PRAMERICA IRELAND SPIRIT OF COMMUNITY AWARDS

PRIVACY STATEMENT

This statement relates to our privacy practices in connection with the Pramerica Spirit of Community Awards Programme (“Programme”) as described on http://spirit.pramerica.ie/ (the ‘Website’).

The purpose of this privacy statement is to inform you about how we treat you and your child’s personal data (being information which identifies you or your child) and to explain how that personal data is processed when your child enters the Programme. Please read this Privacy Statement to understand how you and your child’s personal data that is provided in an application form, via the Website and together with any other information furnished, will be used in connection with the Programme. We are not responsible for the content or privacy practices of other websites. Any external links to other websites are clearly identifiable as such.

This Website is operated by Pramerica Systems Ireland Limited, a company incorporated and registered in Ireland with company registration number 319900 with its registered office at 6th Floor, South Bank House, Barrow Street, Dublin 4, D04 TR29, Ireland (“Pramerica Ireland”, “we”, “us” or “our”). Please use the contact information provided at the end of this statement if you have any queries regarding this statement and the personal data we may hold about you and your child.

General Statement

We are committed to respecting you and your child’s right to privacy and to complying with all applicable data protection laws in force in Ireland, including (without limitation) the Data Protection Acts 1988 and 2003 (as amended) and from the 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/679) (‘Data Protection Legislation’).

We may collect and process the following data about you and/or your child:

  1. Information you and/or your child provide to us by filling in forms on our Website and in connection with the Programme. This includes the information given when registering on the Website and the information inputted when completing the Spirit of Community Application Form. This may include information such as your child’s name, email address, age, address and school and also information relating to you such as your name, phone number and email address.
  2. We may also ask you and/or your child for information if you or they report a problem with our Website.
  3. If you or your child contact us, we may keep a record of that correspondence.
  4. Details of you or your child’s visits to the Website including, but not limited to, traffic data, weblogs and other communication data and the resources that you or they access.
  5. We may collect information about you or your child’s device, including where available, IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not personally identify you or your child.
  6. We use cookies to facilitate registrations and to determine if you or your child are logged in. However, we do not use intrusive or persistent cookies that would need to be explained and consented to in accordance with the ePrivacy Regulations (SI 336 of 2011).
  7. Photographs, images (including likeness), video footage and recordings of you and/or your child in connection with the Programme.
  8. We may use third-party web analytics on the Website, such as Webtrends. The information collected by this technology will be disclosed to or collected directly by these service providers, who use the information to evaluate our users’ use of the Website.
    Please note that the types of personal data we collect or obtain varies depending upon the role of your child in the Programme and as such additional personal data to that listed above may be collected at times as necessary to run the Programme.

Use of your Information

We use the personal data held about you and your child for the following purposes:

  1. to operate and publicise the Programme, including disclosure to panel judges who may not be employees of Pramerica Ireland;
  2. to administer the Programme;
  3. to process and assess your child’s Spirit of Community Awards application;
  4. to publicise finalists of the Programme, Youth Volunteers of the Year, and All Ireland Youth Volunteers of the Year, as further described below in the section called 'Spirit of Community Awards - Publicity';.
  5. to respond to you or your child’s queries and requests, and to communicate with you or your child regarding the Programme;
  6. to manage and improve our services and the Website;
  7. to verify your child’s eligibility to enter the Programme;
  8. to allow you access to certain features of the Website and your user account with us if you have registered one via our Website;
  9. to notify you or your child of changes to our services, the Website, our Privacy Statement and/or any of our other published notices;
  10. to provide you or your child with informational newsletters;
  11. if applicable, to facilitate you or your child’s participation in surveys you or your child may wish to partake; and/or
  12. to understand statistical data about user browsing actions and patterns, which does not personally identify you or your child.

Please note we do not use your personal data for targeted advertising or behavioural advertising.

Legal Bases

We will only process you or your child’s personal data where we can rely on one or more of the following legal bases:

  1. Contract – The processing is necessary for the performance of a contract with you or your child (where you have entered into such on their behalf), or for taking steps at your request with a view to entering into a contract. Without such personal data, we cannot process your child’s application to the Programme.
  2. Consent – Where you have given your consent or consented on your child’s behalf to us processing you and/or your child’s personal data for any of the purposes described in this Privacy Statement.
  3. Legal obligations – The processing is necessary for compliance with a legal obligation which we are subject to.
  4. Vital interests – The processing is necessary to protect you and/or your child’s vital interests;
  5. Public interest – The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority by us.
  6. Legitimate interests - The processing is necessary for the legitimate interests pursued by us or by a third party, and such shall be balanced against you and your child’s fundamental rights (e.g. right to privacy) and freedoms

Spirit of Community Awards – Referees and other persons

The Volunteer Activity Reference section of the Spirit of Community Awards application form asks you to give details (name, email and telephone number) of a referee from your child’s volunteering organisation/activity who can be contacted if your child’s application is shortlisted as a finalist for national judging. We will use the referee’s information you provide us for this purpose only. By giving us this information, you confirm you have received the referee’s consent to do so and have all necessary rights for the purpose of our and third-party panel judges considering and judging your child’s application.

If in your child’s application you identify any other person we and third-party panel judges will use this information to consider and judge your child’s application and to otherwise operate and publicise the Programme. By giving us this information you confirm you have received the relevant person’s prior consent for these purposes and have all necessary rights to provide this information to us for this purpose.

You represent and warrant that you will comply with all applicable laws, including but not limited to Data Protection Legislation, regarding all personal data you provide to us.

Spirit of Community Awards – Publicity

If your child’s application is shortlisted as a finalist for national judging, or your child is chosen as a Youth Volunteer of the Year, or an All-Ireland Youth Volunteer, we may use the information you give us through the Website and through our other interactions:

  1. to operate and publicise the Programme;
  2. to announce and publicise your child’s name, age, town and county as a finalist of the Programme, as a Youth Volunteer of the Year and/or an All-Ireland Youth Volunteer; and
  3. to use photograph(s) and video footage of your child (and sometimes you), including your child’s likeness (and yours, where relevant) for purposes of news, publicity and advertising in connection with the Programme, as further described in the Spirit of Community Awards application.

Where we store your personal data

The data that we collect from you and your child may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting you and your child’s personal data to us, you agree to this transfer, storing and/or processing. We will take steps reasonably necessary to ensure that such data is treated securely, in accordance with this Privacy Statement and Data Protection Legislation.

Disclosure of your information

Any personal data which you or your child provide to us in this way is not made available to any third parties unless you give your prior consent, and is used by us only in line with the purposes set out in this Privacy Statement. However, we may consider it necessary to disclose personal data without your consent or without consulting you, when we believe that it is appropriate to comply with our legal obligations and/or a Court Order, to cooperate with any law enforcement agencies, to enforce this Privacy Statement, our User Agreement, or other legal rights, to protect the security of the Website, to protect the security and safety of others, to prevent fraud, or otherwise to protect our legitimate interests and/or the legitimate interests of other users. We may also transfer you and your child’s personal data on the sale, transfer or reorganisation of our business.

Newsletters and Updates

If you or your child subscribe to our newsletter or any other e-mail updates, by submitting an e-mail address through a subscribe facility on the Website, and you or your child wish to opt-out of receiving these communications, please access the "Unsubscribe" link that is available on all such emails. If you or your child have any difficulty unsubscribing please contact us using the contact information provided at the end of this Privacy Statement.

Retention of data

We retain you and your child’s personal data for no longer than is allowed under applicable Data Protection Legislation and, in any case, no longer than such personal data is necessary for the purpose for which it was collected or otherwise processed, unless a longer retention period is required by applicable law. This means that you and your child’s personal data will be processed as necessary for establishing, performing and terminating your relationship with us and will thereafter be retained until applicable limitation periods have been passed and in order to comply with statutory retention obligations under applicable law (such as retention obligations arising under commercial and tax law).

Data protection rights

To the extent permitted under applicable law, you are entitled to obtain information about the processing of you and your child's personal data, access to such personal data, to object to processing of you and/or your child’s personal data, make use of you and/or your child’s right to data portability and to have you and your child’s personal data rectified or deleted or their processing restricted. You also are entitled to withdraw any consent that you might have given with respect to the processing of you and/or your child’s personal data at any time with future effect.

To exercise you or your child’s data subject rights, you must write to us at our mailing address provided below, or e-mail us at spirit@pramerica.ie. You should include any personal identifiers which you supplied earlier via the Website (e.g. username, e-mail address). We will also require you and your child’s full name and residential address in the circumstances.

If you are not satisfied with our response or believe that you and/or your child’s personal data is not being processed in accordance with the law, you also may contact or lodge a complaint with the competent supervisory authority.

Changes to this Statement

We reserve the right to make changes to this Privacy Statement at any time to reflect changes in the law, our data collection and use practices, the features of our Website, or advances in technology. Please check this page periodically for changes. If we make any material changes to this Privacy Statement, we will post the updated Privacy Statement here and notify our registered users by email or by means of a notice. Save for urgent changes (such as those required by law) we will post such a notice on our Website prior to the changes becoming effective. Please review the changes carefully. If you do not agree with such changes you can delete your user account and stop using the Website.

Contacting Us

If you have any questions, requests or complaints regarding this Privacy Statement please contact us using the following information:

Web:

            

http://spirit.pramerica.ie/

Email:

 

This email address is being protected from spambots. You need JavaScript enabled to view it.This email address is being protected from spambots. You need JavaScript enabled to view it.

Mailing Address:

 

Pramerica Systems Ireland Limited, Pramerica Drive, Letterkenny Business & Technology Park, Letterkenny, Co. Donegal, F92 W8CY, Ireland

This statement was last modified 7 May 2018