Privacy Policy
PRIVACY POLICY
TOMPHIBBS.IE
1. INTRODUCTION
1.1 Purpose of the Privacy Policy
The primary objective of this Privacy Policy for tomphibbs.ie is to transparently describe how we collect, process, store, and utilize personal data from our users and visitors. Our commitment is not merely to the enforcement of legal regulations, but equally to fostering trust between us and our valued user community. A clear understanding of our practices related to personal data is crucial to ensuring that users are always well-informed and can make the right decisions regarding their interaction with our platform.
1.2 Commitment to Data Protection and User Privacy
Tomphibbs.ie staunchly prioritizes the protection of user data and their right to privacy. Ensuring the confidentiality, integrity, and availability of user information is paramount to our operations. We ardently adhere to the principles laid out by the General Data Protection Regulation (GDPR) of the European Union and other relevant legal frameworks that mandate a strict approach to personal data processing. By being on our website and interacting with our services, users should find assurance in our proactive endeavors to not only meet but exceed legal requirements and set a high standard for user data privacy and protection.
This policy acts as a comprehensive guide to make our users aware of:
· The nature and purpose of data collection.
· The procedures and protocols we have implemented to safeguard their personal information.
· The rights they have concerning their data, including the right to withdraw consent.
· How their data might be used, especially in the context of personalizing ads.
· Third-party access to their data, including Google and its suite of services.
Our dedication to upholding these principles is unwavering, irrespective of changes in technology, market conditions, or business models. We want our users to confidently navigate and utilize our services, knowing their privacy is guarded with the utmost diligence.
2. DEFINITIONS
2.1 Personal Data
Within the context of this Privacy Policy, "Personal Data" refers to any information that relates to an identified or identifiable natural person, often termed as the 'data subject'. An identifiable individual is someone who can be recognized, directly or indirectly, especially by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or several factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. This broad definition encapsulates a variety of data types, ranging from basic identity information such as name and address to more complex information like digital identity data, health status, or employment details.
2.2 Processing
"Processing" pertains to any operation or set of operations which is performed on personal data, whether or not by automated means. This can include processes such as collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction of data. Essentially, any action or operation that is undertaken on personal data, irrespective of its nature or method, falls within the ambit of processing.
2.3 Consent
For the purposes of this policy, "Consent" of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them. It is fundamental that the consent is explicit and not inferred from silence, pre-ticked boxes, or inactivity. It is also incumbent on tomphibbs.ie to be able to demonstrate that the user has consented to the processing of their personal data and that they have been provided with clear information about such processing before giving their consent.
2.4 Cookies
"Cookies" are small pieces of data, often including a unique identifier, sent from a website and stored on the user's computer by the user's web browser while the user is browsing. Cookies were designed to be a reliable mechanism for websites to remember stateful information or to record the user's browsing activity, including clicking particular buttons, logging in, or recording which pages were visited by the user months or years ago. They facilitate certain functionalities, improve the user experience, and often pave the way for personalization of content, including ads. It's pivotal to highlight that while cookies are essential tools, their usage mandates clarity and consent, in line with the GDPR's standards on transparency and user empowerment.
3. DATA COLLECTION
3.1 Information You Provide Directly
When you interact with our services on tomphibbs.ie, you may choose to provide us with specific pieces of personal data. This information often includes, but is not limited to:
· Names: This could be your first name, last name, or any pseudonyms you might use while engaging with certain sections of our platform.
· Email Addresses: This is essential for communication purposes, ensuring you receive timely notifications, newsletters, or other relevant correspondence from us.
· Physical Addresses: If our platform offers any delivery or tangible services, your address becomes pivotal to ensure prompt and precise provision.
· Contact Numbers: For some services, it might be necessary for us to reach out to you directly, making your contact number a crucial piece of data.
It is pivotal to understand that any such data is provided by users on a voluntary basis. No user is obligated to share personal details unless they deem it necessary for a specific purpose. We strive to minimize the data we solicit, adhering to the GDPR principle of data minimization, ensuring we only request what's strictly necessary for the provision of our services.
3.2 Information Collected Automatically
Beyond the data you voluntarily provide, certain information is automatically captured when you visit tomphibbs.ie. This is standard across many online platforms and helps in enhancing user experience, among other functions. The automatically collected data can include:
· Browser Type & Version: This helps us ensure our website remains compatible with the most commonly used browsers and can aid in troubleshooting issues specific to particular browser types.
· IP Address: Your Internet Protocol address can provide insights about the general geographical location from which you are accessing our site. It can be essential for security audits and understanding our user demographics.
· Platform Type: Whether you access our site from a desktop, mobile, or tablet can provide invaluable insights to enhance optimization for various platforms.
· Browsing Patterns: The pages you visit, the time you spend on them, and the journey you undertake through our platform can all be essential for improving user experience and understanding user preferences.
This information, while impersonal in nature, is treated with the same rigorous standards of security and confidentiality as any personal data. It aids in improving website functionality, understanding user preferences, and ensuring that our platform remains responsive and user-friendly.
4. PURPOSE OF DATA COLLECTION
4.1 Personalization of Content and Ads
In the digital era, users expect tailored experiences that resonate with their unique preferences and behaviours. To cater to this, tomphibbs.ie collects data to offer a more personalised browsing experience. Through this, we can:
· Recommend Relevant Products/Services: By understanding your browsing patterns and purchase history, we can suggest products, services, or content that align closely with your interests.
· Tailored Advertisements: To ensure that you are not inundated with irrelevant ads, we use the data to showcase advertisements that are pertinent to your interests. This not only enhances your browsing experience but also ensures that marketers reach an audience genuinely interested in their offerings.
· User Engagement: By offering content that resonates with users, we increase engagement and satisfaction. This not only benefits users but also improves our site's overall efficacy and performance.
4.2 Business Operations
The core tenet of any business operation is its ability to offer services or products efficiently and effectively. The data collected plays an instrumental role in:
· Payment Processing: For users availing of paid services or products, their data ensures smooth transaction processing, avoiding any financial discrepancies or issues.
· Order Fulfilment: Details such as your address, contact information, and preferences are pivotal to ensure that any ordered products or services are delivered timely and accurately.
· Customer Support: Understanding user behaviour, past interactions, and collected data aids our customer support team in resolving queries, issues, or concerns more efficiently.
4.3 Email and SMS Marketing
One of the primary modes of communication between tomphibbs.ie and its users is through email and SMS. These channels allow us to:
· Inform about New Offerings: Be it a new product, service, or a piece of content, we use these mediums to ensure our users are kept in the loop.
· Promotions and Discounts: Special promotions, discounts, or exclusive offers are communicated to users, ensuring they can avail of the best our platform has to offer.
· User Feedback: Periodically, we might reach out for feedback, reviews, or surveys. Such interactions not only aid us in understanding our user base better but also in refining our offerings.
Every piece of data collected from our users has a definitive purpose, designed to enhance their experience on tomphibbs.ie. Whether it's offering a more tailored experience, ensuring smooth business operations, or maintaining a direct line of communication, each data point serves a particular function. We, at tomphibbs.ie, understand the sanctity of this data and pledge to use it with the utmost responsibility, integrity, and in alignment with the stipulations of the GDPR and other pertinent regulations.
5. COOKIES AND TRACKERS
5.1 Explanation of Cookies and Their Use on the Site
Cookies are small text files placed on your device when you visit websites. These files are used to store a modest amount of data specific to you and can be accessed either by the web server or your computer. At tomphibbs.ie, cookies are deployed for a variety of reasons, ensuring:
· Improved Site Performance: Cookies can remember your preferences, thereby quickening certain site functionalities. For instance, by remembering items in your shopping cart or your login information, our site provides a more seamless experience.
· Analytics and Insights: Through cookies, we can understand how users engage with our platform, what pages they visit, the duration of their stay, and more. This invaluable information allows us to refine our content and services, catering more closely to our audience's needs.
· Personalization: As touched upon earlier, personalization is a cornerstone of modern digital experiences. Cookies enable us to tailor content, ads, and even site behaviour, mirroring individual user preferences and behaviours.
5.2 Types of Cookies Used
Different types of cookies serve varied purposes on our platform. Key among them are:
· Session Cookies: These are temporary cookies, lasting only as long as your online session. Once you close your browser, these cookies are automatically deleted. They're primarily used to ensure a seamless user experience during a particular browsing session.
· Persistent Cookies: Unlike their session counterparts, persistent cookies aren't deleted when you close your browser. They remain until a set expiry date or until you choose to delete them. Their main purpose is to recognise a repeat visitor, ensuring personal preferences, site customizations, or login details are remembered across sessions.
5.3 Managing or Refusing Cookies
While cookies enhance the online experience, we understand and respect users' rights to privacy and choice. Should you wish to manage or refuse cookies:
· Browser Settings: Most browsers offer inherent functionalities to manage cookies. You can set your browser to notify you when a cookie is being placed, giving you the choice to accept or decline. You can also opt to block all cookies or delete them after every session.
· Third-party Tools: Various tools and plugins allow finer control over cookies, letting you decide which cookies to accept, which ones to block, and even when to delete them.
· Site Customizations: We're working continuously to provide on-site mechanisms to give you more direct control over the cookies employed by tomphibbs.ie. While we refine this functionality, you're encouraged to reach out to our support for any cookie-related queries or concerns.
6. DATA SHARING WITH THIRD PARTIES
6.1 List of Third-Party Services Used
As part of our commitment to offering a comprehensive, effective, and user-friendly digital experience on tomphibbs.ie, we leverage several third-party services. These platforms, chosen after thorough vetting for their security and compliance measures, aid us in various aspects of our operations:
· Google Analytics: An analytical tool designed to understand website traffic, user behaviours, and various other metrics crucial to improving our platform.
· Meta Pixel: Empowers us to serve targeted advertising and gauge the effectiveness of our marketing campaigns.
· Google Ads: Enables us to run advertising campaigns tailored for our audience and measure their effectiveness.
· Google Merchant Centre: Facilitates our ecommerce operations by showcasing our products across Google platforms.
· Authipay Payment Gateway: Ensures secure, seamless, and efficient transaction processing for our services or products.
· Klaviyo: An email and SMS marketing tool designed to help us maintain effective communication with our users.
6.2 Purpose for Sharing with Each Service
Transparency is paramount. Hence, it's essential for us to delineate why we share specific data with each third-party service:
· Google Analytics: To understand our website's performance, user engagement metrics, and areas of improvement, thereby enhancing the overall user experience.
· Meta Pixel: To ensure the advertisements you see are relevant and to understand the effectiveness of our ad campaigns.
· Google Ads: Data shared helps in optimizing our ad campaigns, ensuring you see pertinent ads that resonate with your interests and needs.
· Google Merchant Centre: For efficient listing and showcasing of our products across Google's platforms.
· Authipay Payment Gateway: To facilitate secure payment processing when you avail of our products or services.
· Klaviyo: To ensure you're updated about our latest offerings, promotions, and news via emails or SMS.
6.3 Links to Each Third Party's Privacy Policy
We firmly believe in the power of informed choice. In line with this, we encourage you to peruse the privacy policies of the third-party platforms we engage with. It will provide a deeper understanding of their data handling practices:
Our engagement with third-party platforms stems from our commitment to providing an enriched, effective, and seamless experience on tomphibbs.ie. Each of these platforms has been selected for their proven expertise and stringent data protection measures. Our collaboration with them ensures that our users get the best of what the digital world has to offer, without compromising on their data security or privacy.
7. GOOGLE'S DATA USE
7.1 How Google Uses Personal Data
Being one of the third-party services tomphibbs.ie collaborates with, Google occupies a distinct position in the digital ecosystem due to its expansive range of services. It's imperative for our users to understand how Google interacts with the personal data it collects:
· Ad Personalization: Google employs data to personalize ads for users, ensuring they are relevant and tailored to individual preferences, interests, and behaviours. This means when you consent to data sharing on tomphibbs.ie, and it's passed onto Google, the ads you encounter across Google's advertising network could be influenced by this data.
· Analytical Insights: Through Google Analytics, Google processes user data to offer insights into website traffic, user demographics, behaviours, and other metrics. This helps us refine our platform for an enhanced user experience.
· E-commerce Operations: Via Google Merchant Centre, product listings from tomphibbs.ie might appear across different Google services. Google uses data to ensure the products shown are relevant to potential consumers.
· User Safety and Security: Google may process personal data to detect and prevent fraud, abuse, and other harmful activities on its platforms and the wider web.
· Service Improvements: Google's services, like Google Ads, use data to improve their offerings, ensuring users get better functionality and features over time.
7.2 Link to Google's Privacy Policy and Terms
To foster transparency and empower our users with comprehensive knowledge, we strongly advocate exploring Google's official documentation on its data practices:
· You can access and review Google's Privacy Policy for an exhaustive overview of their data processing methodologies, purposes, and commitments to user privacy.
· Additionally, for terms of service and other related contractual details, you can consult Google's Terms of Service.
8. USER RIGHTS UNDER GDPR
8.1 Introduction to GDPR Rights
Under the General Data Protection Regulation (GDPR), individuals within the European Union are granted a set of rights concerning their personal data. These rights give individuals control and transparency over their personal data, allowing them to understand, access, and manage information that is held about them by entities such as tomphibbs.ie.
8.2 Right to Access
Users have the unequivocal right to request access to their personal data. This means that you can ask us to provide you with a copy of all personal data that we hold about you. Alongside this, we will provide context about how the data is being used, the categories of data we have, any third parties with whom your data might be shared, and other rights related to your data.
8.3 Right to Rectification
Should you believe that any personal data we possess about you is inaccurate or incomplete, you can request that we correct or supplement it. tomphibbs.ie is committed to maintaining accurate records and will undertake necessary actions to amend data as required.
8.4 Right to Erasure (Also Known as the 'Right to be Forgotten')
Users can request the deletion of their personal data under specific circumstances, such as when the data is no longer required for the purposes for which it was collected, or if you choose to withdraw your consent. However, there may be legal or regulatory reasons that require us to retain your data; in such instances, we will inform you of the rationale.
8.5 Right to Restrict Processing
If you have concerns about the way we are processing your data, you can request a restriction on your data's processing. This means we will store your data, but not use it, until the issue is resolved.
8.6 Right to Data Portability
This right enables users to obtain and reuse their personal data across different services. If you request, we will provide your data in a structured, commonly used, and machine-readable format. This allows you to transfer your information easily from tomphibbs.ie to another service provider if desired.
8.7 Right to Object
Users have the right to object to the processing of their personal data for direct marketing purposes or when the processing is based on legitimate interests unless tomphibbs.ie can demonstrate compelling legitimate grounds for the processing.
8.8 Rights Related to Automated Decision-Making
If tomphibbs.ie were to use automated decision-making, including profiling, that has legal or similarly significant effects, you would have the right to obtain human intervention, voice your opinion, and contest such decisions.
Upholding the principles of the GDPR is of paramount importance to tomphibbs.ie. We believe in empowering our users with comprehensive rights over their data, ensuring they remain in control at all times. If at any point you wish to exercise any of these rights, we have procedures in place to respond promptly and effectively. It's our commitment to fostering a transparent, respectful, and user-centric digital space.
9. SECURITY MEASURES
9.1 Commitment to Data Security
The safety, integrity, and confidentiality of your personal data are of utmost importance to tomphibbs.ie. We are fully aware of the immense trust you place in us when providing your personal data, and we are unequivocally committed to maintaining robust and state-of-the-art security measures to ensure that your data is shielded from unauthorized access, alteration, disclosure, or destruction.
9.2 Encryption and Secure Data Storage
All data transferred to and from tomphibbs.ie is secured using advanced encryption technologies. Our encryption protocols are designed to protect your information from interception during transmission. Once your data reaches our servers, it is stored within secure data storage systems that utilize multiple layers of protection, including firewall technologies, intrusion detection systems, and regular monitoring.
9.3 Regular Security Audits
To ensure that our data protection mechanisms remain at the forefront of security technology, we conduct periodic security audits. These audits evaluate the efficacy of our security measures, highlight potential vulnerabilities, and ensure that we adhere to best practices in data protection. By doing so, we can promptly address any emerging security concerns and continually refine our protective measures.
9.4 Employee Training and Access Restrictions
All tomphibbs.ie personnel undergo rigorous training to understand and uphold our data protection principles. Access to user data is restricted to only those employees who require it to perform their job functions. Each such employee is bound by strict confidentiality obligations and is made aware of the grave consequences of any data breaches, both legally and ethically.
9.5 Response to Data Breaches
Despite our best efforts, no system can be entirely immune to vulnerabilities. In the unfortunate event of a data breach, tomphibbs.ie has an established protocol to address and mitigate its effects. This includes immediate notification to the affected users, taking steps to prevent further unauthorized access, and cooperating with legal and regulatory authorities to ensure transparency and accountability.
9.6 Third-party Vendors and Partners
We rigorously vet all third-party vendors and partners to ensure they maintain security standards that are in line with ours. Any data shared with these third parties is done under strict contractual clauses that mandate them to uphold the same high levels of data protection and security.
10. DATA RETENTION
10.1 Purpose of Retention
Tomphibbs.ie acknowledges the necessity to hold personal data only for the period required to fulfil the purposes for which it was initially collected unless a longer retention period is required or permitted by law. We have crafted our data retention policy in strict accordance with the principles of data minimization and storage limitation, which are core elements of the General Data Protection Regulation (GDPR).
10.2 Duration of Data Retention
All personal data collected by tomphibbs.ie is stored for a limited duration. The specific retention period for different categories of personal data may vary based on the nature of the data and the purpose for which it was collected. For instance:
· Data related to user account information, including name, address, and email, is retained for as long as the user's account is active on our platform and for a standard period thereafter to allow for account reactivation, unless the user requests erasure before this period elapses.
· Transactional data, which includes purchase history, payment details, and shipping information, is retained for a period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
10.3 Criteria for Determining Retention Period
Several factors influence our decision on the duration for which we retain personal data:
· Legal and regulatory requirements: Certain data types, especially those related to financial transactions, are subject to legal retention obligations. We adhere to these requirements to remain compliant with the relevant regulations.
· Contractual obligations: We retain some data based on contractual requirements, especially when partnering with third-party vendors or service providers.
· Business operations: Operational necessities, such as facilitating product returns, warranties, or investigating and resolving disputes, can dictate the retention of certain data sets.
· User account preferences: For user profiles and related data, the retention is often tied to the life of the user account. Upon account deletion, we initiate the process to erase personal data, though some might be retained for a brief period to prevent fraud or ensure continuity.
10.4 Periodic Review of Retained Data
Tomphibbs.ie conducts regular reviews of the data held in our repositories. This process ensures that data which is no longer required for the operational, legal, or business purposes is duly identified and deleted.
10.5 Erasure of Data
Once the retention period elapses, or when the data no longer serves its initial purpose (and there's no legal requirement to retain it), it is securely erased from our systems. We deploy robust erasure techniques, ensuring the data is irretrievably destroyed and cannot be reconstructed.
11. INTERNATIONAL DATA TRANSFERS
11.1 Scope of Data Transfers
In the digitally interconnected world that we operate in, tomphibbs.ie occasionally transfers personal data to countries outside the European Economic Area (EEA), particularly when leveraging third-party services or cloud-based solutions. These cross-border transfers might expose data to jurisdictions that do not offer the same level of protection as European Union law. Recognising this, tomphibbs.ie is resolute in ensuring that any such transfer aligns with GDPR provisions and safeguards the rights and freedoms of our users.
11.2 Legal Basis for Data Transfers
Transfers of personal data outside the EEA are anchored on legal instruments and mechanisms that ensure the data remains protected. The primary instruments include:
· Adequacy Decisions: The European Commission has the authority to determine if a non-EEA country offers an adequate level of data protection. If a country receives a positive adequacy decision, data can flow from the EEA to that country without any further safeguard. Tomphibbs.ie prefers to transfer data to countries with adequacy decisions.
· Standard Contractual Clauses (SCCs): In the absence of an adequacy decision, tomphibbs.ie might resort to SCCs. These are pre-approved clauses by the European Commission that the data exporter and the data importer both sign, pledging to protect transferred data to GDPR standards.
· Binding Corporate Rules (BCRs): BCRs apply to multinational corporations, enabling them to transfer personal data internationally within the same corporate group, ensuring protection equivalent to that of the GDPR.
11.3 Engaging with Third Parties
When engaging third-party services that necessitate international data transfers, tomphibbs.ie undertakes rigorous due diligence. This involves:
· Evaluating the third party's data protection standards, privacy policies, and adherence to international data transfer mechanisms.
· Ensuring contractual agreements incorporate the necessary clauses that mandate GDPR compliance.
· Regular audits and assessments to confirm the third party's adherence to our data protection requirements.
11.4 Ensuring GDPR Compliance During Transfers
To guarantee unyielding adherence to GDPR during international data transfers, tomphibbs.ie has instituted the following measures:
· Data Minimization: Only the absolute necessary data is transferred, and redundancy is avoided.
· Encryption: Data in transit is secured using state-of-the-art encryption techniques, ensuring it remains incomprehensible to unauthorized entities.
· Transparency: Users are duly informed about any international data transfers, especially if the transfer destination is a country without an EU adequacy decision.
· User Rights: Even post-transfer, users retain their GDPR rights regarding their personal data. They can access, rectify, or request deletion of their data, irrespective of where it's stored.
12. CONSENT
12.1 Preamble on the Significance of Consent
Consent remains one of the foundational pillars of data protection under the GDPR. At tomphibbs.ie, we firmly believe that the trust placed in us by our users hinges on our commitment to obtaining clear, explicit, and informed consent. Respecting the autonomy of our users over their personal data, we ensure that the act of providing consent is as empowered and transparent as the option to withdraw it.
12.2 Obtaining User Consent
· Clarity and Transparency: When seeking consent, tomphibbs.ie presents users with clear, comprehensible, and easily accessible information. This ensures that users are fully aware of the scope, purpose, and implications of the data processing activities they are consenting to.
· Active Opt-in: Consent is never assumed. We employ active opt-in mechanisms, meaning users must take a positive action (like ticking a box) to give their consent. Pre-ticked boxes, inactivity, or silence do not amount to consent on our platform.
· Distinguished from Other Matters: Consent requests are kept separate from other terms and conditions to ensure users distinctly recognise and understand the consent they are giving.
12.3 Specificity of Consent for Personalization and Third-party Access
At tomphibbs.ie, we believe in specificity when it comes to user data. To that end:
· Ad Personalization: Users are explicitly informed if their data will be used for personalizing ads. They have the choice to consent to this use or deny it without any repercussions to their user experience.
· Third-party Access: Before sharing any data with third parties, including Google and other service providers, we seek explicit consent. Users are furnished with details of which third parties will have access to their data and for what purposes.
12.4 Revoking and Managing Consent
Understanding that circumstances and preferences change:
· Ease of Withdrawal: Withdrawing consent is as straightforward as giving it. Users can revoke their consent at any point, and tomphibbs.ie ensures the process is user-friendly and promptly actionable.
· Periodic Renewal: Consent isn't everlasting. We periodically seek to renew consents, especially if there's a change in the processing purpose or if a significant duration has elapsed since the last consent was obtained.
12.5 Record Keeping
In line with GDPR's emphasis on accountability:
· Documentation: All consents obtained are duly documented, capturing details such as when and how the consent was acquired and the specific information users were presented with at the time.
· Audits: Regular audits are conducted to ensure our consent mechanisms and records remain compliant with GDPR stipulations and best practices.
13. CHILDREN'S DATA
13.1 Preamble on Protecting Children's Data
The protection of children’s personal data is of paramount importance in the eyes of the law and to tomphibbs.ie. Young individuals are particularly vulnerable in the online environment, often lacking the full understanding of the risks and implications associated with data sharing. Recognizing this vulnerability, tomphibbs.ie pledges to take added measures to protect the rights and interests of children in the digital sphere.
13.2 Minimum Age Requirement
· Age Limitation: In line with GDPR provisions, tomphibbs.ie establishes a minimum age of 16 years for users to consent to the processing of their personal data without parental authorization. For users below this age threshold, parental or guardian consent is mandatory.
· Age Verification: To ensure the effectiveness of the age limitation, tomphibbs.ie employs robust age verification mechanisms during account creation or data submission processes. Users may be prompted to provide a date of birth or other verifying information.
13.3 Parental Consent and Notification
· Acquiring Parental Consent: For users identified as under the age of 16, tomphibbs.ie actively seeks verifiable parental or guardian consent prior to data collection or processing. The methods used for verification include, but are not limited to, email confirmations, phone verifications, or signed consent forms.
· Informing the Guardians: Parents or guardians who provide their consent are given a clear and detailed explanation about the nature, scope, and purpose of the data processing activities their wards are being subjected to. This ensures an informed decision-making process on their part.
13.4 Designing for Children’s Privacy
· Data Minimization: When dealing with children’s data, tomphibbs.ie adheres to a stricter policy of data minimization, collecting only the indispensable data necessary for the provision of the service and nothing more.
· Privacy by Design: Features and services targeted at children are designed with privacy as a foundational principle. This includes ensuring clearer language, more prominent privacy notices, and easily accessible options for data management.
13.5 Rights of the Parents or Guardians
Recognizing the role of guardians in safeguarding their children’s rights:
· Access to Children’s Data: Parents or guardians have the unequivocal right to request access to the personal data of their children that's held by tomphibbs.ie. This ensures transparency and allows guardians to ascertain the accuracy and propriety of such data.
· Rectification and Erasure: Parents or guardians can demand the modification or deletion of their children’s data. tomphibbs.ie commits to promptly address such requests, ensuring that the child's data remains protected and accurate.
· Opposition to Processing: Parents or guardians, acting in the best interests of their wards, can object to specific processing activities involving their children’s data, especially in contexts like marketing or profiling.
14. UPDATES TO THE PRIVACY POLICY
14.1 Acknowledgment of Evolving Digital Landscape
The realm of digital services, technology, and regulatory frameworks is in a state of continuous evolution. Given this dynamic nature, it is imperative that privacy policies adapt to reflect new realities, emerging technologies, and updated legal obligations. tomphibbs.ie, while already committed to the highest standards of data protection, recognizes the necessity of updating its privacy policy to stay aligned with the evolving landscape.
14.2 Mechanism for Review and Updates
· Periodic Review: tomphibbs.ie has established an internal policy to periodically review this Privacy Policy. The objective is to ensure that the policy remains up-to-date with current technological practices, operational changes, and regulatory requirements.
· Expert Consultation: As part of the review process, tomphibbs.ie may consult with external data protection and legal experts to ensure that the policy remains compliant with EU regulations and best industry practices.
14.3 Notification of Changes
· Transparent Communication: In the event of any significant alterations to this Privacy Policy, tomphibbs.ie is committed to providing clear and timely information to its users. Users will be notified of such changes through prominent means, which could include notifications on the website, direct emails, or other communication channels.
· Accessibility of Updated Policy: The latest version of the Privacy Policy will always be accessible on the tomphibbs.ie website. Users are encouraged to periodically review the policy to stay informed about how their data is being protected.
14.4 Historical Versions
For the sake of transparency and to provide a historical perspective:
· Archiving: Previous versions of the Privacy Policy will be archived and made available upon request. This allows users and stakeholders to trace the evolution of the policy and understand the rationale behind specific changes.
· Timestamps: Every version of the Privacy Policy will carry a clear timestamp indicating the period of its validity. The date of the last update will be prominently displayed at the beginning of the policy.
14.5 User Engagement and Feedback
· Feedback Mechanism: tomphibbs.ie values the insights and feedback of its user base. A feedback mechanism will be in place to allow users to provide their thoughts, concerns, or suggestions regarding the Privacy Policy. Such feedback will be considered during the review process.
· Engagement Initiatives: tomphibbs.ie may, from time to time, undertake engagement initiatives such as surveys or focus groups to understand user perceptions and expectations related to privacy and data protection. Such insights will guide future policy updates.
15. CONTACT INFORMATION
15.1 General Contact Details
To ensure transparency, facilitate user inquiries, and maintain an open channel of communication, tomphibbs.ie provides users with various means to contact the organization. Users can make general inquiries, seek further clarifications about the Privacy Policy, or initiate any GDPR-related requests through the contact points provided below:
· Business Location: tomphibbs.ie operates out of Sweden, a jurisdiction compliant with stringent data protection regulations, further reinforcing our commitment to user privacy.
· Phone: Users can reach out via telephone at 012118469. Our team is trained to address privacy-related queries, concerns, and facilitate any GDPR-specific requests.
· Email: For written inquiries or detailed requests, users can send an email to support@tomphibbs.ie. Emails directed to this address are flagged for priority review to ensure swift responses, especially for data protection related matters.
15.2 Specific Procedures for GDPR-related Inquiries or Concerns
· Designated Data Protection Officer (DPO): tomphibbs.ie has appointed a Data Protection Officer in compliance with GDPR requirements. The DPO oversees our data processing activities and ensures adherence to GDPR guidelines. Users wishing to direct their inquiries or concerns specifically about GDPR can address them to the DPO via the aforementioned contact details.
· Response Time: In keeping with GDPR stipulations, tomphibbs.ie is committed to responding to user requests within a month. However, we typically strive to respond much sooner. Users will receive an acknowledgment of their request within a few working days.
· Structured Communication: To expedite the processing of GDPR-related requests, users are encouraged to be precise in their communication. Clarity in indicating the nature of the request (e.g., data access, rectification, erasure) will aid in providing timely and efficient resolutions.
15.3 Escalation and Special Requests
In the unlikely event that users feel their concerns or inquiries were not addressed satisfactorily, they have the option to escalate the matter. Our senior management team reviews escalations, ensuring another layer of scrutiny and attention to user concerns.
· Escalation Protocol: If users wish to escalate a matter, they are requested to indicate this explicitly in their communication, ideally by prefixing their subject line with "ESCALATION" for clarity.
· Priority Channels: While all channels are equipped to handle user requests, users with urgent concerns or those requiring special attention are advised to utilize both phone and email channels concurrently for faster resolution.
16. GRIEVANCE REDRESSAL
16.1 Commitment to Addressing Concerns
tomphibbs.ie holds its reputation and user trust in the highest regard. Recognizing the importance of user feedback and concerns, especially in areas concerning their personal data, we've established a robust grievance redressal mechanism. Our goal is to ensure that all grievances are acknowledged, evaluated, and resolved in a timely, transparent, and user-centric manner.
16.2 Procedure for Raising Concerns
· Initial Point of Contact: Users are encouraged to use the standard contact information provided in Section 15 for their initial grievance communication. We advise users to specifically mention "GRIEVANCE" in their email subject or during phone conversations for faster triage and escalation.
· Documentation of Grievance: To ensure that grievances are comprehensively addressed, users are requested to provide as much detail as possible about their concern. This may include any prior communication, specifics of the issue at hand, or any other relevant information that would help in a thorough investigation and resolution.
16.3 Structured Evaluation Process
· Acknowledgment: Upon receipt of a grievance, tomphibbs.ie will send an acknowledgment to the user within three working days. This acknowledgment will confirm the receipt of the grievance and provide an approximate timeline for resolution.
· Assessment: The grievance will then undergo a detailed assessment by our designated grievance redressal team. This team consists of individuals from legal, technical, and customer service backgrounds to ensure a holistic review.
· Engagement: Depending on the nature of the grievance, we might engage with the user for additional details or clarification. Users' active participation and timely response will expedite the resolution process.
16.4 Resolution and Communication
· Timely Redressal: While the complexity of each grievance might vary, tomphibbs.ie is committed to resolving most grievances within 30 days of receipt. For particularly complex cases, users will be informed of any potential delays.
· Transparent Communication: Once a resolution has been reached, users will be informed of the outcome in a clear and comprehensive manner. This communication will detail the nature of the grievance, the findings of our assessment, and the steps taken for resolution.
16.5 Escalation Mechanism
If a user feels that their grievance hasn't been addressed to their satisfaction, they can escalate the matter to our senior management. The escalation process aims to bring a fresh perspective and additional scrutiny to the grievance.
· Procedure: To escalate, users should send a fresh email with the prefix "ESCALATED GRIEVANCE" in the subject line or mention the same during a phone call. This will ensure immediate attention from higher management tiers.
17. DATA RETENTION AND DELETION
17.1 Rationale for Data Retention
At tomphibbs.ie, we recognize the immense value and sensitivity of personal data. As a principle, we are committed to only retaining user data for as long as it serves a legitimate purpose or is mandated by regulatory guidelines. Our data retention practices are guided by both our commitment to serve our users effectively and adherence to European Union's legal and regulatory frameworks.
17.2 Duration of Data Retention
· Transactional Data: Data associated with user transactions, including purchase history, invoices, and payment details, will be retained for a period of 10 years. This duration is in compliance with common fiscal documentation requirements across the EU.
· Account Data: User account information, including login details, preferences, and profile data, will be stored as long as the account remains active. If a user deactivates or deletes their account, the data will be retained for an additional period of 90 days before complete deletion.
· Communication Data: Any communication between users and tomphibbs.ie, including support tickets, emails, or chat transcripts, will be retained for a period of 5 years to ensure quality service and historical reference.
17.3 Methods of Data Deletion
· Physical Data: Any physical records or printouts containing user data will be securely shredded and disposed of in compliance with EU data protection standards.
· Digital Data: Digital records of user data will undergo secure deletion procedures, ensuring that the data is permanently and irretrievably erased. This involves using advanced cryptographic erasure techniques that surpass standard deletion methods.
17.4 User's Right to Erasure
In line with the EU's General Data Protection Regulation (GDPR), users of tomphibbs.ie have the right to request the erasure of their personal data. This is also commonly referred to as the 'Right to be Forgotten'.
· Procedure: Users can initiate a request for data deletion through their account settings or by reaching out to our data protection officer (details provided in Section 15).
· Evaluation: Each request will be evaluated on a case-by-case basis. While we are committed to honoring these requests, certain legal or regulatory obligations might necessitate the retention of specific data sets.
· Timeframe: Upon validation of a data erasure request, tomphibbs.ie will proceed to delete the relevant data within 30 days. Users will receive a confirmation upon successful deletion.
17.5 Periodic Review
We understand that data retention requirements and best practices evolve over time. As such, tomphibbs.ie will conduct a bi-annual review of its data retention policies to ensure alignment with legal requirements and industry best practices.
