Privacy Notice – Updated July 2022
This is the privacy notice of Riverlinn Limited t/a Erin Research. In this document, “we”, “our”, or “us” refer to Erin Research.
We are company number 648779 registered in Ireland.
Our registered office is at 3rd Floor, The Bank Building, Mullingar, Co. Westmeath.
Our trading address is 10 North Quay, Drogheda, Co. Louth, Ireland.
- This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
- We take seriously the protection of your privacy and confidentiality. We understand that you are entitled to know that your personal data will not be used for any purpose unintended by you, and will not accidentally fall into the hands of a third party.
- We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.
- Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
- The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org
- Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
The bases on which we process information about you
The law requires us to determine under which of the six defined bases we process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.
If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.
- Information we process because we have a contractual obligation with you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2 provide you with our services
1.3 provide you with suggestions and advice on services
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.
Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide, or to gather internal statistics so that we can improve our services. If we use it for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
- Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities or our services, you provide your consent to us to process information that may be personal information.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at firstname.lastname@example.org.
- Information we process for the purposes of legitimate interests
We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we do after having given careful consideration to:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for the purposes of:
- record-keeping for the proper and necessary administration of Erin Research
- responding to unsolicited communication from you to which we believe you would expect a response
- protecting and asserting the legal rights of any party
- insuring against or obtaining professional advice that is required to manage Erin Research’s risk
- protecting your interests where we believe we have a duty to do so
- verifying that you are a person that we have been instructed to locate
- tracing your whereabouts when we believe it is in your best interest to do so
- Information we process because we have a legal obligation
We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.
This may include your personal information.
Specific uses of information you provide to us
- Information provided on the understanding that it will be shared with a third party
Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
5.1. posting a message our forum
5.2. tagging an image
5.3. clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in the future in any way we decide.
Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for us to retain it, then at our discretion we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at email@example.com.
- Complaints regarding content on our website
We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.
If you complain about any of the content on our website, we shall investigate your complaint.
If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
- Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.
If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.
- Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.
We record your request and our reply in order to increase the efficiency of Erin Research.
We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
- Affiliate and business partner information
This is information given to us by you in your capacity as an affiliate of us or as a business partner.
It allows us to assess the requirements so as to successfully conduct our duties as instructed by you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
Use of information we collect through automated systems when you visit our website
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
11.1. to track how you use our website
11.2 to record whether you have seen specific messages we display on our website
11.3 to record your answers to surveys and questionnaires on our site while you complete them
- Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.
Disclosure and sharing of your information
- Information we obtain from third parties
Although we do not disclose your personal information to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal information from third parties whose services we use.
No such information is personally identifiable to you.
- Third party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
- Data may be processed outside the European Union
Our websites are hosted in the United States of America.
We may also use outsourced services in countries outside the European Union from time to time in other aspects of our business.
Accordingly data obtained within Ireland or any other country could be processed outside the European Union.
For example, some of the software our website uses may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to data transferred outside the European Union:
15.1. the sub processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
15.2. the data protection clauses in our contracts with data sub processors include transfer clauses written by or approved by a supervisory authority in the European Union, specifically that in the country of Ireland.
15.3. we comply with a code of conduct approved by a supervisory authority in the European Union, specifically that in the country of Ireland
15.4. both our organisation and the sub processor are professional organisations between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information
Access to your own information
- Access to your personal information
16.1. At any time you may review or update personally identifiable information that we hold about you, by signing in to your account on our website.
16.2. To obtain a copy of any information that is not provided on our website you may send us a request at firstname.lastname@example.org.
16.3. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.
- Removal of your information
If you wish us to remove personally identifiable information from our website, you may contact us at email@example.com.
This may limit the service we can provide to you.
- Verification of your information
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
19 Rectification of your information
You have the right to request that we correct any personal information you believe is inaccurate or incomplete.
20 Erasure of your information
We processes your personal data for a number of purposes as detailed above.
You have the right to be forgotten and you can request the erasure of personal data where:
- It is no longer necessary for the purpose Erin Research originally collected/processed it for
- Erin Research was required to obtain your consent to process your personal data; you have the right to withdraw your consent
- Erin Research process data based on legitimate interests, there is no overriding legitimate interest to continue this process and you object to the processing of your data
- Erin Research are processing the personal data for direct marketing purposes and you object to that processing
- Data was unlawfully processed (i.e. otherwise in breach of the GDPR)
- It has to be erased in order to comply with a legal obligation
- It is processed for information society services to a child
Erin Research has the right to refuse to comply with a request for erasure if we are processing the personal data for one of the following reasons:
- to exercise the right of freedom of expression and information;
- to comply with a legal obligation;
- to perform a public interest task or exercise official authority;
- for archiving purposes in the public interest, scientific research, historical research or statistical purposes; or
- to exercise or defence of legal claims
21 Objection to processing of your information
In the event we process your data where we have identified that such processing is based upon legitimate interest and you believe there are no grounds for us to continue to process your data, you have the right to object to Erin Research’s processing of your personal data.
22 Who we share your data with
Personal information is stored, processed and communicated to our clients so that they may fulfil their legal obligations. Your data may also be shared where necessary with researchers, international bodies and other data subjects to assist in this aim, including subprocessors in third countries in accordance with requirements under the GDPR.
23 Transfer of data to third countries
When conducting our research, it is not unusual for family members to move abroad. It is sometimes necessary to use the services of a vetted international researcher, who has access to records available abroad. In this circumstance, or where an international body may also be able to assist, we may transfer data subject’s personal and sensitive personal information to a third party researcher. We employ all of the relevant safeguards under the GDPR, obtain the written consent of the data controller where appropriate and only send children’s information by encrypted email.
24 Where data is obtained from
Erin Research obtain the personal and sensitive personal information of data subjects from public records, licensed databases, legal authorities and from interviewing individuals.
25 Retention of data
Where data is retained for research purposes, the data will not have a specified time limit before erasure due to the nature of research and the requirement to continue to research or archive the research information in the legal interests of the data subjects and our clients.
Where a case is confirmed as closed by our client, Erin Research shall arrange for the secure disposal of all data after 6 years from the date the case has been closed.
In some cases our clients will request that all data is securely disposed of within a specified time-frame less than 6 years after the conclusion of our research.
26 Data portability
Where you have provided your data directly to us for the purpose of a contract, or where you were required to provide your consent for us to process your data, you have the right to request your data in a structured, machine-readable format and where you request (and if possible) we will transmit your personal data to another data controller. We will always try to facilitate such a request where it is technically feasible to do so.
27 Use of site by children
27.1 We do not sell products or provide services for purchase by children, nor do we market to children.
27.2 If you are under 18, you may use our website only with consent from a parent or guardian
28 Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
29 How you can complain
29.1. If you are not happy with our privacy notice or if have any complaint, you can email us to firstname.lastname@example.org.
29.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.
29.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Data Protection Commissioner. This can be done at https://www.dataprotection.ie/docs/complaints/1592.htm
- Retention period for personal data
Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:
30.1. to provide you with the services you have requested;
30.2. to comply with other law, including for the period demanded by our tax authorities;
30.3. to support a claim or defence in court.
- Compliance with the law
However, ultimately it is your choice as to whether you wish to use our website.
We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.
- Types of data we may process
Erin Research retain personal data to fulfil any contractual arrangement with our clients and to provide our clients with a professional service.
This personal information can be collected from our clients and from other sources such as public records, subscribed databases, and from persons that we normally contact as part of our research.
The data which may be collected include;
Personal details such as name (including former names), date of birth, marriage or death, sex, contact details (e.g. home address and former addresses, telephone numbers and e-mail address), and identifiers such as PPS numbers.