Data Protection at Revas Spa

Your information, our duty and your rights

To be our customer, you share information with us. We respect that information.

On this page you will find out how we do that and what your rights are. We think it’s important that you read this page. It will tell you everything you need to know

Our Data Protection Notice is changing under the General Data Protection Regulation (GDPR).

You can read our new Data Protection Notice, effective from the 25th May 2018, here.

GDPR is the General Data Protection Regulation. It comes into effect from 25 May 2018. It sets out a series of new EU laws concerning how data is processed and used. The objective of the regulation is to strengthen and standardize data protection laws for all EU citizens. These regulations will apply to any organisation that controls and/or processes data on behalf of an individual or group of individuals. Those responsible for adhering to these regulations include employees of the organisation, including contractors, consultants, agents and third parties who have access to data either directly or indirectly.

We have always appreciated your trust in us to collect, process and protect your information. As a data controller and processor of your personal data, we will continue to

 

  • develop on our strong risk culture by acting responsibly and putting your security at the front of our priorities;
  • manage our controls, processes and systems to improve our level of customer service while providing you with the assurance that your information is safe and secure; and
  • conduct our business in a fair and transparent way and ensure we minimise the risk of unfair outcomes for our customers or impact on their data rights and freedoms.

 

Our Data Protection Notice and website explains how we collect personal information about you, how we use it and how you can interact with us about it.

When we talk about “Revas Spa” or “us” or “we” on our Data Protection Notice and this website, we are talking about Revas Spa Ltd.

 

We share your information within Revas Spa Ltd. to help us provide our services, comply with regulatory and legal requirements, and improve our products.

 

Our Data Protection Officer oversees how we collect, use, share and protect your information to ensure your rights are fulfilled. You can contact our Data Protection Officer at [email protected] or by writing to them at Revas Spa, Fitzgerald’s Woodlands House Hotel, Adare, Co. Limerick.

We collect personal information from you, for example when you:

  • make a booking;
  • make a deposit;
  • apply for products and services;
  • use your credit or debit card;
  • complete transactions; or
  • look for advice.

We also collect information through our website, apps, social media, discussion forums, market research and our CCTV footage.

We will sometimes record phone conversations and we will always let you know when we do this.

Our websites use ‘cookie’ technology. A cookie is a little piece of text that our server places on your device when you visit any of our websites or apps. They help us make the sites work better for you.

This is some of the information we collect and hold about you when applying for and using our products and services:

  • Full name/Signature
  • Email address
  • Mobile Phone Number
  • Date of birth
  • Medical details
  • Desired result from product/service
  • Consent to contact
  • CCTV images
  • Call recordings

Under GDPR, there are special categories that require additional safeguards for processing. In some instances, we will require this information for processing or it may be volunteered by you. These data types and the reason we collect them are:

Special categories of data Does AIB Group process this information?
Biometric data – Fingerprints, Facial and voice recognition No – We do not request you to provide religious or philosophical beliefs to provide our products and services.
Health data Yes – We may collect health data from you when providing our products and services or to deliver a safe and satisfactory service or product.
Racial or ethnic origin No – We do not request you to provide details of racial or ethnic origin to provide our products and services.
Political opinions No – We do not request you to provide political opinions to provide our products and services.
Religious or philosophical beliefs No – We do not request you to provide religious or philosophical beliefs to provide our products and services.
Trade union membership No – We do not request you to provide trade union membership to provide our products and services.
Genetic data No – We do not request you to provide genetic data to provide our products and services.
Sexual orientation No – We do not request you to provide sexual orientation to provide our products and services.

We use information about you to:

 

  • provide relevant products and services;
  • identify ways we can improve our products and services;
  • maintain and monitor your products and services;
  • protect your interests; and
  • decide and recommend how our products and services might be suitable for you

 

To provide our products and services under the terms and conditions we agree between us, we need to collect and use personal information about you. If you do not provide this personal information, we may not be able to provide you with our products and services.

 

We analyse the information that we collect on you through your use of our products and services and on our social media, apps and websites. This helps us understand your financial behaviour, how we interact with you and our position in a market place. Examples of how we use this information include  offering you products and services and personalising your experience.

 

We sometimes use technology to help us make decisions automatically. For example, when marketing a special offer. Before we market an offer, we automatically search for customers who may have enjoyed this service or product before and contact them letting them know that this offer is available and may be of interest to them.

 

All of our processing must be supported by a lawful basis, as discussed in our Meeting our legal and regulatory obligations section.

To use your information lawfully, we rely on one or more of the following legal bases:

 

  • performance of a contract;
  • legal obligation;
  • our legitimate interests;
  • your consent;
  • protecting the vital interests of you or others; and
  • public interest.

To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. We may also gather information about you from third parties to help us meet our obligations.

The personal information we have collected from you may be shared with law authorities or fraud prevention agencies who will use it to prevent crime and fraud .

If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our products and services.

For direct marketing, we need your consent to make you aware of products and services which may be of interest to you. We may do this by phone, post, email, text or through other digital media.

 

You can decide how much direct marketing you want to accept when you apply for new products and services.

 

As part of our direct marketing, we analyse the information that we collect on you through your use of our products and services and on our social media, apps and websites. This helps us understand your financial behaviour, how we interact with you and our position in a market place. This enables us to personalise your experience and provide you with the most suitable products and services.

 

If we ever contact you to get your feedback on ways to improve our products and services, you have the choice to opt out.

Sometimes we need your consent to use your personal information. For example, when we use sensitive personal information (known as special category information under GDPR) about you, such as medical , we ask for your explicit consent.

 

We have controls to ensure that you are informed when making your decision and that you are aware that you can remove your consent at any time by contacting us. Our consent requests are built on the following principles:

 

  • Positive Action – Clear affirmative action is required. We will no longer use pre-ticked boxes, imply or assume consent in the event of no positive action from you.
  • Free will – Your consent must be freely given and not influenced by external factors.
  • Specific – We will be clear on what exactly we are asking your consent for.
  • Recorded – We will keep a record of your consent and how it was obtained.
  • Can be withdrawn at any time – We will stop data processing requiring your consent at any time you make valid request.

We protect your information with security measures under the laws that apply and we meet international standards. We keep our computers, files and buildings secure.

In addition to our technical controls, our Data Protection Officer oversees how we collect, use, share and protect your information to ensure your rights are fulfilled. Our Data Protection Officer advises on how we can best understand risks to your data rights and freedoms, implemented processes to protect these and has responsibility to report to the Data Protection Authorities if we are not meetings our obligation.

When you contact us to ask about your information, we may ask you to identify yourself. This is to help us protect your information.

To meet our legal and regulatory obligations, we hold your information while you are a customer and for a period of time after that. To help you understand how long we hold some of your data for, we have summarised our internal retention schedules below. We hold all data while you are an active customer with us.

Please note that these retention periods are our policy but are also subject to legal, regulatory and business requirements, which may require us to hold the information for a longer period. We must do this to protect both of our interests.

 

We continuously assess and delete data to ensure it not held for longer than necessary

  • Consent to direct marketing- 1 year
  • Account and service information- 6 years
  • Transaction information- 6 years
  • Repostable accidents and health and safety reports-10 years

Sometimes we share your information with third parties.

 

For example:

 

  • Credit/debit card transaction providors
  • CCTV provider
  • Telephone system provider
  • Law enforcement

We require that these third parties provided sufficient guarantees that the necessary safeguards and controls have been implemented to ensure there is no impact on your data rights and freedoms.

We also have to share information with third parties to meet any applicable law, regulation or lawful request. When we believe we have been given false or misleading information, or we suspect criminal activity we must record this and tell law enforcement agencies, which may be either in or outside Ireland.

You can exercise your rights by contacting us at 061 605120, using our social media channels or calling into Revas Spa.

 

Whenever you contact us to ask about your information, we may ask you to identify yourself. This is to help protect your information.

 

Your right to obtain information cannot adversely affect the tights and freedoms of others. Therefore, we cannot provide information on other people without consent.

 

We generally do not charge you when you contact us to ask about your information. Per regulation, if request are deemed excessive or manifestly unfounded, we may charge a reasonable fee to cover the additional administrative costs or choose to refuse the request.

 

The following section details your information rights and how we can help ensure that you are aware of these rights, how you can exercise these rights and how intend to deliver on your requests.

You can ask us for a copy of the personal information we hold and further details about how we collect, share and use your personal information. You can request the following information:

 

  • the purposes of the processing;
  • the categories of personal data concerned;
  • the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

If you want to update or correct any of your personal details, please contact us at 061 605120 or call into Revas Spa.

You can change your mind wherever you have given us your consent, such as for direct marketing or processing your sensitive information, such as medical  data. By contacting us at 061 605120, you can request that we no longer process data we require your consent for.

You may have the right to restrict or object to us processing your personal information. We will require your consent to further process this information once restricted. You can request restriction of processing where;

 

  • The personal data is inaccurate and you request restriction while we verify the accuracy;
  • The processing of your personal data is unlawful;
  • You oppose the erasure of the data, requesting restriction of processing instead;
  • You require the data for the establishment, exercise or defence of legal claims but we no longer require the data for processing;
  • You disagree with the legitimate interest legal basis and processing is restricted until the legitimate basis is verified

You may ask us to delete your personal information or we may delete your personal information under the following conditions:

 

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw your consent where there is no other legal ground for the processing;
  • you withdraw your consent for direct marketing purposes;
  • you withdraw your consent for processing a child’s data;
  • you object to automated decision making;
  • the personal data have been unlawfully processed;
  • the personal data have to be erased for compliance with a legal obligation.
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Where possible we can share a digital copy of your information directly with you or another organisation. We will provide this information in a structured, commonly used and machine-readable format. Note, we can only share this information where it has been processed automatically (hard copy documents are excluded for portability) and was processed under your consent or performance of a contract.

We do not share information processed under legal obligation or our legitimate interest for portability, in line with GDPR guidance.

If you have a complaint about the use of your personal information, please let a member of staff at Revas Spa know, giving them the opportunity to put things right as quickly as possible. If you wish to make a complaint you may do so in person, by phone, in writing and by email. We will fully investigate all the complaints we receive. You may complain through our website, by phone, by email or in person at Revas Spa. We ask that you supply as much information as possible to help us resolve your complaint quickly.

 

You can also contact the Office of the Data Protection Commissioner in Ireland on the below details:

 

  • Visit their website www.dataprotection.ie.
  • Email [email protected]
  • Phone on +353 (0)57 8684800 or +353 (0)761 104 800
  • Write to Data Protection Office, Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. Or 21 Fitzwilliam Square, Dublin 2, D02 RD28, Ireland.

We will make changes to this notice from time to time, particularly when we change how we use your information, and change our technology and products. You can always find an up-to-date version of this notice on this website at www.revasspa.ie, on display at Revas Spa, or you can ask us for a copy.

Please see explanations below of some of the data protection terms used on this website.

Consent – of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

Data Controller – is a natural or legal person, public authority, agency or other body who determine the purpose and means of the processing – of personal data, where the purposes and means of such processing are determined by Union or Member State law.  AIB are considered a data controller, as they process personal data on behalf of both their customers and their employees.

 

Data Processor – in relation to personal data, means any natural or legal person (other than an employee of the data controller), public authority, agency or another body who processes personal data under the direction of, and on behalf of a data controller. AIB is considered a data processor, as they process personal data on behalf of Third Parties. Additionally, Third Parties engaged by AIB to process personal data are considered data processors.

 

Data Protection Officer – The Data Protection Officer oversees how we collect, use, share and protect information.

 

Data Protection Law and Regulation – means all legislation, regulation and applicable codes of practice relating to the processing, protection and privacy of personal data. See section 1.1 for details.

 

General Data Protection Regulation (‘GDPR’) – is a regulation intended to strengthen and unify data protection for all individuals within the European Union (‘EU’). Non-compliance of GDPR can result in fines the higher of €20 million or up to 4% of AIB Group’s turnover. The aim of the GDPR is to reinforce data protection rights of individuals and facilitate the free flow of personal data. It applies to all data controllers and processors established in the EU, as well as those established outside the EU that process the data of EU citizens.

 

Lawful basis – Processing of data is lawful only if and to the extent that at least one of the following applies:

 

a) Personal data may be processed on the basis that processing is necessary in order to enter into or perform a contract with a customer.

b) Personal data may be processed on the basis that there is a legal obligation for the processing.

c) Personal data may be processed where AIB has a legitimate interest in processing the data.

d) Personal data maybe processed in order to protect the vital interests of the data subject.

 

Location Data – means any data processed indicating the geographical position of the terminal equipment of a user, including data relating to:

 

a) The latitude, longitude or altitude of the terminal equipment;

b) The direction of travel of the user; or

c) The time the location information was ‘recorded’

 

Personal Data – is any data relating to an identified or identifiable natural person (‘data subject’), who may be identified from the data either on its own (directly) or in conjunction with other data (indirectly), in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

Processing – means obtaining, recording or holding the information or data, whether or not by automated means,  or carrying out any operation or set of operations on the information including:

 

a) Collection of data

b) Organisation, adaption or alteration of the information or data

c) Retrieval, consultation or use of the information or data

d) Disclosure of the information, or data by transmission, dissemination or otherwise making available, or

e) Alignment, combination, blocking, erasure or destruction of the information or data

 

Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

 

Recipient – means a natural or legal person, public authority (such as the Office of the Data Protection Commissioner (‘ODPC’), agency or another body, to which the personal data are disclosed, whether a Third Party or not. The processing of those data shall be in compliance with the applicable data protection rules according to the purposes of the processing.

 

Special Categories of Personal Data – is data which relates to:

 

a) Racial or ethical origin, political opinions or religious or philosophical beliefs

b) Trade union membership

c) Biometric data

d) Physical or mental health

e) Sexual Life/Orientation

f) Commission or alleged commission of any offence by the data subject or

g) Any proceedings for any offence committed or alleged

 

Supervisory Authority – means an independent public authority which is established by a Member State. In the Republic of Ireland the Office of the Data Protection Commissioner (‘ODPC’) and in the UK the Information Commissioner’s Office (‘ICO’) are the public authorities established to monitor the application of Data Protection Law.