Website Privacy Policy V01 (Updated 04 Jan 2022)

1. Commitment to Data Privacy Compliance

CIM is committed to compliance with all applicable country-specific data privacy laws, including but not limited to, the EU General Data Protection Regulation (GDPR). Protecting the privacy and security of your Personal Data is of the highest importance to CIM; therefore, we conduct our business by abiding by applicable laws on data privacy and data security.

This Privacy Policy outlines CIM’s policies and practices for the collection, use, processing, storage, hosting, transfer, and disclosure of information that we may collect about you through our website  www.cim.ie and other websites owned and controlled by CIM (the “Sites”).

This Website Privacy Policy is published on our website and continued use of our Sites is accepted as understanding the terms of this Privacy Policy and the processing of information about you as described herein. The collection, use, storage, transfer and disclosure of your Personal Data will be strictly limited to the terms for which you provide your authorisation. For the purpose of this Policy, the reference to Personal Data includes the term “personally identifiable information.”

This Privacy Policy covers all CIM Sites.

2. Personal Data

Through our Sites, CIM will not collect any Personal Data about you (e.g. your name, address, telephone number or e-mail address), unless you voluntarily choose to provide us with it or unless otherwise permitted by applicable laws and regulations for the protection of your Personal Data.

3. Purpose of Use

When you voluntarily provide us with Personal Data, we will use it only for the purpose for which you have provided it, for example, to respond to your enquiry, register you for an event, provide information related to CIM services and events.

• We may store and process Personal Data and share it with our worldwide affiliates to better understand your business needs and how we can improve our products and services;

We do not sell or otherwise market your Personal Data to third parties.

4. Information That We Collect and Use

We collect Personal Data needed to address your specific interests and requests identified through our Sites. Examples of personal information are name, address, telephone number, e-mail address, company name, position and any other contact details you willingly provide to us. For a complete list of all data elements that we collect and the use of those data elements, contact us at privacy@cim.ie.

We may also collect information on what pages visitors access or visit, and other information volunteered by the visitor, such as survey information and site registrations. This information may be used to personalise our communications with you about products that are specific to your needs and interests. No Personal Data is collected, used, accessed, stored, transferred or distributed without your authorisation unless absolutely required to manage this website or respond to a request you have made unless allowed under local law. At any time, even after you have given authorisation, you can opt out of receiving these communications by selecting “unsubscribe”.

We may use the information that we collect to improve the content of our webpages by incorporating information that is relevant to our clients, to notify customers about updates to our Sites, to contact customers for marketing and sales purposes that are related specifically to their needs and interests, to track applicants for career opportunities, and to communicate with our partners. This information is not shared with other organisations for any reason, commercial or business, without your prior explicit consent.

If you browse and/or apply for jobs in the Careers portion of our Sites, your application and any additional information that you provide may be used to assess your skills and interests against career opportunities at CIM. This usage is covered in the initial authorisation that you provide to CIM.  We use your information to communicate with you and to inform you of career opportunities.

We may use third-party entities to provide valuable services on our behalf. We will only share your Personal Data with them in a legally compliant manner. Third parties with which we share your information are bound by all relevant data privacy laws, terms of confidentiality, contractual agreements, including data processing agreements, and this Privacy Policy. Our third-party providers are required to also have equivalent and compliant Website Privacy Policies. Please contact privacy@cim.ie with any questions related to our third-party providers.

If you have supplied us with your email, telephone number and/or postal address and marketing consent but no longer wish to receive marketing information, you may unsubscribe or revoke your consent at any time by contacting us at privacy@cim.ie.

You may also request to have your information corrected for inaccuracies or deleted by contacting us at privacy@cim.ie or at the address at the end of this document.  All privacy related matters are handled by our ATS VP legal and Global Compliance and our Global Data Protection Officer.  Any requests sent to the postal address at the end of the document will be coordinated with those individuals.

The company does not sell, rent, or trade your Personal Data with third parties for any purpose.

We will retain your personal information for the length of time needed to fulfil the purposes outlined in this Privacy Policy and/or in accordance with applicable data retention regulations.

For each visitor to our Web page, our Web server automatically recognises only the visitor’s domain name, but not the e-mail address.

5. Purpose Limitation

CIM will collect, use or disclose Personal Data supplied by you online only for the purposes disclosed to you, unless the disclosure:

• Is a use of the Personal Data for any additional purpose that is directly related to the original purpose for which the Personal Data was collected
• Is necessary to prepare, negotiate and perform a contract with you
• Is required by law, governmental or judicial authorities
• Is necessary to establish or preserve a legal claim or defence, or for any other legal purpose
• Is necessary to prevent fraud or other illegal activities, such as wilful attacks on CIM information technology systems.

6. Communications or Utilisation Data

Through your use of telecommunications services to access our Sites, your communications data (e.g. Internet protocol address) or utilisation data (e.g. information on the beginning, end and extent of each access, and information on the telecommunications services you accessed) are technically generated and could conceivably relate to Personal Data. To the extent that there is a compelling necessity, the collection, processing and use of your communications or data will occur and will be performed in accordance with the applicable data protection legal framework.

7. Non-Personal Data Collected Automatically

When you access our Sites, we may automatically (i.e., not by registration) collect non-Personal Data (e.g. type of Internet browser and operating system used, domain name of the website from which you came, number of visits, average time spent on the site, pages viewed). We may use this data to monitor the relevancy of our Sites and improve their performance or content.

8. “Cookies” – Information Stored Automatically on Your Computer

A cookie is a piece of information that is stored on your computer’s hard drive by your Web browser. When you revisit CIM Sites, our server recognises the cookie, giving us information about your last visit. Most browsers accept cookies automatically, but you can alter the settings of your browser to prevent automatic acceptance. If you choose not to receive cookies, you can still use most of the features of our Sites.

CIM complies with the EU Cookie Directive regarding the use of cookies. Visitors to our site are asked to provide their consent before we place any cookies on your device. For detailed information regarding CIM’s use of cookies, please refer to our Website Cookie Policy.

9. Children

CIM will not knowingly collect Personal Data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose Personal Data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child.

10. Security

To protect your Personal Data against accidental or unlawful destruction, loss or alteration and against unauthorised disclosure or access, CIM uses industry standard technical and organisational security measures.

11. Links to Other Websites

CIM Sites may contain links to other websites. CIM is not responsible for the privacy practices or the content of other websites.

12. Data Security Breaches

To protect your Personal Data from unauthorised access and use, or accidental loss and destruction, CIM has implemented security controls and intrusion detection software to notify us in the case of any potential or actual invasion of our systems. We have implemented a Data Breach Notification Policy and have established an Incident Response Team that has been trained to react to any unauthorised access of our databases and systems. Should any data security breach occur that materially and negatively impacts your Personal Data, you will be notified as soon as possible once the breach has been determined.

13. Right to Be Forgotten

CIM is committed to taking all reasonable steps necessary to ensure that any data you request to be forgotten, and can be erased with existing technology, will be erased. However, any data you post to our Sites that you agree to make available to third parties or for which you make public, is outside the boundaries of which CIM can erase. CIM will, where technically possible, erase your data if you feel it is being held for longer than needed or if you withdraw your consent to receive information from us and request the right to be forgotten. However, CIM will not be able to erase your data if:

• It is technically impossible; or
• It is required to be retained for legal reasons (if mandated by local law).

14. Questions and Comments

CIM will respond to reasonable requests to review your Personal Data and to correct, amend or delete any inaccuracies. If you have any questions or comments about our Website Privacy Policy (e.g. to review and update your Personal Data), please send us your questions and feedback. You can contact us by sending an email to privacy@cim.ie or by writing to us at the following address.

Control and Information Management (CIM) Ltd

ATTN: Data Compliance

50A Rosemont Park Drive

Rosemount Business Park

Dublin, D11 TK4C

Ireland

As the Internet, technology and our systems mature, so will our Website Privacy Policy. We will post changes to our Website Privacy Policy on this page. Please check this page regularly to keep up to date.