Protecting your data and privacy is one of our fundamental responsibilities as a company to ensure that we protect the information entrusted to us by you. This Privacy Notice looks to answer your important questions about the processing of personal information by Neopost. Please take some time to read this Privacy Notice carefully.
This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively you can download a pdf version of the policy at the bottom of this page. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Notice.
- IMPORTANT INFORMATION AND WHO WE ARE
- CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1.1 Purpose of this Privacy Notice
(a) This Privacy Notice aims to give you information on how we collect and process your personal data, including any data you may provide through this website when you use our online ordering facility (eShop), sign up to our newsletter, purchase a product or service, submit a query or use other online services (MyNeopost);
(b) This website is not intended for children and we do not knowingly collect data relating to children.
(c) It is important that you read this Privacy Notice together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them
(a) This Privacy Notice is issued on behalf of Neopost Ireland of Unit 16, Fonthill Retail and Industrial Park Fonthill Road, Dublin 22. Which is the controller and responsible for this website.
(b) If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact firstname.lastname@example.org
(c) You have the right to make a complaint at any time to the Office of the Data Protection Commission (“ODPC”), the Irish supervisory authority for data protection issues at email@example.com. We would, however, appreciate the chance to deal with your concerns before you approach the ODPC so please contact us in the first instance.
The data protection law in Europe will change on 25 May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.1 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
3.1 Types of Data
(a) Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
(b) We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(i) Identity Data includes first name, last name, username or similar identifier, and title.
(ii) Contact Data includes billing address, email address and telephone numbers.
(iii) Financial Data includes bank account and payment card details.
(iv) Transaction Data includes details about payments to and from you and other details or other offers you have purchased from us.
(v) Technical Data includes internet protocol (IP) address, your login data and other data on the devices you use to access this website.
(vi) Usage Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(vii) Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
(c) We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
(d) Aggregated Data and Google Analytics
Neopost uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics does not gather or process any personal information – names, company names, email addresses, IP addresses, phone numbers, fax numbers, or company addresses. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data.
The data collection and storage can be contradicted at any time with effect for the future. For more information about the Google Analytics Terms of Service, please click here.
We may make non-personal information available to third parties, such as the number of unique visitors to our website or the typical motions visitors go through when visiting our website.
(e) We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3.2 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, providing you with supplies or services regarding a franking machine).
We use different methods to collect data from and about you including through:
4.1 Direct interactions. You may give us your Identity, Contact and Financial Data filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
(a) use the eShop;
(b) use MyNeopost;
(c) create an account on our website;
(d) subscribe to our publications;
(e) request marketing to be sent to you;
(f) enter a competition, promotion or survey;
(g) Submit a CV or apply for a job via our website;
(h) give us some feedback; or
(i) submit a query through the Contact Us form.
(j) Call regarding a quote, product or service
4.2 Automated technologies or interactions.
4.3 Third parties or publicly available sources.
We may receive personal data about you from various third parties as set out below:
(a) Technical Data from the following parties:
(i) analytics providers such as Google and Lead Forensics;
(ii) advertising networks such as Google
(iii) search information providers such as Google, Bing and Yahoo;
(b) Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
4.4 How do we protect your data?
We use internal and organisational measures to protect your personal information from unauthorised access, to maintain data accuracy and to help ensure the appropriate use of your personal information. Our CRM is password protected, as are our computers and laptops. While we can assist you in updating passwords we cannot view your existing ones as they are not stored on our systems.
5.1 Lawful basis
(a) We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances where:
(i) we need to perform the contract we are about to enter into or have entered into with you;
(ii) it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
(iii) where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data and communicating with you. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org
Purposes for which we will use your personal data
(a) We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
(b) Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
5.3 General marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms set out in paragraphs 4.4 – 4.8.
5.4 Promotional offers from us
(a) We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from Neopost.
if you have requested information,
received a product or service,
provided us with your details when you enquired about a product, quote, service
registered for a promotion
And, in each case, you have not opted out of receiving that marketing.
You may also receive marketing material if you are on a list that has been lawfully acquired by Neopost or your information has been referred to us by a third party or colleague.
5.5 Third-party marketing
Neopost does not share your data with third-parties to carry out their own marketing. Should this ever change we will get your express opt-in consent before we share your personal data with any company outside Neopost for marketing purposes.
5.6 Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at firstname.lastname@example.org You can also unsubscribe to our newsletter the same way, or by selecting unsubscribe on the newsletter itself.
5.8 Change of purpose
(a) We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com
(b) If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
(c) Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6.1 We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
(a) Internal Third Parties as set out in the Glossary;
(b) External Third Parties as set out in the Glossary;
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets; alternatively, we may seek to acquire other businesses or merge with them; if a change happens to our business, then the new owners or newly acquired businesses may use your personal data in the same way as set out in this Privacy Notice.
5.2 Neopost sometimes shares your personal information with trusted third parties who perform important functions for us based on our instructions and applying appropriate confidentiality and security measures. For example, we use third party service providers to print personalised marketing material on a product or service you may be interested in.
5.3 We require all third parties to sign a non-disclosure agreement and respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions Neopost do not sell lists of data to third parties or third countries unless we are required to do so by law or any court order.
7.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
7.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority or other regulator of a breach where we are legally required to do so.
8.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
8.2 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.
8.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legal purposes.
8.4 In some circumstances you can ask us to delete your data: see below for further information.
8.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data. This privacy notice explains most of these points, contact firstname.lastname@example.org for further information on the below:
(a) Request access to your personal data.
(b) Request correction of your personal data.
(c) Request erasure of your personal data.
(d) Object to processing of your personal data.
(e) Request restriction of processing your personal data.
(f) Request transfer of your personal data.
(g) Right to withdraw consent.
9.2 If you wish to exercise any of the rights set out above, please contact us at email@example.com
9.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
9.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
9.5 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10.1 Lawful Basis
(a) Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best offering and the best and most secure experience; we make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests; we do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law); you can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org
(b) Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
(c) Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
10.2 Third Parties
(a) Internal Third Parties
Other companies in the Neopost Group based in the EEA that provide IT and system administration services and marketing services to the Neopost Group.(b0
(b) External Third Parties
(i) service providers based in Ireland who provide IT and system administration services;
(ii) professional advisers acting as processors or controllers including lawyers, bankers, auditors and insurers based in the EEA who provide consultancy, banking, legal, insurance and accounting services; and
(iii) ODPC, regulators and other authorities acting as processors or joint controllers based in Ireland who require reporting of processing activities in certain circumstances.
11 Your Legal Rights
You have the right to:
Request access: to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction: of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure: of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing: of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have a compelling legitimate ground to process your information which overrides your rights and freedoms.
Request restriction of processing: of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer: of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time: where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain offerings to you. We will advise you if this is the case at the time you withdraw your consent
22 May 2018