Customer privacy notice

19th October 2020 (updates include website cookie policy and general edits)

Action24 – Privacy Notice

Introduction
We are Action Alarms Limited T/A Action24 (“we”, “us”, “our” or “Action24”). Our registered office is at Unit C1, Three Rock Road, Sandyford Business Park, Dublin 18, D18N9P6
This notice has been developed to ensure our customers, website users and all other individuals whose personal data is processed under the control of Action24 feel confident about the privacy and security of personal data, and to meet our obligations under the Data Protection Acts 1988 to 2018 and the EU Regulation 679/2016 General Data Protection Regulation (“Data Protection Law”). Under Data Protection Law, ‘personal data’ is information that identifies you as an individual or is capable of doing so

Action24 is a “Data Processor” and a “Data Controller” which means that we are responsible for processing and controlling data on behalf of our Customers. We are required – under data protection legislation – to notify you of the information contained in this privacy notice.

Why does Action24 process your personal data?

Action24 uses your personal data in order to establish and maintain customer relationships and to fulfil the agreement regarding the delivery of security services. This includes processing for identifying and contacting you as a customer, users you have provided access to, contact persons or other persons related to installing security systems and optional enhancements, service and maintenance, monitoring and following up security situations and any additional services, as well as personalising the service. The information is also used to ensure that outsiders cannot access information and functionality of the service, to carry out identity and other checks prior to providing services to you, and to fulfil legal obligations.

In addition, Action24 processes your personal data to send you responses to, and follow up on, your enquiries, for the improvement and development of existing and new products and services, and to contact you regarding important information, news, offers, and information on products and services from Action24 (including following the conclusion of your contract with Action24 for the purposes of providing necessary services following the conclusion of the contract and facilitating a future return to monitoring), unless you do not consent or choose to opt-out from such communication.

What categories of personal information do we collect, process and what is the legal basis for processing this information?

Existing Customers

  1. CCTV images and recordings: We collect and process CCTV images and recordings in order to perform the contracted security services as part of your service agreement with Action24.
  2. Email addresses, postal addresses and contact numbers of our customers and nominated account contacts: We collect and process this information in order to perform the contracted security services as part of your service agreement with Action24
  3. Bank Details of Customers: We collect and process bank details in order to receive payment for the contracted security services provided to you by Action24.

Prospective customers

  1. Information from telephone calls, enquiries, sales activities and contact forms with web ID / origin, e-mail, SMS and chat dialogue, as well as data from accepted cookies, and in some cases telephone recordings. The legal basis for providing this information is based on consent. You have the right to withdraw this consent at anytime by following the unsubscribe procedure on communications sent to you. Alternatively email data@action24.ie to withdraw this consent.

How do we use your personal data?

1. To comply with applicable law(s) (for example, to comply with a search warrant, subpoena or court order)
2. As part of the carrying out of our contracted security services to you.
3. To market and re-market our services to you.

If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Use of Cookies
The use of cookies on our website is regulated in our Cookie Policy, where you will find information about the use of cookies, and may choose to accept cookies and change which categories of cookies you accept. See here for more details on our website user and cookie policy.

Disclosing your personal data to others
We will not share your personal data with others, unless:
– We are under a duty to disclose or share your personal details to comply with any legal obligation or in order to enforce or apply our rules.
– Our business enters a joint venture with – or is sold to or merged with – another business. We may then share your personal details with our new business partners or owners.
– It is necessary as part of our contract with you.

Whenever we disclose your personal data to third parties, we will only disclose that amount of your personal data necessary to meet such business need or legal requirement. Third parties that receive your personal data from us must satisfy us as to the measures taken to protect the personal data such parties receive, in accordance with Data Protection Law and as stated in this Declaration. Appropriate measures will be taken to ensure that all such disclosures or transfers of your personal data to third parties will be completed in a secure manner and pursuant to contractual safeguards.

We may share your personal data with those partners/companies engaged by Action24 to assist in the provision of our services to you. These companies process your personal data on our behalf for the limited purpose that is necessary for them to perform the assistance and improve agreed products or services in accordance with existing data processing agreements. Otherwise, your personal data will not be disclosed to others unless you have given your consent to this, for example in connection with a benefit/special offer or bonus program, or if Action24 is legally obligated to make such disclosure.

Where do we store your personal data?
1. Our secure on-site server, located in our offices at Sandyford, Dublin 18
2. Secure cloud based servers that we use to access our cloud based third party systems. Information held on our cloud based servers is encrypted, can only be accessed by authorised users (using MFA) and is tracked and monitored for suspicious logins and activity.

How long do we retain personal data sent to us by you?
We only keep your personal data for as long as is necessary to fulfil the purposes we collected it for, 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.

How secure is your data?
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Transfer of data outside EU/EEA
Your personal data is processed within the EU/EEA area, or in a third country pursuant to EU’s standard model clauses, and in accordance with Data Protection Law. Action24 continues to monitor all developments regarding the legal bases for the international transfer of personal data and shall update its processes as necessary

Your rights
The legal basis for processing your personal data depends on why we are processing that personal data. When it comes to the provision of services to our customers, our basis is that it is necessary to do so to fulfil customer agreements and deliver agreed products and services, or to take steps at your request prior to entering into such customer agreements or delivering such services. It may also be necessary to process your personal data to fulfil legal obligations to which we are subject. When it comes to other purposes, the legal basis will be your consent or a legitimate interest. According to  Action24’s assessment, we have a legitimate interest in responding to and following up your enquiries about our products and services, and in contacting you regarding news, offers, and products and services from Action24 [both during and after our provision of services to you] (unless you do not consent, opt out or otherwise object to us doing so), with this legitimate interest being the effective conduct of our business and providing our customers with the best possible service. Action24 does not make decisions based solely on automated processing, but registered personal data and other data are used to select or customise our contact with you and provide you with better follow-up and experience.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of any personal information to another party, please write to us at at Action24, Unit C1, Three Rock Road, Sandyford Business Park, Dublin 18 or email data@action24.ie.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Your right to complain
If you have any problems with the way that we are processing your personal data, you should contact the Data Protection Commissioner.
The DPC can be contacted by telephone on 1890 25 22 31 – or by email at info@dataprotection.ie .

You can also visit the DPC website by following this link: https://www.dataprotection.ie

Changes to our privacy policy
We keep our privacy policy, website user policy and cookie policy under regular review and any updates are will be posted on our website.
If you have any questions about this privacy notice or how we process your personal information, please contact us on data@action24.ie

Action24 linebreak