Privacy & Cookies Policy

WILDLANDS PRIVACY & COOKIES POLICY

Dated: 1 July 2020

Introduction

1.1     We are committed to safeguarding the privacy of visitors to the Website (“www.wildlands.ie”), customers of Wildlands and its services and users of our social media channels.

1.2     This policy applies where we are acting as a data controller with respect to the personal data of visitors of the Website, customers of Wildlands and its services and users of our social media channels (including for the avoidance of doubt service users in an offline capacity); in other words, where we determine the purposes and means of the processing of that personal data. If you do not agree and accept to be bound by this Privacy & Cookies Policy, then you should immediately discontinue your use of the Website and/ or our services.

1.3     We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit the Website.

1.4     The Website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.

1.5        In this policy, “we”, “us” and “our” refer to FDT Outdoors Limited. For more information about us, see Section 13.

Data Processors

In this Section 2 we have set out the specific third party organisations that may process data on our behalf, subject to their compliance with data protection laws and subject to adequate data security and data protection standards being met:

2.1      Roller - online scheduling software; activity and food booking engine provider; marketing services.

2.2      Aró - accommodation booking engine provider; website host and marketing services.

2.3 Google Analytics - online Advertising and Behavioural Advertising i.e. search ads, re-marketing, etc.

2.4    Sage Pay and Elavon  - payment gateway and payment processing services.

Please note that the above processors may be updated by us from time to time.

How we use your personal data

3.1     In this Section 3 we have set out:

(a)     the general categories of personal data that we may process;

(c)    the purposes for which we may process personal data; and

(d)     the legal bases of the processing.

3.2     We may process data about your use of the Website and your use of our services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the Website and services. The legal basis for this processing is monitoring and improving the Website and services.

3.3     We may process your account data (“account data”). The account data may include your name and email address. The account data may be processed for the purposes of operating the Website, providing our services, ensuring the security of the Website and services, maintaining back-ups of our databases and communicating with you. The legal basis for the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.4     We may process your information included in your personal profile on the Website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of the Website and services. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at you request, to enter into such a contract.

3.7     We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent and our legitimate interests.

3.8     We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through the Website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

3.9     We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent and our legitimate interests. You can unsubscribe from our marketing communications if you no longer want to receive by contacting us or clicking ‘opt-out’.

3.10   We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The Website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of the Website and business and communications with users.

3.11   We may process information relating to your medical information which you supply to us (“medical data”). The medical data may include your contact details, your medical history and details of any specific medical conditions that you have. The medical data may be processed for the purpose of supplying the purchased goods and services and ensuring that we can properly perform the services purchased by you and ensure that safety of you and all users of our facilities. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, our legitimate interests, the vital interest of protecting the health and safety of all users of our facilities and the proper protection against business risks.

3.12   We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.13   CCTV is in operation at Wildlands for surveillance purposes, including security, theft and fraud prevention. The building and grounds are covered by an extensive CCTV network and notices are in place. We use footage from these cameras only to as necessary to enable us to protect our legitimate interests, to safeguard our customers and our staff and for the security of our property. The legal basis for this processing is our legitimate interests, namely the proper protection of our business and protecting the health and safety of all users of our facilities and our employees.

3.14In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.15   Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

4.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.2    Financial transactions relating to the Website and services are handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

4.3      We may disclose your enquiry data to one or more of those selected third parties set out in section 2 above. Each such third party will act as a data controller in relation to the data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

4.4   In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, for our legitimate interests or in order to protect your vital interests or the vital interests of another natural person.

International transfers of your personal data

5.1     In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2     We may use third party processors outside of the EEA. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

Retaining and deleting personal data

6.1     This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2     Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

6.3     We will retain your personal data for so long as is necessary for the purposes specific in this privacy policy.

6.4     In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the objective necessity for the retention of such data.

6.5     Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, for our legitimate interests or in order to protect your vital interests or the vital interests of another natural person.

Amendments

7.1     We may update this policy from time to time by publishing a new version on the Website.

7.2     You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3     We may notify you of changes to this policy by email.

Your rights

8.1     In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2     Your principal rights under data protection law are:

(a)     the right to access;

(b)     the right to rectification;

(c)     the right to erasure;

(d)     the right to restrict processing;

(e)     the right to object to processing;

(f)      the right to data portability;

(g)     the right to complain to a supervisory authority; and

(h)     the right to withdraw consent.

8.3     You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data on payment of the appropriate fee.

8.4     You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5     In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6     In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7     You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8     You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9     You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10   To the extent that the legal basis for our processing of your personal data is:

(a)     consent; or

(b)     that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11   If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12   To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13   You may exercise any of your rights in relation to your personal data by written notice to us.

About cookies

9.1     Most websites use cookies to make a user’s web experience better and give users faster interaction. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. They effectively provide a memory for the website, enabling it to recognise a user and respond appropriately.

9.2     Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3     Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

10.1   We use cookies for the following purposes:

(a)     authentication - we use cookies to identify you when you visit the Website and as you navigate the Website;

(b)     status - we use cookies to help us to determine if you are logged into the Website;

(c)     personalisation - we use cookies to store information about your preferences and to personalise the Website for you;

(d)     security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect the Website and services generally;

(e)     advertising - we use cookies to help us to display advertisements that will be relevant to you;

(f)      analysis - we use cookies to help us to analyse the use and performance of the Website and services; and

(g)     cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

 Cookies used by our service providers

11.1   Our service providers use cookies and those cookies may be stored on your computer when you visit the Website.

11.2   We use Google Analytics to analyse the use of the Website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to the Website is used to create reports about the use of the Website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

Managing cookies

12.1   Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)     https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)     https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)     http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)     https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)     https://support.apple.com/safari (Safari); and

(f)      https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

12.2   Blocking all cookies will have a negative impact upon the usability of many websites.

12.3   If you block cookies, you will not be able to use all the features on the Website.

Our details

13.1   This website is owned and operated by FDT Outdoors Limited.

13.2   We are registered in Ireland under registration number 640236 and our registered office is at Corrib House, 3 Waterside, Woodquay, Galway.

13.3   Our principal place of business is at Ballyquirke East, Moycullen, Co. Galway, H91 WYV2.

13.4   You can contact us:

(b)     using the Website contact form;

(d)    by email at www.wildlands.ie.