Privacy Statement

Effective Date

30 November 2018

Purpose

This privacy statement provides information about the ways in which Sluamor collects, stores, shares or keeps personal information provided by our customers. It is a live document, under regular review and as such may be changed from time to time.

Data Protection Principles

Sluamor Limited is an Irish company and as such we comply with our obligations under the data protection legislation of Ireland, a member of the European Union (EU) and the European Economic Area (EEA). Specifically, we are governed by the Data Protection Acts 1988 & 2003 and Statutory Instrument Number 336 of 2011 European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011. All data collected on this site shall be processed in compliance with these acts and regulations.

It is our policy to adhere to the data protection principles set out by the Irish Data Protection Commissioner:

1. Obtain and process information fairly.

2. Keep it only for one or more specified, explicit and lawful purposes.

3. Use and disclose it only in ways compatible with these purposes.

4. Keep it safe and secure.

5. Keep it accurate, complete and up-to-date.

6. Ensure that it is adequate, relevant and not excessive.

7. Retain it for no longer than is necessary for the purpose or purposes.

8. Give a copy of his/her personal data to the individual, on request.

Security

Sluamor takes its security responsibilities seriously, employing the most appropriate physical and technical measures, including staff training and awareness. We review these measures regularly.

Hosting

Sluamor’s hosting services provider is located in Ireland, a member of the European Union (EU) and the European Economic Area (EEA). The servers used to store our data are in Ireland and our data is not stored or transferred outside of the EEA. Access to Sluamor’s data by our hosting partner is strictly limited by Irish law. However, this data may be accessed by staff operating outside the EEA who work for Sluamor. We will take all steps reasonably necessary to ensure that our data is treated securely and in accordance with this privacy statement.

Purposes for which personal data is used

Sluamor may use the data we collect for the following purposes:

• Providing you with a personalised service.

• Allowing you to participate in interactive features of our service, where they choose to do so (e.g., processing subscriptions, payments, enquiries, and pitches and applications regarding opportunities on the Sluamor.com platform).

• Suggesting and recommending content on our website which we believe that you'll find useful or interesting, as part of our attempts to provide a quality service.

• Providing you with communications and services for which you've signed up.

• Providing you with marketing messages (e.g., newsletters), if you've asked us to do so. We will ask for your consent in advance, and thereafter, you can manage your preferences by opting out after signing on the Sluamor.com platform or by using the 'unsubscribe' link we will included in any marketing messages sent.

• To analyse and audit usage of the site. We may record user movements, including page scrolling, mouse clicks and text entered. The data we collect in this way helps us to identify usability issues, to improve the assistance and technical support we can provide to you, and for aggregated and statistical reporting purposes.

• Notifying you of changes to our policies and communicating with you about non-compliance.

• Conducting surveys or research so that we can continue to improve and enhance our business. User participation is entirely voluntary and any information provided is kept anonymous.

• Allowing users to take part in competitions or other promotional activity.

• Managing and tracking our marketing efforts to conduct business with individuals with whom we already have a business relationship or want to develop one. In support of such activities, we will use Customer Relationship Management (CRM) service to collate personal data you may have provided to us via the Sluamor.com platform or at networking events, or using publicly available information (e.g. board membership, published articles, press releases, public posts on social media sites). Activities to be tracked via our CRM service will include your responses to targeted e-mails, activity on our website following links from our emails, and other business information included by members of our team based on their personal interactions with you. If you wish to be excluded from our CRM database, please contact us using the details provided at the end of this statement and we will facilitate the removal of all relevant data.

We will not record financial information such as credit or debit card details. Credit and debit card information is processed directly on our behalf by Stripe our PCI-compliant payment gateway provider.

In capturing the data needed for the purposes outlined above, we may use cookies or similar technology as explained our Cookie Policy.

Sharing of Personal Data

• We may share personal data within Sluamor Limited, and our parent company Keystone Procurement Limited.

• We share personal data with third parties we use to process the data on our behalf when they provide services to us (e.g., accountants, payment providers, lawyers, marketing agencies, providers of security and administration services).

• If we sell, transfer, or merge parts of our business, or if we buy or merge with another business we may share personal data that we've collected. In the event of a change of ownership of our business, the new owners will be expected to use your personal data as set out in this privacy statement.

• We will not release personal data to any third party (other than a person acting as our agent as outlined above), except where a disclosure is required by law (e.g., to comply with a court order).

The content of our pages may include links to third-party sites, apps and social media platforms (e.g., Facebook, Twitter and YouTube). Clicking on such links may allow third parties to collect or share data about you. We do not control third-party sites, apps and social media platforms and we encourage you to read their privacy notices so that you understand how they process information about you.

Retention

Sluamor does not hold data for longer than is necessary for the purpose(s) for which they were obtained. It is our policy to review all data supplied/obtained and delete that which is not necessary, or which is no longer necessary.

Data Security

We use encryption to protect data transmitted to and from our site. However, no data transmission over the Internet is fully secure, so we cannot guarantee security. You may opt to use Sluamor.com at your own risk, with you being responsible for taking reasonable measures to secure you user account.

Right of Access

Under section 4 of the Data Protection Acts, a person has a right to be given a copy of his/her personal data. We only retain personal data you provide to use or that is publicly available. All personal data retained using the Sluamor.com platform can be accessed and viewed by Sluamor users via the "Personal Details" tile of the "My Account" control panel. This information can be amended by users as required.

Please contact us using the contact details provided at the end of this statement if you require clarification on what personal data is retained by us. The correspondence should be addressed to the ‘Sluamor Data Protection Officer’ and should be accompanied by your contact details. Note: we will ask you to verify your identification before processing any requests that impacts your personal data. Changes and amendments made by users will be updated on our systems immediately.

Right of rectification or erasure

Sluamor users have the right under Irish law to have his/her personal data corrected, if inaccurate, or erased data if we do not have a legitimate reason for retaining the information. By law we must comply with such requests within 40 days.

Sluamor users can, and should, maintain the accuracy of the personal data they have supplied to us by updating their personal details (which can be accessed and edited by logged-in users). Should you have difficulty in updating your personal details, please contact us using the contact details provided at the end of this statement and we will facilitate the rectification or erasure of the relevant data.

Placement and retrieval of information on user’s devices

Sluamor uses a limited number of cookies and similar technologies to store information on user devices/terminals, so as to personalise the content on our website, target and report on our ads, provide social media features, and analyse traffic on our site. Our Cookie Policy outlines the cookies used and the reasons for their use.

How to contact us

If you require further information regarding our Privacy Statement, or you wish to register a complaint about how your data is processed on this platform, you can contact us as follows:

• Mail us at customer.service@sluamor.com

• Use our Contact Us page.

• Write to us at: Sluamor Limited, Ardenagh Great, Taghmon, Co. Wexford, Y35 RY91, Ireland.