PRIVACY POLICY

1.1 Under GDPR, the main grounds that we rely upon in order to process your Information are the following:

1. a) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your Information. We may also be obliged by law to disclose your Information to a regulatory body or law enforcement agency;
2. b) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your Information for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your Information protected. Our legitimate interests include responding to requests and enquiries from you or a third party, the delivery/implementation of our services, optimising our website and customer experience, informing you about our services and ensuring that our operations are conducted in an appropriate, fair and efficient manner;
3. c) Consent – in some circumstances, we may ask for your consent to process your Information in a particular way.

2.1 CMLS is a business to business services company only and collects limited amounts of personally identifiable information (PII). We do not offer our logistic services to private individuals, only businesses. As such, we only securely collect, process or store Information from owners/employees of businesses or individuals operating as limited companies in a business capacity. CMLS only collects Information necessary for our services to function or to provide the delivery, administration or statistical analysis of services our customers have requested or for enabling quotations to potential customers.
2.2 We have a policy of limited usage or retention of paper-based materials. Most dates worked with are stored in electronic format, with the exception of hardcopy customer contracts, invoicing and company admin records (e.g. staff contracts, CV’s etc.).
2.3 We classify the data we hold under the following categories:

1. a) Existing Paying CMLS Customers:
   For paying customers of CMLS we may store any business/company or employee data submitted to us for use in the fulfilment or billing of our services. Data would typically be limited to contact full names, company name, email address(es), phone number(s), mobile number(s), materials, including but not limited to any communication emails, website/server login details, strategic business information, notes on phone calls or meetings, or contact details provided of other individuals involved in the quotation purposes.
   CMLS may provide a range of logistics services, which allow a customer to provide a website, store database information, and host their email accounts on shared servers (Servers that share resources with other customers). The responsibility for securing the data is therefore shared between CMLS and the customer as detailed in Section 9.
   Some CMLS customers may store personal information from their customers or website users on our web or server space. This customer data is processed by CMLS in a hosting only capacity or per the instructions of our customer. We accept no responsibility for our customers’ use of this data, how they request that we handle this data, nor do we monitor their usage of this data apart from a server resource capacity/performance point of view. The types of data customers collect varies greatly (including ……. ). We encourage customers who have specific questions or requests relating to GDPR compliance to contact us at privacy@cmls.ie.
2. b) Past CMLS Customers:
   Following then end of a customer relationship, we may retain certain customer detail for a period of 6 years to ensure compliance with tax requirements. Customer website data will be fully deleted from our servers within 90 days of the customer leaving (or earlier if requested).
3. c) Non-CMLS Customers Seeking Quotations: Where owners or employees of businesses seek quotes for our services, we request and securely store the person’s full name, company name, email address(es), phone number(s), mobile number(s), and details of the service request. For quotation purposes, we may also securely store materials, including but not limited to any subsequent communication emails, strategic business information, notes on phone calls or meetings, or contact details provided of other individuals involved in the quotation purposes.
4. d) Subscribers to CMLS’s Email Newsletter:
   Our email newsletter subscription asks for your first name, last name and email address. Typically our newsletters will only use your email address, but may be personalised with your name.

3.1 You may provide us with Information in a number of ways:

1. a) by visiting CMLS.ie’s contact form you may provide us with personal information such as name, company name, email address, phone/ mobile phone number and possible additional information if you choose to do so in the comments box.
2. b) by corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses;
3. c) in phone calls or meetings with CMLS staff where related notes may be securely stored;
4. d) through our mailing list opt-in where we request your name and email address.

3.2 We may collect Information about your computer, including where available your IP address, operating system, browser type and the geographical location of your computer, for system administration, prevention of fraud or business lead identification purposes. We also use statistical and user behaviour analysis software (Google Analytics, userTrack…) to get a better idea of how to improve user experience on our website. We may also report aggregate information. This is statistical data about browsing actions and patterns and does not identify you as an individual. In all cases, the suppliers of these products have stated their GDPR compliance.

4.1 We will hold, use and disclose your Information for our legitimate business purposes including:

1. a) answering or dealing with the purpose of the query, or implementation/quotation for the service(s) requested and any follow-on service or product dealings in the event of a customer.
2. b) emails and postal communication related to billing of our services;
3. c) direct marketing to keep you up to date about important changes to our business; product or service interruptions/outages/updates, product upgrades, or useful product, service, case study, or digital marketing information, research, tips or advice which may help our customers businesses. These communications may also include details of our services, advise you of news and industry, product or company updates, events, promotions or competitions. Before we do so, you will be given an option to opt-out of such communications and an option to unsubscribe will also be provided with each communication;
4. d) to apply profiling technology which analyses our customers’ engagement with our direct marketing communications, activity and interests so that we can send you content that is relevant to you;
5. e) to provide further services to you by sharing your Information trusted GDPR compliant third parties who we use in the provision of our services.
6. f) to release Information to regulatory or law enforcement agencies if we are required or permitted to do so.

4.2 We do not process or hold certain sensitive personal data (known as special category data in GDPR) where you include it in the information you send to us e.g. if you include information about your health in enquiries. We have processes in place to limit our use and disclosure of such sensitive data other than where permitted by law.

5.1 In certain circumstances we will share your Information. Details of those parties are set out below along with the reasons for sharing it.

1. a) Employees: We may disclose your personal data to our employees on a need to know basis. Our employees sign confidentiality agreements on commencement of employment.
2. b) Trusted third party partners: In order to provide certain services, we may share your information with reputable and trusted third party business partners, suppliers and sub-contractors such as IT, hosting, backup, CRM, business productivity, security, billing, phone, network, email logistics providers or data centre infrastructure companies (e.g. Sungard Availability Services, Gmail). For security reasons, we will not publish a full list here to minimise targeting of data within these businesses. We can supply a list of such partners upon request. We will not share your data with any third party if it is not a necessity in providing services to you or where the third party does not clearly state their own GDPR compliance policies either publically or within a direct contract with CMLS.
3. c) Regulatory and law enforcement agencies: As noted above, if we receive a request from a regulatory body or law enforcement agency, and if permitted under GDPR and other laws, we may disclose certain personal information to such bodies or agencies.
4. d) New business owners: If we or our business merges with or is acquired by another business or company, we will share your personal information with the new owners of the business or company and their advisors. If this happens, you will be sent notice of such event and you will be afforded an opportunity to opt-out.
5. e) Aggregated and De-Identified Information: We may share information that has been aggregated or reasonably de-identified so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our services.

We use cloud-based services where personal data may be processed for the purposes of providing our services to you and this may require the transfer of this data outside of the EEA e.g. Gmail.
Where personal data is transferred outside of the EEA, your rights as a data subject are protected by data transfer mechanisms such as Standard Contractual Clauses and EU/US Privacy Shield and we have only chosen suppliers who have stated their GDPR compliance.

We will only retain your Information for as long as is necessary for the purpose or purposes for which we have collected it. The criteria that we use to determine retention periods is determined by the nature of the data and the purposes for which it is kept. For example, if we receive your Information through a competition entry, we will retain your data for as long as is necessary to administer the competition. If we receive your Information when you apply for a job, we will retain your data for as long as is necessary to process your application, and maintain application statistics. If we receive your Information following a request for assistance, information or quotation for our products or services, we will retain your data for as long as is necessary to process your request or generate a quotation and for as long as you are a sale prospect (i.e. have not communicated your intention not to engage with CMLS). We will also maintain your data for statistics related to business lead activity and quotations. If you are a CMLS customer we will retain your data for the full duration of the period we provide you with our products or services and for a period of 6 years after the end of the customer relationship thereafter to ensure compliance with tax requirements. Customer website data will be fully deleted from our servers within 90 days of the customer leaving (or earlier if requested). For non-customers, we will not directly market to you for longer than five (5) years, unless you consent to receive direct marketing by opting in again before the expiry of that five (5) year period. In certain circumstances, once we have deleted or anonymised your data, we may need to retain parts of it (for example, your email address), in order to comply with our obligations under GDPR or other legislation, or for fraud detection purposes.

We use reasonable technical and organisational security measures to protect your data and to prevent the loss, misuse or unauthorised alteration of any data in our control and will use our reasonable endeavours to ensure that such information is kept as secure as possible.
Customer requests sent to CMLS will only be acted upon if the request is from an authorised customer contact listed in our CRM. For security reasons, customer requests must be submitted to privacy@cmls.ie from an authorised email address. Requests will not be acted upon over the phone.

The nature of the Internet is such that no business can guarantee or warrant the security of any server or web application, especially as the underlying technology will be provided by third parties or upon open source software. We will however take all reasonable steps and organisational measures to protect servers and data through appropriate schedule server patching routines and server / network access controls.

10.1 You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.

1. a) Right of Access. You have the right at any time to ask us for a copy of the Information about you that we hold, and to confirm the nature of the Information and how it is used. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
2. b) Right of Correction or Completion. If Information we hold about you is not accurate, or is out of date or incomplete, and requires amendment or correction you have a right to have the data rectified, updated or completed. You can let us know by contacting us at the address or email address set out above.
3. c) Right of Erasure. In certain circumstances, you have the right to request that Information we hold about you is erased e.g. if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based on your consent and there are no other legal grounds on which we may process the Information.
4. d) Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Information by contacting us at the address or email address set out above. For example, if we are processing your Information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your Information for direct marketing purposes.
   You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.
5. e) Right of Data Portability. In certain instances, you have a right to receive any Information that we hold about you in a structured, commonly used and machine-readable format. You can ask us to transmit that Information to you or directly to a third party organisation.
   This right exists in respect of Information that:
   
   • you have provided to us previously; and
   • is processed by us using automated means.
   While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to Information of others without their consent.

10.2 You can exercise any of the above rights by contacting us at the address or e-mail address set out above. You can exercise your rights free of charge. In making any request in this regard, please provide us with sufficient information to enable us to identify you. We reserve the right to request you to provide additional information in order to enable us to identify your personal data and/or to verify your identity.
10.3 We must provide the data request for free unless the request is manifestly unfounded, excessive or repetitive. In these cases, we charge a reasonable fee not exceeding € 6.35 for handling your request. In certain cases, we may refuse your request and will advise you at the time if this is the case. We will respond to your query as quickly as possible and within 30 days of receipt of your request.
10.4 Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.

To the extent that we are processing your Information based on your consent, you have the right to withdraw your consent at any time. You can do this by unsubscribing via the link provided in any direct marketing communication, or contacting us at the address or email address set out above.

12.1 Similar to other commercial websites, our Website “cookies” and web server logs to collect information about how our Website is used. A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org
12.2 Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our Website, and the websites visited just before and just after our Website.
12.3 Cookies, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our Website and which parts of the website are most popular. This helps us gather feedback so that we can improve our Website and better serve our customers. Cookies do not allow us to gather any Personal Information about you and we do not generally store any Personal Information that you provided to us in your cookies.
12.4 We use ‘session’ cookies which enable you to carry information across pages of the Website and avoid having to re-enter information. Session cookies enable us to compile statistics that help us to understand how the Website is being used and to improve its structure.
12.5 We also use ‘persistent’ cookies which remain in the cookies file of your browser for longer and help us to recognise you as a unique visitor to the Website, tailoring the content of certain areas of the Website to offer you content that matches your preferred interests.

This privacy policy can be changed by us at any time. If we change our privacy policy in the future, we will advise you of material changes or updates to our privacy policy by e-mail, where we are holding your e-mail address.

You can request a copy of what data we have on record for you or request any changes to that data by emailing privacy@cmls.ie and we will respond to your query as quickly as possible but in any event within 30 days of receipt of your request.
Customers can update stored recorded billing contact or payment details by contacting us at privacy@cmls.ie.