Privacy Policy

This privacy policy (the "policy") was last updated on 24 May 2018 and refers to the websites; www.thirdageireland.ie

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and applies to all of your personal data irrespective of the medium or method by which we obtained/received your personal data.

In this policy, the term “personal data” means data relating to a living individual who is or can be identified either from the data, or from the data in conjunction with other information, that is in, or is likely to come into, our possession, and includes personal data as described in data protection legislation (as defined below).

Please read the following carefully. Entering into this website and providing your consent to our use of your personal data in accordance with the terms of this policy indicates that the user (either "user" or "you") has reviewed this policy and has agreed to be bound by it. You will be required to expressly accept and consent to this policy before we process your personal data. If you do not agree to these terms you must leave the website immediately. We will keep a record of your consent in this regard. If you no longer consent to our processing of your personal data, you may request that we cease such processing by contacting us via the ‘How to contact us’ facility referred to below.

We fully respect your right to privacy in relation to your interactions with the website, and we endeavour to guarantee to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual user details where we are legally entitled to do so. Information in relation to personal data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commissioner (“DPC”).

We will handle your personal data in accordance with data protection legislation. “Data protection legislation” means the Data Protection Acts 1988 and 2003 and Directive 95/46/EC, and any other applicable law or regulation relating to the processing of personal data and to privacy (including the E-Privacy Directive), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and laws implementing or supplementing the GDPR).

If you submit any personal information about other people to us or to our service providers (e.g. business colleagues), you represent that you have the authority to do so and to permit us to use their personal information in accordance with this privacy policy.

How we collect personal data

We and our service providers may collect personal information from a variety of sources, including:

Through Third Age projects and services

We may collect personal information about you when you use or take part in one of our services or projects, for example, when you sign up for or open a newsletter, when you register for online resources, volunteer with a project, attend a Third Age event or avail of our other services whether paid or unpaid.

Offline

We may collect personal information you provide to us offline, such as when you attend one of our events, share your data over the phone, or contact our projects or office directly. 

We do not knowingly collect personal information from children without proper parental consent. 

If you are aged 18 or under, please get your parent/guardian's permission before you provide any personal information to us. Users without this consent are not allowed to provide us with personal information. If you are under 13 then we will need consent from your parent/guardian before you can use some of our services. If you believe that we may have collected personal information from someone under the age of 18 without parental permission, please let us know using the methods described in the Contact Us section and we will investigate and address the issue promptly.

We and our third-party service providers may collect and automatically process this information in a variety of ways, including:

• When registering with us, you will be asked whether or not you consent to us sending you electronic communications/direct marketing. If you provide your email address and consent for email marketing, some information is collected about when/if the email was opened and what links were clicked. This information is used to assess the engagement and success of an email campaign.

• Clicking on a link in any of these emails may cause you to be personally identified on our site and may cause some part of your past browsing history on our site to be available to our personnel so we may more effectively engage with you and improve our site. If you do not wish for this tracking to occur, you can unsubscribe from our mailings or use private browsing mode to avoid tracking.

• If you fill out a web form on the Third Age website, your information will be stored in our system and some amount of your past browsing on our site may be available to us to determine your interests. We may use this information to more effectively engage with you and improve our site. If you do not wish for us to have your personal information, please do not register or fill out any of the web forms on this site.

• If you contacted us directly by email

• If you contacted us about volunteering or participating in a Third Age project 

• Through your browser or device: most browsers and landing pages collect certain information automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, internet browser type and version, and the name. We use this information, for example, to make sure that the Third Age Ireland services function properly, analyse the performance of our products, and to improve and maintain the services.

• IP address: IP addresses are automatically transmitted as part of any internet communication, and collecting IP addresses is a common practice; many websites, applications and other Third Age services collect IP addresses automatically. We use IP addresses for purposes such as communicating with your device, calculating usage levels of the Third Age services, helping diagnose server problems, security, and administering the Third Age services.

• Location data: We may collect the physical location of a connected device, for example, using satellite, cell phone tower, and WiFi signals. We may use your device’s physical location to provide you with location-based Third Age services and content. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable Third Age services and content.

We may use personal information:

To provide you with information about our services, activities or online content. You should only receive e-newsletters or similar correspondence and updates from us if you have agreed to in response to any contact you have made with us, e.g. on our website, by email or via the ‘How to contact us’ facility. It will be made clear to you where you have these choices, for example, by providing tick boxes for you to decide whether you wish to receive e-newsletters.

For administration reasons related to the service to which you have signed up (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us).

To invite you to participate in surveys, contests or similar promotions about our services (such participation is always voluntary).

Perform other activities consistent with this policy. Where we wish to use your personal information in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed in this policy. 

Third parties:

We wish to remind you that this policy applies to personal data that we collect/process through your use of the website. It does not apply to any links to third-parties’ websites and/or services, such as third-party applications, that you may encounter when you use the website. You acknowledge that the service that we provide may enable or assist you to access the website content of, correspond with, and purchase products and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your personal data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the website. We encourage you to carefully familiarise yourself with terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

We endeavour to keep all personal data that you provide to us accurate and up to date. As such, you must tell us about any changes to such information as soon as possible. You may unsubscribe from newsletters and other updates by selecting the Unsubscribe button at the foot of every communication.

The Third Age services are designed to provide reasonable and appropriate organisational, technical, and administrative measures to protect personal information within our organisation against unauthorised or unlawful access, alteration, disclosure, or destruction. Users of Third Age services must also do their part in protecting the data, systems, networks, and service they are utilising. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to the Third Age Failte Isteach Tutor Resource account has been compromised), please immediately notify us by contacting us in accordance with the “Contact Us” section below.

For your protection, we will only implement requests with respect to personal information about you (not anyone else), and we may need to verify your identity before implementing your request. We will comply with your request as soon as reasonably practicable and in accordance with applicable law. We may need to retain certain information for recordkeeping purposes, as required under applicable legal obligations, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g. when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion). Some of your information may remain within our systems and other records, in compliance with applicable law. 

To meet our legal and regulatory obligations, any information that you provide to us will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance, and our obligations under data protection legislation. In general, your personal data will be retained by us for two years and six months from the last date of contact or transaction.

As a data subject, you have the following rights under data protection legislation:

• the right of access to personal data relating to you.

• the right to correct any mistakes in your personal data.

• the right to ask us to stop contacting you with direct marketing.

• rights in relation to automated decision taking.

• the right to restrict or prevent your personal data being processed.

• the right to have your personal data ported to another data controller.

• the right to erasure.

• the right to complain to the Data Protection Commissioner if you believe we have not handled your personal data in accordance with the data protection legislation.

These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see ‘How to contact us’ below).

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to data protection legislation, we will respond within that time period.

Right to access to personal data relating to you

• You may ask to see what personal data we hold about you and be provided with:

• a summary of such personal data and the categories of personal data held.

• details of the purpose for which it is being or is to be processed.

• details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers.

• details of the period for which it is held (or the criteria we use to determine how long it is held).

• details of your rights, including the rights to rectification, erasure, restriction or objection to the processing.

• any information available about the source of that data.

• whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling.

• where your personal data are transferred out of the EEA, what safeguards are in place.

Requests for your personal data must be made to us (see 'How to contact us' below) specifying what personal data you need access to, and a copy will be retained on your personal file. To help us find the information easily, please give us as much information as possible about the type of information you would like to see.

If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible. There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.

We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to data protection legislation.

Right to update your personal data or correct any mistakes in your personal data

You can require us to correct any mistakes in your personal data, which we hold free of charge. If you would like to do this, please:

• email, call or write to us (see ‘How can you contact us’ below).

• let us have enough information to identify you (e.g. name, registration details).

• let us know the information that is incorrect and what it should be replaced with.

If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort. It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).

Right to ask us to stop contacting you with direct marketing

• You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:

• email, call or write to us (see ‘How can you contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of any Third Age email newsletter. It may take up to five days for this to take place.

• let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).

• We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’.

Rights in relation to automated decision taking (if applicable)

You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. Profiling may occur in relation to your personal data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows us to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. These rights will not apply in all circumstances, for example, where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (iii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.

Right to restrict or prevent processing of personal data

In accordance with data processing legislation, you may request that we stop processing your personal data temporarily if:

• you do not think that your data is accurate (but we will start processing again once we have checked and confirmed that it is accurate).

• the processing is unlawful but you do not want us to erase your data.

• we no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims.

• you have objected to processing because you believe that your interests should override the basis upon which we process your personal data. 

If you exercise your right to restrict us from processing your personal data, we will continue to process the data if:

• you consent to such processing.

• the processing is necessary for the exercise or defence of legal claims.

• the processing is necessary for the protection of the rights of other individuals or legal persons.

• the processing is necessary for public interest reasons.

Right to data portability

In accordance with data protection legislation, you may ask for an electronic copy of your personal data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.

The right to data portability also only applies where:

• the processing is based on your consent or for the performance of a contract

• the processing is carried out by automated means

Right to erasure

• In accordance with data protection legislation, you can ask us to erase your personal data where:

• you do not believe that we need your personal data in order to process it for the purposes set out in this policy.

• if you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data.

• you object to our processing and we do not have any legal basis for continuing to process your personal data.

• your data has been processed unlawfully or have not been erased when it should have been.

• the personal data have to be erased to comply with law.

• We may continue to process your personal data in certain circumstances in accordance with data protection legislation.

• Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.

Right to complain to the Data Protection Commissioner (DPC)

If you do not think that we have processed your personal data in accordance with this policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to data protection legislation. Information about how to do this is available on the DPC website at www.dataprotection.ie.

Offensive content

If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the website or otherwise engage in any disruptive behaviour on any Third Age service, we may remove such content. Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection legislation.

We may change this privacy policy. The “Last Updated” section at the top of this page states when this privacy policy was last revised. Any changes to this privacy policy will become effective when we post the revised privacy policy on the Third Age webiste. Your use of the Third Age services following these changes means that you accept the revised privacy policy. If any change may materially and negatively affect the privacy of your personal information, we will use reasonable efforts to notify you in advance and give you a reasonable period of time to object to any changes. We encourage you to periodically review this privacy policy to stay informed about how we collect, use, and share personal information.

The data controller (as defined in data protection legislation) for the website and services provided through the website is Third Age, Third Age National Centre, Summerhill, Co Meath. We have appointed a data protection officer in accordance with data protection legislation.

Unsubscribing from electronic communications can be achieved by pressing the ‘unsubscribe’ or similar button on any electronic communication received. However, if you need to contact us with regard to any of your rights as set out in this policy, all such requests should be made in writing by:

Emailing: nationaloffice@thirdageireland.ie
Calling: 046 955 7766

Or writing to:

Liam Carey, Data Protection Officer
Third Age Ireland,
Third Age National Centre, 
Summerhill,
Co Meath