BACKGROUND:

Renewal Diary Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.RenewalDiary.com (“Our Site”) 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.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account”

means an account required to access and/or use certain areas and features of Our Site;

“Cookie”

means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and

“Cookie Law”

means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Site is owned and operated by Renewal Diary Ltd, a limited company registered in Ireland under company number number 616369, whose registered office is at Suite 1307, 26 Pembroke Street Upper, Dublin 2. VAT number: 3515058IH.

Data Protection Officer

Email address: security@renewaldiary.com.

Telephone number: +35314434405.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

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.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which We will always work to uphold:

The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact Us to find out more or to ask any questions using the details in Part 15.

The right to access the personal data We hold about you. Part 13 will tell you how to do this.

The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 15 to find out more.

The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose of any of your personal data that We hold. Please contact Us using the details in Part 15 to find out more.

The right to restrict (i.e. prevent) the processing of your personal data.

The right to object to Us using your personal data for a particular purpose or purposes.

The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

The right to data portability. This means that, if you have provided personal data to Us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.

Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep Us informed as long as We have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, We may collect and hold some or all of the personal [and non-personal] data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies.

Data Collected How We Collect the Data
Identity Information including name, title, date of birth, gender. Provided by users by submitting their information to us.
Contact information including address, email address, telephone number. Provided by users by submitting their information to us.
Business information including business name, job title, profession. Provided by users by submitting their information to us.
Payment information including card details, bank account numbers. Provided by users by submitting their information to us.
Profile information including e.g. preferences, interests, login details, purchase history. Provided by users by submitting their information to us.
Technical information including e.g. IP address, browser type and version, operating system. Collected from browser.
Data from third parties including technical information, profile information. Google, Facebook and Twitter cookies.
7. How Do You Use My Personal Data?

Under the Data Protection Legislation, We must always have a lawful basis for using personal data. The following table describes how we may use your personal data.

What We Do What Data We Use
Analytical Purposes We use cookies to analyze user activity in order to improve the Site. For example, we can use cookies to look at aggregate patterns like the average number of job searches that users perform. We can use such analysis to gain insights about how to improve the functionality and user experience of the Site.
Your Preferences & User Experience We use cookies to gather certain information about users, such as browser type, server, language preference, and country setting, in order to store user preferences on our Site to make your user experience more consistent and convenient. For example, we may store the recent searches you have performed in a cookie so that we can allow you to easily repeat those searches when you return to our Site, or so that we can suggest profile information when you sign up for an account and fill out renewal information. In addition, we use cookies to maintain your logged in state when you visit our Site repeatedly. We may also use your IP address to determine your geographic location in order to provide you with the most relevant search results.
Marketing We use cookies from third-party partners such as Google and Facebook for marketing purposes. These cookies allow us to display promotional material to you on other sites you visit across the Internet. We may also share information about your behavior on the Site with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you. We also use cookies to facilitate our targeted ads program. In this program, we use cookies to determine which ads users have seen, and how many times users have seen a particular ad.
Referral Tracking We use cookies to associate user activity with the third party website that referred the user to our Site, or to associate user activity that we referred to a third party website. These third party partner websites receive credit for the activity of users they refer to our Site, or give us credit for the activity of users referred to such third party websites. We do not share any personal information or information about individual user activities with these partner entities. We also use cookies to associate user activity with the email campaign that referred the user to our Site.
Security Purposes We use cookies to limit certain types of cyber attacks.
Testing, Usability, and Performance Improvement Purposes We use cookies to ensure users receive a consistent user experience while we conduct A/B testing on certain aspects of our Site in order to improve our product offerings. We also use cookies to improve the performance and reliability of our Site.
Fraud/Spam prevention We use cookies during fraud reviews and investigations. Some of our cookie/device tracking happens via 3rd party vendors like SiftScience, other times we use our own indexes to identify activity related to specific cookies.
Analytical Purposes We use cookies to analyze user activity in order to improve the Site. For example, we can use cookies to look at aggregate patterns like the average number of job searches that users perform. We can use such analysis to gain insights about how to improve the functionality and user experience of the Site.
Your Preferences & User Experience We use cookies to gather certain information about users, such as browser type, server, language preference, and country setting, in order to store user preferences on our Site to make your user experience more consistent and convenient. For example, we may store the recent searches you have performed in a cookie so that we can allow you to easily repeat those searches when you return to our Site, or so that we can suggest profile information when you sign up for an account and fill out renewal information. In addition, we use cookies to maintain your logged in state when you visit our Site repeatedly. We may also use your IP address to determine your geographic location in order to provide you with the most relevant search results.
Marketing We use cookies from third-party partners such as Google and Facebook for marketing purposes. These cookies allow us to display promotional material to you on other sites you visit across the Internet. We may also share information about your behavior on the Site with third parties (including operators of third-party websites and/or social networking sites) in order to show you targeted advertisements and other content that has been customized for you. We also use cookies to facilitate the targeted ads program. In this Program, we use cookies to determine which ads users have seen, and how many times users have seen a particular ad.
Referral Tracking We use cookies to associate user activity with the third party website that referred the user to our Site, or to associate user activity that we referred to a third party website. These third party partner websites receive credit for the activity of users they refer to our Site, or give We credit for the activity of users referred to such third party websites. We do not share any personal information or information about individual user activities with these partner entities. We also use cookies to associate user activity with the email campaign that referred the user to our Site.
Security Purposes We use cookies to limit certain types of cyber attacks.

We use your Personal Information for the purposes described above:

To honour our contractual commitments to users. Much of our processing of Personal Information is to meet our contractual obligations to our investors, or to take steps at User’s request in anticipation of entering into a contract with them.

For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:

Providing Our Site and service.

Analysing and improving our business.

Communications, including marketing and responding to your inquiries about our services.

Addressing information security needs and protecting our users, Renewal Diary Ltd, and others.

Managing legal issues.

To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.

With your permission and/or where permitted by law, We may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including providers or sellers of products or services which you may wish to purchase or renew or marketing technology partners such as Google or Facebook) whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that We do not control the activities of such third parties, nor the data that they collect and use themselves, and We advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless We reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If We do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If We need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, We will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, We may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data How Long We Keep It
Identity Information including name, title, date of birth, gender. While you have renewal information active on Our Site (i.e. until you delete your account) plus thirty days unless required by law.
Contact information including address, email address, telephone number. While you have renewal information active on Our Site (i.e. until you delete your account) plus thirty days unless required by law.
Business information including business name, job title, profession. While you have renewal information active on Our Site (i.e. until you delete your account) plus thirty days unless required by law.
Payment information including card details, bank account numbers. While you have renewal information active on Our Site (i.e. until you delete your account) plus thirty days unless required by law.
Profile information including e.g. preferences, interests, login details, purchase history. While you have renewal information active on Our Site (i.e. until you delete your account) plus thirty days unless required by law.
Technical information including e.g. IP address, browser type and version, operating system. While you have renewal information active on Our Site (i.e. until you delete your account) plus thirty days unless required by law.
Data from third parties including technical information, profile information. While you have renewal information active on Our Site (i.e. until you delete your account) plus thirty days unless required by law.
 
9. How and Where Do You Store or Transfer My Personal Data?

Your information will be shared internally, including with directors of the company and anyone employed by or contracting with us.

The Company shares your data with third parties where required by law, where it is necessary in order to administer the working relationship with you or where we have another legitimate interest in doing so. We may also share your data with other third parties, for example, in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

Your data may be transferred to countries outside the European Economic Area (EEA) in order to store or process it. Data is transferred outside the EEA on the basis that the company will work with major providers or those with leading or third party certified security standards. If you require further information, please contact the data controller.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

10. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

You specifically request that we send it to a business or provider that you wish to renew with based on your individual decision for a specific renewal.

We sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We use Google Analytics to track user behaviours on the site so that we can learn how people use the site and improve it.

[If any of your personal data is shared with a third party, as described above, We will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.] [If any personal data is transferred outside of the EEA, We will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.] [If We sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that We have used it, as specified in this Privacy Policy.]

In some limited circumstances, We may be legally required to share certain personal data, which might include yours, if [we are] OR [I am] involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.]

11. How Can I Control My Personal Data?

11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, We aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or at the point of providing your details and/or by managing your account. Email notifications and SMS messages with renewal reminders will not contain marketing materials for third parties.

11.2 We will not phone you for sales or marketing purposes or pass your phone information to partners. If you receive unwanted calls we encourage you may also wish to sign up to one or more of the preference services.

UK: Telephone Preference Service

Republic of Ireland: National Directory Database

US: National Do Not Call Registry

Australia: Do Not Call Registry.

These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

To provide you with the ability to prevent data from being used by Google Analytics, you can use the Google Analytics opt-out browser add-on for the Google Analytics JavaScript (ga.js, analytics.js, dc.js).

If you want to opt out, download and install the add-on for your web browser. The Google Analytics opt-out add-on is designed to be compatible with Chrome, Internet Explorer 11, Safari, Firefox and Opera. In order to function, the opt-out add-on must be able to load and execute properly on your browser. For Internet Explorer, 3rd-party cookies must be enabled. Learn more about the opt-out and how to properly install the browser add-on here.

Use the options in your web browser if you do not wish to receive a cookie or if you wish to set your browser to notify you when you receive a cookie. You can easily delete and manage any cookies that have been installed in the cookie folder of your browser by following the instructions provided by your particular browser manufacturer.

Google Chrome

Internet Explorer

Mozilla Firefox

Safari (Desktop)

Safari (Mobile)

Android Browser

Opera

Opera Mobile

12. Can I Withhold Information?

You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies by using the Cookie controls for your browser.

13. How Can I Access My Personal Data?

If you want to know what personal data We have about you, you can ask Us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 7 days and, in any case, not more than one month of receiving it. Normally, We aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date We receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for the purposes set out in section 7. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details Data Protection Officer:

Email address: security@renewaldiary.com.

Telephone number: +35314434405

Postal Address: Suite 1307, 26 Pembroke Street Upper, Dublin 2, Ireland.

16. Changes to this Privacy Policy

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 15 November 2018