Data Protection – Privacy Policy

Privacy Policy for The Bill Moss Partnership Limited

Last Updated 30/01/2024

This Privacy Policy covers the processing of personal data by The Bill Moss Partnership Limited (“The Bill Moss Partnership Limited”, “we”, “us” or “our” in this policy) when providing its services to its clients. If you have any questions or comments about this Privacy Policy, please contact us at:

Data Protection Co-Ordinator, The Bill Moss Partnership Limited, 24/26 Bridge Street, Ringsend, Dublin 4, Ireland.

The Bill Moss Partnership Limited is committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal data we collect from you or from public sources or third parties will be processed by us. Where we decide the purpose or means for which this personal data is processed, we are the “data controller.” We will comply with all applicable data protection laws, including; the General Data Protection Regulation 2016/679 (“GDPR). You have the right to object to us processing your personal data for direct marketing purposes. Please see paragraph 7 below for more details on how to do this.

Processing activities related to creation, development and maintenance of, and supply of data from The Bill Moss Partnership Limited database, are controlled by The Bill Moss Partnership Limited.

This Privacy Policy explains the following:

· What personal data we may collect about you;

· Why our processing is lawful;

· Who we may share your information with;

· How we will use that information;

· Who we may disclose that information to; and

· Your rights regarding the information.

· What information will The Bill Moss Partnership Limited collect about me?

We collect and process the following data, which may include your personal data.

The Bill Moss Partnership Limited’s Website

If you contact us about our services or request a demo on our website, the forms you complete or the emails you send may include information about you, such as your full name, your email address, the organisation on behalf of whom you are contacting us and your enquiry.

Analytics on the Website: Our website uses cookies and other mechanisms to collect and log analytical information, to help analyse use, to compile statistical reports on use of our website and to improve our website and marketing.

This site uses cookies, these are small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

 

Cookies

We use a number of different cookies on our site and we operate an ‘implied consent’ policy, meaning that we assume you are happy with this usage. This can be changed by disabling or deleting the cookies, or using your browser’s anonymous usage setting (e.g. “Incognito Mode” in Google Chrome).

For further information on how to manage and opt-out of cookies please visit: http://www.aboutcookies.org/Default.aspx?page=1

First Party Cookies: These cookies are set by this website directly and include web analytics tools like Google Analytics which are used to collect anonymous information about how users browse the site. This cannot be used to identify personal information (e.g. name or address).

Certain cookies are deemed strictly necessary to the working of the website. For brochure sites and ecommerce sites a session cookie is necessary for remembering your log-in for you, whether you are a registered user or not or remembering what has been put in the shopping basket. If this cookie is disabled it will disrupt the functionality on the site.

Third Party Cookies: These cookies are set on your machine by external websites whose services are used on this site. Cookies of this type include the social network content sharing buttons across the site (e.g. Youtube and Facebook). To facilitate the implementation of these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of our website which we do not control and cannot access. You should check the third party websites for more information about these cookies.

The following data may be collected:

· number of visitors to our website;

· pages visited while at the website and time spent per page;

· page interaction information, such as scrolling, clicks and browsing methods;

· websites where visitors have come from and where they go afterwards;

· page response times and any download errors; and

· other technical information relating to end user device, such as IP address or browser plug-in.

Naturally, if you are not happy with this Website Privacy Policy you should not use this website. By visiting this website, you are accepting the terms of this Website Privacy Policy. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy policies of these other websites.

The Bill Moss Partnership Limited Database

The Bill Moss Partnership Limited gathers current and historic business contact data.

The Bill Moss Partnership Limited collects business contact and similar information related to individuals when they are acting in their professional or employment capacity. The Bill Moss Partnership Limited then uses this information to create professional profiles of individuals and profiles of businesses. We provide this information to our clients, who are businesses trying to reach business professionals for their own business-to-business activities. The data collected about individuals on The Bill Moss Partnership Limited Database comprises:

· Name;

· Employer Company & Company Details (including alias);

· Office Location (including City);

· Business Telephone Number;

· Business Email Address;

· Job Title;

· LinkedIn URL

We also hold data in respect of your employer company such as its Company Registration Number, registered name, trading name, trading address, registered address, social media account links, size, employee numbers, year of formation, website and industry. Where you have moved jobs, we may hold your previous employers and previous titles.

The majority of the personal data we collect about you comes from publicly available sources such as from company websites, open source government data sources and trusted third party partners.

The Bill Moss Partnership Limited does not seek to collect any non-business-related data for The Bill Moss Partnership Limited Database such as date of birth, home address, personal email or home telephone number and The Bill Moss Partnership Limited does not collect sensitive personal data.

Anyone added to The Bill Moss Partnership Limited database may request to be removed at any time, via email or online web form. We will fulfil such requests as promptly as we can, and in any event within any time period that may be required by applicable law.

Controller and Processor

3.1 When The Bill Moss Partnership Limited is a Controller

The Bill Moss Partnership Limited acts as a data controller when we collect and use information about data subjects who are visitors to our website, as well as when we collect and use information about data subjects for purposes of creating and maintaining our database and providing the services.

 

3.2 When The Bill Moss Partnership Limited is a Processor

When our clients use our services, they are acting as the data controller and are responsible for ensuring that personal information collected about data subjects is being processed lawfully. In those circumstances, we are acting as the data processor, and receive personal information as agents of our clients merely for processing as instructed by our clients. Our clients are solely responsible for determining whether and how they wish to use our services, and for ensuring that all third-party individuals that are a visitor to or user of a website, or service on which a client uses our services have been provided with adequate notice regarding the processing of their personal information, have given informed consent where such consent is necessary or advised, and that all legal requirements applicable to the collection, use, or other processing of personal information through our services have been met by such clients. Our clients are also responsible for handling data subject rights requests under applicable law, by their users and other individuals whose data they process through the services. The Bill Moss Partnership Limited’s obligations with respect to personal information for which we are solely a data processor are

defined in our agreements with our clients and are not covered by this Policy. In certain circumstances,

Grounds of Processing

4.1 Consent

On some occasions, The Bill Moss Partnership Limited processes your data with your consent. Your consent may be obtained by third parties on The Bill Moss Partnership Limited’s behalf. You have the right to withdraw such consent at any time and we will cease to process data after consent is withdrawn.

4.2 Legitimate interest

The Bill Moss Partnership Limited processes your personal data when it is in our or our client’s legitimate interest and are not superseded by your rights. Our interests include maintaining an accurate B2B database of Irish business contacts, analysing the Irish business landscape and economy, providing precise business information enabling effective B2B communications, and supporting trade and business within Ireland.

4.3 Necessary because of a legal obligation

The Bill Moss Partnership Limited may process your data to comply with our legal and regulatory obligations e.g. preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.

4.4 Necessary to fulfil an obligation under a contract

The Bill Moss Partnership Limited may process your data where we have a contract with the individual and we need to process their personal data to comply with our obligations under the contract.

Data Sharing

We will share your information with the following:

5.1 Our company

Access to personal data within The Bill Moss Partnership Limited is restricted to those individuals who have a need to access the information for our business purposes.

5.2 The Bill Moss Partnership Limited clients

We may share personal data with our clients as part of the offering of our services. The Bill Moss Partnership Limited clients may use the data to contact individuals on their business telephone, at their business email address, through other electronic mail or through targeted display ads on social networks in order to market products and/or services.

By remaining in our database, you may be contacted by our clients when they are conducting their business-to-business activities. Communications you receive from our clients may be relevant to your profession or employment role, but we cannot guarantee that you will find such communications to be relevant or of interest to you.

Please note that in making available the data to its clients, The Bill Moss Partnership Limited is at times processing such data as a processor on behalf of the client, who is acting as the controller.

Clients will act as controllers and have their own privacy policies and opt-out options, and we recommend you review them. Where The Bill Moss Partnership Limited has made personal data available to its clients, the client privacy policy should list The Bill Moss Partnership Limited as a data source.

5.3 Suppliers, subcontractors, service providers

We keep your information confidential, but may disclose it to suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this privacy policy. However, this is on the basis that they have agreed to safeguard this information.

This includes external third-party service providers, such as accountants, auditors, experts, lawyers and other outside professional advisors; IT systems, support and hosting service providers; technical engineers; data storage and cloud providers and similar third-party vendors and outsourced service providers that assist us in carrying out business activities.

5.4 Government authorities

In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

5.5 Potential sale, acquirers or investors

We reserve the right to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Website Privacy Policy and provided that the third party only uses your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.

6. How we will use information we collect about you

The Bill Moss Partnership Limited Website: We may process your personal data for the following purposes:

· to deliver our services to our clients under the agreed terms of service;

· to process your enquiries to reply and provide support, including providing you and/or your organisation with information about the services The Bill Moss Partnership Limited offers;

· to consider persons for possible employment with The Bill Moss Partnership Limited, and communicate about employment opportunities or submitted employment applications;

· to keep you updated via our mailing list with information on news, offers, and updates about The Bill Moss Partnership Limited (see below for how to unsubscribe);

· to send technical notices, updates, security alerts, and support and administrative messages;

· to provide and maintain the website, and to compile reports on how visitors use The Bill Moss Partnership Limited website and improve the website;

· to conduct remarketing for The Bill Moss Partnership Limited, which allows us to show The Bill Moss Partnership Limited ads to people who’ve previously visited our website;

· to conduct advertising on social networks for The Bill Moss Partnership Limited, which means that if you link to one of our social media platforms you may be subject to targeted marketing displaying The Bill Moss Partnership Limited ads via that site.

· We work with the third-party advertising networks and social media platforms as set out in our cookie policy here. If you would like to find out more about the way these third parties collect and process your information, please refer to their respective privacy policies.

The Bill Moss Partnership Limited Database: We may use your personal data on The Bill Moss Partnership Limited Database for the following purposes:

· to provide, maintain and build our sales intelligence database to enable our clients or their customers to generate and manage sales leads in respect of businesses;

· to deliver, maintain and improve our services;

· to verify, cleanse, update and maintain information provided through our services;

· to enable our clients to enrich their existing customer relationship management records and receive timely updates of changes;

· to undertake research and compile statistical aggregated reports based on data held in The Bill Moss Partnership Limited’s sales intelligence database (which may include inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners or clients may use to provide and improve our respective services;

· to run our own marketing campaigns and promote our services.

General:

We also process personal data to comply with our necessary legal and regulatory obligations. These include preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies, protecting the rights and property of The Bill Moss Partnership Limited and our clients, and responding to rights requests under applicable law.

If you send us objectionable content or otherwise behave in a disruptive manner when using our website, we may process personal data included in your messages to respond to and stop such behaviour. Where we reasonably believe you are or may be in breach of the law (for instance, because content you send amounts to harassment or is defamatory), we may use your personal data to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.

7. In the context of this Privacy Policy, it’s worth noting our utilisation of Hotjar. Hotjar is a technological tool that plays a crucial role in helping us gain deeper insights into our users’ preferences and improve our services by leveraging their feedback. Hotjar collects and safeguards user information within anonymised profiles, and it’s important to emphasize that Hotjar is strictly prohibited from selling any of this data on our behalf. For a more in-depth understanding, about Hotjar please click here.

 

8. Marketing Opt-Out Options

If you’d like to permanently erase your data from The Bill Moss Partnership Limited Database, please complete this form here or contact us using the above contact details. Please note that we need the information included in this form to be able to locate you in our database and action your request. The information provided will only be used to process and action your request. Your request will be processed in the shortest time possible and within the timeframes set forth in GDPR.

Where you receive a marketing email from us, and you would like to be removed from that mailing list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive from us.

9. Your rights in relation to personal data which we process relating to you

You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest.

To make a request, please contact us using the above contact details, addressed to the Data Protection Officer.

9.1 You have the right to request a copy of the personal data we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by applicable law to supply, correct or delete personal data held about you on our files (and with any third parties to whom it has been disclosed to).

9.2 Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

· you consented to The Bill Moss Partnership Limited processing the personal data, and have withdrawn that consent;

· The Bill Moss Partnership Limited no longer needs to process that personal data for the reason it was collected;

· The Bill Moss Partnership Limited is processing that personal data because it is in the public interest or in order to pursue a legitimate interest of The Bill Moss Partnership Limited, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;

· the personal data was unlawfully processed; or

· you need the personal data to be deleted in order to comply with a legal obligation.

9.3 Obtain a machine-readable copy of your personal data, which you can use with another service provider:

If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

If you request, The Bill Moss Partnership Limited will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

9.4 Updating, Verifying and Deleting Personal Data

You may inform us of any changes in your Personal Data, and in accordance with our obligations under the Data Protection Acts 1988 and 2002 we will update or delete your Personal Data accordingly. To find out what Personal Data we hold on you or to have your Personal Data updated, amended or removed from our database, please email us at lists@bill-moss.com

Any such data subject requests may be subject to the prescribed fee.

10. Data Retention

We will hold your personal data for as long as is necessary for the relevant purpose.

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.

11. Children

We do not knowingly solicit data from or market to children under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at lists@bill-moss.com. We will delete such information from our files within a reasonable time.

12. Security

The Bill Moss Partnership Limited is committed to keeping your personal data safe and secure from unauthorised access to or unauthorised alterations, disclosure or destruction of information that we hold. We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal data.

Our security measures include:

· regular review of information collection;

· encryption of our services and data;

· restricted access of data to employees, contractors and agents; and

· internal policies setting out our data security.

Please be aware that, your Personal Data is held on secure servers hosted by our Internet Service Provider. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.

13. Changes

Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Website Privacy policy, or otherwise disclosed to you at the time it was collected, we will notify you by email, and you will have a choice as to whether or not we use your information in the new manner.