Privacy Policy

Who we are

This privacy policy is issued by WrxFlo Limited located at Nexus Innovation Centre, Sreelane, University of Limerick, Co. Limerick, Ireland, V94 NYD3 (collectively referred to as “WrxFlo”, “we”, “us”, “our”). We are the data controller for the purposes of this privacy policy. Our website address is: https://wrxflo.com (“website”).

We take our responsibilities under applicable data protection law, including but not limited to, the EU General Data Protection Regulation, very seriously. This privacy policy only sets out details of our processing of personal data in connection with your use of the website and the Wrxflo software program provided by Wrxflo (the “Application”), with the Application and any use of the website being together the “Services”).

The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Services, we encourage you to read the privacy policy of every website you visit.

 

What personal data we collect and why we collect it

We collect and process the following personal data relating to you in connection with your use of the Services:

• Identity and Contact Data: Information relating to you that you choose to provide to us in the comments form, such as your name and contact details, including your phone number, email address and any other personal data relating to you that you provide to us or that we generate about you in connection with your use of the Services.
• Usage Data: Information that is generated in connection with your use of our Services by our analytics tools, such as which pages you visit, how long you stay on them, and any previous website address from which you reached us, including any search terms used, your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. We may also collect
• Technical Data: Technical information that is used to help detect spam and assist in providing the Services to you, including but not limited to, your IP address, browser type and version, operating system and device.
• Marketing and Communications Data: This includes your preferences in receiving marketing from us and our third parties and your communication preferences.

In certain circumstances, the information that is collected above is aggregated and anonymised. If you upload images to the Services, you should avoid uploading images with embedded location data (EXIF GPS) included as visitors to the website can download and extract location data from images on the website.

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). Nor do we collect any information about criminal convictions and offences.

We use cookies to facilitate the use of our Services and collect some of the information set out above. For more information on the cookies we use and the purposes for which we use them, see our Cookies Policy.

 

How we collect your personal data

We may obtain data from and about you using different methods including through:

• Direct Interactions: you may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise.
• Automated Technology or Interactions: As you interact with our Services, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data through the use of cookies and other similar technologies.
• Third Parties or Publicly Available Sources: we may receive personal data about you from various third parties and public sources.

 

Purposes of Processing and Legal Basis

We will use personal data relating to you for the purposes of:

• to provide and maintain our Services including to monitor the usage of our Services;
• to manage your registration as a user of our Services. The personal data you provide can give you access to different functionalities of our Services that are available to you as a registered user;
• the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through our Services;
• performing our obligations relating to or in accordance with any contract that we may have with you;
• communicating with you, either in response to correspondence that you send to us via the Services, or where you have signed up to receive updates from the Services;
• operating advertising campaigns, including working with third parties to display adverts to you on those third-party websites on the basis of your use of our website and to track the effectiveness of the advertisements;
• to attend and manage your requests to us;
• to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us and our service users is among the assets transferred;
• running our recruitment processes;
• improving and developing our Services;
• generating and analysing statistics regarding usage of our Services (where possible, personal data will be anonymised before being used for this purpose);
• sending you promotional and marketing materials;
• carrying out research and customer satisfaction surveys;
• fraud protection, investigation and detection;
• establishing, exercising or defending legal claims; and
• for other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, product, marketing and your experience.

The legal bases on which we process your personal data are:

• where you have consented to our processing of your personal data;
• it is necessary to perform our obligations relating to or in accordance with any contract that we may have with you;
• it is in our legitimate interest to use your personal data to ensure that we can carry out our activities as effectively as possible. We will not process your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms;
• the processing is necessary for the establishment, exercise or defence of legal claims or for the purposes of providing legal advice or for the purposes of, or in connection with, legal claims, prospective legal claims, legal proceedings or prospective legal proceedings; or
• we need to do so in order to comply with any legal or regulatory obligations.

 

Consent

Where we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us via our website. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Recipients of Data

We may disclose your personal data to other organisations in connection with the above purposes, including:

• to our affiliates and associated companies or partners;
• to third parties who we engage to provide services to us in connection with the Services, such as outsourced service providers, IT services providers, professional advisers and auditors;
• to third parties with whom we may merge or to whom we may choose to sell or transfer all or part of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy;
• in connection with or during negotiation of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company;
• to our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us;
• to our business partners to offer you certain products, services or promotions;
• to other users, when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside;
• to third party advertisers to assist in the display of advertisements on third party sites and tracking the effectiveness of our advertisements; and
• to competent regulatory authorities and bodies as requested or required by law.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Retention

We will not hold your personal data for longer than is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

Notwithstanding the foregoing, if you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognise and approve any follow-up comments automatically instead of holding them in a moderation queue.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available by contacting us.

Transfer of your personal data

Your information, including personal data, is processed at WrxFlo’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws differ than those from your jurisdiction.

Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.

WrxFlo will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of your personal data relating to business transactions

If WrxFlo is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

Requirement to provide personal data

You are not under a statutory or contractual obligation to provide us with any personal data. However, where you submit a query to us in the ‘Contact’ section of our website or sign up for one of our newsletters or other promotional events, we will ask you to provide certain information, such as your name, contact number and email address. If you do not provide this information, we may not be in a position to process your request.

Your Rights

You have the following rights, in certain circumstances and subject to certain restrictions, in relation to your personal data:

• Right to access your personal data- You have the right to ask us if we are using or storing your personal data and to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data. We will provide the first copy of your personal data free of charge, but we may charge you a reasonable fee for any additional copies.
• Right to request the rectification of your personal data- You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete. All users of the Services can see, edit (with the exception of their username) or delete their personal information at any time. Website administrators can also see and edit this information. We may not always be able to change or remove this information, but we will correct factual inaccuracies and may include your comments in the record to show that you disagree with it.
• Right to erasure of your personal data - You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the “right to be forgotten” or the “right to erasure”. We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Right to restrict the use of your personal data - You have the right to request restriction of processing of your personal data if you are concerned about its accuracy or how it is being used. Where restriction of use has been granted, we will inform you before we carry on using your personal data.
• Right to object to the processing of your personal data - You have the right to object to the processing of your personal data if we are using it for certain purposes, including but not limited to, for (i) our legitimate interests; (ii) statistical purposes; or (iii) direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Right to data portability- You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format. This right only applies if you have provided us with the personal data and we hold that data electronically. It does not apply where it would adversely affect the rights and freedoms of others.

If you wish to exercise any of the rights set out above, please contact us via our website.

 

Updates

We may occasionally update this policy. We encourage you to periodically review this policy for the latest information on our privacy practices.

 

Queries and Complaints

If you have any queries or complaints in connection with our processing of your personal data, you can contact us via our website.

You also have the right to lodge a complaint with the Data Protection Commission (“DPC”), the Irish supervisory authority for data protection issues, if you are not happy with the way we have used your information or addressed your rights. Details of how to lodge a complaint can be found on the DPC’s website or by calling the DPC at 353 (0)761 104 800. We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.