PRIVACY POLICY

FRAMEWORK COMPUTER CONSULTANTS LIMITED (trading as DIGITARY) (“We“) are committed to protecting and respecting your privacy.

This policy (together with our Terms of Use and, in the case of organisations with whom we have separate contracts, any applicable terms of service, and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Terms defined in any referenced terms of service shall have the same meaning in this policy unless the context indicates otherwise. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (‘GDPR’), the data controller is:

  • In respect of any digital documents or data issued through Digitary’s systems and/or any information contained within them – the Issuing Organisation; and
  • In respect of any other information provided to Digitary by a user of the system – Digitary.

INFORMATION WE MAY COLLECT

We may collect and process the following data:

  • Information that is provided by any person filling in forms on our site digitary.net (our site).
  • Information that is provided by any person (whether on their own behalf or as agent, employee or contractor of another person) using the services available through our site (together, the “Service“). This information will include without limitation the personal information (such as name, age, email address, contact details, certification of degrees, transcripts etc.) of any person whose details are stored as part of use of the Service.
  • Information provided by any person reporting a problem with the site and/or the Service.
  • If any person contacts us, we may keep a record of that correspondence.
  • Details of transactions carried out through our site.
  • Details of visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that are accessed by users.

COMPANIES OR EMPLOYERS

We will process all information uploaded by you to our site on the basis that you have complied with all your own obligations in relation to the Acts and GDPR. In particular, we will operate on the basis that, where you are a company, employer or contractor, that you have obtained the express consent of all employees, contractors, agents, sub- contractors, customers or other persons whose personal information is uploaded by you to our site. Do not upload any personal information belonging to any person to our site without the express consent of that person.

IP ADDRESS

We may collect information about your computer, including where available your IP address, operating system and browser type, for administration and ongoing security monitoring of our systems.

COOKIES

Our site uses cookies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose
PLAY_SESSION Session Cookie This cookie is essential for our site to enables us to:

  • Recognise you when you have logged in to our site, so that we can make your browsing experience more convenient.
  • Store information about your preferences
  • Estimate our audience size and usage pattern.

Please note that third parties (including, for example, advertisers or providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Except for essential cookies, all cookies will expire after 30 minutes of inactivity on our site.

WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you is, in the first instance, stored and processed within the European Economic Area (“EEA“). Your data may be accessed by us from time to time as part of the provision of the Service. Your data may also be accessed by a registered organisation who issues Secure Electronic Documents to you (“Issuing Organisation“), as part of provision of the Service, and/or by a third party whom you have given your consent to access your Secure Electronic Document(s) (“Receiving Organisation“). Your data may be transferred to, and stored at, a destination outside the EEA to facilitate processing by an Issuing Organisation and/or Receiving Organisation with whom you have interacted via the Service.

Staff of Issuing Organisations may be involved in uploading any Secure Electronic Document, processing any Secure Electronic Document, or (at your request) receiving and reviewing any Secure Electronic Document. Any such staff may also have sight of certain limited administrative personal information that relates to you, such as unique identifier, education and qualification details, name, address and other related information. Where applicable, they may also have access to data as part of the processing of your payment details (if any) and the provision of support services (if any). By submitting or agreeing to the submission of personal data on your behalf, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Payment transactions (if any) will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

USES MADE OF THE INFORMATION

We use information held about you in the following ways:

  • To provide the Service, which includes in particular the provision of your personal data to Receiving Organisations. This includes both Secure Electronic Documents and other information relating to you which we hold and which you may send to a Receiving Organisation via the Service.
  • To ensure that content from our site is presented in the most effective manner for you and for your computer.
  • To provide you with information, products or services that you request from us.
  • To carry out our obligations arising from any contracts entered into between you and us.
  • To allow you to participate in interactive features of our service, when you choose to do so.
  • To notify you about changes to our service.

We may also use your data in order to provide you with information about goods and services which may be of interest to you. We may contact you about these through our site, by email or by other electronic means. We will not provide any personal data to any third parties for this purpose. By registering for the Service you consent to the use of data in this manner.

We may also aggregate information that is collected from users on our site. This information will not identify any person. We may also provide third parties with this aggregate information about our users that does not identify them.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 155 of the Irish Companies Acts, 1963.

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Digitary or a substantial part 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 legal obligation, or in order to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of Digitary, our customers, or others.

USER RIGHTS

Users are in control of the use of personal data for marketing purposes on an opt-in basis. User settings can be viewed or changed in the user’s account preferences.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

DESTRUCTION OF DATA

We may destroy or otherwise dispose of any of personal data we collect from you unless we receive, no later than ten days after the end of any agreement with you (whether under terms of service or otherwise) or a trial period (where no contract is entered into immediately following the trial period), a written request for the delivery to you of the then most recent back-up of any of your personal data we hold. We shall use reasonable commercial endeavours to deliver the back-up to you within 30 days of our receipt of such a written request.

You may lodge a request to have any data that we have collected from you erased. Your request should be lodged in writing and sent to dataprotection@digitary.net. We will review your request and act on it in accordance with the as per the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (‘GDPR’). Please note that in cases where we are not the Data Controller, we may have to refer such requests to the Data Controller for processing.

ACCESS TO INFORMATION

The current legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the legislation. You may lodge a Subject Access Request to have a copy of any of your personal data that we hold sent to you. You should lodge the request in writing via email to dataprotection@digitary.net. The request will be acted on in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (‘GDPR’).

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, may be notified to you by e-mail.

USE OF SERVICES PROVIDED THROUGH OUR SITE

Contracts for the use of Services through our site are governed by our Terms of Use.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to dataprotection@digitary.net.