Distinctions – Privacy Policy

Data Protection and Security Policy

Distinctions is committed to ensuring the confidentiality and privacy of our customers' personal information. We are guided by the General Data Protection Regulation (GDPR) (EU) 2016/679.

 

This Data Protection and Security Policy below describes the principles and practices that apply to the Personal Information that we collect, store and use. These we will protect the security and appropriate use of your Personal Information in line with GDPR compliance and best practice, to the best of our abilities.

Definitions

In this Privacy and Security Policy, the following terms are defined as set out in this section:

 

Customer means an individual, business or other entity that engages with Distinctions for the provision of our Products or Services, including, without limitation: (a) an individual or business that purchases any product or service provided by Distinctions; (b) employee of a business that purchases any product or service provided by Distinctions; (c) an entity with which Distinctions has a contractual relationship to provide their own or a third party Products or Services

Personal Information means any information, or an opinion about an identified individual, or an individual who is reasonably identifiable, whether that information is true or not and whether recorded in material form or not. This includes: name, email address, mailing address, telephone number, billing information, account information, and other information incidental to providing or receiving Products or Services.

Products or Services means the Products or Services promoted, sold or available for sale from the Distinctions Website or through the Distinctions Employees or subcontractors.

Site or Digital Tools include but are not limited to; www.distinctions.ie, www.distinction.ie www.distinctionsconsulting.com. Webhosting, Dropbox, Wave Accounting, Setmore Calendar, Survey Monkey, Type Form, Google+, Facebook, Twitter, LinkedIn.

Consent

Customers;

  • Consent will be implied where personal information has been provided in connection with the fulfilment, delivery and evaluation of contracted Products or Services. We will securely hold your personal data for a period of up to six years.

Marketing and Research

  • Explicit consent will be sought before sending you any marketing or research related communications. Explicit consent will be asked, where you have initiated an interaction with us, and in the process of doing so have provided us with your Personal Information. The purpose of consent will be limited to type of interaction established, as per the guidelines below ‘How We Collect and Use Personal Information.’ Consent will be valid, and your personal details stored, for up to 12 months from our last interaction. A request to extend or amend level of consent may be sought within this period, for a further period of six months.
     

  • However, it is important to note that the six-month period does not apply if you are following or subscribed to any of Distinctions social media platforms or if you are connected to an employee of Distinctions on any social media platforms. In this case, consent will be implied and remain valid until which time you chose to cancel your association/ connection.

By providing another person’s Personal Information, you represent that you have that person’s permission to do so.

How we Collect and Use Personal Information

We use Personal Information to provide and enhance the Products or Services that we offer, as explained below:

In connection with the fulfilment, delivery and evaluation of our Products or Services:

  • If you are a Customer, or if you are an employee or agent of a Customer, we will collect contact information as necessary to fulfil the agreed contract (such as name, address, shipping information, email address or telephone number) and any information provided by you to enable us to deliver a high standard of service in the regular course of our service delivery. The limited payment information that we receive from our payment processors is used to verify that a Product or Service has been paid for. Client references may be shared with prospective clients, during a bid or tender process. Any information provided will be shared confidentially, unless explicit consent has been obtained to use the content provided to be published for marketing purposes. E.g. Testimonial, Case Study.

  • If you purchase a Product or Service for delivery to, or use by, another person, we collect your Personal Information as the person initiating the purchase, as well as Personal Information about the other person (such as name, shipping address, telephone number or email address) as necessary to fulfil the order.

  • If you interact with our authorised third parties regarding ancillary Products or Services related to our scope of work with you, we may receive Personal Information about you from third parties, such business partners and service providers of psychometric tools or assessments.
     

  • If you purchase a Product or Service where we act as an agent for a third party, we will send the information you provide to us to that third party. The third parties for whom we act as agent are not subject to this Privacy Policy. We recommend that you read the privacy policies and statements that are posted on the relevant third parties' websites to understand their procedures for collecting, using, storing and disclosing Personal Information.

  • If you are a Customer, or if you are an employee or agent of a Customer, we will collect contact information as necessary to fulfil the agreed contract (such as name, address, shipping information, email address or telephone number) and any information provided by you to enable us to deliver a high standard of service in the regular course of our service delivery. The limited payment information that we receive from our payment processors is used to verify that a Product or Service has been paid for. Client references may be shared with prospective clients, during a bid or tender process. Any information provided will be shared confidentially, unless explicit consent has been obtained to use the content provided to be published for marketing purposes. E.g. Testimonial, Case Study.

  • If you purchase a Product or Service for delivery to, or use by, another person, we collect your Personal Information as the person initiating the purchase, as well as Personal Information about the other person (such as name, shipping address, telephone number or email address) as necessary to fulfil the order.

  • If you interact with our authorised third parties regarding ancillary Products or Services related to our scope of work with you, we may receive Personal Information about you from third parties, such business partners and service providers of psychometric tools or assessments.
     

  • If you purchase a Product or Service where we act as an agent for a third party, we will send the information you provide to us to that third party. The third parties for whom we act as agent are not subject to this Privacy Policy. We recommend that you read the privacy policies and statements that are posted on the relevant third parties' websites to understand their procedures for collecting, using, storing and disclosing Personal Information.

For marketing and research purposes;

  • General information and promotions - having obtained your explicit consent, we may use you email address, postal address, telephone number or any other contact information provided by you to send mailings, newsletters and other marketing collateral regarding product information and releases. We may use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of the communications that we send. If you participate in our blogs or forums, or if you write to us, we may collect Personal Information such as your name, email address as well as any other Personal Information that you may choose to provide to us so that we can correspond with you on the related subject matter.

  • Social Media Platforms – if you are following or subscribed to any of Distinctions social media platforms or if you are connected to an employee of Distinctions on any social media platforms, we will hold and use any Personal Data made available by you or the third-party platform provider, for the purpose of engaging with you on social interaction subject matter relevant to that platform.
     

  • Competitions – Competition winner consents to participating in promotional activity including providing feedback and testimonials.

  • Surveys and Research – By opting to participate in a survey or research project (including surveys administered by our related companies and other publishers), the information you provide through this interaction will only be used to garner survey results and statistical analysis. Your identity will not be disclosed, unless you have given explicit consent.

  • Website and Digital optimisation – having interacted with our website or digital tools, we may use aggregated digital interaction data (analytics) to better understand, improvement and evaluate the effectiveness of our digital tools and content. For example, use of session data may be used to enhance navigation through and in general, the quality of our Site and the content.

  • We may use IP addresses to gather broad demographic information – This information is not associated with any individual and is therefore anonymous. The IP addresses are then disposed of in accordance with our record retention policy.

  • Cookies and pixel tags are used to help recognise a returning visitor, and to help customise the visitor’s online experience. Unless a visitor specifically informs us of his/her identity (e.g. by registering with us), we will not know who the individual visitor is. Our third-party advertising partners may employ pixel tags that help us better manage content on our Site by informing us what content is effective. Cookies can be accepted, rejected or identified by configuring your browser’s preferences. You can learn more about cookies by visiting www.allaboutcookies.org or http://networkadvertising.org.

Data Accuracy

We will exercise reasonable efforts to keep your Personal Information accurate. However, we need your help in making sure that your Personal Information is correct in our systems. Please notify us of changes to information that you have previously provided by contacting us as indicated in the Contact Us section (below).

Your rights

Right of access, modification – In general, you have the right to access your Personal Information and to correct or update the Personal Information that you have provided to Distinctions. If you wish to do so, please contact us with proof of identity, as provided in the Contact Us section (below). You can expect a response to your request within 20 business days.

Right to be forgotten – If you wish to cancel your participation or request that we no longer use your information to provide you services, please contact us with proof of identity, as provided in the Contact Us section (below). We will accommodate your request to the extent practicable, and to the extent that it does not otherwise conflict any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Right to opt-out of the use of your Personal Information – If you wish to opt-out of direct marketing communications you can always do so by contacting us as set out in the Contact Us section (below).

Right to Block Cookies – You have the right to block cookies and pixel tags. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our cookies, you will be able to access those parts of our Site that are available to the general public, but you will not be able to access most of our Products or Services.

To Whom We Disclose Personal Information

From time to time, we may disclose Personal Information to someone other than the individual who provided this information, as follows:

Client organisation – We may disclose Personal Information we collect …. to the organisations stakeholders.

Related companies – We may disclose any Personal Information we collect to our related companies or may store or process Personal Information using systems which are shared with our related companies. This includes sub-contractors with material involvement in the delivery of our products or services.

Service providers – We may engage certain third parties to perform functions and provide services to us, including, without limitation, psychometric /assessment suppliers, customer relationship management, contract management, shipment, order fulfilment, payment credit card processing, mass mailing, hosting and maintenance, database storage and management, business analytics, fraud prevention, direct marketing campaigns and survey administration.

Aggregated data – Other than as stated above, if Distinctions provides a third party with Personal Information, it will be in the form of aggregated data and used for product development, research or statistical analysis. Aggregated data is created from records that are stripped of all personal identifiers, such as a combination of thousands of answers to survey questions and instrument responses.

Co-marketing – If we collaborate with other companies to offer you additional products or services, we will ask for your consent to share Personal Information that is necessary for these other companies to provide the products or services that you have requested. This Privacy Policy does not cover the use of your Personal Information by these companies. We encourage you to read a company’s privacy policy before providing consent to access any of its products or services.

Public forums – Distinctions may offer publicly accessible blogs or community forums. Any Personal Information that you provide on these blogs or forums may be read, collected and used by others who access them.

Merger, acquisition or bankruptcy – If any or all of Distinctions assets are acquired by, or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of our users’ Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing services to our users. If the recipient of the Personal Information has personal information practices that do not meet the substance of this Privacy Policy, you will be given the opportunity to exercise your rights with respect to your Personal Information.

To defend or enforce our rights – Distinctions may use Personal Information to protect itself or to protect the Site, to respond to a breach of its terms and conditions, to prevent fraudulent activity, or where it is necessary to pursue available remedies. If a Customer neglects to pay amounts due and owing to Distinctions, we may send that customer’s name, contact information, and account information to a third-party service provider for collection of overdue payments.

Law enforcement and litigation – Certain federal, state, local, overseas or other government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information: (i) if we believe in good faith that a law, regulation, rule or guideline requires it; (ii) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person; or (iii in other circumstances where we are permitted to do so by law.

How We Protect Personal Information

Security – We follow generally accepted industry standards such as GDPR to protect personal information, during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect it from unauthorised access, loss, misuse, disclosure, alteration or destruction.

Encryption - Any data collected by Distinctions for the purposes of service delivery is protected by encryption. This means we keep data in an unreadable state unless a user or process presents the appropriate key. In accordance with GDPR, this simple control method restricts data processing only for authorized use, and restricts the amount of time that you are identifiable by your data. Our data is encrypted at rest and in transit. Encryption prevents unauthorized data manipulation; limits data access to authorized users, and monitors key usage to ensures that the data cannot be changed without authorization.

Transit – When we need to transfer information out of our firewall, we use encryption methods to protect your data while in transit through the internet. We use encryption and a comprehensive authentication protocol to provide reasonable security. Therefore, while we use the highest standards commercially available to protect your personal information, no method of transmission over the internet or method can ever guarantee its absolute security.

Please understand that you also have a responsibility in protecting your information. The only time when a Distinctions associate may contact you (via electronic communication, postal mail, telephone, etc.) about your credit card or payment information is in connection with a transaction that you have initiated. Otherwise, no one from Distinctions is permitted to contact anyone to request your payment information, national identification number, or other identifier or sensitive information in a non-secure or unsolicited email or telephone communication.

Complaints and Disputes

If you have questions or complaints regarding our privacy policy or practices, you should first contact Distinctions as indicated in the Contact Us section (below). We will respond to you within a period of 21 working days and will attempt to resolve all complaints promptly.

If we are unable to satisfactorily resolve your concerns about the privacy or handling of your Personal Information, you can contact the Data Protection Commissioners Office

Changes to this Privacy Policy

From time to time we will revise and change this Privacy Policy. If we make material changes, we will place a prominent notice on our website, social media platforms, or will send you a notice to the email address that you provided to us.

Contact us

If you have any questions or complaints about (i) this Privacy Policy, (ii) the collection, use, management, or disclosure of your Personal Information, or (iii) accessing or modifying your Personal Information please contact us as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them.

By email: info@distinctions.ie

By phone: +353 1 549 0319

By Mail: Distinctions, 40 Kill Avenue, Dun Laoghaire, Co. Dublin, A96 V562. Ireland

Connect
Address

Newmarket House 

108A Patrick Street

Dún Laoghaire

A96 AD82

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