Privacy

LEILex is committed to respecting your privacy and protecting your Personal Identifiable Information

• We will be transparent about the information we are collecting and what we will do with it.
• We will use the information you give us for the purposes described in our Privacy Policy, which include providing you with services you have requested and enhancing your experience with LEILex.
• We will also use the information to help us understand you better and so that we can give you relevant offers.
• If you tell us, you don’t want to receive marketing messages we will stop sending them. We will, of course, continue to send essential information relating to a product or service you have purchased to keep you informed about your service.
• We will put in place measures to protect your personal identifiable information and keep it secure.
• We will respect your data protection rights and aim to give you control over your own personal identifiable information.

You can access our full Privacy Policy below to help you to understand better how we use your Personal Identifiable Information. In it, we explain in more detail the types of Personal Identifiable Information we collect, how we collect it, what we may use it for and who we may share it with.

Within the Data Privacy Policy you will find some specific examples of why and how we use your Personal Identifiable Information. If you have further questions please get in touch with us by writing to Data Protection Officer, LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

Without prejudice to your rights under applicable laws, the above and the Privacy Policy are not contractual and do not form part of your contract with us.

Full Privacy Policy

Controller of Personal Identifiable Information

Any Personal Identifiable Information processed by LEILex in connection with this Data Privacy Policy is controlled by LEILex, which is considered the “data controller” of your Personal Identifiable Information under European Union and Irish data protection law.

Our address is Data Protection Officer, LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

What do we mean by Personal Identifiable Information?

Personal Identifiable Information means details which identify you or could be used to identify you, such as your name and contact details, your company details and payment history. It may also include information about how you use our websites and mobile applications.

When does this policy apply?

This Privacy Policy applies to Personal Identifiable Information about you that we collect, use and otherwise process regarding your relationship with us as a customer or potential customer, including when you use our services, use our websites or mobile applications and contact our service agents or support centres to support our services.

How can you keep your Personal Identifiable Information secure?

We take great care to protect the Personal Identifiable Information you provide to us. Here are some things you can do to keep your information secure.

Keep your LEILex.com registered account log-in details confidential

To make sure your access to our websites, other online services, and mobile applications is secure, you should not share your log in details with anyone else. When you finish using the website, online services or mobile app you should log out if others may be able to access your computer or device. This is especially important if you are using a publicly accessible computer.

Be aware of and protect yourself against Internet fraud and ‘phishing’

There is an Internet fraud practice known as ‘phishing’ which the illegal gathering of Personal Identifiable Information by deception is. Unsolicited emails are sent to individuals from lists illegally gathered by a third party, and recipients are asked to enter or reconfirm bank or password details into a ‘cloned’ or illegal copy website

When do we collect Personal Identifiable Information about you?

We collect Personal Identifiable Information about you whenever you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you when you use our website or mobile applications, or interact with us via email or use our support centres. For additional details see ’What types of Personal Identifiable Information do we collect and retain?’ below.

In addition, we may receive Personal Identifiable Information about you from third parties, such as companies contracted by us to provide services to you.

What types of Personal Identifiable Information do we collect and retain?

When you use our services, you will need to provide us with your personal details.

We collect the following categories of Personal Identifiable Information:

• Information you provide for LEILex to complete and manage a query you have made with us or a service you have requested from us.
• Information about the services we have provided to you in the past.
• Information about online registration and other interactions.
• Information about your use of our websites, support centres and mobile applications. For more details of the methods please see ‘How we use cookies and other methods for the collection of website usage data’.

When and why do we collect ‘sensitive personal data’?

Certain categories of Personal Identifiable Information, such as that about race, ethnicity, religion, health, sexuality or biometric information are special categories of data requiring additional protection under European Union and Irish data protection law and is referred to here as “sensitive personal data”. Generally, we try to never collect and process sensitive personal data. Examples of where we may collect and process ’sensitive personal data’ includes the following:

• You have otherwise chosen to provide such information to us or it has been passed onto us by a third party through which you made your contact with us.

What do we use your Personal Identifiable Information for?

The main purposes for which we use your Personal Identifiable Information are:

• To fulfil your requests and deliver the services you have asked for.
• To send status updates and service communications to you.
• To provide services tailored to your requirements and to treat you in a more personal way.
• To carry out analysis and market research.
• To carry out marketing including online advertising and keep you informed of LEILex products and services.
• To undertake targeted online advertising.
• To improve our websites, products and services.
• For management and administrative purposes.

When will you receive our marketing communications?

When we collect information directly from you we may ask you if you do not want to receive our marketing communications.

We will ask if you consent to receiving marketing communications from LEILex and we never share your information with third parties.

We will respect your choice as to what communications you wish to receive and how these are sent.

How can you change what marketing communications you receive and how you receive them?

If you decide you would no longer like to be sent marketing communications, you can change your mind at any time. The ways to stop being sent marketing communications are described below:

You can change your marketing preferences at any time in by writing to Connect@leilex.com and or writing to us at, LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

In addition, each marketing communication we send by email will also have an unsubscribe option which will allow you to stop you receiving further marketing emails. We aim to action requests to stop being sent marketing communications within 10 working days of receiving those requests, but it is possible you will receive some marketing in the period prior to that change being made.

Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications. If you ask us to stop sending marketing communications, please note we will retain your Personal Identifiable Information for the purposes of indicating that you do not want to receive marketing communications.

What is our legal basis for using your Personal Identifiable Information?

LEILex will only process your Personal Identifiable Information where we have a legal basis to do so. The legal basis will depend on the reason or reasons LEILex collected and needs to use your information. Under EU and Irish data protection laws in almost all cases the legal basis will be:

• Because we need to use your Personal Identifiable Information so that we can process your requests and otherwise perform the contract we have with you.
• Because LEILex needs to use your Personal Identifiable Information to comply with a legal obligation.
• Because you have consented to LEILex and/or consented to a Data Controller whom LEILex is acting on their behalf by using your Personal Identifiable Information for a particular purpose.

More information on each legal basis is provided below

If processing of your Personal Identifiable Information is subject to any other laws, then the basis of processing your PII may be different to that set out above and may in those circumstances be based on your consent in all cases.

How long do we keep Personal Identifiable Information?

We will keep your Personal Identifiable Information for as long as we need it for the purpose it is being processed for. For example, where you enquire about a product or service with us we will keep the information related to your query, so we can fulfil the specific service arrangements and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the service. The information may also be retained so that we can continue to improve your experience with us.

We will actively review the Personal Identifiable Information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your Personal Identifiable Information after 18 months of inactivity.

Performance of a contract with you

It will be necessary for LEILex to use your Personal Identifiable Information to complete a query you have made with us. For example, we will need to use information such as your contact details, company and payment information to provide you with service you have requested and paid for

Legitimate Interests

As a software as a service (SaaS) provider, LEILex has a legitimate business interest to use the Personal Identifiable Information we collect to offer an effective service and carry out our business.

Compliance with legal obligations

There are situations where LEILex is subject to a legal obligation and needs to use your Personal Identifiable Information to comply with those obligations. For example, if we collect and process medical information we are required to store that data for 7 years. These situations are described in our Terms of Service contract and/or Data Processing Agreements.

Consent

Alternatively, we may collect and use your Personal Identifiable Information where you have given your specific consent to us doing so.

If the basis of our processing your Personal Identifiable Information is consent to marketing, you can withdraw your consent to such processing at any time, by writing to Connect@leilex.com and or writing to us at, LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

Who do we share your Personal Identifiable Information with?

We may also disclose your Personal Identifiable Information to the following third parties for the purpose described here:

• Third party service providers we are using to provide services that involve data processing, for example, to carry out marketing initiatives or run customer surveys on our behalf.
• Third parties, such as law firms and law courts, to enforce or apply any contract with you.
• Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets.
• We may provide usage information (but not your personal details) to other websites so that they know that you have visited our websites (see ’How we use cookies and other methods for the collection of website usage data’ above).
• We may provide usage information including your personal details to marketing agencies to deliver online advertising on websites or social networks.
• If necessary to comply with a legal or regulatory obligation in any jurisdiction, including where that obligation arises because of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision).

We do not sell Personal Identifiable Information to third parties, and we only allow third parties to send you marketing information where we have your consent to do so.

What countries will your Personal Identifiable Information be sent to?

Your Personal Identifiable Information may be sent to and stored by us and third parties in countries outside the country in which you are located but it will remain inside the European Economic Area. We never send your Personal Identifiable Information outside the European Economic Area to fulfil any of our services.

If you would like more information on these safeguards, please contact Connect@leilex.com the Data Protection Officer, and or writing to us at, LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

Requesting a copy of your Personal Identifiable Information

Under the Data Protection Acts 1988-2003 and the General Data Protection Regulation (GDPR), you may request a copy of any Personal Identifiable Information about you held by LEILex. There is no fee for this request.

The request must be in writing and must contain the following:

• Your name and postal address.
• Details of your request.
• Any details which may help us locate the information which is the subject of your request, for example:
• Telephone recording details (identifier number, the number you call from, the number and option you dialled, the date and time of your call(s)).
• Email address

You must also provide:

• A photocopy of your passport or driving licence, so that we can verify your identity.
• Your signature and the date of the request.
• If you are applying on behalf of another person then signed authority from the individual is required.

Please send your request to:

Data Protection Officer by writing to Connect@leilex.com and or writing to us at, LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

What are your legal rights in relation to the Personal Identifiable Information we hold about you?

Under data protection laws in the European Union and Ireland, you have certain rights in relation to your Personal Identifiable Information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to three months, but we will let you know if this is the case.

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the Personal Identifiable Information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.

Details of how to exercise your rights are set out in the section below “How can you exercise your legal rights and change how we use your data?

Your rights include the following:

1. You may request us to stop sending you marketing. To see how to change your permission to market please refer to “How can you change what marketing communications you receive and how you receive them?” which can be located in “When will we send you marketing?”. If you do so we will no longer be able to send you marketing communications. However, if you subsequently engage with us we will need to send you communications about the services you wish to use.
2. You may request us to stop using your Personal Identifiable Information where we are doing so under legitimate interests (see the section “What is our legal basis for using your Personal Identifiable Information” for examples of when that applies) unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights.
3. You may request us to stop processing of your Personal Identifiable Information for marketing purposes including analytics for the purposes of targeted marketing, including online advertising.
4. You may access the Personal Identifiable Information we hold on you. There are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged. Please see “Accessing your Personal Identifiable Information” which can be located within “How can you exercise your legal rights and change how we use your data?” for more details.
5. You may ask us to correct your Personal Identifiable Information (the ‘right of rectification’) if that information is inaccurate. How to do this see section on “How can you change what marketing communications you receive and how you receive them?”
6. You may ask for Personal Identifiable Information which identifies you to be erased (or forgotten).

To do this we will remove the Personal Identifiable Information that identifies you from the data we hold in our active systems (“anonymise”).

Considerations

• We may need to retain certain elements that relate to a contract between you and LEILex because we need it for our own legal and auditing purposes (for more information on the basis on which we process your Personal Identifiable Information see the section “What is our legal basis for using your Personal Identifiable Information?”).
• A record of your request including the Personal Identifiable Information you supplied will be retained in the application used to carry this out for 3 years.
• We cannot erase your Personal Identifiable Information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past 6 years. We are required to retain this information in case there is a need to re-open the complaint.

How can you exercise your legal rights and change how we use your data?

If you wish to change how we use your Personal Identifiable Information, please contact use using the information below.

We will ask for some information to identify you, which will only be used to process your request. We will verify your identity via email before processing your request.

Alternatively, you can make a request by writing to us, ensuring you mark the letter for the Data Protection Officer.

Data Protection Officer LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

Accessing your personal information

If you wish to receive a copy of your Personal Identifiable Information, you can make your request in writing and include the following information with your request:

• Your name and postal address
• Details of your request
• A photocopy of your passport or driving licence, so that we can verify your identity
• Your signature and the date of the request
• If you are applying on behalf of another person then signed authority from the individual is required

Any details which may help us locate the Personal Identifiable Information which is the subject of your request, for example:

• Telephone recording details (identifier number, the number you call from, the number and option you dialled, the date and time of your call(s)).
• Email Address

If you wish the Personal Identifiable Information to be provided to you in a machine-readable copy, please indicate that at the time of making your request. Please send your request to:Connect@leilex.com

Or alternatively you can make a request by writing to:

Data Protection Officer, LEILex, Unit 1, CHQ Building, Custom House Quay, Dublin 1.

How will we inform you of changes to this Data Privacy Policy?

If we change this Privacy Policy, we will let you know about the changes by publishing the updated version on www.LEILex.com. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Policy.

This Privacy Policy came into effect on 1st May 2019 replacing our previous Privacy Policy. This Privacy Policy applies to all information we process about you in connection with your relationship with us as a customer or potential customer.

Please write to the Data Protection Officer if you would like to find out more about any matters to do with this Privacy Policy.

How to get in touch with us and your right to complain to our supervisory authority?

If you have any questions about this policy, please contact the Data Protection Officer.

The Data Protection Officer for LEILex can be contacted at Connect@leilex.com

We work hard to handle your Personal Identifiable Information responsibly. If you are unhappy about the way we do this, please contact LEILex Data Protection Officer who will address your concerns.

We hope that we will be able to resolve any concerns you may have

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Last updated: 9th December 2022