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”), is committed to protecting and respecting your privacy. This Privacy Statement (together with our Licences.ie Cookie Policy, Licences.ie Website Terms and Licences.ie Terms of Service) sets out the basis on which any personal data we collect from you, or that you provide to us, in each case through your use of the Site and Service (each as defined below), will be processed by us. Please read these policies and terms carefully to understand our practices regarding your personal data and how we will treat it.
By visiting our website at www.licences.ie (the “Site”) you accept and consent to the practices described in this Privacy Statement. To the extent that you also choose to register and use the Licences.ie integrated licence application service which is made available on the Site (the “Service”), this includes the provision of your personal data to third party licensing authorities with whom you interact through the Service (the “Licensing Authorities”) for purposes of obtaining a licence, permit or certificate issued by the relevant Licensing Authority (each, a “Licence”).
The extent to which An Post and a Licensing Authority are acting as data controllers and / or data processors (as such terms are defined in the applicable data protection legislation) is determined by such legislation.
For example, An Post will be a data controller of certain personal data (as defined in the applicable data protection legislation) that we collect from and about you in connection with your use of the Site and Service. Please see below in this Privacy Statement for a description of the personal data that we collect from and about you and how we use it.
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. Depending on the way in which such data is made available to us by the relevant Licensing Authority and the purpose(s) for which we are permitted to use it, we may be acting as a data processor of such personal data on behalf of the relevant Licensing Authority who is the data controller.
2.1 Information you give us. You may give us information about you by using our Site and/or Service. This includes information you provide when you register to use the Service and any such information stored and otherwise processed by us through the Service when you apply for a Licence and/or when you report a problem with our Site or Service. The information you give us may include your:
(a) name, postal address (including eircode), e-mail address and phone number;
(b) usernames and passwords;
(c) payment details;
(d) any other information requested by a Licensing Authority in connection with your application for a Licence (eg, your date of birth or PPS number).
You shall have sole responsibility for the legality, reliability, integrity, accuracy and quality of the information you provide to us.
2.2
Information we collect about you when you visit the Site.
With regard to each of your visits to our Site, we may automatically collect the following information:
(a) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
(b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time), products and/or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number; and
(c) information to determine your location as some of our location-enabled features require your personal data for the feature to work
2.3 Information we collect about you when you use the Service.
Each Licence that you may apply for using the Service will require you to provide specific information required by the relevant Licensing Authority to facilitate the processing of your Licence application and if issued, the administration and enforcement of the Licence by the Licensing Authority. Any such information provided by you will be forwarded by An Post through the Service to the relevant Licensing Authority with your Licence application.
2.4 Information we receive from other sources.
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). It is only in such circumstances that information about you may be received by us from third party sources (other than the Licensing Authorities themselves). In such circumstances, the information received from the third party source will be forwarded to the relevant Licensing Authority with your Licence application.
We use first party and third party cookies on our Site and in our Service. We use cookies in order to make our Site and Service easier to use, to support the provision of information and functionality to you, as well as to provide us with information about how the Site and Service are used so that we can endeavour to make sure that they are up to date, relevant and to help us find and remedy errors. Our use of cookies is governed by the Licences.ie Cookie Policy. Please review this policy to understand how we use cookies on our Site and in our Service.
4.1 Information you give to us.
We will use this information:
(a) 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;
(b) to facilitate your application and payment for Licences issued by Licensing Authorities through use of the Service;
(c) to maintain your Licences.ie account;
(d) to check and verify your identity in connection with your use of the Service;
(e) to prevent and detect security threats, fraud or any other malicious activity;
(f) to notify you about changes to our Site and/or Service; and/or
(g) to ensure that content from our Site and Service is presented in the most effective manner for you and for your device.
4.2 Information we collect about you.
We will use this information:
(a) to administer our Site and the Service and for internal operations, including troubleshooting, data analysis, testing, research and statistical and survey purposes;
(b) to improve our Site and the Service to ensure that content is presented in the most effective manner for you and for your device;
(c) to allow you to participate in interactive features of our Site and the Service when you choose to do so; and/or
(d) as part of our efforts to keep our Site and the Service safe and secure.
4.3 Information we receive from other sources.
We may combine information that we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out in this Privacy Statement (depending on the types of information we receive).
4.4 Anonymised Information.
We may use information we collect about you and information you give us to develop aggregated, anonymised information. We may use such aggregated and anonymised information for our own internal and external commercial purposes, including selling the aggregated, anonymised information to third parties. This information will not identify specific individuals and will therefore not be personal information.
4.5 Payment Information.
If you choose to pay licences fees (“Licence Fees”) (and any applicable payment processing fees (“Payment Processing Fees”) using a debit or credit card, you will be transferred to the An Post payment page which uses the services of a third party payment processor (Worldpay) to process your payment. Your card transaction will be authorised in real time using the Verifone software package PayWare and your payment information will be obtained by Worldpay and An Post. If you choose to pay Licence Fees and any applicable Payment Processing Fees using a debit or credit card, you hereby consent to Worldpay and An Post processing your payment information and related personal data solely for purposes of facilitating such payment and performing payment-related activities (eg, facilitating chargebacks).
4.6 Data Retention
We retain your personal information in order to use it in the manner described in this section and elsewhere in this Privacy Statement and in accordance with the relevant data protection and other applicable legislation. If you decide to stop using the Service and/or close your Licences.ie account or if your access to the Service is terminated, we may retain your personal information for a legally permissible period after such an event for the purpose of:
(a) 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;
(b) complying with legal and regulatory obligations that may require and/or apply to the retention of information in connection with your Licences.ie account; and
(c) any other lawful purpose which may apply.
Where we retain personal information in relation to you but we retain such information as a data processor on behalf of a data controller (eg, a Licensing Authority), we will retain and otherwise process such information in accordance with the instructions of that data controller and otherwise in accordance with applicable data protection legislation.
5.1 We will share your relevant personal information with a Licensing Authority when you use the Service to apply for a Licence. The information shared shall be limited to that required by the relevant Licensing Authority for the processing of your Licence application
This information may be used by the Licensing Authority:
(a) to process your application for a Licence
(b) to seek further information from you in respect of your application
(c) to process your payment for a Licence
(d) to issue you with a Licence or reject your application for a Licence
(e) to provide you with information in relation to Licences; and / or
(f) to administer and enforce a Licence.
A Licensing Authority may request that you provide additional personal information to them in connection with a Licence, outside the Service (eg, via post, email or in person). To the extent that you provide such additional personal information outside the Service, we have no involvement in such information collection by the relevant Licensing Authority, and this Privacy Statement does not apply to such collection and other processing of such personal information. If you provide personal information to a Licensing Authority outside the Service, you should review the relevant Licensing Authority’s privacy statement, cookie policy and related terms and policies as we have no control over, and are not responsible for, any Licensing Authority’s use and other processing of your personal information.
5.2 We may also disclose your personal information to third parties:
(a) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation or to comply with the rules of any stock exchange or other trading exchange to which we are subject;
(b) in order to enforce or apply this Privacy Statement, our Licences.ie Website Terms, our Licences.ie Terms of Service or other terms or agreements that you have with us;
(c) to protect our (and our customers’ or other relevant third parties’) rights, property and/or safety; and/or
(d) as otherwise permitted or required by applicable law.
6.1 Information that we collect from and about you will be stored by us in a safe and secure manner. We will not transfer such information to, and/or store it at, a destination outside the European Economic Area ("EEA"). We will not process such information using personnel located outside the EEA.
6.2 Where you have chosen (or where we have given you) a password which enables you to access the Service, you are responsible for keeping the password confidential and are responsible for all use of your Licences.ie account.
6.3 The Site secures your information by using a Verisign SSL (secure socket layer) certificate for all information provided by you. Please be aware that the transmission of information via the internet is not completely secure. Although we will use our reasonable efforts to protect your information, we cannot guarantee the security of your information transmitted to our Site and Service, which you transmit at your own risk. Once we have received your information, we will apply procedures and use security features to endeavour to prevent unauthorised access or other use of your information.
7.1 To the extent permitted by applicable law, you have the right to request a copy of your personal data currently held by us by submitting a data subject access request to us. Subject to applicable law, we will provide you with a copy of your personal data as soon as practicable. There may be a charge for such an access request (which will not be higher than the amount permitted by applicable law, currently €6.35). We may also request proof of identification to verify that you are the person making the access request. Any data subject access requests or other queries in relation to personal data should be sent in writing to: The Company Secretary, An Post, General Post Office, O’Connell Street Lower, Dublin 1, D01 F5P2.
7.2 To the extent permitted by applicable law, you also have the right to rectify, block or erase your personal data to the extent that it is inaccurate. If you believe that your personal data held by us is inaccurate, you should inform us by contacting support@licences.ie.
7.3 Please note that the rights exercisable under sections 6.1 and 6.2 above, only apply in respect of your personal data held by An Post. If you wish to exercise your rights under applicable law in respect of your personal data held by a Licensing Authority, please contact the Licensing Authority directly.
Our Site and Service may, from time to time, contain links to and from other websites, including those of the Licensing Authorities. If you follow a link to any of those websites, please note that they have their own privacy and cookie policies and other terms and we do not accept any responsibility or liability for those websites, policies or terms. Please check the applicable policies and terms before you submit any personal data to those websites or otherwise use those websites and any products and services made available through those websites.
We may from time to time revise this Privacy Statement. We will change the ‘Last Updated’ date at the start of this Privacy Statement if we make any changes. You should therefore periodically check this Privacy Statement to see if we have updated it.
Non-Material Changes.
Non-material changes to this Privacy Statement shall take effect immediately and you will be deemed to have accepted such non-material changes when you first access the Service after we make such changes. If you do not agree to such changes, you must discontinue using the Service and you should contact us to immediately close your Licences.ie account.
Material Changes.
If we make any material changes to this Privacy Statement we will notify you by email and we will also post a notice to this effect on the Site.
You will also be asked to agree to the revised Privacy Statement when you first access your Licences.ie account after we make any material change. In any event however, material changes will take effect thirty (30) calendar days after the date on which we send you an email notifying you of such changes (the “Change Notification Period”); if you access the Service after the expiration of the Change Notification Period you will be deemed to have accepted such material changes.
Notwithstanding the previous paragraph, material changes will take effect immediately if: (a) the change is required by applicable law; or (b) the change relates to a new Service-related product, service or functionality.
If you do not agree to a material change, you must discontinue using the Service and you should contact us immediately to close your Licences.ie account.