GLB REFUND LIMITED is a Company incorporated under Irish law with Company Number 602529 having its registered office at 31 Westland Square, Pearse Street, Dublin 2, D02 AW71 (the “Company”). We are fully compliant with the General Data Protection Regulation (“GDPR”) and all applicable legislation made in the Republic of Ireland thereunder. The purpose of this policy is to explain how our organisation uses the personal data we collect from you when you use our website and services. This privacy policy sets out how the Company uses and processes any information which you give to us directly or which has been made available to us through any third party, acting on your behalf, including agents, custodians, etc. We respect your privacy and are committed to protecting your personal information.
Our Data Protection Representative is Stanislas Conte who can be contacted at contact@globerefund.com.
What Data do we collect?
Our Company collects data comprising personally identifiable information from our Clients, prospective clients, staff of our clients and prospective clients, agents and representatives of our Clients, consultants, employees and contractors. The personal data which we collect includes the following:
- Name
- Address
- Email address
- Telephone numbe
- Tax number
- Certificates of Good Standing
- Date of birth
- Place of birth
- Nationality
- Bank account numbers
We may also obtain certain sensitive personal data from our clients and employees with their consent where necessary for performance of our obligations as their employer or our obligations pursuant to the Contract as appropriate. Where such information is provided, the information will be shared only where necessary taking into account the nature of the information. Sensitive data will not be retained for any longer than necessary for the performance of the Company’s obligations. We will not disclose sensitive personal data otherwise than in accordance with GDPR.
How do we collect your Data?
The Company collects data from our data subjects and processes it in the provision of our services as a Tax Advisor and our obligations as an employer. We will collect data from our Clients and prospective Clients (including their staff and agents) through our website, contact forms, questionnaires, correspondence, telephone calls, details of your visit to our website and browser cookies. We will collect data primarily by way of production of same by our Clients, prospective Clients and their employees and agents. On occasion we may also receive your Data indirectly via publicly available information including on social networking sites.
We collect data from our employees and contractors through application forms, contact forms, curriculum vitaes, correspondence, telephone calls and employment records. Our Company will collect data primarily by way of direct production of same from our employees and contractors. We may on occasion receive data indirectly via publicly available information including on social networking sites and our website.
How will we use your Data?
Our Company collects your data so that we can perform the services of a Tax Advisor and in our capacity as an employer. Our Company collects your Data so that we can:
- Process your enquiry or request for our service
- To enable you and us to manage your account in the provision of those services
- To engage with you and respond to any requests which you may have.
- To improve our level of service
- For general marketing purposes which are in the legitimate interest of our business
- To process payments
- To meet our legal and statutory obligations (including, defence of legal claims, if applicable)
- To meet our contractual obligations to you and to comply with any applicable laws
Basis of processing Data
The Company will process data on behalf of natural persons comprising its data subjects and will ensure that your data is processed in a lawful, clear and transparent manner at all times for a specific and legitimate purpose. The Company relies on the following legal basis for the processing of data.
- Processing necessary for the performance of a Contract.
- Processing necessary for the compliance with a legal or statutory obligation.
- To protect the vital interest of a Data Subject.
- With the consent of the Data Subject for one or more specific and legitimate purposes.
- Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
- Processing necessary for the purposes of the legitimate interest pursued by the Controller or a third party except where such interest is overridden by the fundamental rights and freedoms of the Data Subject.
Where we rely on the legitimate interest of the Company for the processing of the personal data, we will take all reasonable measure to ensure that the interests of the Data Subject are protected. The legitimate interests of the Company in this context include direct marketing, prevention of fraud and information system security.
We will rely on our legitimate interests as a company to process your data for direct marketing purposes. We consider it to be a legitimate interest of our company in promoting its services, products and in the administration operation of our business. Any such processing will not be carried out where such interest is overridden by the rights and freedoms of the Data Subject. In all direct marketing communications, we will give an unsubscribe option. A Data Subject can unsubscribe at any time.
We will only rely on consent as the basis for processing in limited circumstances. Where consent is utilised as the basis for processing, such consent can be withdrawn at any time. In that event, we will cease processing your data, unless there is a separate basis upon which we can rely to process your data, such as same being necessary for the performance of the contract between us or necessary for us to comply with our legal and statutory obligations.
How do we store your Data?
The Company securely stores your data at 31 Westland Square, Pearse Street, Dublin 2. We will ensure the appropriate, technical and organisational measures are put in place commensurate with the level of security required for the data held on your behalf. We will use all appropriate and reasonable measure to ensure integrity and confidentiality of the personal as maintained at all times.
Marketing
Our Company would like to send marketing information to you about the products and services which we think will be of relevance to you. We will always give you an option to unsubscribe from our marketing list, Please Click Here or Contact contact@globerefund.com if you wish to unsubscribe from our marketing list. You have a right to object to our processing your data for direct marketing purposes at any stage.
Sharing of Personal Data
It may be necessary for us to share your personal data with third parties to enable us to comply with our legal and statutory obligations and to perform the contract between us. We will never provide your data to third parties for marketing purposes.
We will need to share your personal information with our subsidiaries and agents to enable us to perform the contract between us. We will need to share your personal data including payment information with the relevant tax authorities to enable us to provide the services to you. We may also share your data with our professional advisors where necessary including lawyers, bankers, auditors and insurers who provide professional services necessary for the operation of the business of the Company.
We do not propose to transfer personal data to any parties not resident within Europe. In the event that a transfer of personal data outside the EU is required by virtue of the services which you have requested us to provide to you, we will obtain your specific consent to the transferring of that data to the relevant tax authorities and any agents who we are obliged in connection with same in advance of affecting such transfer. We will use reasonable endeavours to ensure that equivalent measures are in place with any such parties prior to obtaining your consent.
Data Retention
The Company will keep your data for no longer than necessary for the purpose for which the data was provided taking into account the basis for processing the data and applicable law, and in any event no less than six years.
Rights of Data Subject
You have the following rights under the GDPR, in certain circumstances and subject to certain exemptions, in relation to your personal data:
- Right to access data – you have the right to request a copy of the personal data that we hold about you together with other information about our processing of that personal data.
- Right to rectification – you have the right to request that any inaccurate data that is held about you is corrected or if we have incomplete information you may request that we request that we update the information such that it is complete.
- Right to erasure – you have the right to request us to delete personal data that we hold about you. This is sometimes referred to as a right to be forgotten.
- Right to restrict processing or object to processing – you have the right to request that we no longer process your personal data for particular purposes or object to our processing of your personal data for a particular purpose
- Right to data portability – you have the right to request us to provide you or a third party with a copy of your personal data in a structured commonly used readable format
- Right to object to processing – you have the right to object to processing of data under certain conditions.
If you wish to exercise any of the rights set out above, please contact contact@globerefund.com .
We ask that you ensure that all data which you furnish to us is kept accurate and up-to-date at any stage. If we were processing personal data on the basis of your consent, you may withdraw consent at any time. This does not affect the lawfulness of processing which should take place prior to its withdrawal.
You can object to the processing of your personal data for direct marketing purposes at any stage. If you are unhappy with how we process your personal data we ask that you contact us so that we can rectify the situation. You may lodge a complaint with the Supervisory Authority of the Irish Supervisory Authority of the Data Protection Commission.
Cookies
Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. When you visit our website we may collect information from you automatically through Cookies or similar technologyto improve the user experience on our website. For further information visit Allaboutcookies.org
You can set your browser not to accept Cookies. In certain cases however, if you decline to accept Cookies certain of our website features may not function as a result.
Automated decision-making and profiling
We do not use personal data for the purposes of automated decision-making or profiling
Changes to this Privacy Notice
Our privacy notice may change from time to time. Please check back frequently to see if there are updates or changes to our privacy policy which have been implemented. If you do not agree to these changes or any of the terms of this policy, please do not continue to use this website to submit personal information.
Date 23rd of September 2019