The Policy explains how we use any personal data we collect about you (either "user" or "you") when you use the Website. This Policy is designed to protect you, our users, by informing you what personal data is collected, how we will use the information about you, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of your personal information. Your use of the Website and any micro-sites is subject to your agreement with this Policy.
In this Policy, the term "personal data" or "personal information" means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).
Please read the following carefully. Entering this Website and providing your consent to our use of your personal data in accordance with the terms of this Policy indicates that the user has reviewed this Policy and has agreed to be bound by it. If you no longer consent to our processing of your personal data, you may request that we cease such processing by contacting us via the 'How to contact us' facility referred to below.
Matrix Claims Services is proudly committed to complying with the Data Protection Acts 1988 and 2003 and SI 336 of 2011 EUROPEAN COMMUNITIES (ELECTRONIC COMMUNICATIONS NETWORKS AND SERVICES) (PRIVACY AND ELECTRONIC COMMUNICATIONS) REGULATIONS 2011 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) which replaces the previous data protection directive (officially Directive 95/46/EC) on May 25th 2018 ("Data Protection Legislation").
What information do we collect about you?
We do not collect information for marketing purposes. We only collect contact information in regard to enquiries about our claims service. The provision of your personal information is entirely at your discretion. If you do decide to opt-in, we will require certain limited personal data from you. This will include your name, and email address. In all cases, you can be assured that we seek only the most basic details. Website usage information is collected using cookies (see Cookies section below).
Matrix Claims Services does not collect the kind of data that facilitates individual identifiable profiling without the consent of the owner of that data. We collect and collate generic information on all of our Website traffic; this is only ever used or represented in aggregate format.
How will we use the information about you?
We collect this contact information about you only to contact you directly about our products and services that you have requested information on.
We do not collect IP addresses from visitors to our Website (an IP address is a number that can uniquely identify a specific computer or other network device on the internet).
A cookie is a small text file that is placed on your hard disk by a web server which enables a website and/or mobile app to recognise repeat users, facilitate the user's ongoing access to and use of a website and/or the mobile app and allows the website and/or mobile app to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising.
We use a session cookie to do this. This type of cookie expires and is deleted when you close your browser.
If you have consented to receive communications from us, you may opt out at any time. You have a right at any time to stop us from contacting you. If you have 'opted in' to receive emails, we may send promotional emails to your email address containing information on products and services that we feel may be of interest to you. Such emails may include links to the websites of third parties, and in this regard, we would refer you to the section headed 'Security' below.
Children under the age of 16
We ask that persons under the age of 16 do not submit any personal information to us. We will not knowingly accept any data from a person who is under the age of 16 years.
What rights do you have?
As a data subject, you have the following rights under the Data Protection Legislation:
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see 'How to contact us' below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a certain time period pursuant to Data Protection Legislation, we will respond within that time.
Right to access to personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
Requests for your personal data must be made to us (see 'How to contact us' below) specifying what personal data you need access to, and a copy will be retained on your personal file. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.
If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.
We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your personal data or correct any mistakes in your personal data
You can require us to correct any mistakes in your personal data which we hold free of charge. If you would like to do this, please:
If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.
It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see 'How to contact us' below).
Right to ask us to stop contacting you
You can ask us to stop contacting you. If you would like to do this, please:
We will provide you with information on action taken on a request to stop contacting you.
Right to restrict or prevent processing of personal data
In accordance with Data Protection Legislation, you may request that we stop processing your personal data temporarily if:
If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:
Right to data portability
In accordance with Data Protection Legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.
The right to data portability also only applies where:
Right to erasure
In accordance with Data Protection Legislation, you can ask us to erase your personal data where:
We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.
Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC
If you do not think that we have processed your personal data in accordance with this Policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the DPC website at https://www.dataprotection.ie
If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the Website or otherwise engage in any disruptive behaviour on any Matrix Claims Services service, we may remove such content.
Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to personal data to employees, contractors and agents who need to know such personal data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place.
We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of your personal data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data transmitted to our Website and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the Website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your personal data arising from such risks.
Matrix Claims Services may also be linked to websites operated by third parties. These links are meant for your convenience only. Links to third party sites do not constitute endorsement on the part of Matrix Claims Services of those sites and we are not responsible for the privacy practices of the owners and operators of those sites. We encourage you to review the privacy policies and practices on each site which asks you to submit personal information.
We will notify serious data breaches to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A personal data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your personal data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
Who we share your data with
We may disclose your personal information to any business unit, company or other corporate entity under the control and direction of Matrix Claims Services Limited.
Matrix Claims Services may also share your information in the following, highly unlikely instances:
We may also use service providers to help us run the Website or services available on the Website. Any third parties who access your data in the course of providing these services on our behalf are subject to strict contractual restrictions to ensure that your data is protected, in compliance with Data Protection Legislation.
We reserve the right to access and disclose personal data in compliance with Data Protection Legislation.
Where we store your data
The data that we collect from you 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 your personal data, you consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. The safeguards in place with regard to the transfer of your personal data outside of the EEA are the entry by us into appropriate contracts with all transferees of such personal data.
All information you provide to us is stored on our secure servers.
How long will we retain your personal data?
Matrix Claims Services complies with the highest standards when collecting and using personal information. No personal information will be retained for longer than is necessary to fulfil a legitimate business need or as required by applicable law.
Changes to the Policy
We keep our Policy under regular review and we reserve the right to amend this Policy at our discretion and users shall be deemed to accept the modified Policy by continuing to access the Website to submit personal information on or after the date of modification. We will place any updates on this Website.
How to contact us
The data controller (as defined in Data Protection Legislation) for the Website and services provided through the Website is Matrix Claims Services Limited, located at Matrix Claims Services, Third Floor Merchants House, 27-30 Merchants Quay, Dublin 8, Ireland.
You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us at the following address.
Matrix Claims Services Ltd.,
Third Floor Merchants House
27-30 Merchants Quay
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate.
We will not levy any charge in respect of the above actions.
draft date: 24/5/2018