Crann Service User Privacy Notice
BACKGROUND
Crann understands that your privacy is important, and you care about how your personal data is used. We respect and value the privacy of all individuals that interact with us and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
INFORMATION ABOUT US
Crann Centre Limited (“Crann”)
Main trading address: Classis, Ovens, Co. Cork, P31TX39
Telephone number: 021 4289267
Email: info@cranncentre.ie
Introduction
1.1 This Privacy policy applies where we are acting as a data controller with respect to the personal data of all persons interacting with Crann; in other words, where we determine the purposes and means of the processing of that personal data. We are committed to safeguarding the privacy of our clients, family clients, family members, staff, volunteers, website visitors and anyone else we interact with.
1.2 This policy explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
1.3 If you are a parent or legal guardian of a child engaging in centre, digital or website activities, this Policy applies both to your own personal information and that of your child.
Credit
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
What is Personal Data?
3.1 Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identified or identifiable natural person. This includes data that can directly or indirectly identify an individual’.
3.2 Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we collect
4.1 We have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
4.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name, email address, telephone number, and postal address. The source of the contact data is you and/or a healthcare professional, on your behalf. This information is stored using Salesforce. Contact data may also be processed when you submit a resume and/or cover letter when applying for a job at Crann. This data can include employment and education history. This information is stored on our servers.
4.3 We may process information relating to transactions, including requesting a booking, purchases of goods, delivering of services, and/or donations, that you provide directly to us and/or through our website (“transaction data“). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider. Donations are facilitated by Donorbox and payment is facilitated using Stripe. Booking requests are facilitated by Salesforce.
4.4 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website and/or Salesforce (CRM) and/or Brevo (newsletter platform) and/ or Microsoft Forms and/ or Jot Forms will generate the metadata associated with communications.
4.5 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics.
4.6 We may process medical information (“medical data”) provided to us by you or a healthcare professional referring to us on your behalf, for use in assessing needs and suitability of our services. This data may include a primary diagnosis, health risk factors and any information you choose to include in the “Any other relevant information” section. The source of this data is you or a healthcare professional acting on your behalf via this web page: https://cranncentre.ie/crann-referral-form/. The basis for processing this data is consent, however it is important to note this also falls under Legitimate Interest, as we would not be able to provide services without this information.
4.7 Additional data we may process in order to provide services to you as an individual can include postal address, email address, telephone number, email address of parents/ legal guardians, gender, date of birth, language(s) spoken, photographs and/or moving film images of parents/guardian and/or the child, information relating to the child him or herself, and other information needed by us to help us in organising and delivering an activity for the child, or for answering any enquiries and requests.
Your rights
5.1 We have listed the rights you have under data protection law.
5.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
5.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en.
5.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
Purposes of processing and legal bases
6.1 We have set out the purposes for which Crann may process personal data and the legal bases of the processing.
6.2 Operations – We may process your personal data for the purposes of operating and delivering services, the processing and fulfilment of orders, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is legitimate interest, namely the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract.
6.3 Publications – We may process data for the purposes of publishing on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent. Aggregated anonymous data can be used, however any personal and identifiable data or imagery will be used only with the individual’s consent.
6.4 Relationships and communications – We may process contact data, account data, transaction data, communication data and medical data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, the maintenance of relationships, and the proper administration of our website, services and business.
6.5 Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent.
6.6 Research and analysis – We may process usage data and/or transaction data for the purposes of researching and analysing the use of our services, our fundraising donations and our marketing work, including use of our website. The legal basis for this processing is consent, where appropriate and our legitimate interests, namely monitoring, supporting, improving and securing our services, website and business generally.
4.7 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
6.8 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
6.9 Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
6.10 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
6.11 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
Providing your personal data to others
7.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
7.2 Your personal data will be stored on the servers of our hosting services providers.
7.3 We may disclose contact data and medical data to our subcontractors insofar as reasonably necessary for use of services at Crann.
7.4 Financial transactions relating to our website and services are handled by our payment services providers, Stripe. Donations are handled by donation service Donorbox and payment is handled by Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
7.5 As Crann receives a level of core funding from the HSE to support service delivery, we have an obligation to report annually on what services we have provided and to whom. This information is loaded onto a secure system called the National Ability Supports System (NASS), run by HIQA. If you have any questions regarding this, please speak to your Client & Family Liaison.
7.6 In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
International transfers of your personal data
8.1 In this Section, we provide information about the circumstances in which your personal data may be transferred to a third country under EU data protection law.
8.2 We may transfer your personal data from the European Economic Area (EEA) to Ireland and process that personal data in Ireland for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which Ireland is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from Ireland to the EEA and process that personal data in the EEA for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which EEA states are not treated as third countries under Irish data protection law or benefit from adequacy regulations under Irish data protection law.
8.3 The hosting facilities for our website are situated in The Netherlands. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of this country. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain upon request to communications@cranncentre.ie.
8.4 The Data Centre for our instance of Salesforce is situated in Paris, France. The competent data protection authorities have made an adequacy determination with respect to the data protection laws of each of these countries. Transfers to France will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities.
8.5 Jotform servers are co-located in a cloud-based architecture with Google Cloud and Amazon Web Services (AWS). Google Cloud data centers are hosted in Iowa (US). AWS data centers are located both in Germany, Frankfurt (EU), and US, Virginia (US).
8.6 We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in Ireland and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the GDPR as follows. We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the GDPR.
Retaining and deleting personal data
9.1 This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
9.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that or those purposes.
9.3 We will retain and delete your personal data as set out in our Data Retention Policy, available upon request to info@cranncentre.ie. This defines the legal requirements Crann have in order to retain data, defined by type.
9.4 We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Website specifics
About cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server 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.
10.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
11.1 We use cookies for the following purposes:
(a) authentication and status – we use cookies to identify you when you visit our website (cookies used for this purpose are: HTTP/Browser Cookies);
(b) shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website (cookies used for this purpose are: (HTTP/Browser Cookies);
(c) personalisation – we use cookies to store information about your preferences and to personalise our website for you (cookies used for this purpose are: HTTP/Browser Cookies);
(d) security – we use cookies as an element of the security measures used to protect users, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: Google reCAPTCHA and SSL certificate);
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you (cookies used for this purpose are: YSC (Youtube), VISITOR_INFO1_LIVE (YouTube), yt-remote-device-id (YouTube), yt.innertube::requests (YouTube), yt.innertube::nextId (YouTube), yt-remote-connected-devices (YouTube), personalization_id (Twitter), muc_ads (Twitter))
(f) analysis – we use cookies to help us to analyse the use and performance of our website and services (cookies used for this purpose are: CONSENT (Youtube), _fpb (Facebook), _ga_* (Google Analytics), _ga (Google Analytics));
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: HTTP/Browser Cookies) and,
(h) salesforce – we use session cookies from Salesforce to identify trusted web traffic (cookies used for this purpose are: _cfruid). Sessions cookies are deleted as soon as you exit the browser.
Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
11.2 We use Google Analytics, which gathers information about the use of our website and uses cookies for this purpose. We use the information gathered by Google Analytics to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://policies.google.com/technologies/partner-sites and you can review Google’s privacy policy at https://policies.google.com/privacy. The cookies used by Google Analytics are named _ga and _ga+container-id.
Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can obtain up-to-date information about managing cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(b) https://support.mozilla.org/en-US/products/firefox/privacy-and-security (Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/ (Opera);
(d) https://support.apple.com/en-gb/guide/safari/welcome/mac (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
Amendments
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
Our details
14.1 This website is owned and operated by Crann Centre CLG.
14.2 We are registered in Ireland under registration number 630347, and our registered office is at Classis, Ovens, Co. Cork, P31 TX39.
14.3 Our principal place of business is at Classis, Ovens, Co. Cork, P31 TX39.
14.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on (+353) 021 428 9267 or
(d) by email, using info@cranncentre.ie.
Representatives
15.1 Our representative within the EU with respect to our obligations under data protection law is Eimear Daly and you can contact our representative by email for the attention of Eimear Daly at info@cranncentre.ie or by phone on (+353) 21 428 9267.
Data Protection Officer
16.1 Our Data Protection officer is Padraig Mallon, and you can contact them by email for the attention of Padraig Mallon at info@cranncentre.ie or by phone on (+353) 21 428 9267.