Privacy Policy

Lucy O’Sullivan operates https://www.cleverconveyance.ie (the “Site”). This page informs you of my policies regarding the collection, use and disclosure of Personal Information I receive from users of the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

My privacy policy (the “Privacy Policy”) explains the information I collect, how I use and share it, how to manage your privacy controls and your rights in connection with my website. Please also read my terms of service which sets out the terms governing the Services. Lucy O’Sullivan is based in the Republic of Ireland and my Services are provided to you by Lucy O’Sullivan Solicitor. If you are a resident of the European Economic Area (“EEA”), Lucy O’Sullivan is the controller of your personal data for the purposes of EEA data protection law. This privacy notice aims to give you information on how Lucy O’Sullivan collects and processes your personal data through your use of this platform, including any data you may provide through this platform when you sign up to my platform and/or use the website. This platform is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Lucy O’Sullivan is the controller and responsible for your personal data.

Contact Details

Information Collection And Use:

While using our Site, I may ask you to provide me with certain personally identifiable information that can be used to contact or identify you.

Log Data:

Like many site operators, I collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this.

Communications:

I may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. Prior to this contacting you I will ensure you have consented to receiving the same by opting-in to our use of your Personal Information for this purpose. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Cookies:

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. Like many sites, I use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of my Site. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy for more information.

Disclosures of Your Personal Data:

I may have to share your personal data with the parties set out below for the purposes set out above.

• Internal Third Parties:

Other business process outsourcing companies as joint controllers or processors and who are based in the USA or elsewhere and provide IT and business process outsourcing services. This includes customer support staff at Auctioneera Limited, which provides customer support and IT services to me.

• External Third Parties:

Service providers acting as processors based in the USA and elsewhere, who provide IT and business process outsourcing services.

Third parties to whom I may choose to sell, transfer, or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy policy.

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.

Security:

The security of your Personal Information is important to me. I will use appropriate organisational and technical measures to protect your Personal Information, in compliance with applicable data protection law.

Service Providers:

I may employ 3rd party service providers and individuals to maintain my Services, to provide Services on/for our behalf, to perform Service-related services, to assist how my Service is used. These 3rd parties may have access to your Personal Information only to perform the tasks on our behalf & are obligated not to disclose / use it for any other purpose than intended. Before engaging any 3rd party Providers I have satisfied myself that they have in place appropriate technical & organisational measures to keep your Personal Information secure and safe.

Compliance with Laws:

I will never disclose your Personal Information unless I am required to do so by law or subpoena or if I believe that such action is necessary to comply with the law and the reasonable requests of law enforcement or to protect the security or integrity of my Service.

International Transfer:

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your country or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

If you are located outside Ireland and choose to provide information to me, please note that I transfer the information, including Personal Information, to Ireland and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

I share your personal data with certain third party service providers. This will involve transferring your data outside the European Economic Area (EEA). The external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where I use providers based in the US, I may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.

Links to Other Sites:

My Service may contain links to other sites that are not operated by me. If you click on a third party link, you will be directed to that third party’s site. I strongly advise you to review the Privacy Policy of every site you visit. I have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Clicking on links or enabling those connections may allow third parties to collect or share data about you. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my platform, I encourage you to read the privacy notice of every website you visit.

Changes to the Privacy Notice and Your Duty to Inform Me of Changes

This version was last updated on 21 May 2022 It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with us.

Complaints:

You have the right to make a complaint at any time to the Data Protection Commissioner's Office (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). I would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact me in the first instance at info@cleverconveyance.ie

Information I Collect

Lucy O’Sullivan collects information about you, including information that directly or indirectly identifies you, if you choose to share it with me. I receive information in a few different ways, including when you create an account with me or engage with my website and use the Services. I also collect information about how you use the Services. I may use this personal information to authenticate you and to provide you with the Service you have requested from me and as per the terms and conditions you accept when creating an account. There are also several opportunities for you to share information about yourself on my website.

Account, Profile, Activity, and Use Information:

Account, Profile, Activity, and Use Information: I collect basic account information such as your name, email address, phone number, username and password and payment information that helps secure and provide you with access to my Service. I use your contact information so I can respond to your support requests and comments and connect with you in respect of the Services.

Payment Information:

I may collect your payment information to pay for any Services you have requested from me. This includes but is not limited to your credit and debit card number, card expiry date, CSV /CV2 number, BIC (Bank Identifier Code), IBAN (International Bank Account Number), direct debit mandate authorisation and cheques. Credit and debit card information is processed directly by PCI-compliant payment providers who perform payment services on my behalf. Occasionally, my employees or third party business process outsourcing companies engaged by me may receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately.

Technical Information and Log Files:

I collect information from your browser, computer, or mobile device, which provide me with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyse trends, administer, protect and secure the Services, track usage in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to account information and device identifiers.

Other Information:

I may collect information from you through third parties, such as when I collect your feedback through surveys.

How I Use Information:

Lucy O’Sullivan uses the information I collect and receive as described below.

To Provide the Services:

I use the information I collect and receive to provide the Services, including providing you with the ability to:

• Record Your Activities.
• Interact with me.

To Customise Your Experience:

I use some of the information you provide to personalise your experience with me as you use my services, such as addressing you personally on my services and making navigation on my website easier. Where I collect this information by way of cookies or other similar technologies, I only collect this information with your consent, which you can withdraw at any time. However where I further process this information, I rely on the lawful processing ground of legitimate interest in delivering relevant content to my users. You have the right to object to this processing if you wish – please contact us at info@cleverconveyance.ie if you wish to object.

To Improve my Services:

I also use the information I collect to analyse, develop and improve the Services. To do this, I may use third-party analytics providers to gain insights into how my Services are used and to help me improve the Services.

To Communicate With You:

I use the information I collect to provide support in response to your requests and comments. This includes marketing and push communications, where you have not opted out of receiving such messages and notifications.

To Process Your Account:

I use the information I collect to process your end user account to access the platform.

Aggregate Information

I do not sell your personal information. I may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties, including the Metadata pursuant to my Terms.

How Information is Shared:

In addition to sharing aggregated data about my users as described above, I also share personal information in accordance with your preferences, as needed to run my business and provide the Services, and where required for legal purposes, as set forth below.

Service Providers:

I may share your information with third parties who provide services to me such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on my behalf and are required to protect and secure your information. I may also engage service providers to collect information about your use of the Services over time on my behalf, so that I or they may promote me or display information that may be relevant to your interests on the Services or other websites or services.

How I Protect Information:

I take several measures to safeguard the collection, transmission and storage of the data I collect. I employ reasonable protections for your information that are appropriate to its sensitivity. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. I engage providers that are industry leaders in online security, including Services verification, to strengthen the security of my Services. The Services are registered with site identification authorities so that your browser can confirm my identity before any personal information is sent. In addition, my secure servers protect this information using advanced firewall technology.

Managing Your Settings

Privacy Controls:

I offer several features and settings to help you manage your privacy and share your activities.

Updating Account Information:

You may correct, amend or update profile or account information at any time by adjusting that information in your account settings.

Deleting Information and Accounts and Downloading Your Data:

After you make a deletion request, I permanently and irreversibly delete your personal data from my systems, including backups. Once deleted, your data, including your account cannot be reinstated and a new account will need to be set up by you. Following your deletion of your account, it may take up to 90 days to delete your personal information and system logs from our systems.

Your Legal Rights in the EEA:

If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information.

Our Legal Bases:

I rely on a number of legal bases to collect, use, share, and otherwise process the information I have about you for the purposes described in this Privacy Policy, including:

• as necessary to provide the Services and fulfil my obligations pursuant to the terms of service;
• where you have consented to the processing;
• where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
• to protect your vital interests, or those of others, such as in the case of emergencies; and
• where necessary for the purposes of my or a third party’s legitimate interests, such as my interests in protecting my users, my partners’ interests in collaborating with my users, and my commercial interests in ensuring the sustainability of the Services.

Privacy Policy Information:

I reserve the right to modify this Privacy Policy at any time. Please review it occasionally. If I make changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if I make material changes, I will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.

Your Legal Rights:

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

No fee usually required:

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

What I may need from you:

I may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. I may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond:

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.