PRIVACY POLICY


BACKGROUND:

Haay Media Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.haay.com (‘Our Site’) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it.

  1. Definitions and Interpretation
    In this Policy the following terms shall have the following meanings:

    “Cookie” means a small text file placed on your computer or device by Our Site. Details of the Cookies used by Our Site are set out in Part 14, below;
    “Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the General Data Protection Regulation;

  2. Information About Us
    Our Site is owned and operated by Haay Media Limited a limited company registered in Ireland under company number 649817.
    Registered address: Amesbury, 8 Silchester Court, Glenageary, Co. Dublin. A96 W6Y6, Ireland.
    Data Protection Officer: Haay Data Protection.
    Email address: hello@haay.com
    Postal address: Amesbury, 8 Silchester Court, Glenageary, Co. Dublin. A96 W6Y6, Ireland.

  3. What Does This Policy Cover?
    This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

  4. What Is Personal Data?
    Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

  5. What Are My Rights?
    Under the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018, you have the following rights, which we will always work to uphold:
    1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
    2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
    3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
    4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
    5. The right to restrict (i.e. prevent) the processing of your personal data.
    6. The right to object to us using your personal data for a particular purpose or purposes.
    7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
    8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
    9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

    10. For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
      It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

      Further information about your rights can also be obtained from the Data Protection Commissioner.
      If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Data Protection Commissioner.
      We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

  6. What Data Do You Collect and How?
    Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy. We do not collect any ‘special category’ or ‘sensitive’ personal.

  7. How Do You Use My Personal Data?
    Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
    With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or phone with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

  8. How Long Will You Keep My Personal Data?
    We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

    1. Identifying Information including name: We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Haay Media Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
    2. Contact information including email and phone: We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Haay Media Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
    3. Subject information including your qualifications (for tutors) and subjects (for students): We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Haay Media Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual needs.
    4. Chat messages exchanged, including all media types such as text, images, audio, and videos: We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. Haay Media Limited is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual needs.
    5. Technical information including IP address, browser type, and link source: 2 years

  9. How and Where Do You Store or Transfer My Personal Data?
    We will only store or transfer your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

    The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:
    1. limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
    2. procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Data Protection Commissioner where we are legally required to do so;

  10. Do You Share My Personal Data?
    We contract with the following third parties to supply certain products and services.

    If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  11. How Can I Control My Personal Data?
    In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you will be given the option to opt-out from future communication.

  12. Can I Withhold Information?
    You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
    You may restrict our use of Cookies. For more information, see Part 14 below.

  13. How Can I Access My Personal Data?
    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. This Subject Access Request must be accompanied by a fee of €6.35. Please note the following important requirements:

    1. We reserve the right not to process an access request that is not accompanied by proof of identification;
    2. We shall not process an access request unless the prescribed fee of €6.35 is received by cheque or postal money
    3. order made payable to Haay Media Limited; and
    4. We do not accept access requests via telephone, e-mail or text message.

    We will respond to your subject access request within 1 month. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

  14. How Do You Use Cookies?
    Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

    All Cookies used by and on Our Site are used in accordance with current Cookie Law.

    By continuing to browse the Site you are agreeing to our use of cookies and the cookies notice at the bottom of your browser will disappear. If you block our use of cookies, you may be unable to access certain areas of our Site and certain functions and pages will not work in the usual way. Doing so may also affect our ability to update this Site to cater for user preferences and improve its performance.

    Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them. The following first-party Cookies may be placed on your computer or device:

    Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and services offered through it.

    The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

    In addition to Google Analytics we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom's use of cookies, please visit https://www.intercom.com/terms-and-policies#cookie-policy. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third party applications such as Stripe. You should consult these third parties' privacy notices for further information on their use of your personal data. As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/terms-and-policies#privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/terms-and-policies#terms. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

    In addition to the controls that we, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

    The links below provide instructions on how to control Cookies in all mainstream browsers:
    1. Google Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB
    2. Microsoft Internet Explorer: https://support.microsoft.com/en-us/kb/278835
    3. Microsoft Edge: https://support.microsoft.com/en-gb/products/microsoft-edge (Please note that there are no specific instructions at this time, but Microsoft support will be able to assist)
    4. Safari (macOS): https://support.apple.com/kb/PH21411?viewlocale=en_GB&locale=en_GB
    5. Safari (iOS): https://support.apple.com/en-gb/HT201265
    6. Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-Cookies-website-preferences
    7. Android: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=en (Please refer to your device’s documentation for manufacturers’ own browsers)
    You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

    It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

  15. How Do I Contact You?
    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of Haay Data Protection Officer;
    Email address: hello@haay.com
    Postal Address: Haay Media Limited, Amesbury, 8 Silchester Court, Glenageary, Co. Dublin, A96 W6Y6, Ireland.

  16. Changes to this Privacy Policy
    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 14/04/2021.