Privacy and Data Processing Statement
Version 1.12, 8 May 2018.
This statement applies to and governs your access to and use of services provided by We Monitor Email, a business registered in Dublin, Ireland. When we say “we” and “us” we are referring to We Monitor Email. Services provided by We Monitor Email are referred to as the “Service”, while the officers, employees, agents, sub-contractors and affiliated companies of We Monitor Email are referred to as the “Team”. When we say “you” or “customer” we are referring to the person or entity that is registered with us to use our services. When we refer to the “parties” we mean We Monitor Email and the you, the customer.
Information We Collect
When you communicate with us in respect of any matter related to the Service, you are giving us information that we collect. By giving us this information, you consent to your information being used, disclosed, maintained and stored by us, as described in this statement. We Monitor Email may request or collect personal information (that is, information that can be used to identify a person). For example, you are required to provide contact details when you request a quotation. The data we collect that identifies you personally covers information such as:
- Your name
- Company name
- E-mail address
- Postal address
- Telephone numbers
- Billing information (excluding payment card data)
Please contact us if you want to review or change any personal information that you have previously submitted. We Monitor Email may also collect non-personal information. When we combine non-personal with personal data, the combined information will be treated as personal information.
If you supply an EU VAT number during the ordering process (to facilitate a reverse-charge), that information is a) stored by us and b) transmitted to the Irish tax authorities. Depending on the legal entity the EU VAT number is associated with, it may or may not be considered personally identifiable information. We are legally obliged to store and transmit this information.
If you elect to pay an invoice by credit/debit card then we will receive notification of that payment, including personal information you may have submitted and the last four digits of your payment card. We do not receive the complete payment card number. If you elect to pay an invoice by bank transfer, then we will receive descriptive information from your bank or money transfer service related to the payment which may include personally identifiable information. We are legally obliged to store such information for taxation and accounting purposes.
During the course of delivering the Service, you may be required to supply or you may volunteer information to us as required. This customer data may contain access credentials for applications or on-line services, statistical information related to your business operations and copies of raw data relating your clients. Customer data may contain personal information or sensitive information related to your clients.
Maintenance and Storage of Information
The information provided to and collected by We Monitor Email is saved for as long as it is reasonably required to fulfil the purpose for which it was gathered. Some information is retained after a customer leaves us in order to comply with accounting regulations and company law. Information may be stored on one or more databases directly or indirectly maintained by us. We employ industry-standard security controls to protect the confidentiality of the information along with appropriate technical and organisational measures.
Customer data is data which is supplied by you to us during the delivery of the Service.
We Monitor Email treat customer data as strictly confidential and it is always encrypted during storage. Customer data is not shared with any third parties unless such action is expressly permitted and directed by you. One month after the conclusion of the Service, the associated customer data is destroyed unless you direct us differently.
Customer data is stored within the European Union.
Information, including personally identifiable information, may also be retained in our computer backup files for longer periods, but not indefinitely. Our backups are only used as part of the process to recover from a computer system crash or failure. Due to the nature of how computer backup systems work, it is not possible to identify, query or modify individual customer data on backup files. We have processes in place to mitigate the risk of information (including personally identifiable information) belonging to recent former customers being re-activated after a backup recovery operation.
Backup files are stored within the European Union.
Disclosure of Information
Though we make every effort to preserve your privacy, we may need to disclose personal information when required by law, or if We Monitor Email believes that disclosure is reasonably necessary to protect our operations or our customers.
Before providing information to a non-customer, we require:
a) in the case of a criminal investigation: a request signed by a Garda Superintendent or higher grade officer, a warrant, or Irish court order, unless we believe in good faith that there is an emergency involving death or serious physical injury and b) In the case of tax investigation: a request in writing by the Revenue and Customs Commissioners of Ireland or their legally appointed representatives.
We Monitor Email is an Irish registered company and governed by the laws of the Republic of Ireland.
In case We Monitor Email is sold to a third party, we may transfer any and all of the information collected from customers to the new owners. In this case, the new owners will be subject to our obligations under this statement as part of the conditions of sale. Such a sale would also be protected and regulated by Irish and European law.
We use third parties to fulfil some business functions. All third parties we engage are required to implement industry-standard security controls along with appropriate technical and organisational measures to ensure the confidentiality of data shared with them.
Quotations and Invoices
We use a third party service called Xero to handle quotations and invoicing. We send information, including personal information to Xero in order to generate quotations and invoices.
We use third parties to process certain types of electronic payments. We use a company called Stripe to process credit/debit card payments and a company called PayPal to process PayPal payments. If you elect to pay an invoice by credit/debit card or by PayPal then you will be required to share payment details, including personal information directly with those third parties.
You should ensure that the information we collect and hold in relation to you is accurate and kept up to date. You have the right to review the information we have collected on you at any time. You also have the right to have the information erased if we do not have a legitimate reason for retaining it.
We will honour any valid requests within 40 calendar days of the receipt of the request.
We may require that you provide reasonable proof of identity before disclosing any information to you.
Governing Law and Jurisdiction
This Privacy and Data Processing Statement and all issues regarding such are governed exclusively by Irish law and are subject to the exclusive jurisdiction of the Irish courts. This statement is effective with respect to any information – personal and non-personal – that we have collected or collect about and/or from customers.
We may update our Privacy and Data Processing Statement from time to time. We will post the update here on the website. If we make material or significant changes we will inform existing customers as promptly as possible.
Thank you for reading, please contact us if you have any questions about them or require any clarifications.
To contact us in connection with a Data Subject Request, please use the following contact details:
By Email: firstname.lastname@example.org with subject line "Data Subject Request"
By Post: FAO Data Protection Officer / We Monitor Email, Suite 19, 20 Harcourt Street, Dublin 2, Ireland.