This is the Privacy Statement of DE Power Solutions Limited (“DEPS”) .In this statement we use the terms “we”, “our” and “us” to refer to our businesses .
The purpose of this Privacy Statement is to outline our position concerning the collection, use, retention, disclosure, and transfer of Personal Data which is gathered and processed by us . This Privacy Statement also sets out our information management practices.
We respect the privacy of all those individuals whose Personal Data we encounter, which in particular includes the following:
- All users of our Websites, Social Media Pages or Apps;
- Employees and contractors of DEPS (including applicants for employment);
- All members of DEPS (including former employees) on sponsored pension schemes;
- Business contacts and suppliers;
- Customers or prospective customers.
For each of these categories of individuals, this Privacy Statement will explain why we collect and how we use the Personal Data collected. We will ensure that we keep all Personal Data provided in accordance with our obligations under applicable data protection laws. We may update this Privacy Statement from time to time to reflect any material changes in technology, legislation or data use practices which may materially affect the way in which we process Personal Data.
This is not an exhaustive statement of all our data protection practices, and we may apply specific policies within certain environments. We might include a separate privacy notice at the point of capturing data on a new service and any specific consents obtained or information provided in this way will apply specifically to that service and will supplement this Statement.
1. What is Personal Data?
Personal Data is any information relating to a living individual that allows for the identification of that individual. Personal Data can include a name, address, contact details, an identification number, IP address, CCTV footage, accesses cards/co-tags, fobs, audio-visual or audio recordings of a person, details about an individual’s location or any other detail(s) specific to that individual such in certain cases special category data such as (Biometric).
2. Who we are and how to contact us?
In circumstances where DEPS controls Personal Data by deciding why and how that Personal Data is processed, we will be a “Data Controller”. Any entity that processes Personal Data controlled by us and does so on behalf of us, is a “Data Processor”. Data Processors may include third party service providers engaged by us (for example communications providers, payroll and marketing or recruitment agencies). As required by applicable data protection law, when we appoint a Data Processor, we will ensure that appropriate contractual protections are in place.
If you have any questions about this privacy statement, including any request to exercise your legal rights, please contact us by writing to our Data Compliance Officer, C/O OHM Group, Clonlara Rd, Baldonnell Business Park, Dublin, D22 or emailing us at firstname.lastname@example.org .
3. Categories of personal data and how we use it.
This section of the Privacy Statement sets out the type of Personal Data collected by us, the purposes for which such Personal Data is collected and processed and the lawful justifications for such processing in the context of our Website.
We also collect, use, and share aggregate data such as statistical or demographic data. Aggregate data is information gathered and expressed in a summary form for purposes such as statistical or demographic analysis. Aggregate data may be derived from your personal data but is not data that directly or indirectly reveals your identity. For example, we may aggregate your usage data of our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregate data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this data protection statement.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data (apart from consented employees). Nor do we collect any information about criminal convictions and offences. However, if it is necessary to collect special categories of personal information and/or criminal conviction information, we will only do so with your explicit consent and we will explain the purpose for which the information will be used at the point when we ask for your consent.
4. How we obtain your information?
We may collect your information though our website or social media platforms where you provide it to us, such as when you fill out contact forms, request information on a product or service or where you request a brochure . We may also collect information from you at events and brand displays, such as at conferences etc.
DEPS is not responsible for the privacy practices of any external websites, manufacturers or platforms which may be accessed or used in connection with a person’s use of our website or social media pages. They are subject to their own privacy statements which may materially differ from those of DEPS so users should review them for further information.
5. What Personal Data does DEPS collect and use online?
We collect various types of Personal Data when a person uses our website or social media sites. The following are examples of Personal Data collected by us:
- Social Media Pages: Content such as messages and photographs, that are posted on social media pages on which we have a presence and maybe made publicly available and used in connection with the operation and promotion of our social media pages, services, and our websites. If content is posted that is deemed to be in breach of this Privacy Statement or the policies operated by such websites or social media platforms, such content may be removed by or at the request of DEPS or the operators of those social media websites. If such inappropriate content is posted to a social media page that we control, you can report it at the following address email@example.com and we will endeavor to ensure that appropriate action is taken in accordance with our policies and the policies of the relevant social media platforms.
6. The purpose and legal basis for processing your information.
We collect and process the Personal Data described below for a variety of purposes. Below is a summary of these purposes and the lawful justifications that support them:
a) To enter into and perform a contract with you.
We may process your information in order to enter into a contract with you or to provide you with a product or service which you have requested from us. For example, we need to process your personal information in order to enable you to purchase a product or service, warranty, or to provide you with a brochure or information about a product or service where you have requested it.
b) To comply with our legal obligations
We are required to process your personal information to comply with certain legal and regulatory obligations to which we are subject. For example, we are required to obtain certain business records in accordance with company and revenue law which may include your personal information.
c) For our legitimate business interests
We may use your personal information for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.
If you are a customer or business prospect, we may use your information to send you communications on products and services that may interest you and that you would reasonably expect to receive, you can at any stage easily opt out of these communications by contacting us on firstname.lastname@example.org or by clicking the unsubscribe link in the communication.
We may use your personal information to manage our everyday business needs, including accounting, internal reporting needs, and market research, to progress and respond to legal claims, security of our premises and staff through use of CCTV, to process claims, to ensure appropriate IT security and to prevent fraud, to monitor and audit warranty claims. Our legitimate interest is the effective management of our business.
We may use your personal information to send you notifications on your order such as delivery dates or maintenance/services appointments ,we do so in our legitimate interest. Our legitimate interest is connecting with our customers.
We may use your personal information in an aggregate form to classify our customers and to acquire an aggregated overview of our customer base in our legitimate interest. Such processing does not assess individual characteristics. Our legitimate interest is to grow our business, understand our customer base and provide products and services of interest to our customer base as a whole.
We may use your information which we collect, including personal information we obtain from publicly available sources such as social media, to help us understand our customers and provide products or services which may be of interest to you, in our legitimate interest. You have the right to object to this at any time by contacting us on email@example.com
We may acquire your contact data from reputable marketing agencies, which may include your personal data with the intention to provide you with information on products or services which may be of interest to you, in our legitimate interest. We will notify you of any such acquisition and you have the right to object to this at any time by contacting us on firstname.lastname@example.org
We may also contact you in the event of updates about our business such as opening hours, change in address, updates about our site etc. We do this in our legitimate interest in order to keep our customers updated of changes within our organisation.
d) With your consent
e) To protect your vital interests
We will in certain circumstances use your personal information to protect your vital interests, for example we may contact you in the event of a significant recall or safety issue with your Generator.
|Purpose||Description||Lawful Basis for Processing|
|Purchasing a Product/Service||We will process your personal data in order to provide you with the product or service that you requested.
We may process your data for warranty purposes upon your request.
|The processing is necessary for the performance of a contract to which the data subject is party.|
|Service & Maintenance||We may process your data for the purpose of conducting maintenance on your product.||The processing is necessary for the performance of a contract to which the data subject is party.|
Marketing to Potential Customers and Customers
|Information is collected by our Sales, and/or Marketing staff when any customer, or potential customer, contacts us.||Where you are a Business Prospect or Customer
The processing is in our legitimate interests to develop our business by providing information that is relevant and where the data subject has not opted out of the processing.
|Quality Improvement / Staff Training||All, written communications, and communications received through the web are stored by us.||The processing is in our legitimate interests in providing a high standard of services to our customers, by assessing the ongoing development and identifying areas for improvement.|
|CCTV||We operate a CCTV system on our premises to protect the safety and security of our staff and property and for health and safety purposes.||The processing is in our legitimate interests as a private company regarding Health, Safety and Security.|
|Safety Incidents / Product recall||We may use your personal data to contact you regarding an urgent safety measure and / or a product recall.||The processing is necessary for compliance with a legal obligation to which the controller is subject.
The processing may be necessary to support your vital interests.
|Legal obligation||We may use your personal information to comply with various legal obligations to which we are subject including.
We may use your personal data to comply with anti-money laundering regulations.
Making a payment of VAT and revenue reporting purposes.
COVID 19 Contact Tracing Logs
COVID 19 Return to work Safely Forms.
|The processing is necessary for compliance with a legal obligation to which the controller is subject|
|Dealing with sales and other enquiries||To respond to correspondence, you send to us and fulfil the requests you make to us (for example brochure requests or information about products);||To takes steps prior to the entry into a contract with you and for our Legitimate Business Interests|
|To understand our customer base||We may use your personal information on an aggregate basis for market research purposes to help us understand our customer base||We rely on our legitimate interest in order to understand our customer base.|
|Business needs||We may also use your personal information to manage our everyday business needs, including accounting, sharing your information within our company group for administrative purposes, and to prevent fraud.||We rely on our legitimate interest in the effective management of our business|
|Website Security||To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|Website analytics||To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||With your consent where your data has been collected through our website. We use the data to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
7. Who do we share information with?
Third party service providers: DEPS discloses Personal Data to third parties in certain instances. For example, we use third party service providers for the processing of Personal Data for a number of purposes, including, security service providers, consultant advisors, IT service providers, printers, debt collection agencies, valuers, marketing companies market research and providers of administrative services. These service providers are subject to a contractual obligation to only process Personal Data obtained from us for purposes to which it was obtained and in accordance with our instructions.
We will not provide your Personal Data to third parties who may contact you for direct marketing or promotional purposes unless you have consented to disclosing your Personal Data to such third parties for that purpose.
In certain circumstances we will disclose personal data to other external third parties such as our professional advisors as necessary in the context of the performance of their services. Such recipients may include external legal advisors, auditors, actuaries, pension and tax advisors, pension administrators and other professional advisors.
Disclosure of such data will take place for a variety of reasons including in order to ensure that we meet our tax and other statutory obligations.
We may also disclose personal data to its insurance providers in connection, with legal claims and prospective legal claims or proceedings.
OHM Group and other OHM Group entities: We are part of the OHM Group and we may pass your information on to OHM Group entities, for the purpose of administrative efficiencies and for storing your data in central IT Systems. https://www.ohm.ie/brands/
Insurance Companies: We may disclose personal data to our insurance providers in connection, with legal claims and prospective legal claims or proceedings.
Manufacturer: We may pass on your information to the manufacture of your generator for warranty requests and claims. See below details of manufacturers that we may provide your information to.
- KOHLER – SDMO https://www.kohler.com/corporate/privacy_uk.html
An Gardai Siochana, Revenue Commissioner, Government Bodies/Officials: We may provide your personal information to the Gardaí, or Government Bodies where required to do so by law.
Potential sale or merger
If we sell any part of our business and/or integrate it with another organisation, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs, the new owners of the business will only be permitted to use your information in the same or similar way as set out in this data protection statement.
8. What type of information is collected?
We may need to collect many categories of personal data (about you and other parties) for the purposes set out in this Privacy Statement.
The following table is a non-exhaustive list and provides an indication of the categories and types of personal data we use to perform our duties.
|Purpose||Type of Data|
|Sales of Product/Service||Name, Address, Contact Details, Bank Details, Account History, Gender|
|Customer Care||Name, Address, Contact Details, Phone Calls|
|Finance||Bank Details, Visa/Debit Card Details|
|Marketing||Name, Address Contact Details, Occupation, Gender, Purchase History, I.P Address, Cookie Preferences, Contact Forms|
|Security||CCTV Footage, I.P Address|
|IT Information||We collect information about your internet activity using technology known as cookies. Your consent will be required for certain cookie types. See our cookies policies on our website for further information.|
9. Storage Periods
The period for which we will keep your personal information will depend on the service you have requested from us. The retention period may be longer than the period for which we are providing services to you where, for example, we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, or where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in the event of a legal claim.
We will endeavor to ensure that Personal Data is retained for an appropriate period and no longer than necessary. Retention of data is detailed in our Data Retention Policy.
10. Transfers outside the European Economic Area
We may transfer, store, or process your personal information to countries outside the European Economic Area. Where the laws of such countries do not afford an equivalent level of protection of personal information as the laws of Ireland, we take specific steps in accordance with data protection law to protect your personal information.
We will use one of these safeguards:
- Transfer to a non-EEA country with privacy laws that give the same protection as the
- Put in place a contract (in a form that is approved by the European Commission) with the recipient of the personal information that means they must protect it to the same standards as the
- Transfers to organisations that are part of an EU Framework that sets privacy standards for data sent between countries. These frameworks make sure those standards are similar to what is used within the EEA.
11. How we use automated processing
We may analyse your personal information by automated means for the purposes of market research, analysing our customer database and for our marketing activities. You have the right to object to this at any time by emailing email@example.com .
12. Marketing communications
If you are a customer or prospective business contact, we may use your name, address, email address, postal address and/or telephone number for marketing communications. We will conduct a legitimate interest assessment to ensure there is an appropriate balance between our interests and your rights and freedoms.
Customers can opt-out of receiving direct marketing communications from us by following the unsubscribe link in the relevant marketing message.
We will not provide any personal information to third parties or partners for direct marketing purposes unless the users have consented to us giving their Personal Data to third parties or partners for that purpose.
If a user opts-out from receiving communications from third parties or partners, we will no longer share that user’s contact details with our partners or third parties. However, users will still need to directly opt-out from communications from the partners to whom we have already given their information.
We may use third party service providers to help deliver its marketing communications. Those third-party data processors are subject to contractual and legal restrictions in relation to any unauthorised use of your information.
13. Processing for Security Purposes
We operate closed circuit television cameras (“CCTV”) located throughout its premises covering buildings, internal spaces, car parks, roads, pathways, and grounds. Our CCTV system is implemented in a proportionate manner as necessary to protect our property against theft or pilferage and for the security of employees, customers, and visitors to our premises (to protect their vital interests). Whilst CCTV footage is monitored by senior management, security staff or contractors, access to recorded footage is strictly limited to authorised personnel. Footage is retained for 60 days, except where incidents or accidents have been identified in which case such footage is retained specifically in the context of an investigation of that issue. CCTV footage may be used in the context of disciplinary proceedings involving our employees and to detect, establish and/or defend legal proceedings (to protect the vital interests of our staff and affected individuals). CCTV footage is not disclosed to third parties except where disclosure is required by law (such as for the purpose of preventing, detecting, or investigating alleged offences) and in such instance’s disclosure is based on a valid request. Signage indicating that CCTV is in use is displayed throughout our premises.
14. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
15. Information Security
In accordance with applicable laws, we ensure that all Personal Data controlled by us is held securely using appropriate security measures including the following:
- Physical measures such as locked filing cabinets and offices containing Personal Data;
- IT security systems;
- Restricted access to Personal Data subject to approvals;
- Time limits on retention of personal data;
- Provision of targeted data protection training to employees, contractors and other staff who have access to and process Personal Data;
- Password restrictions on access to Personal Data; and Technical measures including:
- Encryption on laptops/portable devices; and
- Logging mechanisms to record certain access to Personal Data and alteration and other processing of Personal Data.
In the event of a personal data breach, we will comply with applicable reporting and notification obligations under data protection law. We have in place a Breach Notification Policy.
16. Your Rights
In certain circumstances, you have the following rights under data protection law in relation to your personal data:
A right to access Personal Data held by DEPS.
- Any individual has a right to make an access request, in writing, under data protection law for a copy of their Personal Data held by us .We may ask for further identification details to confirm your identity before the relevant information is provided.
- It should be noted that there may be specific exemptions relating to accessing Personal Data. If we utilise any of the exemptions, we will provide you with details and our justification for their use.
Other data protection rights
- Rectification of inaccurate personal data;
- Erasure of personal data (also known as the “right to be forgotten”);
- Restriction of processing of persona data;
- Right to data portability;
- Right to object to processing of personal data.
However, under data protection law, these rights are available only in certain circumstances. If you wish to exercise any of your data protection rights, please contact firstname.lastname@example.org . Please provide as much detail as possible to enable us to respond to your request and to locate relevant personal data about you. We will endeavor to respond to your request within a month. If we are unable to deal with your request within a month, we may extend this period by a further period of two months and we will explain why.
By Post: DCO,C/O OHM Group, Clonlara Rd, Baldonnell Business Park, Dublin, D22
By Email: email@example.com
By Phone: + 353 (0) 1 4034100
You also have the right to lodge a complaint to the Office of the Data Protection Commission. For further information please see www.dataprotection.ie
This Data Privacy Statement may be updated from time to time (Latest update 30th April 2021). You will always find the most up to date version on our websites at https://depower.ie/privacy-statement/