Licences.ie, a service provided by An Post, a limited liability company with its registered office at General Post Office, O’Connell Street Lower, Dublin 1, D01 F5P2, with company number 98788 (“An Post”, “we” or “us”), will collect and process your Personal Data and other information relating to your interactions and dealings with An Post. This Privacy Statement explains how we will manage your Personal Data through your use of www.licences.ie (this “Website”) and, to the extent that you also choose to register and use the licences.ie integrated licence application service, which is made available on this Website (the “Service”), the Service including how and why we use it, and how you may contact us if you have a query about Personal Data that we hold about you. This Website is owned and operated by An Post. Where you use other An Post websites or obtain specific products and services, separate privacy statements may apply.
Where we need to process your Personal Data in connection with your application for a product or service provided by the An Post Group, or where we have a legal obligation to collect certain Personal Data relating to you, we will not be able to provide you with the product or service which you have requested if you do not provide this information to us.
Personal Data means any information which An Post has or obtains or which you provide to us such as, where you register to use the Service and/or when you report a problem with our Website or Service, your name, email address, telephone number(s), and company name (to the extent that this contains Personal Data), from which you can be directly or indirectly personally identified, and may include information such as licences.ie account reference numbers, IP addresses and online identifiers, depending on the services which we provide to you and the manner in which we interact.
We may also collect certain statistical and other analytical information collected on an aggregate basis relating to all visitors to our Website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of our Website. We collect this information to help us monitor traffic and enhance your experience of our Website.
We will obtain some of your Personal Data directly from you, such as when you register to use the Service, complete an application form for one of our Services, where you enter your details into our online forms, send us or our customer care team a communication, or otherwise provide your details to us (for example at a conference) in order to receive information about our Service.
We may also obtain some of your information indirectly, from a variety of sources, such as from your spouse or family member; third party licencing authorities with whom you interact through the Service (the “Licencing Authority”) for the purposes of obtaining a licence, permit or certificate (a “Licence”) issued by the Licencing Authority; (where required by a Licencing Authority) sanctions checking databases, judgments databases and public registries such as the Companies Registration Office, and public directories such as the Institute of Public Administration.
We will use your Personal Data, but only to the extent necessary:
a) for the purposes of performing a contract you have entered into with An Post, such as:
(i) for the purposes of setting up and administering your licences.ie account;
(ii) to facilitate you in accessing your licences.ie account online in a secure manner where we have agreed to give you access to our online Service;
(iii) to carry out our obligations arising from any contracts entered into between you and us, which includes providing the Service to you when you register with us to use the Service;
(iv) to facilitate your application and payment for Licences issued by Licensing Authorities through use of the Service;
(v) to contact you if required in connection with, or to deal with queries, complaints or suggestions in relation to, the Service, and transactions on or relating to your accounts or following a period of inactivity to enquire whether you wish to keep your account open; and
(vi) to check and verify your identity in connection with your use of the Service;
b) where you have consented to our use for a particular purpose. If you do give your consent for us to use your Personal Data for a particular purpose, you have the right at any time to withdraw your consent to our future use of your Personal Data for some or all of those purposes by writing to us at the address set out under “Contact Us” below;
c) for compliance with our legal obligations, including:
(i) compliance with applicable tax and regulatory reporting obligations; and
(ii) where we are ordered to disclose information by a court with appropriate jurisdiction;
d) where our use is for a legitimate purpose of An Post, including:
(i) where we have agreed to give you access to the Service, continuing to provide you with access to the Service, including details of your previous use of the Service and content added to it by you, in order to facilitate future use by you of the Service. See Retention of your Personal Data
below for more information;
(ii) to notify you about changes to our Website and/or the Service;
(iii) for day to day operational and business purposes, including board and group reporting and management purposes;
(iv) for the purposes of managing our contracts and relationships with Licencing Authorities, our customers, suppliers, service providers, vendors and other commercial partners;
(v) taking advice from our external legal and other advisors;
(vi) to help us improve our services and systems, and to improve your experience on our Website and online services;
(vii) to prevent and detect security threats, fraud or any other malicious activity;
(viii) to undertake market research, statistical and product development analyses;
(ix) to ensure that content from our Website and Service is presented in the most effective manner for you and for your device. When you input Personal Data into a licences.ie online Licence application form, we may for your convenience, pre-populate certain fields in the Licence application form with information that you provided previously. You will always be able to change the pre-populated data before you submit the Licence application to a Licensing Authority. We may disable this pre-population feature at any time at our sole discretion;
(x) to provide you with information in relation to An Post Group products and services, as well as those of certain selected third parties, where we are permitted to do so (please see “Marketing Preferences”
below for further information);
(xi) to administer our Website and the Service and for internal operations, including troubleshooting, data analysis, testing, research and statistical and survey purposes;
(xii) as part of our efforts to keep our Website and the Service safe and secure; and
(xiii) to develop aggregated, anonymised information using information we collect about you and information you give us. We may use such aggregated and anonymised information for our own internal and external commercial purposes. This information will not identify specific individuals and will therefore not be Personal Data;
e) where necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and
f) for such other purposes as were notified to you at the time you provide the information to us.
We will not disclose your Personal Data except as outlined above and / or as follows:
a) where the disclosure is necessary to enable us to carry out our obligations under any agreement we have with you, including the provision of Personal Data required to process your Licence application to Licencing Authorities with whom you interact through the Service for the purposes of obtaining a Licence issued by the Licencing Authority;
b) to verify the authenticity of information provided to us (for example, we may use external databases and other address verification tools to verify a customer’s identity). In respect of applications for certain Licences, there may be a requirement on us to validate information supplied by you in advance of passing your application to the relevant Licensing Authority (for example, we may be required to validate any company registration number with the Companies Registration Office). In such circumstances, the information received from the third party source will be forwarded to the relevant Licensing Authority with your Licence application;
c) where we need to provide your Personal Data to counterparties to transactions entered into by you.
d) where you choose to pay Licence fees using Licences.ie and a debit or credit card, you will be transferred to the An Post payment page, which uses the services of third party payment processors (“Payment Processors”) to process your payment. An Post will process your payment information and related personal data solely for purposes of facilitating such payment and performing payment-related activities (eg, facilitating chargebacks).
e) where you use your licences.ie account to purchase a licence on behalf of a third party, we may, where required under applicable law, notify those individuals that you have provided their details to us;
f) to anyone providing a service to us or acting as our agents, which may include either other companies within the An Post Group or third party service providers, on the understanding that they will keep the Personal Data confidential;
g) where we need to share your Personal Data within the An Post Group or with our auditors, actuaries and our legal and other advisors; and
h) if the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators.
We will not otherwise share your Personal Data with any third party unless we receive your prior written consent to do so.
In certain circumstances, we act as a data processor for other organisations, such as Licencing Authorities.
Licensing Authorities may sometimes provide us with your Personal Data that we are required to display to you through the Service in connection with your application for a Licence. This may be Personal Data that you have previously provided to the relevant Licensing Authority or that they have obtained from another source. For example, you may have provided that personal data to the Licensing Authority when you applied for a Licence in the past.
Additionally, we may be instructed by a Licencing Authority to make a published register available. In that event, a subset of your Personal Data may be included on such published register. The type of register (public or restricted), the data to be displayed in it and the parties that may access it is determined by the Licensing Authority in accordance with its statutory powers. Licences.ie provides the technical functionality to Licensing Authorities to display such published registers. Licences.ie does not otherwise have control over the content of them. Requests for removal from or amendment to such published registers should be directed to the relevant Licensing Authority.
In each of the circumstances above, we act as a data processor of such Personal Data on behalf of the relevant Licensing Authority who is the data controller.
In cases where we are acting on behalf of a different data controller (such as a Licencing Authority), we will act only on their instructions in relation to processing your Personal Data. In these cases, it is that third party which is responsible to you for complying with your rights in relation to your Personal Data. If you send any request to us to exercise your rights, we will send it on to the data controller as soon as possible.
In any case where we are acting on our own behalf and we share your Personal Data with a third party data controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
Personal Data may be transferred outside of Ireland where necessary to provide our services to you, including for example where you have explicitly consented, and / or as otherwise required or permitted by law.
Many of the countries will be within the European Economic Area (the “EEA”), or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in Ireland.
However, some transfers may be to countries which do not have equivalent protections, and in that case An Post shall use reasonable efforts to implement contractual protections for your Personal Data. While this will not always be possible where we are required to transfer your Personal Data in order to comply with and perform our agreement(s) with you or where we have a legal obligation to do so, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.
Where you provide us with Personal Data relating to other people, such as your spouse, children, mail recipients (if you use the postal service or for the administration of postal services), partners, directors, officers, employees, advisors or other related persons, you represent and warrant that you will only do so in accordance with applicable data protection laws. You will ensure that before doing so, the individuals in question are made aware of the fact that we will hold information relating to them and that we may use it for any of the purposes set out in this Privacy Statement and the relevant terms and conditions, and where necessary you will obtain their consent to our use of their information. We may, where required under applicable law, notify those individuals that you have provided their details to us.
We are obliged to retain certain customer information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes.
If Personal Data is disclosed to us by you in connection with a general enquiry through this Website, for example where you enter your details into a Website form or you send us an email, that Personal Data will be retained for a period of 13 months, unless we have a legal obligation to hold this information for longer.
Where you register your contact details to create a Licences.ie account, we will retain your contact details and other information entered by you for a period of 5 years from your last use of the Licences.ie Service, unless we are required to hold this information for longer to comply with our legal obligations or instructions from a Licencing Authority acting as a controller of the same information.
If you close your licences.ie account or if your access to the Service is terminated, we may retain your personal information for 3 months after such an event for the purpose of dealing with any subsequent queries that arise in relation to your Licences.ie account including for example, payment-related queries and/or actions such as chargebacks or to facilitate the conclusion of any actions relating to your use of the Service that were in process but had not been completed at the time of your Licences.ie account closure or termination of your use of the Service, unless we are required to hold this information for longer to comply with our legal obligations or instructions from a Licencing Authority acting as a controller of the same information.
Where we retain personal information in relation to you that we process as a processor on behalf of a controller (eg, a Licensing Authority), we will retain and otherwise process such information (eg, information in relation to Licences purchased by you) in accordance with the instructions of that controller in accordance with applicable data protection laws.
Other information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, we hold this information for a period of seven years, unless we are obliged to hold it for a longer period under law or applicable regulations.
A cookie is a small piece of information which is transferred to your computer’s hard disk from a website. Cookies can store information about your preferences and other information which you need when you visit a website.
Updating and correcting your Personal Data
If we hold incorrect Personal Data about you, you have the right to have the data amended. While we will use reasonable efforts to keep your Personal Data up to date, you will need to notify us without delay in the event of any change in your personal circumstances, so that we can keep the Personal Data up to date.
If you have a licences.ie account, you can update your Personal Data by logging on to your profile page on our Website.
You can update your Personal Data by writing to the Data Privacy Office, An Post, GPO, O’Connell Street Lower, Dublin 1, D01 F5P2 or firstname.lastname@example.org together with:
1. Your name and address; and
2. A description of the specific Personal Data you wish to have rectified.
Right of erasure
You have the right in some circumstances to have your Personal Data, which we hold, erased by writing to the Data Privacy Office, An Post, GPO, O’Connell Street Lower, Dublin 1, D01 F5P2 or email@example.com together with:
1. Your name and address; and
2. A description of the specific Personal Data you wish to have erased.
If you request an erasure of your Personal Data, all your data will be erased subject to the following important notice.
We will not be required to erase your data where to do so would prevent us from meeting our respective contractual obligations, or where we are required to process (including retaining) your Personal Data in order to comply with a legal obligation, or if the Personal Data is necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings.
Right of Access
You have a right to be given a copy of your Personal Data on request, subject to certain exceptions. Please note that we have the right to require that you identify yourself before we will respond to any access request.
For more information, see our Data Access Policy.
Your Other Rights
You also have the right, in certain circumstances, to request restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your Personal Data can be obtained by writing to us at the address set out under “Contact Us” below.
In any case where we rely on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to us at the address set out under “Contact Us” below.
Where we rely on a legitimate purpose of ours or of a third party recipient of the Personal Data, in order to use and disclose Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do so, we will cease to use and process your Personal Data for that purpose, unless we can show there are compelling legitimate reasons for us to continue or we need to use the Personal Data for the purposes of legal claims.
In limited circumstances, you may also have the right to data portability in respect of certain of your Personal Data, which means you can request that we provide it to you in a structured, commonly used and machine-readable format, or transmit it to your third party nominee where this is technically feasible.
You have the right to lodge a complaint about our processing of your Personal Data with the Data Protection Commission at firstname.lastname@example.org.
Where you request Information about Licences.ie or Contact Licences.ie
Where you choose to give us Personal Data, such as where you enter your details into our Website forms, we will use this information to send you an acknowledgement e-mail and to provide you with the information you have requested. We may also send you subsequent emails, SMS messages or contact you by phone to follow up on your initial query.
Where you have agreed, we may also contact you in relation to other marketing (see Other Marketing by Licences.ie).
Other Marketing by Licences.ie
Where you have agreed (via this Website or otherwise) to receive marketing communications from Licences.ie, or where we are otherwise permitted to do so, we may use your contact details to contact you by post and / or email with news, information and special offers from Licences.ie.
Opting out of Marketing
You can change your marketing preferences at any time by contacting Licences.ie, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2.
Each time we send you marketing information, we will give you the option to change your mind about receipt of marketing (eg SMS: text STOP).
We use the Non-Personal Data gathered from visitors to our Website in an aggregate form to understand the demographics of the users of our Website, to help us better design and organise our Websites and mobile applications. We use these analytics tools to assist in gathering and analysing Non-Personal Data for the reasons described above.
Our analytics solutions may also collect your IP address as part of this analysis. No other form of Personal Data is gathered by these analytics services.
Except as explained above in relation to your IP address, by simply visiting our Website, you do not disclose, nor do we collect, Personal Data on you. The information collected about your visit may be limited to technical data which is used for administrative and statistical purposes, for example whether you reached the Website using a search engine or if you clicked a link on another website; the type of web-browser you used; or the type of device you used to access the Internet. We will use this information to help us to improve our Website.
We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of the An Post Website. For example, we may inform third parties regarding the number of unique visitors to the An Post Website, the demographic breakdown of users of our Website, or the activities that visitors to the An Post Website engage in while online. The third parties to whom we may provide this information may include our Website design, development, digital, support and hosting contractors.
Any queries or complaints regarding our use of the Personal Data and / or the exercise of your individual rights should be addressed to the Data Privacy Office, An Post, GPO, O’Connell Street Lower, Dublin 1, D01 F5P2 or email@example.com.
Last updated on 3 August 2018