Privacy Policy

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users.

1.2    This policy applies to any personal data collected or processed through our website.

2. How we collect and use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we collect and process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing of your personal data.

2.2    We use different methods to collect data from and about you including through:

1. Direct interactions. You may give us your identity, profile data, contact data and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our gift vouchers or when booking a table at our restaurant; enter a competition, promotion or survey; or give us some feedback.
2. Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and Google Analytics.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
4. Technical Data from the following parties:
5. Analytics providers such as Google based outside the EU;
6. Advertising networks [such as Google Adwords and Facebook based inside OR outside the EU;
7. Search information providers such as Google based inside OR outside the EU.
8. Contact, financial and transaction data from providers of technical, payment and delivery services such as our payment providers identified in section 4.4.

2.3    We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services and to offer you content tailored for your preferences.

2.4    We may process your account data (“account data“). The account data may include your name, postal address, delivery addresses, telephone number and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.5    We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, address, telephone number, email address. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.6    We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.7    We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent and our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.8    We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.

2.9    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website or other channels (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

2.10  We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.11  We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website and applications will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.12  We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.13  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

4. Providing your personal data to others

4.1    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.2    We may disclose your personal data to our suppliers or subcontractors insofar as reasonably necessary for the purposes of providing our services to you and for the completion of contracts entered into by you through our websites and applications. A full list of these suppliers or contracts can be obtained by contacting us directly.

4.3    Financial transactions relating to our website and services are handled by our payment services providers,  PayPal. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at their websites.

4.4    We may disclose your enquiry data and transaction data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can complete the service for which you have contracted. Each such third party will act as a data controller in relation to the enquiry data and transaction data that we supply to it;

4.5    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    The hosting facilities for our website are situated in Carlow, Ireland (Blacknight Solutions).

Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

5.3    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1    This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

6.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

6.3    Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7. Security of personal data

7.1    We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2    We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.

7.3    Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

7.5    You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

8. Amendments

8.1    We may update this policy from time to time by publishing a new version on our website.

8.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

8.3    We may notify you of changes to this policy by email.

9. Your rights

9.1    In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.2    Your principal rights under data protection law are:

(a)    the right to access;

(b)    the right to rectification;

(c)    the right to erasure;

(d)    the right to restrict processing;

(e)    the right to object to processing;

(f)    the right to data portability;

(g)    the right to complain to a supervisory authority; and

(h)    the right to withdraw consent.

10. Third party websites

10.1  Our website includes hyperlinks to, and details of, third party websites.

10.2  We have no control over, and are not responsible for, the privacy policies and practices of third parties.

11. Updating information

11.1  Please let us know if the personal information that we hold about you needs to be corrected or updated. See our details below.

12. Our details

12.1  This website is owned and operated by Eithna’s By The Sea. at The Harbour, Mullaghmore, Sligo. F91 FF24.

12.2  You can contact us:

(a)    by post to: Eithna’s By The Sea, The Harbour, Mullaghmore, Sligo. F91 FF24.

(b)    using our website contact form;

(c)    by telephone, on the contact number published on our website from time to time; or

(d)    by email, using the email address published on our website from time to time.

12. Data protection officer

Any enquiries regarding our data protection can be addressed to Eithna O Sullivan at info@bythesea.ie