Privacy Policy

This privacy policy applies between you, the User of this Website and Coyle Group, the owner and provider of this Website. Coyle Group takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.

Please read this privacy policy carefully.

DEFINITIONS AND INTERPRETATION

1. In this privacy policy, the following definitions are used:

Data collectively all information that you submit to Coyle Group via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 2018;

Cookies a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Data Protection Laws any applicable law relating to the processing of personal Data, including but not limited to the Data Protection Act 2018 and the General Data Protection Regulation ((EU) 2016/679) ("GDPR") ("Data Protection Legislation"), and any national implementing laws and regulations as amended or updated from time to time in Ireland;

GDPR the General Data Protection Regulation (EU) 2016/679; GDPR Act 2018

Coyle Group, or us Coyle Group, a company incorporated in Ireland whose registered office is at the LINC, Blanchardstown Dublin 15, Ireland;

Ireland and EU Cookie Law S.I. No. 336/2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011

User or you any third party that accesses the Website and is not either (i) employed by Coyle Group and acting in the course of their employment or (ii) engaged as a contractor or client or otherwise providing services or receiving services and accessing the Website in connection with the provision of such services; and

Website the website that you are currently using, www.CoyleGroup.com, and any sub-domains of this site unless expressly

excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:

a. the singular includes the plural and vice versa;

b. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

c. a reference to a person includes freelancers, companies, government entities, trusts and partnerships;

d. "including" is understood to mean "including without limitation";

e. reference to any statutory provision includes any modification or amendment of it;

f. the headings and sub-headings do not form part of this privacy policy.

SCOPE

3. This privacy policy applies only to the actions of Coyle Group and Users with respect to this Website.

It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

4. For purposes of the applicable Data Protection Laws, Coyle Group is the "data controller".

This means that Coyle Group determines the purposes for which, and the manner in which, your Data is processed.

DATA COLLECTED

5. We may collect the following Data, which includes personal Data, from you:

a. name;

b. job title;

c. profession;

d. IP address (automatically collected);

e. in each case, in accordance with this privacy policy.

HOW WE COLLECT DATA

6. We collect Data in the following ways:

a. data is given to us by you; and

b. data is collected automatically.

DATA THAT IS GIVEN TO US BY YOU

7. Coyle Group will collect your Data in a number of ways, for example:

a. when you contact us through the Website, by e-mail or through any other means;

b. when you register with us and set up an account to receive our services;

c. when you elect to receive marketing communications from us;

d. when you use our services;

in each case, in accordance with this privacy policy.

DATA THAT IS COLLECTED AUTOMATICALLY

8. To the extent that you access the Website, we will collect your Data automatically, for example:

a. we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

b. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

OUR USE OF DATA

9. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

a. internal record keeping;

in each case, in accordance with this privacy policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed "Your rights" below).

11. When you register with us and set up an account to receive our services, 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.

WHO WE SHARE DATA WITH

12. We may share your Data with the following groups of people for the following reasons:

a. relevant authorities - Detection of crime or corruption or misrepresentation or fraud ;

in each case, in accordance with this privacy policy.

KEEPING DATA SECURE

13. We will use technical and organisational measures to safeguard your Data, for example:

a. access to your account is controlled by a password and a user name that is unique to you.

b. we store your Data on secure servers.

14. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: [email protected].

15. If you want detailed information from Be Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.gov.ie/en/campaigns/be-safe-online.

DATA RETENTION

16. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

17. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

YOUR RIGHTS

18. You have the following rights in relation to your Data:

a. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

b. Right to correct - the right to have your Data rectified if it is inaccurate or incomplete.

c. Right to erase - the right to request that we delete or remove your Data from our systems.

d. Right to restrict our use of your Data - the right to "block" us from using your Data or limit the way in which we can use it.

e. Right to data portability - the right to request that we move, copy or transfer your Data.

f. Right to object - the right to object to our use of your Data including where we use it for our legitimate interests.

19. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@coyle group.com.

20. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant Data Protection Commission.

21. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

LINKS TO OTHER WEBSITES

22. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

CHANGES OF BUSINESS OWNERSHIP AND CONTROL

23. Coyle Group may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Coyle Group. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

24. We may also disclose Data to a prospective purchaser of our business or any part of it.

25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

COOKIES

24. We may also disclose Data to a prospective purchaser of our business or any part of it.

25. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Type of Cookie	Purpose
Strictly necessary cookies	These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website

30. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

31. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

32. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

COOKIES

33. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

34. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

35. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

36. Any breach of this policy will be investigated and recorded as per the IP-08 Communication & Consultation Procedure. Under the GDPR a breach which is reportable to the Data Protection Commission must be reported not later than 72 hours after having become aware of it.

37. This Agreement will be governed by and interpreted according to General Data Protection Regulation (GDPR) Data Protection Act 2018. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the courts of the Republic of Ireland.

CHANGES TO THIS PRIVACY POLICY

38. Coyle Group reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.

You may contact Coyle Group by email at [email protected].

Gavin Coyle Date Coyle Group CEO

12th March 2021

GENERAL DATA PROTECTION REGULATIONS (GDPR) POLICY

SCOPE

This policy applies to all personal data created or received in the course of the Coyle Group business in all formats, of any age. Personal data may be held or transmitted in paper and electronic formats or communicated verbally. All contractors and suppliers working for or on behalf of the Coyle Group that are processing personal data are subject to the provisions of this Policy.

OUR COMMITMENT

The Coyle Group, are committed to ensuring the security and protection of the personal information that we retain and process, and to provide a compliant and consistent approach to data protection. We have robust and effective data protection controls in place which comply with data protection principles and statutory requirements.

The Coyle Group are dedicated to safeguarding the personal information under our remit and in maintaining a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation of the General Data Protection Regulations. Our GDPR compliance includes the development and implementation of policies, procedures, controls and measures to ensure maximum and ongoing compliance.

GDPR COMPLIANCE

The Coyle Group have internal security and privacy controls in place to ensure that all personal data within, or passing through the company, is handled in accordance with GDPR. As a company we will ensure consistent review and implementation of the relevant tools and practices to ensure the safeguarding of any data held or used within the Coyle Group.

The Coyle Group have three GDPR compliance objectives:

To ensure our own compliance as a business that holds and processes personal data.
To ensure our direct contractors and suppliers adhere to compliance and GDPR requirements.
To ensure that our work practices and software applications comply with the GDPR requirements.

DATA PROTECTION PRINCIPLES

he Coyle Group undertakes to perform its responsibilities under the legislation in accordance with Article 5 of the GDPR as follows:

Obtain and process information lawfully, fairly and in accordance with statutory and other legal obligations.
Keep personal data for purposes that are specific, lawful and clearly stated. Personal data will only be processed in a manner compatible with these purposes.
Only use and disclose personal data for the purposes for which it was collected.
Take appropriate security measures against unauthorized access to, or alteration, disclosure or destruction of data and against accidental loss or destruction of the data.
Keep the data accurate, complete and up-to-date.
Ensure it is adequate, relevant and not excessive in data retention terms.
Retain for no longer than is necessary.

All Employees have been made aware of all GDPR requirements, with the relevant training provided as required and Clients have given consent to retain their data for specific purposes.

This Policy shall be reviewed at least annually.

Gavin Coyle Date Coyle Group CEO

12th March 2021