1. What’s in this policy?

This privacy policy sets out how Ingenium Training and Consulting Limited (“Ingenium”) processes your personal information when you engage with us.

This policy covers a wide range of data subjects including service users, clients and external third party consultants and suppliers. It also applies to prospective service users, clients and external third party consultants and suppliers (“Users” or you/your).

We are required by data protection law i.e. the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Data Protection Acts 1988-2018 to advise you of the information set out in this privacy policy.

This policy should be read along with our cookie policy which can be found here, or our data protection policy which can be found here.

This policy applies regardless of how your personal information is collected by Ingenium for e.g. via our website (https://www.safechoicesafety.com/), by telephone, by CCTV (if and when you attend at our premises at No. 68 O’Connell Street, Limerick, Ireland (“the Premises”)), or otherwise.

2. Who we are and how to contact us

  1. Ingenium is a company registered in Ireland and for the purpose of data protection law, is a controller of Users personal information.
  2. Any further information or queries in relation to this policy, to include how your information is handled by Ingenium, should be directed to Alan Higgins at alan.higgins@ingeniumtc.com.

3. Information we collect from you

Ingenium will collect and process the following personal information about its Users:

  1. Information you provide to us directly which may include your name, address, email address, date of birth, contact number, personal image data, employment details and education history.
  2. Information provided about you by third parties for e.g. your employer, internal/external consultants or third party referees, which may include any/all of the information set out at 3.1 above.
  3. Each time you visit our website, and subject to our cookie policy, we will automatically collect the following technical information:
    1. The pseudonymised internet protocol (IP) address (i.e. an address which doesn’t immediately allow us to identify any individual but which may identify your location) used to connect your computer to the internet, your login information, browser name, type and version, time zone setting, language, browser plug-in types and versions, operating system and platform;
    2. information about your visit including the full Uniform Resource Locators (URL), the title of the page you are viewing, clickstream to, through and from the Site (including date and time), properties you viewed and/or searched for, type of device being used to visit the page and its operating system, page response times, download errors, length of visits to certain pages, how the page was found, page interaction information (such as scrolling, clicks, screen resolution, level of engagement and mouse-overs), methods used to browse away from the page and whether or not a user has Javascript technology enable;
    3. Subject to your preferences and any other features you might opt in to, such as advertisement personalisation, other technical information about your visit to the Site may be collected by Google Analytics, further information of which can be found here; and
    4. Cookies in line with our cookie policy.
  4. Each time you attend at the Premises, your personal image and/or voice recording data via our CCTV cameras.

4. Purposes for which we collect your information

Ingenium will process the personal information outlined at section 3 above, for the following purposes:-

  1. On the basis of your consent:-
    • to provide you with information that you have requested from us;
    • to sign you up for any of our products and/or services;
    • to respond to issues or queries raised by you;
    • to engage in certain, electronic marketing practices with you (other than those for which we have a legitimate interest as outlined in clause 4.1.3).
  2. In certain circumstances, to carry out our obligations arising from any contract(s) entered into between you and Ingenium for e.g. to provide a product or contracted service to you;
  3. On the basis that we have a legitimate interest in carrying out our day to day business, to use third party data processors to carry out certain functions on our behalf and to provide software applications to us, to engage in certain, limited forms of electronic marketing to existing clients/customers (which otherwise comply with Regulation 13(11) of the ePrivacy Regulations), to receive business referrals from third parties, to otherwise try and enhance our business etc.;
  4. On the basis that we have a legitimate interest in ensuring the security of our business, to engage in CCTV monitoring at the Premises;
  5. To comply with any statutory obligations to which Ingenium is subject; and
  6. In relation to the information referred to at paragraph 3.3 above, to administer our website, for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes, to improve the website and to ensure that content is presented in the most effective manner for you and for your computer and to do our best to keep the website safe and secure. Ingenium relies on its legitimate interests to process this information.

5. Disclosure of your information to third parties

  1. Ingenium does not share your personal information with any unauthorised third parties. In certain circumstances however, in order to carry out our day to day business activities, it might be necessary to share the personal information you provide to us with limited third parties, including:
    1. Your employer where they put through you through one of our courses, or where you engage with us on behalf of your employer;
    2. External advisers, consultants and/or third party service providers for example IT support companies/technicians, software providers, shredding companies, mailing companies and/or researchers who carry out projects for Ingenium or who are instructed on behalf of Ingenium.
    3. Google Analytics for the purposes outlined at paragraph 4.1.6. of this Policy.
  2. In those instances where we are required to share your personal information as set out at paragraph 5.1 above, we will ensure that we comply with data protection law in respect of such sharing i.e. a contract will be in place with the relevant third party so as to try and ensure the onward protection and security of your personal information when it is in the hands of a third party and to prevent any unlawful use of your information by that party.
  3. In certain, unlikely circumstances Ingenium may be required to disclose or share your personal information in order to comply with a legal or statutory obligation, in order to enforce other agreements or to protect the privacy rights of individuals (to include you/your parent or legal guardian). This may require the sharing of your personal information with third parties such as the Data Protection Commission, An Garda Siochána and/or our legal advisors or insurers.
  4. Where Ingenium obtains your personal information from third parties such as your employer or a third party referee, it presumes the said party has a lawful basis to transfer your personal information to Ingenium and Ingenium accepts no liability for the lawfulness or otherwise of such transfers.

6. How long we retain your information

  1. Ingenium will generally only retain your personal data for as long as necessary to fulfil the purposes for which it was collected.
  2. The technical data referred to at paragraph 3.3 of this Policy and processed by Google Analytics will be processed for a minimum of 2 months and a maximum of 14 months, after which time it will be automatically deleted
  3. Personal image data will generally only be retained for a maximum of one month unless an incident has occurred on the Premises, which warrants its retention beyond this timeframe.
  4. In some limited circumstances it may be necessary to retain your personal information for longer than the purpose for which it was collected for e.g. to comply with a relevant legal requirement or where we believe it is necessary to retain the information for longer for example to allow us to defend or pursue a legal claim.
  5. We will securely delete your personal information when it is no longer required.

7. Transfers outside the European Economic Area (“EEA”)

  1. Ingenium will generally not process your personal information outside the EEA.
  2. An exception to this is where you engage with and create an account (which requires a name and email address) on our learning management system, which is hosted via Docebo. Docebo’s privacy policy can be found here https://www.docebo.com/docebo-privacy-policy/.
  3. Where we do process your personal information outside the EEA, we will ensure that such transfer is in compliance with data protection law i.e. that it is either to a country which has been deemed safe by the European Commission due to the standard of that country’s privacy laws or by way of a contract adopting standard clauses which have been prepared by the European Commission for the purposes of protecting personal data outside the EEA.

8. Your rights

  1. Subject to limited exceptions, you have a number of rights in relation to your personal information:
    1. The right to information about what data or personal information we hold about you;
    2. The right to a copy of all data we hold about you either by way of a data access request or, in a machine readable format, by way of a data portability request;
    3. The right to object to Ingenium’s processing of your data;
    4. The right to request that your personal information be erased or restricted from further use;
    5. The right to correct, amend or update information you have given us;
    6. In circumstances where we process your personal information on the basis of your consent, you have the right to withdraw this consent at any time.
    7. To exercise any of the above rights please contact Alan Higgins at the following email address alan.higgins@ingeniumtc.com. Please note that whilst we will carefully assess every request we receive we may not always have to comply. When this happens, we will explain why.

9. Queries/Complaints

  1. If you have any questions about the contents of this policy or if you are not happy with the way Ingenium handle/have handled your personal information or have dealt with a rights request, please let us know by emailing alan.higgins@ingeniumtc.com.
  2. If you are not satisfied with the response you receive from us you also have a right to complain to the Data Protection Commission of Ireland via their website https://www.dataprotection.ie/

10. Changes to this policy

Any changes we make to this policy in the future will be posted on this page and we ask you to check back frequently to see any updates or changes.