Privacy Policy - Independent Offers

Privacy Statement

May 25th 2018

 


1 INTRODUCTION
1.1 This website Independentoffers.ie is operated by MROCOM Ltd t/a Markettown
1.2 This Privacy Statement  together with the [Cookie Policy], [Terms and Conditions] of use of the Site for www.independentoffers.ie provides guidance and information to users/visitors of our Website regarding the processing of personal data by Markettown
1.3 The documents referred to in the Privacy Statement and Terms and Conditions sets out the basis on which any personal data we collect from you or that you provide to us (“Data”) in connection with the Site will be processed by us. Please read this Privacy Statement carefully to understand our treatment and use of Data.
1.4 The Privacy Statement applies to the operations of this Site operated by MARKETTOWN, a company registered in the Republic Of Ireland under number 526911 and having its registered office at Unit 18, Churchtown Business Park, Dublin 14 (hereinafter "MARKETTOWN”, "us", "we" or "our"). For the purposes of this agreement "MARKETTOWN" shall mean Mrocom Ltd t/a Markettown
1.5 MARKETTOWN and its associated companies are fully committed to protecting and respecting your privacy.
1.6 It is the intention of this Privacy Statement to explain to you the information practices of MARKETTOWN in relation to the information we collect about you and other users.
1.7 In this Privacy Statement, references to “you” means the person whose personal information we collect, use and process.
1.8 We will use your Data only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of your Data is in compliance with the Data Protection Acts 1988 and 2003 (as amended) and any subsequent data protection and privacy legislation, European Union Law including Regulation (EU) 2016/679, known as the General Data Protection Regulation or GDPR and any subsequent amendments (collectively referred to as “Data Protection Legislation”).
2. IDENTITY OF THE CONTROLLER OF PERSONAL INFORMATION
2.1 For the purposes of the Data Protection Legislation, the Data Controller of the Site is Mrocom Ltd t/a Markettown, a private company limited by shares and registered in Ireland (Registered Number 526911) and having its registered office address at Unit 18, Churchtown Business Park, Dublin 14, Ireland].
3 CONTACT DETAILS OF THE DATA PROTECTION OFFICE
3.1 The contact details of the MARKETTOWN Data Protection officer are as follows:
Email Address: info@markettown.ie
Address: MARKETTOWN Data Protection Office, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14, Ireland
4 WHEN DOES THIS PRIVACY STATEMENT APPLY
4.1 This Privacy Statement applies to Data that we collect, use and otherwise process about you in connection with your use of our Website. The Data we process will depend on how you use our Website.
5 ACCEPTANCE OF THIS PRIVACY STATEMENT
5.1 By using this Site and by disclosing your Data to us, you consent to the collection, storage, processing, use and disclosure of your Data by us as described in this Privacy Statement. If you do not agree with or are not comfortable with any aspect of this Privacy Statement, your only remedy is to discontinue using our Site. We reserve the right to modify this Privacy Statement at any time. Your continued use of any part of our Site following notification or posting of such changes will constitute your acceptance of those changes.
6 INFORMATION WE MAY COLLECT FROM YOU
6.1 When you visit or use the Site in any way, we may collect and process different types of information about you.
6.2 We have set out below the different types of Data that we collect. Please note that if you do not provide us with your contact information we will not be able to provide you with any information you request.
On our Mobile apps:
We collect technical information, including the type of mobile device you use, unique mobile device identifier, mobile network information, your mobile operating system, and the type of mobile browser you use. This helps us understand what types of devices are most commonly used to access our apps. This information is collected in an anonymized fashion for aggregated reports.
On our Web Sites:
We collect technical information including your Internet Protocol (IP) address, browser type and version, operating system and device type. This is collected in an anonymous manner and helps us optimize the site for our users.
We also anonymously collect information about your visit, including the Uniform Resource Locators (URLs) of the pages you visit during your visit, products you view, length of time on page and referring URL. This is the web page that you came from if you followed a link to our site. This helps us better understand what content appeals to our users and how to best structure our site.
When you sign up or register for one of our services we will track and store information about you in order to provide that service. For example, when you subscribe to a newsletter we may collect:
• Your email address and name
• Details of the newsletter emails we send to you that you open, including any links in them that you click on.
If you take part in any competitions we store your contact details with your consent in order to deliver the competition prize if you win.
6.3 The Data we collect, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties, (see “Disclosure of your Data” section below).
7 WHERE WE STORE YOUR DATA
7.1 Your Data is stored within the European Economic Area (EEA). The EEA comprises those countries that are in the European Union (“EU”) and some other countries that are considered to have adequate laws to ensure personal data is protected.

8 USE MADE OF YOUR DATA
8.1 We may use your Data that we hold to:
8.1.1 provide you with general information on our Site and to provide you with personalised services;
8.1.2 provide marketing information with your consent;
8.1.3 provide you with information about your registration or accounts;
8.1.4 provide you with information regarding our competitions, promotions or newsletters chosen;
8.1.5 enable you to login to the site, using  your email address, username and the password that you have chosen
8.1.6 analyse your online purchases on our website(for example, what you have bought, when you bought it and how you paid for it).
8.1.7 analyse your online browsing behaviour on our Site, Mobile Apps or email communications based on information about when you click on our content or one of our adverts
8.1.8 ensure that content from our Site is presented in the most effective,    responsive and compatible manner for you and for your computer or device;
8.1.9 respond to your requests for information and other communication or correspondence you may submit to us;
8.1.10 improve the services that we provide to you;
8.1.11 provide you with information or services that you request from us;
8.1.12 carry out statistical analysis and market research;
8.1.13 allow you to participate in interactive features of our Site, when you choose to do so;
8.1.14 allow you to participate in competitions on our site;
8.1.15 investigate any improper use of our services or the network;
8.1.16 carry out activities necessary to the running of MARKETTOWN, including systems testing, network monitoring, staff training and quality control; and
8.1.17 notify you about changes to our Site, services or policies.

9 DISCLOSURE OF YOUR DATA
9.1 We consider your Data to be private and confidential. Your Personal data is held within  MARKETTOWN , for any of the purposes set out in this Privacy Statement.
9.2 We may access and/or disclose your Data if required to do so by law or in good faith and belief that such action is necessary to: (a) conform with the law or comply with legal process served on us; (b) protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or (c) act under exigent circumstances to protect the personal safety of users of our services or members of the public.
9.3 Service Providers
We use third party service providers who work for us in the provision of our services. In providing the services, your Data will, where applicable, be processed by the service provider on our behalf.
We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your Data. We will have written contracts with them which provide assurances regarding the protections that they will give to your Data and their compliance with our data security standards and international transfer restrictions.
9.4 Disclosure to Third Parties
In certain circumstances, we may share and/or are obliged to share your Data with third parties for the purposes described above and in accordance with Data Protection Legislation.
These third parties include:

  • regulatory authorities;
  • financial institutions;
  • revenue who, under the Standard for Automatic Exchange of Financial Account Information in Tax Matters (Common Reporting Standard) may share information with the tax
  • authorities of other countries police, public prosecutors;
  • auditors;
  • relevant industry bodies;
  • external professional advisors; and
  • others, where it is permitted by law, or where we have your consent.

9.5 These organisations will also use your Data as a “Data Controller” – they will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable Data Protection Legislation.
10 RETENTION
10.1 We keep your personal data for as long as it is necessary to do so to fulfil the purposes for which it was collected as described above. The criteria we use to determine data retention periods for personal data includes the following:
10.1.1 Retention in case of queries; we will retain it for a reasonable period after the relationship between us has ceased; and
10.1.2 Retention in accordance with legal and regulatory requirements.
10.2 If you would like further information about our data retention practices, please contact MARKETTOWN’s data protection officer (see the “Contact Us” section below).
12 SECURITY
12.1 We endeavour to use appropriate technical and physical security measures to protect your personal data which is transmitted, stored or otherwise processed by us, from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access. Our service providers are also selected carefully and required to use appropriate protective measures.
12.2 As effective as modern security practices are, no physical or electronic security system is entirely secure. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Site. Any transmission of Data is at your own risk. Once we receive your Data, we will use appropriate security measures to seek to prevent unauthorised access. We will continue to revise policies and implement additional security features as new technologies become available.
12.3 In the event that there is an interception or unauthorised access to your personal data, we will not be liable or responsible for any resulting misuse of your personal information.
13 YOUR RIGHTS
13.1 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).
13.2 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 in writing to  Data Protection Officer by email to Info@markettown.ie and/or by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14, Ireland. 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 in writing to Data Protection Officer, by email to info@markettown.ie ot by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14, Ireland. 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 the MARKETTOWN or supplied to the MARKETTOWN 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. Please always check first whether self-help tools are available. Requests for such information should be made in writing to to Data Protection Officer,  by email to info@markettown.ie and/or by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14, Ireland.
  • 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 in writing to to Data Protection Officer by email, info@markettown.ie and/or by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14, Ireland.
  • Conditions to exercise? This right applies only if the processing of your personal data is 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 in writing to  Data Protection Officer by email, info@markettown.ie and/or by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14, Ireland.
  • 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 the MARKETTOWN’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 in writing to to Data Protection Officer by email,  info@markettown.ie and/or by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14, Ireland.
  • Conditions to exercise: If you withdraw your consent, this will only take effect for the future.

14 COMPLAINTS
14.1In the event that you wish to make a complaint about how your personal data is being processed by MARKETTOWN, or how your complaint has been handled, you have the right to lodge a complaint directly to the Data Protection Officer by email info@markettown.ie and/or by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14 Ireland.
15 YOUR RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY
15.1 If you are unhappy about any aspect of the way we collect, share or use your personal data, please let us know using the contact details below. 
15.2 You also have a right to complain to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois by telephone at 1890 25 2231 and/or by email to info@dataprotection.ie.
16 CHANGES TO OUR PRIVACY STATEMENT
16.1 We reserve the right to change this Privacy Statement at any time in our sole discretion. If we make changes to this Privacy Statement they will be posted on the Site so that you are always are of what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our website after we post any such changes, you accept and agree to this Privacy Statement as modified.
17 CONTACT US
17.1 In the event you have any Questions, comments and requests about the information set out in this Privacy Statement, please contact us by email info@markettown.ie and/or by post to Data Controller, MARKETTOWN, Unit 18, Churchtown Business Park, Dublin 14 Ireland.

This privacy policy sets out how Independent Offers uses and protects any information that you give Independent Offers when you use this website. Independent Offers is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. Independent Offers may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

What we collect

We may collect the following information:

  • name
  • contact information including email address
  • demographic information such as postcode, preferences and interests
  • other information relevant to customer surveys and/or offers

For the exhaustive list of cookies we collect see the List of cookies we collect section.

What we do with the information we gather

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

  • Internal record keeping.
  • We may use the information to improve our products and services.
  • We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
  • From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
  • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at denis@markettown.ie

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to Unit 18, Churchtown Business Park, Churchtown, Dublin 14, Ireland .

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE nameCOOKIE Description
CART The association with your shopping cart.
CATEGORY_INFO Stores the category info on the page, that allows to display pages more quickly.
COMPARE The items that you have in the Compare Products list.
CURRENCY Your preferred currency
CUSTOMER An encrypted version of your customer id with the store.
CUSTOMER_AUTH An indicator if you are currently logged into the store.
CUSTOMER_INFO An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS Stores the Customer Segment ID
EXTERNAL_NO_CACHE A flag, which indicates whether caching is disabled or not.
FRONTEND You sesssion ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST_CATEGORY The last category you visited.
LAST_PRODUCT The most recent product you have viewed.
NEWMESSAGE Indicates whether a new message has been received.
NO_CACHE Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history if you have asked the site.
POLL The ID of any polls you have recently voted in.
POLLN Information on what polls you have voted on.
RECENTLYCOMPARED The items that you have recently compared.
STF Information on products you have emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS The products that you have recently viewed.
WISHLIST An encrypted list of products added to your Wishlist.
WISHLIST_CNT The number of items in your Wishlist.