This Privacy Policy sets out how we, HeavenTree, collect, store and use information about you when you use or interact with our websites, www.heaventreedesign.ie, www.myheaventree.com, www.heaventreeseo.com or www.gdprwebready.ie (each a ‘website’ and together the ‘websites’) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from January 2018.

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
  • Data controller: Sean O’Byrne
  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us, ordering goods and services from us or registering an account on www.myheaventree.com)
    • from your use of our website, using cookies and similar technologies, and
    • occasionally, from third parties.
  • Information we collect: name, contact details, payment information e.g. IP address, information from cookies information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable) and VAT number (if applicable).
  • How we use your information: for administrative and business purposes (particularly to contact you and process orders you place for goods and services), to improve our business and website, to advertise our goods and services, to analyse your use of our website, to fulfil our contractual obligations and in connection with our legal rights and obligations.
  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies on our websites, including essential, functional and analytical cookies (on www.heaventreeseo.com and www.heaventreedesign.ie) and Facebook Pixel (on www.heaventreeseo.com). We also use web beacons in our marketing emails. For more information on which cookies we use on each of our websites, please visit our cookies policy here.
  • Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place, including ensuring that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield or use EU-approved model clauses.
  • Use automated decision making and profiling: we use profiling in relation to our web analytics (Google analytics) and online advertising (including Facebook Ads and Google AdWords).
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is Sean O’Byrne (Companies Registration Office number 483396) of 4/5 High Street, Galway City, Ireland, H91 HX3D. You can contact the data controller by writing to HeavenTree, 4/5 High Street, Galway City, Ireland, H91 HX3D or sending an email to sales@heaventreedesign.ie If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

We use a server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system. Our servers are based in Germany.  

Use of website server log information for IT security purposes

We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised.
This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity. Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our website server provider to make, any attempt to identity you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.


Cookies are data files which are sent from a website to a browser to record information about users for various purposes. We use cookies on our website, including essential, functional and analytical cookies and Facebook Pixel. We also use web beacons in our marketing emails. For further information on how we use cookies and similar technologies, please see our cookies policy which is available here. You can reject some or all of the cookies we use on or via our website by changing your browser settings by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Emails are stored on our servers in Germany. We also backup your emails using Google which stores your information on its data centres around the world, including outside the European Economic Area.
For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.


When you contact us using a contact form on one of our websites, we collect the following information:
www.heaventreedesign.ie: your name, email and any information you input in the message field.
We also collect your phone number if you provide it to us.
www.heaventreeseo.com: your name, email address and any information you input in the message field. We also collect your company name and phone number if you provide it to us.
www.gdprwebready.ie:
your name, email and any information you provide in the message field. If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
If you do not supply a phone number, we will not be able to respond to your enquiry by phone and if you do not provide a company name, we will not know what company you are from which may prevent us from obtaining relevant information to assist with your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form are stored in the same way as emails you send us, and are backed up on servers outside the European Economic Area. For more information, see ‘Email’ immediately above.


When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third party telephone service provider. Information about your call is stored in the United Kingdom and is not transferred outside the European Economic Area.


If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Information we collect when you interact with our websites

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

When you sign up for our e-newsletter on www.myheaventree.com or opt to receive offers from us by in relation to our goods and services we collect your name and email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, called MailChimp. You can access their privacy policy here: https://mailchimp.com/legal/privacy/
Information you submit to subscribe for our newsletter will be stored outside the European Economic Area on MailChimp’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) and similar technologies in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve.
We will only use web beacons in our emails if you have consented to us doing so. For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here.

For more information about how MailChimp handles your information and their use of web beacons and similar technologies in emails, please see their privacy policy which is available here: https://mailchimp.com/legal/privacy/


When you register and create an account on www.myheaventree.com, we collect the following information: first name, last name, email address, phone number, address, password and security question answer (we do not see or know your password or security question answer). We also collect any optional information you provide when you register on the website, including your company name (if applicable). If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us and to manage them. Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: registering and administering accounts on our website to facilitate the smooth running and operation of our business.

Transfer and storage of your information.

Your account information is stored on our servers in Germany. We also back up your account information on our back-up servers in the Netherlands and with Google in its data centres around the world, including outside the European Economic Area. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Information we collect when you place an order for our goods or services

We collect and use information from individuals who place an order with us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Mandatory information

You can place an order for goods or services with us in different ways. The different ways of placing an order with us and the information we collect by each method are set out below. If you do not provide this information, we will not be able to register on the relevant website, purchase goods or services from us on our website or enter into a contract with us.

Placing an order on www.myheaventree.com

When you place an order for goods or services on www.myheaventree.com, we collect the information required to register an account, which is set out above in the section entitled Registering on www.myheaventree.com.  

Placing an order on www.gdprwebready.ie

When you place an order for goods or services on www.gdprwebready.ie, we collect your first name, last name, address, phone number, email address, password (we do not see or know your password). We also collect your company name if you provide it to us.

Placing an order with us over the phone or by email If you place an order with us over the phone or by email we collect your first name, last name, address, phone number and email address.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose.

Transfer and storage of your information

Your information is stored on our servers in Germany. We also store your information on our third party accounting management software platform in the United Kingdom. The information stored on this platform includes your name, phone number, address, email and any invoices we have issued you with. Where you register an account on www.myheaventree.com, your information is also transferred and stored in accordance with the section above entitled Registering on www.myheaventree.com


After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment, we use third party payment processors, including PayPal and Stripe or, if you pay using a cryptocurrency, Coingate. Your payment will be processed by the payment processor you select to process your payment. PayPal, Stripe and Coingate collect, use and process your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following links:

Transfer and storage of your information

PayPal and Stripe may transfer the information they collect in relation to the processing of your order outside the European Economic Area. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Generally, we do not receive information about you from third parties. It is also possible, however, that third parties with whom we have had no prior contact may provide us with information about you. Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances. For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract. Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.


In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as business directories, media publications, social media, and websites (including your own website if you have one).

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard. For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.  

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Our use of automated decision-making and profiling

We use profiling in relation to our website. We do not consider that this has any legal effect on you or similarly significantly affects you. You have the right to object to our use of automated decision making and profiling described in this section.

You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here.

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Our web analytics service, Google Analytics uses and collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on).
We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy.

Information collected by Google Analytics is transferred by Google outside the European Economic Area. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area .

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website where you have allowed cookies using our cookie tool and your location will be analysed based on your IP address. How to object: If you accepted the use of Google Analytics cookies using our cookie tool, you can turn them off using our cookie tool as well. You can also opt out of Google Analytics using this free browser extension: https://tools.google.com/dlpage/gaoptout

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: we have a legitimate interest in getting to know our website visitors’ preferences and improving our website’s effectiveness.


YouTube uses cookies when you watch videos to track what you watch and on which websites across the internet. You can find out more about how YouTube uses information collected from cookies in their privacy policy which is available here: https://www.google.co.uk/intl/en-GB/policies/privacy/
Information collected by YouTube cookies is transferred by Google outside the European Economic Area. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Logic involved: YouTube can improve the relevance of the advertisements and suggested videos it shows you by collecting information on what videos you watch, allowing them to improve their YouTube service for you.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website where you have allowed cookies using our cookie tool and this information will be added to information that YouTube has about you.

How to object: You can stop YouTube collecting this information by using our cookie tool on our website (if you turned on the use of YouTube cookies using this tool). You can also block such cookies by blocking third party cookies in your browser settings.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you consent to YouTube collecting this information and using it for these purposes by [insert description of how user consents to YouTube collection and processing of information using your cookie tool]


We use web beacons and similar technologies in our marketing emails to analyse who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy.

Logic involved: by analysing how our email recipients respond to our emails, we are able to improve the content and effectiveness of our emails and gauge who is most interested.

Significance and envisaged consequences: your behaviour when you open our emails will be tracked using small gif files (web beacons), including open rates and click through rates.

How to object: send an email to sales@heaventreedesign.ie asking us to stop using web beacons in the marketing emails we send you.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: analysing the level of engagement and effectiveness of our marketing emails and content


We use profiling to advertise on Facebook. Information collected by Facebook in relation to its advertisements and the Facebook Pixel on our website is transferred by Facebook outside the European Economic Area. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Logic involved: by targeting individuals based on criteria such as what they have liked on Facebook, we are able to more effectively advertise our services to those who we think are most likely to be interested in purchasing them, making our advertising more cost-effective and relevant.

Significance and envisaged consequences: advertisements will be displayed to you on Facebook if you meet the relevant criteria which form the basis of our advertising campaign. If you click on any relevant advertisements displayed to you on Facebook, your behaviour will be tracked using the code (Facebook Pixel) which we have installed on our website (if you have consented to the use of such technologies on our website) and your actions on our site will be tracked and the information shared with Facebook (you can access Facebook’s Privacy Policy here: https://www.facebook.com/about/privacy/).

How to object: If you accepted the use of Facebook Pixel using our cookie tool, you can use our cookie tool to turn it off and stop it processing your information as well. You can also opt-out of Facebook processing your information using Facebook Pixel by changing your ad settings in your Facebook account here: https://www.facebook.com/ads/settings
You can opt out of Facebook and other companies that participate in the Digital Advertising Alliance in Europe from showing you interest based ads by visiting http://www.youronlinechoices.com, selecting your country, clicking ‘Your Ad Choices’, then locating Facebook (and any other companies you want to block) and selecting the ‘Off’ option.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: marketing our goods and services effectively.

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
  • Telephone provider (Ireland),
  • Email provider (stored on our servers in Germany and backed up using Google in its data centres around the world),
  • Hosting provider (Germany),
  • Backup providers (Netherlands, EU Member States, USA),
  • Payment service providers (USA, Lithuania),
  • Domain name registrars (Ireland, USA), and
  • Accounting management software provider (United Kingdom).

Apart from our cloud storage providers, which are located in the United States of America, our service providers are located in the European Economic Area. Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us. We do not display the identities of our service providers publicly by name for security and competitive reasons.
If you would like further information about the identities of our service providers, however, please contact us directly and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.


Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties. We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of the Republic of Ireland or if they have been integrated into Ireland’s legal framework (for example in the form of an international agreement which Ireland has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into Ireland’s legal framework, we have a legitimate interest in complying with these obligations.


We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service ( https://www.google.com/analytics/terms/us.html) You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners, independent contractors, and insurers.
Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.  
Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts. Our accountants are located in Ireland.
Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice. Our advisors are located in Ireland.  
Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
Our business partners are based in the legal services and data protection industries, specifically the provision of legal documentation for websites. Our business partners are located in the United Kingdom.
Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them. Our insurers are located in the United Kingdom.   We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).  
We will share your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Server log information: we retain information on our server logs for 45 days.
Account information: account information on www.myheaventree.com is backed up for 60 days.
Order information: when you place an order for goods and services, we retain that information for 6 years, in accordance with our legal obligation to keep records for tax purposes.
Enquiries: when you make an enquiry, whether by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 3 further month(s) after which point we will delete your information.
Newsletter: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • encrypting any passwords you use to create an account on www.myheaventree.com; and
  • using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Google Analytics

Google transfers information collected by its Google Analytics service (your IP address and information about you use our website) outside the EEA and stores that information on its servers in the United States of America. You can view Google’s privacy policy here https://www.google.com/policies/privacy/ and how the use the information collected by cookies here: https://www.google.com/policies/privacy/partners/
Countries of storage: United States of America. The United States of America is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google transfers your information outside the EEA to entities which have self-certified themselves as compliant under the EU-U.S. Privacy Shield. The EU-U.S. Privacy Shield is available here: https://www.privacyshield.gov/welcome.

The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. you can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm


YouTube

YouTube transfers information collected about you using YouTube cookies outside the EEA. See the section above entitled ‘Google Analytics’ for more information, including the safeguards used.


Facebook

Facebook transfers information it collects from its advertisements and the Facebook Pixel on our website outside the EEA.

Countries of storage: United States of America and other countries. These countries are not subject to an adequacy decision by the European Commission.

Safeguard(s) used: where Facebook transfers your information outside the EEA they will ensure EU-approved model contract clauses are in place, obtain your consent for such transfers or adopt other means under European Union law. EU-approved model clauses are standard data protection clauses adopted by the European Commission in accordance with its committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(b) of the General Data Protection Regulation. Transfers on the basis of your explicit consent are permitted under Article 49(1)(a) of the General Data Protection Regulation.


Information you submit via contact forms on our websites is transferred outside the EEA and backed up on our third party cloud service provider’s servers. Our third party cloud service provider is Google and you can access their privacy policy here: https://www.google.com/policies/privacy/. For further information on the countries of storage and safeguards used by Google, see ‘Email’ below.


Information you submit to us by email is transferred outside the EEA and backed up on our third party cloud service provider’s servers. Our third party cloud service provider is Google and you can access their privacy policy here: https://www.google.com/policies/privacy/.

Countries of storage: United States, Taiwan, Singapore and/or Chile. These countries are not subject to an adequacy decision by the European Commission. You can find out more about Google’s data centres: https://www.google.com/about/datacenters/inside/locations/index.html.

Safeguard(s) used : Google transfers your information outside the EEA to entities which have either self-certified themselves as compliant under the EU-U.S. Privacy Shield or have put EU-approved model contract clauses are in place. The EU-U.S. Privacy Shield is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. you can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
EU-approved model clauses are standard data protection clauses adopted by the European Commission in accordance with its committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(b) of the General Data Protection Regulation.


Information you submit to us when you sign up for our newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is MailChimp. You can access their privacy policy here: https://mailchimp.com/legal/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: MailChimp has self-certified its compliance EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm


When you pay for goods and services via one of our websites, if you select Stripe or PayPal, information about your order and the processing of your order may be transferred outside the European Economic Area.

Stripe

Information processed by Stripe is transferred outside the EEA and stored on Stripe’s servers. You can access their privacy policy here: https://stripe.com/gb/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Stripe has self-certified its compliance with EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

PayPal

PayPal may transfer information they process about your order overseas. Where they do so, they will ensure appropriate safeguards are in place. You can access PayPal’s privacy policy here: https://www.paypal.com/ee/webapps/mpp/ua/privacy-full

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to HeavenTree, 4/5 High Street, Galway City, Ireland, H91 HX3D or sending an email to sales@heaventreedesign.ie:
  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. For the purposes of Ireland, the supervisory authority is the Office of the Data Protection Commissioner (An Coimisinéir Cosanta Sonraí) (the DPC), the contact details of which are available here: https://www.dataprotection.ie/docs/EN/Contact-us/m/11.htm

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the DPC’s website:
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf


Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to HeavenTree, 4/5 High Street, Galway City, Ireland, H91 HX3D or sending an email to sales@heaventreedesign.ie:
  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests , including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an email to sales@heaventreedesign.ie, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation. We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation.
We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.


Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet.
We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers.

If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to sales@heaventreedesign.ie.

California Do Not Track Disclosures


“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as web beacons, and other similar technologies, to track visitors to the website.
Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here.
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software.
All intellectual property rights in this document are reserved.