NEWSTAGE PRIVACY POLICY

INTRODUCTION 

About Us. 

Newstage Limited (“Newstage ”) is a private company limited by shares incorporated in Ireland, registered number 696833 with its registered office at 14 Riverside Drive, Churchtown, Dublin 14, Ireland (“we ”/ “us ”/ “our ”/ “Newstage ”). We deliver creative and innovative solutions to help people transition to meet changing business and personal needs, whether individually or through their organisations. 

About our Privacy Policy. 

We respect your right to privacy and take seriously our responsibilities in relation to the processing of personal data. We do not collect or process personal data unnecessarily. 

This privacy policy (the “Policy ”) sets out important information about your rights in relation to the processing of your personal data, and the basis on which any personal data we collect from you, or that you provide to us, will be processed in connection with your use of our website (www.newstage.ie) and/or Newstage services (the “Services ”). We do not knowingly attempt to solicit or receive information from children. 

Data Controller.   

Under this Policy, and unless we have entered into a different agreement with you, we will be what’s known under the General Data Protection Regulation (EU) 2016/679 (the “GDPR ”) as the “controller ” of the personal data you provide to us. 

THE INFORMATION WE COLLECT 

We will collect and process the following data about you for the following purposes: 

Information you give us. 

Your Data

This is information about you that you give us by filling in forms on our Sites or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you use our Sites, or the Services, or report a problem with our Sites. 

The information you give us may include: 

• Identity Data: your full name, address, e-mail address, phone number, age, title and personal description. 
• Financial Data: your financial, including bank account details, billing contact email address and VAT number. 
• Personal Data: personally identifiable information contained in your profile page, application form or similar documents, to the extent not already captured under the Identity Data section above. 
• Survey Data: your full name, e-mail address, gender, age, country or other responses to survey questions or statements given by you (which may be numerical only) in relation to your career progression to the extent they contain personal data relating to you. 

Information we collect about you.   

Automatically Collected Information. With regard to each of your visits to our Sites we will automatically collect the following information: 

• Technical Data: 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, how often you use the application and other performance data; and 
• Usage Data: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Sites (including date and time), products, services or programmes you viewed or searched for, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page. 

No special categories of personal data. 

We do not require or collect any personal data that is sensitive personal data or any special category of personal data under the GDPR, unless you decide to provide this information to us. 

COOKIES 

What are cookies and why we use them.   

The Sites may use cookies from time to time. “Cookies” are small text files which are stored by your browser on your computer and are normally used to gather statistical information and to analyse trends of use or access to a website. Cookies cannot be used to run programs or deliver viruses to your computer. 

Cookies may be used to save your personal preferences so you do not have to re- enter them each time you access the Sites. 

For more about our use of cookies and how you can disable them, please see our Cookie Policy. 

WHAT WE DO WITH YOUR INFORMATION 

We will only use your personal information when the law allows us to. Most commonly, we will use your personal data in the following circumstances: 

• Where we need to perform the contract we are about to enter into or have entered into with you. 
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests. 
• Where we need to comply with a legal or regulatory obligation. 

How long we keep your information.  Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law. 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This means that the period of time for which we store your personal data may depend on the type of data we hold. 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. For example, we may hold personal data as needed for our accounting or tax compliance purposes for a period of 6 years. 

DISCLOSURE OF YOUR INFORMATION 

We do not sell your personal information to third parties for marketing purposes. We may disclose information to third parties if you consent to us doing so as well as in the following circumstances: 

You agree that we have the right to share your personal information with the following recipients or categories of recipients: 

• Any department or authorised person within our company or any member company within our group, which means any subsidiary or holding company within the meaning of sections 7 and 8 of the Companies Act 2014. 

• Selected third parties including: 

- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in relation to the Services; 

- Customer Relationship Management Software providers to maintain out database of business contacts 

- Analytics and search engine providers and research partners that assist us in the improvement and optimisation of our Sites, the Services and/or in the conduct of any survey; 

We will disclose your personal information to third party recipients: 

• in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of our business or assets. 
• if Newstage or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. 
• if we are under a duty to disclose or share your personal data in order to comply with any law, legal obligation or court order, or in order to enforce rights under the GDPR or other agreements. 
• to protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organisations for the maintenance and security of the Sites and Services. 

INTERNATIONAL TRANSFERS 

Personal Data may be transferred to our trusted partners and service providers who maintain their servers outside of the European Economic Area (“EEA”), where the privacy and data protection laws may not be as protective as those in your jurisdiction. This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. There are special requirements set out under Chapter V of the GDPR (with which we would comply) to regulate such data transfers and ensure that adequate security measures are in place to safeguard and maintain the integrity of your personal data on transfer. 

SECURITY MEASURES 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

YOUR PERSONAL DATA AND YOUR RIGHTS 

Accessing your Personal Data. 

You may request access at any time to a copy of the personal data we hold about you. Any such request should be submitted to us in writing and sent to hello@newstage.ie. We will need to verify your identity in such circumstances and may request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. 

There is usually no charge applied to access your personal data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances. 

Right of Restriction.   

• You may restrict us from processing your personal data in any of the following circumstances: 
• you have contested the accuracy of the personal data we hold on record in relation to you or for a period of time to enable us to verify the accuracy of the personal data; 
• the processing of your personal data is unlawful and you request the restriction of use of the personal data instead of its erasure; 
• we no longer require your personal data for the purpose of processing but you require this data for the establishment, exercise or defence of legal claims; or 
• where you have contested the processing (under Article 21(1) of the GDPR) pending the verification of our legitimate grounds. 

Corrections or Erasure ( Right to Rectification and Right to Be Forgotten). 

If we hold personal data concerning you which are no longer necessary for the purposes for which they were collected or if you withdraw consent for us to process your personal data, you can request the deletion of this personal data. This right, however, will not apply where we are required to process personal data in order to comply with a legal obligation or where the processing of this information is carried out for reasons of public interest in the area of public health. If the personal information we hold about you is inaccurate, you may request to have your personal information updated and corrected. To do so at any time, please contact us by email at hello@newstage.ie. 

Your Right to Object.   

You have the right to object to the processing of your personal data at any time: 

• for direct marketing purposes 
• for profiling to the extent it relates to direct marketing 
• where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights and freedoms or in connection with the enforcement or defence of a legal claim. 

To exercise your right to object at any time, please email hello@newstage.ie. 

Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above. For more information about our marketing practices, please see the Marketing Communications section below. 

Data Portability.   

Where we process your personal data by automated means (i.e., not on paper) and this processing is based on your consent or required for the performance of a contract between us, you have the right to request from us a copy of your personal data in a structured, commonly used machine-readable format and, where technically feasible, to request that we transmit your personal data in this format to another controller. 

Profiling.   

Profiling is an automated form of processing of personal data often used to analyse or predict personal aspects about an individual person. This could relate to a person’s performance at work, economic situation, health, personal preferences, reliability, behaviour, location or movements. An example of this would be where a bank uses an automated credit scoring system to assess and reject a loan application or where you choose to participate in a survey that scores your readiness for a particular career path. 

You have the right to be informed if your personal data will be subject to automated decision making, including profiling. You also have the right not to be subject to a decision based solely on automated process, including profiling, where that decision impacts on your legal rights. There are some exceptions to this rule, where, for example, the decision is necessary in connection with the performance of a contract between us, is authorised by law or where you have given your explicit consent to this automated processing. In this case, however, we do not engage in profiling or automated processing for profiling purposes. 

Personal Rights 

The rights described in this section are personal rights and are exercisable only by the individual person (or data subject) concerned. 

MARKETING COMMUNICATIONS 

General.   

We will not use your data to send marketing communications to you about promotions, competitions, updates and new products or services that may be of interest to you, unless we have your permission to do so. We will not use your Survey Data for our marketing purposes. 

Your right to object.   

You have the right to object to the processing of your personal data for our marketing purposes. To object or if you change your mind at any later time, you can withdraw your consent to the processing of your personal data for such marketing purposes by contacting us at hello@newstage.ie.  You may also opt out of receiving marketing communications at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact upon the lawfulness of processing based on your consent prior to the withdrawal. 

THIRD PARTY MATERIAL 

We always endeavour to deal with vendors and other third parties who are GDPR compliant or, in the case of the third parties located outside of the EEA, who are certified as compliant with the EU-US Privacy Shield, as applicable, or who have adequate security measures in place to safeguard the security of personal data. That said, we, our employees, agents, holding company and subsidiaries, accept no liability howsoever arising for the content or reliability of any third party materials or websites referenced by hyperlink or other means on the Sites or for the data collection and use practices or security measures used by such third parties. If you submit personal data to any of those sites, your personal data is governed by their privacy policy. We encourage you to carefully read their privacy policies. 

CHANGES TO THIS POLICY 

Any changes made to this Policy from time to time will be published at the Sites. 

Any material or other change to the data processing operations described in this Policy which is relevant to or impacts on you or your personal data, will be notified to you in advance by email. In this way, you will have an opportunity to consider the nature and impact of the change and exercise your rights under the GDPR in relation to that change (e.g., to withdraw consent or to object to the processing) as you see fit. 

QUESTIONS OR COMPLAINTS. 

Contact Us. If you have any questions or complaints relating to this Policy, please contact us at: 

Newstage Limited,

14 Riverside Drive, Churchtown,

Dublin 14, Ireland 

Website: www.newstage.ie

Email: hello@newstage.ie.  

Supervisory Authority. We are committed to complying with the terms of the GDPR and to the processing of personal data in a fair, lawful and transparent manner. If, however, you believe that we have not complied with our obligations under the GDPR, you have the right to lodge a complaint with the Data Protection Commission in Ireland. 

Effective Date of this Policy: June 2021