NEC Aspire Technology Limited (referred to collectively as “Aspire”, or “we” or “us” or “our”) understands that privacy and the protection of your personal data is of the utmost importance. This Privacy Policy (“Policy”) sets out the types of information we collect and use, who that information relates to, how and why we use that information, who we share it with and your legal rights as a data subject. Unless indicated otherwise, this Policy applies to all our websites and domains and to any personal data we collect from you through our websites or from your online visits. Consequently, we ask that you read this Policy carefully as it contains important information as to how we use your personal data.

Who is responsible for your personal data?

NEC Aspire Technology Limited is responsible for your personal data. This Policy applies to Aspire, a technology company, located at Unit 111, Q House, 76 Furze Road, Sandyford, Dublin 18, D18 V6K0, which is the data controller for the purposes of this Policy. A data controller is a person or organisation who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be processed. If you want to get in touch and exercise any of the rights as set out below in relation to your personal data, please contact us at privacy@aspiretechnology.com.

What data do we collect?

Aspire may collect the following personal data from you:

Identity and contact information: your name, username or similar identifier, position, role, company or organisation, email address, telephone numbers and work address;

Physical access information: to record your attendance at our offices for security purposes;

Profile and usage information: including passwords to protected websites or platforms or services, your preferences in receiving marketing information from us, your communication preferences, information about how you use our websites including your referral website, pages your visit, actions you take, patterns of page visits, forms you complete while on our websites;

Technical information: including information collected during your visits to our websites, the IP address, login data, browser type and version, device type, time zone setting, browser plug-in types and versions, operating system and platform. To learn more about our use of cookies, please read our Cookie Policy available here;

Subscriptions/preferences: when you subscribe to receive our monthly newsletter or updates as well as consent preferences to help us identify which materials you are interested in receiving;

Events data: attendance at and provision of feedback forms in relation to our events;

Social media data: posts, likes, tweets and other interactions with our social media presence;

Recruitment information: where you apply for a position with us and may include name, email address, phone number, date of birth, passport or identifying card data, nationality, image, academic and professional data, job history and professional social network profiles.

We may obtain or collect personal data from you from other companies within the NEC group or from other third parties including:

• Partners with which we offer co-branded services or engage in joint marketing activities or for targeted advertising purposes;
• Supplemental personal data obtained from business partners and third parties to create customised profiles about you; and
• Public Information e.g. information from Linkedin and similar professional networks, directories or internet publications.

We will ensure that all processing is proportionate to the purposes outlined below.

How do we use your data?

How we use your data will depend on how you interact with us. In accordance with the principles of- the GDPR, we always try and minimise any personal data we collect and use. Information collected may be used for:

• Delivery of products and/or services or carrying our any support requests from you;
• Administrative and commercial purposes which includes storing your information in our CRM database, communications between Aspire and you in the past for business intelligence purposes, the use of CCTV (which may capture your image) at our offices for safety, security and administrative purposes;
• Marketing which includes sending relevant communications about our products and services, surveys and events, customizing, analysing and improving our products and services (including the content and advertisements on our website to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you, personalising content and implementing your preferences (please also see the Cookie Policy for information on this) and for other purposes which may contribute to the development or enhancement of our website;
• Enforcing our standard terms and conditions, website terms and separate contracts (if applicable) with you;
• Recruitment where you have applied for a position with us and which will include using your information as part of the selection and interview processes; and
• Security and legal purposes including protecting the security of our websites, apps and platforms, preventing fraud and other prohibited or illegal activities and performing functions required by law, complying with our legal obligations, resolving disputes and enforcing our agreements.

What are our legal bases for collection and usage of your personal data?

In order to collect, use, share, and otherwise process your information for the purposes described in this Policy, we rely on a number of legal bases, including where:

1. necessary to perform a contract we have with you and to provide our products and/or services;
2. you have consented to the processing (in which case you may revoke your consent at any time);
3. necessary for us to comply with a legal obligation, or to establish, exercise or defend legal claims;
4. necessary to protect your vital interests or those of others; and
5. necessary for the purposes of Aspire’s legitimate interests provided that those interests are not overridden by your interests or fundamental rights and freedoms.

We have legitimate business interests in:

• providing our software and services;
• managing our business and relationship with you or your company or organisation;
• understanding and responding to inquiries and customer feedback;
• understanding how our customers use our services and websites;
• identifying what our customers want and developing our relationship with you, your company or organisation;
• improving our services and offerings;
• receiving information from other NEC companies for shared customers;
• enforcing our standard terms and conditions and website and other terms and conditions;
• ensuring our systems and premises are secure;
• managing our supply chain;
• developing relationships with business partners;
• ensuring debts are paid;
• operating suppressors to exclude you from direct marketing if you unsubscribe;
• sharing data in connection with acquisitions and transfers of our business.

Who we share your personal data with?

In line with the information set out above, we may share information provided by you with third parties including service providers, affiliates, regulators and statutory and public bodies. We do this based upon the legal bases as set out above.

• Affiliates: we may share your information with companies affiliated with Aspire through the NEC Group to help us provide products and services to your and respond to queries or requests for support that you raise with us.
• Service providers: we may share your information with service providers that allow us to provide our services and communicate with your such as IT hosting providers, law firms, accountants and auditors. Where such third parties are processors, they are contractually required to only use the information to provide the services to use and cannot use the information for their own purposes.
• Business reorganisation: in circumstances where our business is subject to a reorganisation, we may, in accordance with our legitimate interests, need to share information as part of the transaction. Any such sharing of information will be done in accordance with applicable law.
• Legal reasons: where required by law enforcement, regulatory or judicial authorities to disclose any information you have provided to us, we will do so where required by law or where we believe such disclosure is necessary to exercise, establish or defence our legal rights. We reserve the right to report to law enforcement any activities that we, in good faith, believe to be unlawful.

Please be aware that some affiliates and third parties may be located in countries outside of the EEA however when we are required to transfer your information we do so in accordance with EU data protection law. We may rely on different legal mechanisms to ensure the transfer is lawful. For further information and/or to obtain a copy of the documents used to protect your information, please contact
us on privacy@aspiretechnology.com.

How long do we retain your data for?

We retain your information only for as long as necessary in light of the purposes set out in this Policy, 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 and nature 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.

What are your rights as a data subject?

You have a number of rights in relation to your information that we process. To exercise these rights, please contact us at privacy@aspiretechnology.com. While some of these rights apply generally, certain rights apply only in specific circumstances. In addition, these rights are not absolute and can be subject to conditions set out in relevant law.

Access: You have the right to request access to your information that we control.

Data Portability: You have the right to request that some of your personal information that you initially provided to us is returned to you or another controller in a commonly used machine readable format.

Correction: You have the right to ask us to correct any incomplete or inaccurate personal data we hold about you.

Deletion: You have the right to ask us to delete person data in certain circumstances. Please note that despite a deletion request, we may continue to process your information if we have a legal basis to do so.

Restriction: You have the right to ask us to restrict the processing of your information until such restriction is lifted.

Objection: If we process your information based on our legitimate interests you can object in certain circumstances. In such cases, where legally required to do so, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object using the unsubscribe link in such communications or by contacting us at privacy@aspiretechnology.com.

Complain: You have the right to submit a complaint about our use of your information with your local supervisory authority or Aspire’s supervisory authority, the Irish Data Protection Commission.

Security

We will hold your information securely in line with physical, technical and administrative security measures. However, the transmission of information via the internet is not completely secure.  Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted and any transmission is at your own risk.

Updating and amending this Policy

This Policy may be updated and amended from time to time and such changes will be posted on our website.

This Policy was last updated on 19 October 2023.