Privacy Policy

This policy addresses CW Applied Technology (Shannon) Ltd’s use of Personal Data

1. Our Privacy & Cookies Notice:

CW Applied Technology (Shannon) Ltd. takes its obligations to protect privacy and personal information very seriously. Please read this Privacy & Cookies Notice (“the Notice”) carefully as it sets out important information relating to how we handle your personal information.

2. Ownership of this Notice:

In this Notice, references to “we”, “us”, “CWAT” or “CW Applied Technology” are references to CW Applied Technology (Shannon) Ltd. This Notice sets out how we, as data controller, will collect and use personal information, and the choices and rights available to you in connection with our use of your personal information.

In all cases, any complaints and requests to exercise data subject rights should be addressed to the Managing Director and the Managing Director will handle the complaint or request. The Manging Director will act in the role of Data Protection Liaison Officer for CWAT.

3. To whose personal information does this Notice apply?

This Notice describes our practices when using data related to….

(a) The personal information of the business contacts, employees of clients, customers of our clients and suppliers to CWAT.

(b) Persons who (i) may visit our website or (ii) who may visit our CWAT pages on social media sites.

This Notice will apply whether you have provided the information directly to us or we have obtained it from a different source, such as a third party.

4. Business Contacts:

Sources of business contact information:

We collect personal information from our business contacts directly or from the following sources:

  • Third party referrals.
  • Client checking and verification processes such as due diligence checks.
  • Social media sites such as LinkedIn, Twitter and other public internet sites.
  • Credit reference agencies, insurance information bureaus and government or financial institutions; and other public resources such as directories, newspapers, internet sites, commercially available marketing lists, registries or public records.

Personal information we may collect about business contacts:

The categories of information we collect about business contacts includes:

  • Personal details including name, home address, employer, office address, personal and work telephone numbers and home and work email addresses.
  • Financial details including payments made and received and VAT/sales tax.
  • Goods or services provided or purchased.
  • Communications with our business contacts.
  • Image capturing, such as photos taken at events, videos, and CCTV footage.
  • In certain circumstances criminal proceedings, outcomes and sentences, subject to applicable law.

How we use the personal information we collect about business contacts:

We use this information for certain activities, including:

  • Facilitating smooth running of the business through communication with customers and suppliers.
  • Maintaining and building upon customer and supplier relationships.
  • Business planning.
  • To fulfil a transaction initiated by a business contact.
  • To fulfil a transaction initiated by a member of CWAT such as the purchase of supplies or equipment.
  • To fulfil a transaction with, or for, CWAT customers.
  • Keeping accounts related to any business or other activity carried on by CWAT.
  • Deciding whether to accept any person as a customer or supplier.
  • Keeping records of purchases, sales or other transactions for the purpose of ensuring that the required payments and/or deliveries are made or services provided.
  • Completion of customer satisfaction surveys.
  • Research and development.
  • Business development.
  • Event planning and organisation such as inviting our business contacts to events and exhibitions.
  • Database management.
  • For fraud and theft prevention or investigation, or other risk management purposes.
  • Compliance with contractual, legal and regulatory obligations.
  • For internal analysis and research to help us improve our services.

Why we use the personal information of business contacts:

We use this information because:

  • It is necessary for performing our obligations, or exercising our rights, under our contracts with customers or suppliers.
  • It is necessary for compliance with any legal or regulatory obligations that we are subject to.
  • We have a legitimate business interest to:
  • Manage our business and brand.
  • Provide and improve our services.
  • Operate our business.

A legitimate interest will only apply where we consider that it is not outweighed by a business contact’s interests or rights which require protection of their personal data.

  • In limited circumstances, such as in the case of marketing, a business contact’s consent as required under applicable law. Where we rely upon a business contact’s consent, they will have the right to withdraw their consent by contacting the Manging Director. If a business contact requires further information regarding our legitimate interests as applied to their personal information, they may contact the Managing Director.

Recipients of business contact information:

We may disclose personal information of business contacts to third parties as follows:

  • To suppliers and/or providers of goods and services and other third parties who work on our behalf to service or maintain business contact databases and other IT systems, such as suppliers of the IT systems which we use to process personal information, or who provide other technical services.
  • to third parties providing services to us, such as our professional advisors (e.g. auditors and lawyers).
  • to competent authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary.
  • subject to applicable law, in the event that CWAT is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such transaction.
  • Claimants, beneficiaries, assignees and payees.

Further Information:

Please see sections 6 to 10 below for further information concerning our use of personal data.

5. Website users and web related privacy issues:

5.1 The personal information we collect about website users and visitors to CWAT social media pages:

The categories of information we collect about users of our website and CWAT webpages on social media sites such as LinkedIn, Twitter and Facebook include:

  • Information users provide when they enter information on our website, such as when they provide contact details, answer online questionnaires, feedback forms or applications for employment or submit CVs
  • Information provided when users subscribe to email newsletters such as name, email address, job title.
  • Information users provide when posting content on social media sites.

We also collect personal information about the use of our website from users, including:

  • Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g URL, browser type, pages visited, date/time of access).
  • Advertising information (such as size/type of ad, ad impressions, location/format of ad, data about interactions with ad).
  • Behavioural information (such as information on the behaviour or presumed interests of individuals which are linked to those individuals and may be used to create a user profile) and
  • Information captured by our cookies (see Cookies section below).

If a website user does submit their data via one of our forms and they have cookies installed on their browser, all behavioural and web log data will be associated back to them. The website user will be informed of this when completing our forms.

CWAT also uses cookie technologies (e.g. VWO) which fully anonymise your personal information (such as IP address or keystrokes) therefore the information cannot be traced back to a website user.

5.2 How we use the personal information of website users and visitors to CWAT social media pages:

We use personal information of users of our website and CWAT webpages on social media sites such as Facebook, LinkedIn and Twitter for certain activities, including:

  • Personalizing the experience of our website.
  • Providing products and services that website users have requested.
  • Administering the website, investigating any complaints and providing customer services.
  • Providing website users and individuals accessing our web pages on social media sites with information and offers on products or services that may be of interest to them.
  • Monitoring social media content to manage relations with our customers and promote our business and brand.
  • Performing statistical and trend analysis to improve the user experience and performance of our website.

5.3 Why we use the personal information of website users and visitors to CWAT social media pages:

  • It is necessary for compliance with any legal or regulatory obligations we are subject to.

We have a legitimate business interest to:

  • Promote our brand and business through our website and through social media tools.
  • Monitor, investigate and report any attempts to breach the security of our website.

A legitimate interest will only apply where we consider that it is not outweighed by a website or social media user’s interests or rights which require protection of their personal data.

  • In the case of marketing, a user’s consent as required under applicable law. Where we rely upon a user’s consent, they will have an option to “Unsubscribe” and will also have the right to withdraw their consent by contacting the Managing Director.
  • Monitor, investigate and report any attempts to breach the security of our websites.
  • Improve the performance and user experience of our websites.

If a website user or individual accessing our web pages on social media sites requires further information regarding our legitimate interests as applied to their personal information, they may contact the Managing Director.

5.4 Recipients of personal information of website users and visitors to CWAT social media pages:

We may disclose website and social media users’ personal information to third party recipients, as follows:

  • to third parties who work on our behalf to service or maintain our IT systems which we may use to process personal information, or third parties who provide other technical services.
  • to third parties providing services to us, such as our professional advisors (e.g. auditors and lawyers);
  • to competent authorities such as tax authorities, courts, regulators and security or police authorities where required or requested by law or where we consider it necessary;
  • subject to applicable law, in the event that CWAT is merged, sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such transaction.

5.5 Further Information:

Our websites and online services are for individuals who are at least 18 years of age. Our online services are not designed to be used by children under the age of 18.

Please see sections 6 to 10 below for further information concerning our use of personal data.

6. Retention Periods:

We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information. We may also retain personal information for the period during which a claim may be made in relation to our dealings with you.

In general terms, this will mean that your personal data will be kept for the duration of our relationship with you and

  1. the period required by tax and company laws and regulations and
  2. as long as it is necessary for you to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under the laws of the Republic of Ireland.

In certain circumstances, data may need to be retained for a longer period of time, for example, where we are in ongoing correspondence or there is a continuing claim or investigation.

If you wish to obtain further information about the retention periods as applied to your personal information, you may find this in the retention schedule maintained by CWAT or can contact the Managing Director.

7. Data Subject Rights:

Individuals have the following rights, in certain circumstances, in relation to their personal information:

  1. Right to access personal information.
  2. Right to rectify personal information.
  3. Right to restrict the use of personal information.
  4. Right to request that personal information is erased.
  5. Right to object to processing of personal information.
  6. Right to data portability (in certain specific circumstances).
  7. Right to lodge a complaint with a supervisory authority.

A summary of each right and how an individual can take steps to exercise it is set out below.

If you wish to exercise any of the above rights, please contact us using the contact details specified below for the Managing Director. Such requests should include appropriate identity verification information (such as your name, address, email address or other information reasonably required).

Where we receive a request to exercise one of these rights, we shall provide information on the action we take on the request without undue delay and in any event within one month of receipt of the request. This may be extended by a further two months in certain circumstances, for example where requests are complex or numerous.

The information will be provided free of charge, except where requests are manifestly unfounded or excessive, in particular because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise an individual of any fees prior to proceeding with a request.

We may ask for additional information to verify an individual’s identity before carrying out a request.

Where we do not carry out a request, we shall inform the individual without delay and within one month of receipt of the request, providing our reasons for not taking the action requested.

7.1 Right to access personal data:

Individuals have the right to confirm the following with us:

a). Whether or not we process personal data about them.

b). Certain specified information about the processing.

Individuals also have a right to access the personal data and be provided with a copy.

7.2 Right to restrict processing of personal data

Individuals have the right to request that we restrict processing of their personal data where one of the following applies:

  1. An individual contests the accuracy of the personal data. The restriction will apply until we have taken steps to verify the accuracy of the personal data;
  2. The processing is unlawful but an individual does not want the personal data to be erased and requests restriction instead.
  3. We no longer require the personal data for the purposes of processing, but it is still required by an individual in connection with a legal claim.
  4. An individual has exercised their right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

7.3 Right to object to processing of personal data

Where personal data is used to target marketing to an individual, they have the right to object to this at any stage.

An individual also has the right to object to processing of their personal data where the legal basis of the processing is our legitimate interests. We will stop processing until we are able to verify that we have compelling legitimate grounds for processing which override the individual’s interests, rights and freedoms, or alternatively that we need to continue processing for the establishment, exercise or defence of legal claims.

7.4 Right to rectification of personal data

If an individual believes that the personal data we hold on them is inaccurate, they may request that it be amended. They may also request that incomplete personal data be completed, including by providing a supplementary statement.

7.5.Right to request erasure of personal data (“right to be forgotten”)

An individual may also request the erasure of their personal data in certain circumstances, including the following (this is not an exhaustive list):

  1. The personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  2. The processing was based on consent which has been withdrawn and there is no other legal basis for processing.

There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required to comply with a legal obligation or for the establishment, exercise or defence of legal claims.

7.6 Right to Data Portability

Where we are relying upon the legal basis either of consent or that the processing is necessary for the performance of a contract to which an individual is a party, and that personal data is processed by automatic means (e.g. electronically), an individual has the right to receive all the personal data which they have provided to us in a structured, commonly used and machine-readable format and to transmit this to another controller directly, where this is technically feasible.

7.7 Right to lodge a complaint with a Supervisory Authority

An individual also has a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where they are habitually resident, where they work or where an alleged infringement of data protection laws has taken place.

8. Miscellaneous:

8.1 Security

We have put in place technical and organisational security measures to prevent the loss or unauthorised access of your personal information. We train our employees in the proper handling of personal information. However, whilst we have used our best efforts to ensure the security of your data, please be aware that we cannot guarantee the security of information transmitted over the Internet. If you have reasons to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us as set out below.

8.2 Links

Our Website or social media sites may contain links to other “non-CWAT” websites. We do not control and assume no responsibility for the content, security or the privacy policies and practices on those websites.

CWAT encourages all users to read the privacy policies of those sites to determine how they protect and use personal information.

8.3 Changes to this Notice

From time to time, we may change and/or update this Notice. If this Notice changes in any way, we will post an updated version on our website. We recommend you regularly review this website to ensure that you are always aware of our information practices and any changes to such. Any changes to this Notice will go into effect on posting to this page.

9. Cookies and Similar Technologies:

A cookie is a small text file which includes a unique identifier that is sent by a web server to the browser on your computer, mobile phone or any other internet enabled device when you visit an on-line site. Cookies and similar technologies are widely used to make websites work efficiently and to collect information about your online preferences. For simplicity, we refer to all these technologies as “cookies”.

Some of our website pages may contain electronic images known as web beacons (also known as clear gifs, tags or pixels) that allow us to count users who have visited our pages. Web beacons collect only limited information, e.g. a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. We may also carry web beacons placed by third party advertisers. These beacons do not carry any information that could directly identify you.

9.1 How do we use cookies?

We use cookies and other tracking technologies to customise content and advertising, provide social media features and to see how our visitors move through our website. We use this information to make decisions about ways to improve the services we offer you.

We may engage third party tracking and advertising providers such as those named below to act on our behalf to track and analyse your usage of our website through the use of cookies. These third parties collect, and share with us, usage information about visits to our website and, sometimes by correlating this information with other information (e.g. your IP address), measure and research the effectiveness of our advertisements, track page usage, help us target our recommendations and advertising, and track use of our recommendations and advertisements.

9.2 Cookies and types of cookies we use:

Cookies enable the function of Google Analytics. This software allows us to measure and analyse visitor information such as browser usage, visitor numbers, and which pages are used. We use this information to help improve our Website: www.cwappliedtechnology.com

Example: Google Analytics _ga

The analytics.js library uses a single cookie named _ga to store a unique client identifier (Client ID), which is a randomly generated number. This ID is used by Google Analytics servers to calculate visitor, session, and campaign data. We use this information to help improve our website.

We may use other cookies to target and re-target visitors to our websites with digital advertising that is most relevant to the user. These cookies are also used to limit the number of times you see an advert or particular content, as well as help measure the effectiveness of an advertising or marketing campaign. Using existing cookies from many sites already on your computer, we partner with 3rd party companies to deliver advertising to specific computers. For more information about digital advertising visit AdChoices at: www.youradchoices.com.

Social media cookies

These cookies allow users to share our websites on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media provider for how their cookies work.

Performance cookies

These cookies collect information on how users use our websites, in order to help us improve areas such as navigation, and to help us fix technical issues or errors. For example, we use these cookies to help us understand how you arrive at our website, browse or use our website and highlight areas where we can improve our website.

Functionality cookies

These cookies help us customise our website content based on a user’s preferences. They remember the user’s choices such as identifying the user as a particular investor type (Retail, Professional or Institutional), their language, the country pages visited and any changes the user makes to text size or other parts of our website pages. The information these cookies collect may be anonymised and they cannot track browsing activity on other websites.

Essential cookies

These cookies are essential for parts of our website to operate. They enable users to move around our website and allow us to recognise a user within our website so that we can provide them with service they asked for such as remembering the user’s sign-in details.

You can find more information about cookies, behavioural advertising and online privacy at www.allaboutcookies.org or www.youronlinechoices.eu.

9.3 How do I reject cookies?

If you do not want to be tracked by Google Analytics cookies you can opt-out by installing a browser plug-in here: https://tools.google.com/dlpage/gaoptout/

At any time, you can prevent cookies from being set on your browser. For instructions on how to block, delete or disable any cookies, please consult your browser’s ‘Help’ or ‘Support’ section. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.

Please consult the following links for information on cookie management and blocking according to your browser:

Explorer: http://windows.microsoft.com/en-gb/internet-explorer/delete-manage-cookies#ie=ie-11.

Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Chrome: https://support.google.com/chrome/answer/95647?hl=en

Safari: https://support.apple.com/kb/PH19214?locale=en_GB

You can also find more information and manage cookie storage at: www.youronlinechoices.eu

10. CWAT HR Data management:

Personal Information Collected: We collect the information below about you during the recruitment process. If you fail to provide certain information when requested, we will not be able to progress your application.

  • Information provided in your curriculum vitae, application form, covering letter and during the interview process including: your name, date of birth, age, gender, home address, personal email address, education, qualification and work experience details, and references.
  • Information collected or created by us during the recruitment process including: interview notes, test scores and correspondence between us.
  • Information about criminal convictions: we carry out background checks as part of the recruitment process.

Special categories of personal data including: Racial and ethnic origin information [and information relating to disabilities, religious beliefs or sexual orientation], physical or mental health information and immigration/naturalisation records (if this discloses racial/ethnic origin information).

Sources of Information: This information is (a) provided by you; (b) obtained from third parties through the application and recruitment process; (c) obtained from public sources, such as LinkedIn, or (d) created by us in the course of the recruitment process.

How we use personal information: We use your personal information to progress the recruitment process, assess and make a decision about your suitability for a role, to communicate with you and to carry out reference checks.

We will also use your information to comply with legal and regulatory requirements.

Why we use personal information: We will use the information collected from you because:

  • It is necessary for us to do so before entering into a contract with you.
  • We need to process your information in order to comply with a legal or regulatory obligation.
  • Because we or a third party have a legitimate interest to: (a) ensure the effective administration and management of the recruitment process; (b) ensure we hire a suitable individual for a role; (c) deal with disputes and accidents and take legal or other professional advice; and (d) ascertain your fitness to work.

How we use special category personal information: We will process your special categories of personal data

(1) to consider whether we need to provide appropriate adjustments for any disabilities during the recruitment process.

(2) for equal monitoring purposes.

(3) comply with any legal or regulatory obligation.

Why we use special category personal information: We will use special categories of personal information collected about you because:

(1) you have provided your explicit written consent.

(2) we need to do so to carry out our legal obligations.

(3) it is necessary for the establishment, exercise or defence or legal claims on in relation to court cases.

(4) there is a substantial public interest.

(5) it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent.

Information about criminal convictions: As part of the recruitment process we carry out criminal background checks. We use these checks

(1) to assess your suitability for a regulated role.

(2) to protect your interests, our interests and third party interests.

(3) because it is necessary in relation to legal claims. We are allowed to use your personal information in this way where it is necessary to carry out our employment rights and obligations and we will always process your data in accordance with applicable law of the Republic of Ireland.

Information that we share: We will only share your personal information with the following third parties for the purposes of processing your application:

(1) employment agencies,

(2) background check and online test providers, and

(3) regulators and competent authorities.

We will also share personal data within our group for the purposes of administration, accounting and reporting purposes.

Retention of your information: We will retain your personal information for the duration of the recruitment process and for the length of any applicable limitation period for claims which might be brought against us later.

Your rights: You have the following rights in connection to your data: the rights of access, correction, erasure, objection, restriction, transfer, and the right to withdraw consent and to complain to a Supervisory Authority.