Privacy Policy
OUR PLEDGE
- Ensuring your privacy is key to our business
- No Surprises: we will tell you clearly how your personal data is used in our business
- Your Privacy Ally: Your data is key to our business, so we’ll mind it as if it was our own.
- No Spam: We will always aim to send you information that is relevant to you
- The Bare Essentials: we won’t collect information that we don’t need
- When it’s no longer needed – it’s gone: We won’t hold onto information that we don’t need!
IMPORTANT: PLEASE READ THIS NOTICE CAREFULLY
Thank you for your interest in the website of Solvotrin Therapeutics Limited, hereinafter referred to as “Solvotrin”. We take data protection and privacy issues very seriously and comply with the applicable national and European data protection regulations. Therefore, we would like to inform you with this declaration about data protection measures and which data we store and how we use this data.
Who we are:
Solvotrin Therapeutics Limited
Where we are:
Hoffmann Park, Little Island, Cork, Ireland, T45 YX04
You can contact us by phone on +353 (0) 21 4510220
-OR-
You can contact us by email on Info@solvotrin.com/info@myactiveiron.com
We would prefer if you contacted us by email, as that way there will be a paper trail, which will protect us both. This would be a good thing, but if you want we can record your telephone calls too, but we would only do so with your blessing (unless we felt there might be a legal requirement to do so)
Daphne O’Neill is Data Controllers representative and data protection compliance officer for Solvotrin.
What personal data do we collect and how is it used?
We process the following data:
A: Data collection from this website
Whenever a user accesses the website, the user’s internet browser automatically transfers the following data to Solvotrin’s web server for technical reasons:
- Names, addresses and telephone numbers
- E-mail addresses
- Text submitted via forms on our website (which may or may not include names, e-mail addresses and telephone numbers)
- IP Addresses of the requesting computer
- Date and time of access
- Name and URL of the retrieved file
- Transferred data volume
- Access status (file transferred, file not found, etc.)
- Identification data of the browser and the operating system used
- Name of the provider of the user’s internet access
- Website from which access is made
- Bank/Credit/Debit Card details
- Sensitive Personal data (such as responses to questionnaires etc)
B.Use of Google Analytics:
This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies” which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, if you activate the IP anonymization on this website, your IP address will be shortened previously by Google within Member States of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases the full IP address is transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with further services related to website and internet use. The IP address transmitted by your browser within the scope of Google Analytics will not be aggregated with other Google data. You may refuse the use of cookies by selecting the appropriate setting on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plug-in available under the following link:https://tools.google.com/dipage/gaoptout?hl=en. You can prevent Google Analytics from collecting data by clicking on the link. An opt-out cookie is set out that prevents future collection of your data when you visit this website.
For more information on terms of use and privacy, please visit https://www.google.com/analytics/terms/ or https://google.de/intl/en/policies/. Please note that on the website Google Analytics has been extended by the code “anonymizelp” in order to guarantee an anonymous registration of IP address (so-called IP masking).
C.Use of Google Adwords Remarketing
This website may use the Facebook Pixel to advertise specific informational content based on your browsing activity by placing a cookie on your web browser. This cookie does not identify you personally and is only used to serve you with limited-time ads based on the specific page you have visited. For more information on Facebook’s data and privacy policy please visit: https://www.facebook.com/about/privacy/your-into
The legal basis for processing is Art. 6 para. 1f GDPR, whereby Solvotrin’s authorization arises from the fact that, on the one hand, Solvotrin has an interest in evaluating the website data for purposes of website optimization and, on the other hand, a concerned person can reasonably foresee at the time when the personal data is collected and in view of the circumstances under which it is carried out (in particular the above-mentioned measures) that it will possible by processed for this purpose.
D.Social Media Plugins
We use social media plugins from various social networks (e.g. Facebook). With the help of these plugins you can share content or recommend products. The plugins re deactivated by default and therefore do not send data to other
Why do we process it?
We process data for a variety of reasons
- Customer administration (invoicing etc) and Customer Relationship Management
- To disseminate our newsletters/marketing
- Direct Marketing
- Provision of goods or services
- Employee administration
- Monitoring (e.g. web history, Apps, Cookies)
- Profiling of personal data
- To process purchases/subscriptions on our website
- Other day-to-day administration purposes that would be in our legitimate interests
If we are in receipt of a valid request from Irish and European law enforcement authorities, we would make data available to them.
The legal basis for this processing is:
- Consent
- Legitimate Interests (processing purchased good, suppliers, customers (Business to Business and Personal….)
- Performance of a contract including possible consequences of failing to provide the personal data
- Legal obligations (completing purchases made by customers, ensuring records kept for taxation purposes, ….), including possible consequences of failing to provide the personal data
- To protect the vital interests of the data subject
Who do we share it with, and why?
We use: Stripe/PayPal/HubSpot/Zen Desk
These are third party service and you will have signed up your specific consent via our website, which we will have passed your name, e-mail address, address, bank/credit/debit card details where required, via a secure channel. By virtue of them storing your personal data they are therefore considered a Data Processor. Their privacy policies are available here:
https://stripe.com/ie/privacy
https://www.paypal.com/en/webapps/mpp/ua/privacy-full
https://legal.hubspot.com/privacy-policy
https://www.zendesk.com/company/customers-partners/privacy-policy/
We have no intention or interest in sharing your personal data with other services, other than the above. If we were thinking of doing so, we would ask you first. We are polite like that!
Links to Third Party websites
Our sites may contain links to the sites of third parties. We are not responsible for the privacy policies or the content of third party sites and we suggest that you read their privacy policies when you wish to visit such sites.
Data Transfers
We utilise servers around the world and your information may be processed on servers located outside the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply (and ensure our suppliers comply) with certain legal frameworks relating to the transfer of data such as the GDPR and EU-US Privacy Shield Frameworks.
Data Retention Period:
The data retention period for personal data consumer is 10 years where consent has been obtained.
This is a data controller decision based on our customers/supplier needs.
Criteria used are:
Consumer profile spread over a large age period
Changing needs of consumer over time
Associated product information
For B2B personal data the retention period is up to seven years from closing of any account with a customer or supplier. The basis for this is legitimate interest in retaining information.
Your rights:
To exercise the following rights, please send an e-mail to info@solvotrin.com. You may be asked for additional data to verify your identity as part of processing the requests to exercise your rights. We will endeavour to respond to all requests within 30 days of receiving the initial request. If we are unable to complete the request within the 30 day limit, we will notify you within the required time limit.
You have the following rights in respect to the personal data that Solvotrin hold on you
- The right to be informed – You have the right to receive “fair processing information” which will be completely transparent about how wee gathered and will use your data. We will also notify you about any third party processors with whom we share your personal data, along with the reason for doing so. But you’re pretty much already it all in this policy anyway.
- The right of access – You have the right to confirmation that your personal data are being processed and get access to a copy of your personal data and any other supplementary information.
- The right to rectification: You have the right to have your personal data corrected if it is inaccurate or incomplete.
- The right to erasure (includes withdrawal of consent) – You have the right to have your personal data erased, in the following circumstances:
- You withdraw consent
- The personal data has to be deleted to comply with a legal obligation
- The personal data was unlawfully processed
- Where the personal data is no longer necessary in relation to the purpose for which it was originally collected.
- Where you object to the processing and there is no superseding legitimate requirement to continue the processing.
- The personal data is processed in relation to the offer of “information society services” to a child
- We may have grounds to refuse such deletion requests for the following reasons:
- Exercise the right of freedom of expression
- For public health purposes in the public interest
- To comply with legal obligations
- The exercise or defence of legal claims
- Archiving purposes in the public interest
- The right to restrict processing – You can request that we no longer process your data, but that we can still store it
- The right to object – You have the right to object to any direct marketing from us. We will immediately cease any such marketing upon request (via unsubscribe ling at the bottom of the direct marketing e-mail).
- Rights in relation to automated decision making and profiling – You have the right not to be subject to a decision when:
- It is based on automated processing
- It produces a legal effect or similarly significant effect on the data subject
Cookies:
Cookies are delicious snacks enjoyed by many people, but in this context a cookie is a small text file containing an identifier (a string of letters and numbers) that is sent by a web serer to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
The type of cookies we use are session cookies and persistent cookies.
The cookies used by this site are used for the following:
- Statistics
- Marketing>
- Ecommerce Functionality
- Language Selection
Cookies can be erased anytime when someone clears the cache on their device.
The legal basis for processing is Art. 6 para.1f GDPR, whereby Solvotrin’s authorization arises from the fact that, on the one hand, Solvotrin has an interest in evaluating the website data for the purposes of website optimization and, on the other hand, a concerned person can reasonably foresee at the time when the personal data is collected and in view of the circumstances under which it is carried out (in particular the above-mentioned measures) that it will possibly be processed for this purpose.
You may set your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it is important to remember that some of our services may not function properly if cookies are disabled. For example, we may not remember your currency preferences.
You can find information on how to use browser settings to stop unwanted cookies in Chrome, Firefox, Opera, Safari and Internet Explorer. For other spurious browsers, please consult the help menu for that product.
https://support.google.com/analytics/answer/6004245?hl=en
Security
We take appropriate measures to ensure that the security of personal data under our control and to prevent unauthorised access, disclosure, modification or destruction of data. We have defined procedures and protocols for processing personal data including
-Information Security Policy
-Data Retention Policy
We retain data only for the length of time necessary to provide services/products to customers, engage in marketing activities and other legitimate purposes of the business.
Detailed Data Retention policies are available on request.
All data stored on all mobile devices belonging to Solvotrin is encrypted with Microsoft Office 365 Encryption
Other Purposes:
Other purposes for which Solvotrin might process personal data include:
Legal Action:
Where necessary we will process personal data provided to us for the purposes of seeking legal advice or other legal purposes.
Also, where we receive a formal request under Section 8 of the Data Protection Acts, 1988 and 2003 or Article 23 of the General Data Protection Regulation (GDPR) we may be required to disclose personal data of website users, newsletter subscribers and/or clients to An Garda Siochanna, Other local Police Forces, the Revenue Commissioners of other relevant organisation.
System Logs, Maintenance and Investigation of Data Security Breaches:
We process certain data, including IP addresses, as part of our internal system logging on this website to support the diagnosis of issues and maintenance of the website.
In addition, we will make use of detailed system logs on our webhosting platform and within our Content Management System to support investigations of Data Security breaches.
Updates and Questions:
This Privacy Policy is reviewed annually to determine if it needs to be updated. If any update occurs, this will be communicated:
On our website’s front page
By an item in our newsletter
It would also be reviewed each time we add functionality to our website.
Please direct any questions you may have directly to info@solvotrin.com
The right to complain:
If you feel that Solvotrin has not fulfilled its obligations under the General Data Protection Regulation 2016/679, then you have the right to lodge a complaint with the Data Protection Commissioner (DCP).
The DCP offers guidance on how to make a complaint here:
https://www.dataprotection.ie/en/individuals/exercising-your-rights/complaints-handling-investigations-and-enforcement-individuals
Automated decision making, including profiling:
Solvotrin do not use any automated decision making or profiling
OR
Solvotrin use (Specify personal data) and analyse it to (Specify outcomes of analysis)
These outcomes will: (specify the significance and the consequences of the analysis)
Disclaimer Statement
With the exception of the pages containing the steps required to complete an online payment relating to the Property Registration Authority, the contents of these pages are provided as an information guide only. They are intended to enhance public access to information about the Property Registration Authority process. While every effort is made in preparing material for publication, no responsibility is accepted by or on behalf of the State for any errors, omissions or misleading statements on these pages or any site to which these pages connect.