At LPP we respect your right to privacy. Any personal data required by LPP for the purpose of providing services to you will be held securely and will only be used for the purposes described in this document. LPP has never, and will never, sell your data to any 3rd party.
“personal data” is as defined in the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) and other applicable European and national privacy legislation and regulations (together the “Data Protection Law”), and is information that identifies you as an individual, such as:
- Postal address
- Telephone number
- Email address
“data controller” means the entity which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“data processor” means the party that processes personal data on behalf of the data controller.
“European Economic Area” or “EEA” means Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, the UK, Iceland, Liechtenstein, and Norway.
“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. “process” and “processing” are interpreted accordingly.
“special categories of personal data” are types of personal data that reveal any of the following information relating to an individual: racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership. Special categories of personal data also include the processing of genetic data, biometric data, health data, data concerning sex life or sexual orientation and any personal data relating to criminal convictions or offences.
Collection of personal data
LPP will act as a data controller in respect of personal data collected through our site or during the course of your interactions with us. Collection of personal data by LPP arises in various ways:
- Information that you provide to us when registering as a member with LPP such as your first name, last name, home address and e-mail address.
- Information that you may provide by availing of our services or registering for training courses and/or attending our events.
- If you contact us for any reason, we may keep a record of that correspondence.
- Website visitors can submit enquiries by completing enquiry forms or by submitting email enquiries.
Certain personal information is needed to enable LPP to provide certain services to you, e.g. if you want to subscribe to our group mailing list, we need your email address in order to send you information about our upcoming events. In these circumstances, if an individual does not provide the relevant personal information to LPP, LPP may not be able to provide its services to the individual. To obtain more information in relation to this, please contact us using the details in the “Contacting Us” section below.
Use of personal data
The personal data that you provide to us may be processed for the following purposes:
|Purpose of processing your personal data
|Lawful basis under Data Protection Law|
|· To contact you in response to communications you might send us.||As required for the performance of a contract with you (per Art. 6(1)(b) GDPR) or as is necessary and proportionate in LPP’s legitimate interests (per Art. 6(1)(f) GDPR).|
|· To provide you with the information and services that you have requested.||As required for the performance of a contract with you (per Art. 6(1)(b) GDPR) or as is necessary and proportionate in LPP’s legitimate interests (per Art. 6(1)(f) GDPR).|
|· To provide you with the information and services necessary in the fulfilment of our contractual obligations to you.||As required for the performance of a contract with you (per Art. 6(1)(b) GDPR)|
|· To send you important information regarding LPP, your membership, changes to our terms, conditions, and policies and/or other administrative information.||As is necessary and proportionate in LPP’s legitimate interests (per Art. 6(1)(f) GDPR).|
|· To personalise your experience on the LPP website.||As is necessary and proportionate in LPP’s legitimate interests (per Art. 6(1)(f) GDPR).|
|· For our internal reporting purposes, such as data analysis, audits, developing new events, enhancing our website and services, improving our services, and identifying usage trends.||As is necessary and proportionate in LPP’s legitimate interests (per Art. 6(1)(f) GDPR).|
|· To comply with legal obligations to which LPP is subject.||To comply with legal obligations to which LPP is subject (per Art. 6(1)(c) GDPR).|
|· To contact you in relation to our services, events, general news from LPP and other communications from LPP deemed to be of possible interest to you. Such correspondence will always include the facility to unsubscribe.||As is necessary and proportionate in LPP’s legitimate interests (per Art. 6(1)(f) GDPR).|
DISCLOSING PERSONAL DATA
From time to time, LPP may disclose personal data to third parties, or allow third parties to access personal data which we process (for example where a law enforcement agency or regulatory authority submits a valid request for access to personal data) and for the purposes of fraud prevention or investigation. We may also disclose personal data to LPP’s professional advisors, auditors, technology providers and service providers, such as third parties in connection with the operation and administration of the website.
INTERNATIONAL TRANSFERS OF PERSONAL DATA
From time to time, LPP may transfer personal data to countries outside the EEA which may not have the same or equivalent Data Protection Laws. If such transfer occurs, LPP will ensure that such processing of your personal data is in compliance with Data Protection Law and, in particular, that appropriate measures are in place such as entering into Model Contractual Clauses (as published by the European Commission) or ensuring that the recipient is Privacy Shield certified, if appropriate. For further information about these transfers and to request details of the safeguards in place, please contact us using the details in the “Contacting Us” section below.
Browser information collected on our website
As with any website operator, LPP analyzes our website logs to constantly improve the value of our website. We use an external service to provide real-time reporting to us and our authorized agents of browser accesses to our site. This reporting includes page views, unique views, unique visitors, repeat visitors, frequency of visits, and peak-volume traffic periods. We do not use this service to gather, request, record, require, collect or track any Internet users’ personally identifiable information.
Accessing and updating your personal data
LPP wants to ensure that your data is kept updated, so we do request that changes are notified to us. You have the right to request a copy of the personal data held by us about you and you also have the right to have such data corrected where it is inaccurate.
Data Protection Law also provides you with other rights in respect of your personal data, including: the right to erase your personal data (right to be forgotten), the right to restrict processing of your personal data; the right of data portability; the right of objection; and the right to object to any automated decision making.
These rights will be exercisable by you subject to limitations as provided for in Data Protection Law. To exercise any of these rights, please contact us using the details in the “Contacting Us” section below.
While you may make a complaint in respect of our compliance with Data Protection Law to the Irish Data Protection Commission, we request that you contact us in the first instance to give us the opportunity to address any concerns that you may have.
Retention of personal data
LPP will retain the information you have provided as long as you remain a member or as long as there is legitimate interest. If legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions, we may also retain some of your information for a limited period as required.
Like most websites, we gather statistical and analytical information collected on an aggregate basis of all visitors to our website. This non-personal data comprises information that cannot be used to identify or contact you.
We use anonymous session cookies (short-term cookies that disappear when you close your browser) to help you navigate the website and make the most of the features.
Should users wish to deny the use and saving of cookies from this website onto their computer’s hard drive, they should take necessary steps within their web browser’s security settings to block all cookies from this website and its external serving vendors.
We undertake to hold any personal data provided by you in confidence and in accordance with Data Protection Law. Accordingly, we have technical and organisational measures in place to protect personal data from unlawful or unauthorised destruction, loss, change, disclosure, acquisition or access. Personal data is held securely using a range of security measures including, as appropriate, physical measures, IT measures and restricted access through approvals and passwords.
The GDPR obliges LPP acting as data controller to notify the Data Protection Commission and affected data subjects in the case of certain types of personal data security breaches. Any personal data security breaches identified in respect of personal data controlled by LPP will be dealt with in accordance with Data Protection Law.
The nature of the internet is such that there is no guarantee or warranty in relation to the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be totally secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
Links to external websites
Some sections of the LPP website provides links to external websites. These are clearly identifiable as such. Such websites are subject to their own privacy policies and we are not responsible for the content or the privacy policies of these third-party websites.