Privacy Policy

PRIVACY POLICY

Who We Are

This privacy policy is issued by Clíste Consultants Limited located at 4th Floor, 11 Anglesea Street, Ballintemple, Cork, Ireland (collectively referred to as “Cliste”, “we”, “us”, “our”). We are the data controller for the purposes of this privacy policy. Our website address is: https://clistehospitality.ie/ (“website”).

We take our responsibilities under applicable data protection law, including but not limited to, the EU General Data Protection Regulation, very seriously. This privacy policy only sets out details of our processing of personal data in connection with your use of this website. 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

What Personal Data We Collect and Why We Collect It

We collect and process the following personal data relating to you in connection with your use of this website:

  • Identity and Contact Data: Information relating to you that you choose to provide to us in the comments form, such as your name and contact details, including your phone number, email address and any other personal data relating to you that you provide to us or that we generate about you in connection with your use of this website.
  • Usage Data: Information that is generated in connection with your use of our website by our analytics tools, such as which pages you visit, how long you stay on them, and any previous website address from which you reached us, including any search terms used.
  • Technical Data: Technical information that is used to help detect spam and assist in providing the website and our services to you, including but not limited to, your IP address, browser type and version, operating system and device.
  • Marketing and Communications Data:This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

In certain circumstances the information that is collected above is aggregated and anonymised. An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment. If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included as visitors to the website can download and extract location data from images on the website.

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.

We use cookies to facilitate the use of our website and collect some of the information set out above. For more information on the cookies we use and the purposes for which we use them, see our Cookies Policy.

Purposes of Processing and Legal Basis

We will use personal data relating to you for the purposes of:

  • performing our obligations relating to or in accordance with any contract that we may have with you;
  • communicating with you, either in response to correspondence that you send to us via the website, or where you have signed up to receive updates from the website;
  • operating advertising campaigns, including working with third parties to display adverts to you on those third party websites on the basis of your use of our website and to track the effectiveness of the advertisements;
  • running our recruitment processes;
  • improving and developing our website;
  • generating and analysing statistics regarding usage of our website, including the frequency of use of individual pages (where possible, personal data will be anonymised before being used for this purpose);
  • sending you promotional and marketing materials;
  • carrying out research and customer satisfaction surveys;
  • fraud protection, investigation and detection; and
  • establishing, exercising or defending legal claims.

 

The legal bases on which we process your personal data are:

  • where you have consented to our processing of your personal data;
  • it is necessary to perform our obligations relating to or in accordance with any contract that we may have with you;
  • it is in our legitimate interest to use your personal data to ensure that we can carry out our activities as effectively as possible. We will not process your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms;
  • the processing is necessary for the establishment, exercise or defence of legal claims or for the purposes of providing legal advice or for the purposes of, or in connection with, legal claims, prospective legal claims, legal proceedings or prospective legal proceedings; or
  • we need to do so in order to comply with any legal or regulatory obligations.

Consent

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us at info@clistehospitality.ie. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

Recipients of Data

We may disclose your personal data to other organisations in connection with the above purposes, including:

  • to our affiliates and associated companies or partners;
  • to third parties who we engage to provide services to us in connection with this website, such as outsourced service providers, IT services providers, professional advisers and auditors;
  • to third parties with whom we may merge or to whom we may choose to sell or transfer all or part of our business or 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 policy;
  • to third party advertisers to assist in the display of advertisements on third party sites and tracking the effectiveness of our advertisements; and
  • to competent regulatory authorities and bodies as requested or required by law.

Retention

We will not hold your personal data for longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

Notwithstanding the foregoing, if you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

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. Details of retention periods for different aspects of your personal data are available by contacting us.

Requirement to Provide Personal Data

You are not under a statutory or contractual obligation to provide us with any personal data. However, where you submit a query to us in the ‘Contact’ section of our website or sign up for one of our newsletters or other promotional events, we will ask you to provide certain information, such as your name, contact number and email address. If you do not provide this information, we may not be in a position to process your request.

Your Rights

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

  • Right to access your personal data– You have the right to ask us if we are using or storing your personal data and to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data. We will provide the first copy of your personal data free of charge, but we may charge you a reasonable fee for any additional copies.
  • Right to request the rectification of your personal data– You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete. All users of the website can see, edit (with the exception of their username) or delete their personal information at any time. Website administrators can also see and edit this information. We may not always be able to change or remove this information, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
  • Right to erasureof your personal data – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the “right to be forgotten” or the “right to erasure”. 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.
  • Right to restrict the use of your personal data – You have the right to request restriction of processing of your personal data if you are concerned about its accuracy or how it is being used. Where restriction of use has been granted, we will inform you before we carry on using your personal data.
  • Right to object to the processingof your personal data – You have the right to object to the processing of your personal data if we are using it for certain purposes, including but not limited to, for (i) our legitimate interests; (ii) statistical purposes; or (iii) direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Right to data portability– You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format. This right only applies if you have provided us with the personal data and we hold that data electronically. It does not apply where it would adversely affect the rights and freedoms of others.

If you wish to exercise any of the rights set out above, please contact us at info@clistehospitality.ie.

Updates

We may occasionally update this policy. We encourage you to periodically review this policy for the latest information on our privacy practices.

Queries and Complaints

If you have any queries or complaints in connection with our processing of your personal data, you can contact us at info@clistehospitality.ie.

You also have the right to lodge a complaint with the Data Protection Commission (“DPC”), the Irish supervisory authority for data protection issues, if you are not happy with the way we have used your information or addressed your rights. Details of how to lodge a complaint can be found on the DPC’s website or by calling the DPC at 353 (0)761 104 800. We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.