Privacy Statement

  1. Introduction

ThorsNet Secure Limited (“we”, “us”, “our”, “ThorsNet”) respects your privacy and is committed to keeping your information private. We understand that your privacy and the security of your information is very important to you.

The following discloses our information gathering and dissemination practices relating to ThorsNet Secure Limited. In order to fully understand your rights, we encourage you to read this Privacy Statement and to consult our Website Terms of Use. Each time you use this Website you will be bound by the then current Privacy Statement and you should review this each time you use the Website to satisfy yourself that you are happy with it. Any external links to other websites are clearly identifiable as such and we are not responsible for the content or the privacy statements of these other websites.

  1. Acceptance Of This Privacy Statement

By using this Website, you signify acceptance of this Privacy Statement. If you do not agree with or you are not comfortable with any aspect of the Privacy Statement, your only remedy is to discontinue use of the Website. We reserve the right to modify this Privacy Statement at any time. Your continued use of any portion of the Website following notification or posting of such changes will constitute your acceptance of those changes.

  1. Information We Collect From You Through Use Of Our Website & Services

We may collect and process the following data about you:

  1. Customer/User Communication (e.g. via email, phone or the Website’s Contact Us):

Information we Capture:

  • Name
  • Company/Organisation Name
  • Contact Number
  • Email Address

But, we also anticipate some users of our service may volunteer additional information, which is likely to include reasons for contacting us.

Purpose of Capturing this Information:

We use this information for the purpose of contact and communication with you.

Legal Basis:

We use this information on the Legal Basis of Legitimate Interest.

Retention Period:

The information captured is maintained for the length of time needed to address the query and/or engagement.

Sharing Information:

Except in situations where we are required to do so by law, we do not share this information with any third parties, unless a user requests us to specifically engage with a third party on their behalf, at which point it will be made very obvious and clear from our communication that this is OK and has the users consent.

  1. ThorsNet Website:

Information we Capture:

Cookies and other similar methods (e.g. digital certificates) are used to monitor website traffic and enhance your experience of our website. Cookies are pieces of data which your computer, mobile or tablet device downloads when you visit a website. Cookies are used to keep track of your preferences and to recognise return visitors.

You can set your browser to reject cookies. However, if you choose to reject cookies, you may not be able to use or access certain of our online or mobile services. Alternatively, you can clear (delete) all cookies from your web browser once you finish using our website. Please refer to Cookie Policy for more information.

The cookies and digital certificates used in our Website are:

  • _ga
    • This is a Google Analytics cookie and is used to distinguish users
    • Expiration Time: 2 years
  • _gid
    • This is a Google Analytics cookie and is used to distinguish users
    • Expiration Time: 24 hours
  • _gat_gtag_UA_107411820_2
    • This is a Google Analytics cookie and is used to throttle request rate
    • Expiration Time: 1 minute
  • catAccCookies
    • This is a cookie consent plugin to record that you accept the fact that the site uses cookies
    • Expiration Time: 30 days
  • Channel ID
    • This is a “ecdsa_sign” type certificate used for google-analytics.com
  • Channel ID
    • This is a “ecdsa_sign” type certificate used for googletagmanager.com

Purpose of Capturing this Information:

We capture this information to manage and improve your user experience on the website.

Legal Basis:

We use this information on the Legal Basis of Legitimate Interest.

Retention Period:

The information captured is maintained for the length of time needed to address the query and/or engagement. The retention period of individual cookies has been outlined above.

Sharing Information:

Cookies or certificates associated with Google Analytics are shared with Google. Apart from these, except in situations where we are required to do so by law, we do not share this information with any third parties, unless a user requests us to specifically engage with a third party on their behalf, at which point it will be made very obvious and clear from our communication that this is OK and has the users consent.

Google Universal Analytics

What is Google Analytics?

Google Analytics is a web analytics service provided by Google, Inc. Google Analytics uses cookies in order to evaluate your use of the ThorsNet website. Browsers do not share cookies across domains.

How Google Analytics Works

Google does not collect or store personal information. Google Analytics prohibits the tracking or collection of personal information or association of personal information with web analytics information. Google Analytics does not report the actual IP address information to Google Analytics customers.

Opt Out?

Users may opt out of Google Universal Analytics’ use of cookies by visiting the Google Universal Analytics opt-out page.

Storage Location

Google stores the information collected by their cookies on secure Google servers.

  • ThorsNet Services:

ThorsNet Secure Limited processes data on behalf of a number of data controllers. The processing of this data is governed by contract, and unless specifically requested to do so by the data controller, none of this data will be shared with any third party.

  1. Where We Store Your Personal Data

The data that we collect from you is stored at a destination within the European Economic Area (“EEA”). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password or username which enables you to access certain parts of our Website or services, you are responsible for keeping this password or username confidential. We ask you not to share this information with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We have security in place such as firewalls, backup and other appropriate technical security measures.

  1. Uses Made Of Your Information

We use information held about you:

  • to ensure that content from our Website is presented in the most effective manner for you and for your computer;
  • to provide you with information, products or services that you request from us where you have consented to be contacted for such purposes;
  • to carry out our obligations arising from any contracts entered into between you and us;
  • for verification, administration and statistical analysis purposes (e.g. Google Analytics); and
  • to notify you about changes to our Website and/or services.

 

  1. Disclosure Of Your Information

We consider your Data to be private and confidential. We may disclose your personal information to other partner companies and approved contractors or sub-contractors working on our behalf.

We may disclose your personal information to third parties if:

  • our agents and/or contractors require this information in order to operate, develop or improve our services;
  • we need to work with advisors;
  • we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • if ThorsNet Secure Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its users will be one of the transferred assets;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use and other agreements; or to protect the rights, property, or safety of ThorsNet Secure Limited and its subsidiaries and its group companies, our users, or others. This may include exchanging information with other companies, such as payment processing companies and organisations for the purposes of fraud protection and credit risk reduction.

 

  1. Links To Other Sites

Our website may contain links to and from other websites and web platforms. In addition, third parties websites may also provide links to the Website. If you follow a link to any of those websites or web platforms, please note that those websites and web platforms have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those websites.

We do not accept, and we disclaim, any responsibility for the privacy policies and information protection practices of any third party website (whether or not such website is linked on or to the Website). These links are provided to you for convenience purposes only, and you access them at your own risk. It is your responsibility to check the third party website’s privacy statement before you submit any personal data to their websites.

  1. Security

We take your online security very seriously and this Website has security measures in place to protect the loss, misuse and alteration of the information under our control. However, as no data transmission over the Internet can be guaranteed as 100% secure, we cannot ensure or warrant the security of any information you transmit to us and you transfer the data at your own risk. We endeavour to use appropriate security measures.

  1. Your Rights

You may have various rights under Data Protection Legislation. However, in certain circumstances, these rights may be restricted (Article 23 of the General Data Protection Regulation, [which is transposed into Irish law by section 54 of the Data Protection Bill 2018], sets out the circumstances in which your rights may be restricted). In particular, your rights may be restricted where this is necessary: (i) for the prevention, detection, investigation and prosecution of criminal offences, and/or (ii) in contemplation of or for the establishment, exercise or defence of a legal claim or legal proceedings (whether before a court, tribunal, statutory body or an administrative or out-of-court procedure).

Subject to the above, your rights under Data Protection Legislation may include (as relevant):

Your Right: Right of Access

  • What does it mean? Subject to certain conditions, you are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”).
  • How do I execute this right? Requests for such information should be made through Contact Us. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
  • Conditions to exercise? We must be able to verify your identity. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other individuals and/or businesses.

Your Right: Right of Data Portability

  • What does it mean? Subject to certain conditions, you are entitled to receive the data which you have provided to us and which is processed by us by automated means, in a commonly-used machine readable format.
  • How do I execute this right? Requests for such information should be made through Contact Us. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
  • Conditions to exercise? The GDPR does not establish a general right to data portability. This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (e.g. not for paper records). It affects only personal data that was “provided” by you. Therefore, it does not, as a rule, apply to personal data that was created by ThorsNet or supplied to ThorsNet by any other individual and/or business.

Your Right: Rights in relation to inaccurate personal or incomplete data

  • What does it mean? You may challenge the accuracy or completeness of personal data which we process about you. If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.
  • How do I execute this right? We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details. Requests for such information should be made through Contact Us.
  • Conditions to exercise? This right only applies to your own personal data. When exercising this right, please be as specific as possible.

Your Right: Right to object to or restrict our data processing

  • What does it mean? Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data.
  • How do I execute this right? Requests for such information should be made through Contact Us. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
  • Conditions to exercise? This right applies only if the processing of your personal data is not necessary for the performance of a task carried out in the public interest (see “basis of processing” above). Objections must be based on grounds relating to your particular situation. They must not be generic so that we can demonstrate that there are still lawful grounds for us to process your personal data.

Your Right: Right to have personal data erased

  • What does it mean? Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”), e.g. where you think that the information we are processing is inaccurate, or the processing is unlawful.
  • How do I execute this right? Requests for such information should be made through Contact Us. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
  • Conditions to exercise? There are various lawful reasons why we may not be in a position to erase your personal data. This may apply (i) where we have to comply with a legal obligation, (ii) in case of bringing legal proceedings or defending legal proceedings, or (iii) where retention periods apply by law or under ThorsNet’s internal data retention policies.

Your Right: Right to withdrawal

  • What does it mean? You have the right to withdraw your consent to any processing for which you have previously given that consent.
  • How do I execute this right? Requests for such information should be made through Contact Us. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations.
  • Conditions to exercise: Withdrawal of consent affects processing of data which was based on consent from the time your consent is withdrawn. It does not affect any processing of data which was based on your consent, and which has occurred up to the time you withdraw consent.

 

  1. Access to Information

You have the right to request a copy of the information held by us about you. You also have the right to access your data, have changed any inaccuracies in the details we hold about you, the right to object to the use of your data and the right to block any specific uses of your data, by contacting us through Contact Us.

  1. Contact

Questions, comments and requests regarding this Privacy Statement are welcomed and should be sent through Contact Us and addressed to ThorsNet’s Data Protection Officer (DPO), Adrienn Ratku.