted to process your personal information for legal purposes or otherwise in accordance with our legal obligations.<\/p>\n If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact us by post at Chief Executive Officer, ERP Ireland, 11 James\u2019s Terrace, Malahide, Co Dublin K36 CV08 or by email at\u00a0ireland@erp-recycling.org<\/a>\u00a0setting out in writing your request clearly, including by specifying the personal data to which the request relates.\u00a0 We recommend that you provide as much detail as possible in your when sending requests to us, and that you identify yourself clearly, so that we can deal with your query properly and efficiently.<\/p>\n | | | | | | | |