Privacy Policy

Actavo is committed to ensuring that your privacy and personal data are protected. Our use of your personal data is governed by this Privacy Policy. This Privacy Policy explains how we use your personal data and your rights in relation to that data, such rights being set out in the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018 (DPA).

In this statement we use the terms “Actavo”, “we”, “our” and “us” to refer to Actavo Group Limited and its subsidiaries and associated companies. Actavo Group Limited is a registered company (Companies Registration Office number 510327) and our registered office is at Westland House, Willow Road, Dublin 12. Please note that the application of this Privacy Policy is applicable to the Actavo Website which is owned and controlled by Actavo Group Limited. Actavo is the data controller responsible for the personal data it collects, uses and stores about you. A data controller is someone who alone or jointly with others, determines the purposes and means of the processing of personal data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out in section 10 below.

1. What is personal data?

Personal data is any information relating to an identified or identifiable individual that allows us to identify you. This could include information such as your name, postal address, telephone number, email address or date of birth.

2. When and how do we collect your personal data?

We use different methods to collect personal data from and about you 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. This includes personal data you provide when you:

Give us feedback or contact us;
Apply to work with us;
Request information to be sent to you or signing up to a mail list;
Enter a competition, promotion or survey;
Reply to a request for the provision of goods or services or solicitation of same; or
Engage in business dealings with us.

Automated technologies or interactions
As you interact with the Actavo Website, we will automatically collect information about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy (https://actavo.com/cookie-policy/) for further details.

Publicly available sources such as social media and the Companies Registration Office.
The Actavo Websites 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 how they use your personal data or their privacy statements. When you leave the Actavo Website, we encourage you to read the privacy policy of every website you visit.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).

3. The purpose and legal basis for processing your personal data

Under data protection law we are only permitted to use your personal data if we have a legal basis for doing so. We rely on the following legal bases to use your personal data:

a) To enter into and perform a contract with you or your employer
We may use your personal data in order to enter into a contract with you or your employer or to provide you or your employer with a service that you or your employer have requested from us.

b) To comply with a legal obligation
We are required to use your personal data to comply with certain legal and regulatory obligations to which we are subject.

c) For our legitimate interests
We may use your personal data for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). When we use your personal data in this way, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms. In more limited circumstances we may also rely on the following legal bases:

Where we need to protect your vital interests (or someone else’s vital interests); or
Where your personal data is needed in the public interest or for official purposes.

d) With your consent
We may send you information by post, text, email and/or phone from time to time about our activities or initiatives where you have consented to us contacting you in this way. You can withdraw this consent at any time free of charge by following the opt-out links on any such communications sent to you.

e) To recruit staff

4. Categories of personal data we collect and process and how we use it

We have set out below, in table format, a description of the ways we use your personal data, and which of the legal bases we rely on to do so:

Purpose/activity for which it is used	Lawful basis for processing
To provide services to you or your employer	Performance of a contract with you or your employer
To manage the provision of services to you or your employer including: (a) Managing payments (b) Collecting and recovering money owed to us	Performance of a contract with you or your employer Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you or your employer which will include asking you to leave a review or take a survey	Performance of a contract with you or your employer Necessary for our legitimate interest (to keep our records updated; to assess how users engage with us.)
To enable you or your employer to partake in a campaign, prize draw, competition or complete a survey	Necessary for our legitimate interests (to assess how users engage with us; to raise awareness and generate interest in our campaigns and initiatives)
To administer, secure and protect our business and the Actavo Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Necessary for our legitimate interest (for the running of our business; provision of administration and IT services and network security; to prevent fraud) Necessary to comply with a legal obligation
To deliver relevant website content to you, measure or understand the effectiveness of the content we serve and to allow you to participate in interactive features of the Actavo Website when you choose to do so	Necessary for our legitimate interests (to assess how users engage with our services; to develop our services; to grow our business and to inform our marketing strategy)
To use data analytics to improve the Actavo Website, services, marketing, member relationships and experiences	Necessary for our legitimate interests (to keep our Actavo Website updated and relevant; to develop our business; to inform our marketing strategy)
To respond to any queries or other communications you submit to us	Necessary for our legitimate interest.
To create a candidate profile for you if you are a prospective employee	Necessary for our legitimate interest.

Purpose/activity for which it is used

Lawful basis for processing

To provide services to you or

your employer

Performance of a contract with

you or your employer

To manage the provision of services to

you or your employer including:

(a) Managing payments

(b) Collecting and recovering money

owed to us

Performance of a contract with

you or your employer

Necessary for our legitimate

interests (to recover debts due to us)

To manage our relationship with

you or your employer which will

include asking you to

leave a review or take a survey

Performance of a contract

with you or your employer

Necessary for our legitimate

interest (to keep our records updated;

to assess how users engage with us.)

To enable you or your employer to

partake in a campaign, prize draw,

competition or complete a survey

Necessary for our legitimate interests

(to assess how users engage with us;

to raise awareness and generate interest

in our campaigns and initiatives)

To administer, secure and protect

our business and the Actavo Website

(including troubleshooting, data analysis,

testing, system maintenance,

support, reporting and hosting of data)

Necessary for our legitimate interest

(for the running of our business;

provision of administration and

IT services and network security;

to prevent fraud)

Necessary to comply with a legal obligation

To deliver relevant website content

to you, measure or understand the

effectiveness of the content we serve

and to allow you to participate in

interactive features of the Actavo

Website when you choose to do so

Necessary for our legitimate interests

(to assess how users engage with our

services; to develop our services;

to grow our business and to inform

our marketing strategy)

To use data analytics to improve

the Actavo Website, services,

marketing, member relationships

and experiences

Necessary for our legitimate

interests (to keep our Actavo

Website updated and relevant;

to develop our business;

to inform our marketing strategy)

To respond to any queries or

other communications you

submit to us

Necessary for our legitimate

interest.

To create a candidate profile

for you if you are a

prospective employee

Necessary for our legitimate

interest.

We do not collect special categories of personal data about you. Special categories of personal data include details about your and health, race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation and political opinions.

5. Your Personal Data and Other Parties

Third Party Service Providers
In order for us to fulfil our duties and our contract with you or your employer we may share your personal data with third party product and service providers and sub-contractors that perform services and functions at our direction and on our behalf. Such third-party service providers include auditors, accountants, legal and tax advisers, communication services, financial and banking services, insurers, professional advisors, IT service providers, security service providers and administrative services providers.
We also may share your personal data with analytics and search engine providers that assist us in the improvement and optimisation of the Actavo Website.
An Garda Síochána, government or quasi-government bodies, courts and tribunals
We may share your personal data with these organisations and bodies where required to do so by law.

6. Data Retention Period

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

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, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. Transfers outside the European Economic Area

If required, for storage or processing purposes, we may need to transfer your personal data to a destination outside the European Economic Area (“EEA”). It may be processed by our staff operating outside the EEA who work for us or for one of our suppliers. We and our service providers will take all steps reasonably necessary to ensure that storage and processing of your data outside the EEA continues to comply with the provisions of the GDPR and the DPA.

8. 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 requirement to access same for business purposes. 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.

9. Your Rights

You have several rights under data protection law in relation to how we use your personal data. These include the right, free of charge, to:

1. Be informed about the personal data we hold about you and how we use that information.

2. Obtain access to personal data we hold on you.

3. Have any personal data that we hold about you which you believe is incorrect, incomplete, or inaccurate, updated or corrected.

4. Have your personal data erased in the following circumstances:

If Actavo is continuing to process personal data beyond the period when it is necessary to do so for the purpose for which it was originally collected.
If Actavo is relying on consent as the legal basis for processing and you withdraw consent.
If Actavo is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing.
If the personal data has been processed unlawfully.
If it is necessary to delete the personal data to comply with a legal obligation.

5. Have our processing of your personal data restricted where you consider that:

The personal data is inaccurate.
The processing is unlawful, and you oppose erasure and request restriction instead.
Where we no longer need the personal data, but you require us to keep it to enable you to establish, exercise or defend a claim.
Where you have raised an objection to our use of your personal data.

6. Object to our processing of your personal data where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection, we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal data.

7. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only apples to automated information which you initially provided consent for us to use or where we use the information to perform a contract with you.

Where our processing of your information is based on your consent to such processing, you have the right to withdraw that consent at any time but any processing that we carried out before you withdraw your consent remains lawful.

These rights are in some circumstances limited by data protection law. If you wish to exercise any of these rights, you can contact us using the details below. We will endeavour to respond to your request within one month. If we are unable to deal with your request within one month, we may extend this period by a further two months and we will explain why.

10. Complaints and contact details

Complaints

You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues through the form on the website (www.dataprotection.ie), or by post to Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland. We would, however, appreciate the opportunity to deal with your concerns before you approach the DPC so please feel free to contact us in the first instance.

Contact details

If you have any questions, comments or requests regarding any aspect of this Privacy Policy, please do not hesitate to contact us:

By emailing us at [email protected];
By writing to us at Actavo Group Limited, Westland House, Willow Road, Dublin 12; or
By telephone, on +353 (0)1 9059700

11. Updates

We may update this Privacy Policy from time to time. Any changes to this policy will be posted here, and we will inform you of any significant changes if we have your contact details.

This version of the Privacy Policy is effective from 24 April 2024.