EPIC Conjoint Limited (“us”, “we”, or “our”) operates the https://www.epicconjoint.com/ website (the “Service”)
- where we obtain the data from,
- what we do with that data,
- how we comply with the data protection rules,
- who we transfer data to and
- how we deal with individuals’ rights in relation to their Personal Data.
Any Personal Data is collected and processed in accordance with Irish and EU data protection laws.
Please note that we may disclose individuals’ information to trusted third parties for the purposes set out and explained in this document. We require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with Irish and EU laws on data protection.
We will not disclose personal information to any third party without your consent or on one of the grounds listed herein, except in incidences where an individual is potentially at risk or where the law requires it.
We are not responsible for the content or the privacy policies for any websites that we provide external links to.
We need to demonstrate accountability for our data protection obligations. This means that we must be able to show how we comply with the data protection rules, and that we have in fact complied with the rules. We do this, among other ways, by our written policies and procedures, by building data protection compliance into our systems and business rules, by internally monitoring our data protection compliance and keeping it under review, and by taking action if our employees or contractors fail to follow the rules. We also have certain obligations in relation to keeping records about our data processing.
Identity of the Data Controller and Contact Details
EPIC CONJOINT provides an advanced online survey platform for companies, research companies, and universities. The software is provided in an Application Service Provider (ASP) model, accessed using a modern browser via the Internet. EPIC CONJOINT’s products are self-service, whereby the end-users are responsible for what data to collect and from whom. Survey respondents may use mobile devices to complete a survey.
All customer data collected using the software is stored in a single secure data center; data does not “float” around in the cloud.
Surveys may be distributed in numerous ways: via email, a web link, or off-line.
Our Data Protection Co-Ordinator can be contacted as follows:-
EPIC CONJOINT LTD.
Nova UCD, Belfield, Dublin 4
Data protection provides rights to individuals with regard to the use of their Personal Data by organisations, including EPIC CONJOINT Limited. Irish and EU laws on data protection govern all activities we engage in with regard to our collection, storage, handling, disclosure and other uses of Personal Data.
Compliance with the data protection rules is a legal obligation. In addition, our compliance with the data protection rules helps individuals to have confidence in dealing with us and helps us to maintain a positive reputation in relation to how we handle personal information.
The data protection rules that apply to EPIC CONJOINT Limited are currently contained in the Data Protection Acts 1988 and 2003, in the ePrivacy Regulations 2011 and in related legislation (together the “DPAs”). Effective 25 May 2018, the applicable rules are contained in the EU General Data Protection Regulation (EU Regulation 679/2016) (the “GDPR”) and in related Irish data protection legislation which gives effect to the GDPR.
“Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any Personal Data is processed, who/which make independent decisions in relation to the Personal Data and/or who/which otherwise control that Personal Data.
What are the data protection rules?
This Policy aims to ensure compliance with the relevant data protection laws. We aim to comply with the following:
- Lawfulness, fairness and transparency – Personal data must be processed lawfully, fairly and in a transparent manner.
- Purpose Limitation. Personal data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.
- Data minimisation – Personal Data must be adequate, relevant and limited to what is necessary in relation to purposes for which they are processed.
- Accuracy – Personal data must be accurate and, where necessary, kept up to date. Inaccurate Personal Data should be corrected or deleted.
- Retention – Personal data should be kept in an identifiable format for no longer than is necessary.
- Integrity and confidentiality – Personal data should be kept secure.
- Accountability – An important change for Data Controllers. Under the GDPR, we must not only comply with the above six general principles but we must be able to demonstrate that we comply by documenting and keeping records of all decisions.
Type of Information Collected
We collect two types of information:
“Personal data” means any information relating to and identified or identifiable natural person. We will collect this from you when you:
- While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). We hold many types of data about you, including: your personal details including your name, email address, phone number
Technical Information We Collect on Our Website
Cookies are small text files that are transferred to your computer’s hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site. A cookie contains your contact information and information to allow us to identify your computer when you travel around our site for the purpose of helping you accomplish your survey.
Most web browsers automatically accept cookies, but, if you wish, you can set your browser to prevent it from accepting cookies. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:
Session Cookies – We use Session Cookies to operate our Service
Preference Cookies – We use Preference Cookies to remember your preferences and various settings
Security Cookies -We use Security Cookies for security purposes
Certain information in relation to web usage is revealed via our internet service provider who records some of the following data. The information we receive depends upon what you do when visiting our site: The logical address of the server you are using; The date and time you access our site; The pages you have accessed and the documents downloaded; The previous Internet address from which you linked directly to our site; Some of the search criteria you are using
How we may use this technical information
Aggregate cookie and tracking information may be shared with third parties.
The technical information is used to allow us improve the information we are supplying to our users, to find out how many people are visiting our sites and for statistical purposes.
Some of the above information is used to create summary statistics which allow us to assess the number of visitors to the different sections of our site, discover what information is most and least used, inform us on future design and layout specifications, and help us make our site more user friendly.
We will make no attempt to identify individual visitors, or to associate the technical details listed above with any individual. We will only use the technical information for statistical and other administrative purposes. You should note that technical details, which we cannot associate with any identifiable individual, are not “Personal Data” within the meaning of the GDPR.
Use of Information Collected
We collect and use your information for the following purposes:
To provide and maintain the Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer care and support
To provide analysis or valuable information so that we can improve the Service
To monitor the usage of the Service
To detect, prevent and address technical issues
We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. At the point at which you provide us with your Personal Data you will be asked whether you wish to receive any marketing communications from us.
We may use your Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will not share your Personal Data with any third party for marketing purposes.
You may object to direct marketing by using the contact details herein to opt-out.
Third Party Data Processors
We may use trusted third parties as data processors. We require all third parties to have appropriate technical and operational security measures in place to protect your Personal Data, in line with Irish and EU laws on data protection. Any such organisation or individual will have access to personal information needed to perform these functions but may not use it for any other purpose.
Specifically, we need to have written agreements in place with all of our data processors and, before we sign each agreement, we need to have vetted and be satisfied with the processor’s data security. The agreements also need to contain specific clauses that deal with data protection.
We use the following categories of data processors in the course of our business:
- Cloud Service Provider, Cloud-based Support Services, Cloud-based Email Notification Services
We use the following third party data processors in the course of our business:
We may pass on your details if we are under a duty to disclose or share a Data Subject’s Personal Data in order to comply with any legal obligation, or in order to enforce or apply any contract with the Data Subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes reporting information about incidents (as appropriate) to the law enforcement authorities and responding to any requirements from law enforcement authorities to provide information and/or Personal Data to them for the purposes of them detecting, investigating and/or prosecuting offences or in connection with crime sentencing.
Other than the above, we will not disclose personal information to any third party without your consent except in incidences where an individual is potentially at risk or where the law requires it.
When we transfer your Personal Data out of the EEA, we ensure an adequate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for and for up to seven (7) years afterwards or otherwise permitted by applicable laws. We may also retain your information during the period of time needed to complete our legitimate business operations, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your Data Protection Rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a “Data Subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
How You Exercise Your Rights
We have appointed a Data Protection Co-Ordinator to monitor compliance with our data protection obligations and with this policy and our related policies. If you have any questions about this policy or about our data protection compliance, please contact the Data Protection Coordinator.
Data subjects must make a formal request for Personal Data we hold about them or otherwise to exercise their data protections rights whether to make an access request or otherwise by contacting our Data Protection Co-Ordinator who will respond to the request within 30 days.
We are obliged to comply with exceptions to your requests where laid out in law. Such exceptions relate to health data, disclosures that would be likely to cause serious harm to your physical or mental health or emotional condition and opinions given in confidence.
Our Data Protection Co-Ordinator can be contacted as follows:-
EPIC Conjoint Ltd.
Nova UCD, Belfield, Dublin 4
Your Right to Lodge a Complaint
You as the Data Subject have the right to complain at any time to a data protection supervisory authority in relation to any issues related to our processing of your Personal Data. As our organisation is located in Ireland and we conduct our data processing here, we are regulated for data protection purposes by the Irish Data Protection Commissioner.
You can contact the Data Protection Commissioner as follows:
Use their website www.dataprotection.ie
Phone: +353 57 8684800 or +353 (0)761 104 800
Address: Data Protection Office – Canal House, Station Road, Portarlington, Co. Laois, R32 AP23. Or 21 Fitzwilliam Square Dublin 2. D02 RD28 Ireland.
You may withdraw consent at any time by providing an unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify withdrawal of consent to the processing of Personal Data relating to you. If you have any queries relating to withdrawing your consent, please contact our Data Protection Co-Ordinator using the contact details set out below.
Withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal.
Security of your Personal Data
We take appropriate security measures against unlawful or unauthorised processing of Personal Data, and against the accidental loss of, or damage to, Personal Data.
We have put in place procedures and technologies to maintain the security of all Personal Data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if they agree to comply with those procedures and policies, or if they put in place adequate measures himself. In addition, we have appropriate written agreements in place with all of our data processors.
We maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:
- Confidentiality means that only people who are authorised to use the data can access it.
- Integrity means that Personal Data should be accurate and suitable for the purpose for which it is processed.
- Availability means that authorised users should be able to access the data if they need it for authorised purposes.
We follow strict security procedures in the storage and disclosure of your Personal Data, and to protect it against accidental loss, destruction or damage. We use third party vendors and hosting partners to provide the necessary hardware, software networking, storage, and related technology required to run. The data you provide to us is protected using modern encryption, intrusion prevention, and account access techniques.
Sale of Business
Existence of Automated Decision-Making
Automated Decision Making refers to a decision which is taken solely on the basis of automated processing of your personal data. This means processing using, for example, software code or an algorithm, which does not require human intervention.
As Profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.
As a responsible company, we do not use automatic decision-making or profiling.
This website contains an automated decision-making mechanism, which is used to determine user
location. You have the right to object to the use of your Personal Data. Please submit your request
through the contact details on this website in writing.
We will not process Personal Data involving automated decision making, unless if necessary for the
performance of a contract (e.g. avoid fraudulent payment) or subject to your explicit consent, to
better serve your needs in accordance with your preferences. Please note that in such case, you will
be informed through layered notices on the conditions of processing of your Personal Data, the
profile built, how the profile is used, the logic involved. You will be requested to explicitly consent to
such profiling if it is not necessary for the performance of a contract.
We regularly check the automated tools used to ensure that the profiling is done fairly. Specific
measures such as data minimization are implemented when creating profiles. You are invited to
express your point of view through the right of access described above. You can also contest the
result of the automated decision by sending an email to the contact details provided in this Policy.
Children’s Personal Data
If you would like to make use of our services and you are not yet 18 years old, we require that an adult is present when you register. Where consent is required to process your Personal Data as a child, we will obtain that consent from the adult who is authorised to give the consent on your behalf.
This Policy has been approved and authorised by:
NAME: Matt Johnston
DATE: August 5, 2018
POLICY IMPLEMENTATION DATE: May 25, 2018