1. PURPOSE AND SCOPE OF NOTICE
This notice is intended to explain how your Personal Data
will be handled by Smurfit Kappa Group (the "Group", "we",
"us" and "our") and sets out the information including the
personal information detailed below relating to you ("Personal Data")
that will be collected and processed by the Group and/or on its behalf by its
third party service providers in the context of your dealings with us.
2. APPLICATION OF THIS NOTICE
IMPORTANT: please note that this Notice, while intended to
be as complete and accurate as reasonably possible, is not exhaustive and may
be updated from time to time in accordance with section 7 of this Notice.
3. WHAT PERSONAL DATA WE PROCESS
If you use the Website, information about your visits to our
Website, your location and IP address, the browser software you use and the
date and time you access the Website.
4. WEBSITE USERS
If you visit our Website we may obtain, collect and process your Personal Data
for the following purposes:
To provide, improve, test and monitor the effectiveness of
To monitor metrics such as total number of visitors, traffic
data and demographic patterns;
To ensure content on the website is presented in the most
effective manner for you and to enhance your use of the website; and
To notify you of any changes to the Website and/or our
We obtain, collect and process this personal information
based on our legitimate interest in ensuring that the Website is operating
smoothly and in order to analyse which content is of most interest to visitors.
This helps us to keep the Website available and to improve your experience when
you visit the Website.
5. RETENTION OF YOUR PERSONAL DATA
In general, we expect to keep your Personal Data for what we
deem a reasonable period. Once we have determined that we no longer need to
hold your Personal Data, we will delete it from our systems.
Please note that in certain circumstances, we may hold your
data for a longer period, for example, if we are processing an ongoing claim or
believe in good faith that the law or a relevant regulator may reasonably in
our view expect or require us to preserve your Personal Data.
6. YOUR RIGHTS AND HOW TO EXERCISE THEM
You have a number of rights in relation to your Personal Data, which are set
out in this section. In particular these rights include the right to object to
processing of your Personal Data where that processing is carried out for our
legitimate interests. Note that in certain circumstances these rights might not
Right to Object
You have a right to object at any time to the processing
of your Personal Data where we process your Personal Data on the legal basis
of pursuing our legitimate interests. When we process your Personal Data
based on our legitimate interests, we make sure to consider and balance any
potential impact on you and your data protection rights. We will not use your
Personal Data for activities where our interests are overridden by the impact
on you (unless we have your consent or are otherwise required or permitted by
Member State or European Union law).
Right of Access
You have the right to request a copy of the Personal Data
held by us about you and to access the information which we hold about you.
We will only charge you for making such an access request where we feel your
request is unjustified or excessive.
Right to Rectification
You have the right to have any inaccurate Personal Data
which we hold about you updated or corrected.
Right to Erasure
In certain circumstances, you may also have your personal
information deleted, for example if you exercise your right to object (see
below) and we do not have an overriding reason to process your Personal Data
or if we no longer require your Personal Data for the purposes as set out in
Right to Restriction of Processing
You have the right to ask us to restrict processing your
Personal Data in certain cases, including if you believe that the Personal
Data we hold about you is inaccurate or our use of your information is
unlawful. If you validly exercise this right, we will store your Personal
Data and will not carry out any other processing until the issue is resolved.
Right to Data Portability
You may request us to provide you with your Personal Data
which you have given us in a structured, commonly used and machine-readable
format and you may request us to transmit your Personal Data directly to
another data controller where this is technically feasible. This right only
arises where: (1) we process your Personal Data with your consent or where it
is necessary to perform our contract with you; and (2) the processing is
carried out by automated means.
We will provide you with information on any action taken upon your request in
relation to any of these rights without undue delay and at the latest within 1
month of receiving your request. We may extend this up to 2 months if
necessary however we will inform you if this arises. Please note that we may
ask you to verify your identity when you seek to exercise any of your data
You also have the right to
lodge a complaint with the Data Protection Commission. For further
information see www.dataprotection.ie.
7. CHANGES TO THIS NOTICE & QUESTIONS
We may amend this Notice on occasion, in whole or part, at
our sole discretion. Any changes will be effective immediately upon
communicating the revised notice to you.
If at any time we decide to
use your Personal Data in a manner significantly different from that stated in
this notice, or otherwise disclosed to you at the time it was collected, we
will notify you by e-mail or post, and you will have a choice as to whether or
not we use your Personal Data in the new manner.
If you have any questions, comments or concerns about the
way your Personal Data are being used or processed by the Company, please
submit your question, comment or concern in writing to our Data Protection
Representative at firstname.lastname@example.org.