Privacy Policy

Spotlight Skills Ltd. (“we”, “us” or “our”) welcomes you to NameDown - https://namedown.ie (the “Website”). Spotlight Skills Ltd. is our legal company name and this Privacy Policy relates to our NameDown service. To keep things simple, we will refer to us as 'NameDown' throughout this Privacy Policy. NameDown is based in Ireland.

NameDown takes data privacy seriously and we are committed to protecting and respecting your privacy in accordance with applicable data privacy regulations. This privacy notice describes how and why we, as Data Controller, obtain, store and process personal data. We are the Data Controller when we are responsible for determining how and why your personal data is processed. We will process your personal data fairly, lawfully and transparently.

If you would like to understand how we process data as a Data Processor, please see our Data Processing Addendum (DPA), which can be found in our Privacy Centre. As the nature of our offering involves the processing of children’s and sensitive data, we want to assure you that we will only process this data in line with the instructions received from our School in accordance with the DPA.

In the spirit of data privacy principles, we will only collect and use your personal data for the following purposes, to:

• Provide our services
• Improve our services
• Make our marketing more relevant
• Meet our legal responsibilities

Please do not hesitate to contact us if you have questions in addition to the information provided in this Privacy Notice at info@namedown.ie.

'Personal data’ means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Depending on the type and level of engagement you have with us, we may collect the following categories of personal data:

Information you provide to NameDown

• Identifying and Demographic Information: such as your full name, email address and phone number (if provided)
• Billing Information: such as payment preferences, address, bank account details (if provided)
• Communications: such as a record of our interaction with you using one or multiple of the following; direct messages, emails, posts, phone conversations
• User Feedback: while using our services, occasionally you may be asked to provide feedback. Providing this feedback is entirely optional.

When you visit our website, we may automatically collect technical data such as:

• Usage data: (if permitted) we collect certain information related to your device, such as your device’s IP address, what pages your device visited, and the time that your device visited our website (for more information please see 'Our Use of Analytics' section)
• Cookies: (if permitted) your IP Address and other information provided to us by cookies (for more information please see our Cookies Policy)

Information We Process on Behalf of Schools

When Schools use the Service, they may collect Personal Data such as first and last name, usernames, email addresses, postal addresses, phone numbers, job titles, transactional information (including Services purchased), as well as any other contact or other information they choose to collect and upload to our systems in connection with the Services. We do not control the types of Personal Data that our Schools may choose to collect or manage using the Service. We store School Data on our service providers' servers but process it as a processor under our Schools’ instructions and in accordance with the DPA, which prohibits us from using the information except as necessary to provide and improve the Service and as required by law.

Our Schools control and are responsible for correcting, deleting or updating the information they process using the Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to NameDown for processing purposes.

Special Categories Personal Data

As part of using the Service our Schools may collect and process sensitive personal information, such as Gender, Religion, Country of Birth, Nationality, Health Conditions and Special Educational Needs. This data is processed by Schools for information and admissions selection purposes. This information is considered Special Categories Personal Data under GDPR. We will only process Special Categories Personal Data under the direction of our School and in accordance with the DPA.

Children

While our services are designed for a general audience, we will not knowingly collect any data from children under the age of 16, without the consent of a parental guardian to do so. If you are under the age of 16, you are not permitted to use or submit your data to the website.

It is the nature of our Services that our Schools might collect and process data relating to children. Our Schools are the Data Controllers of this data and therefore the responsibility rests with them to ensure that relevant consent is collected and that this information is processed in compliance with data privacy laws. As Data Processors of this data, we will only process this data in line with the instructions received from our School in accordance with the Data Processing Addendum.

We may collect your personal data in one of the following ways:

• When you create an account with us
• When you provide additional information directly into our products and services
• When you visit our website
• When you express an interest to use our services
• When you contact us for service related queries
• When you engage with us on social media
• When you review our services
• When you interact with our website (see our Cookies Policy for more details)
• When you apply for an employment vacancy with us

We may also receive data about you from various third parties, including:

• Technical data from our website and cookies providers. Please see further information in the section entitled 'Our Use of Cookies'
• Contact and/or transactional data from our trusted third-party providers. Please see further information in the section entitled 'How We Share Your Data'

We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it. We will only collect personal data from you when:

• We have your consent to do so, or
• We need your personal data to perform a contract with you, or
• We are pursuing our legitimate interests in a way that you might reasonably expect to be a part of running our business and that does not significantly impact your interests, rights, and freedoms. For example, communicating with you if we have a sufficient legal ground based on the e-marketing laws in Ireland
• We have a legal obligation to collect or disclose personal data from you (for example, in suspected instances of fraud we may need to give personal data to relevant government bodies).

We process your personal data in order to fulfil any of the activities below:

• Setting up an account with us
• Providing, operating, and maintaining our services
• Providing communications to existing Schools or subscribed users
• Processing and completing transactions, and sending related information, including transaction confirmations and invoices
• Managing our Schools’ use of our services, responding to enquiries and comments, and provide School service and support
• Sending Schools technical alerts, updates, security notifications, and administrative communications
• Investigating and preventing fraudulent activities, unauthorised access to our services, and other illegal activities

We sometimes share your personal data with our trusted categories of third parties we use to conduct our business. Our trusted categories of third parties include:

• Website provider
• Cloud service (SaaS) providers
• Social media providers
• Professional services providers (e.g., our lawyers, accountants, and insurance providers)
• E-marketing providers
• Advertising providers
• Recruitment partners
• Payment providers

A full list of our data sub-processors can be found in our Privacy Center on our website.

As part of fraud monitoring and prevention, we may be legally required to share your personal data with government bodies and law enforcement. Please note that these bodies may retain a record of the information that we provide to them for this purpose.

We may send you marketing communications, product information and promotional offers:

• If you have consented to receiving such communications from us, or
• If you have recently created an account with us and not opted out of receiving such communications from us, or
• If you have bought a product or service from us and have not opted out of receiving communications from us, or
• If you are from a country where the laws permit us to send you such communications

You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us at any time:

• You can unsubscribe or 'opt-out’ by using the unsubscribe link included in the footer of any marketing message from us; or
• You can unsubscribe by managing your preferences using the Privacy Center on our website

We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers it may take a few days for any opt-out request to be implemented.

Our website uses cookies. They help us to provide you with the very best experience when you browse our website and to make improvements to our website. You can accept or reject cookies by clicking on the cookie consent banner on our website or by navigating to the 'Cookies Preferences’ Area in our Privacy Center on our website.

For detailed information on the cookies which we use and the reasons why we use them, please refer to our Cookie Policy and Cookie Declaration in our Privacy Center on our website.

Our website may include links to social media platforms and other websites. If you follow a link to any of these platforms or websites, please note that they 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 their platforms or websites.

The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.

We have put in place physical, electronic and managerial security procedures in the storage and disclosure of your personal data to protect it against accidental loss, destruction or damage. Nevertheless, any data transmission over the internet or by any other means can never be fully secure, such is the character of the internet, and provision of personal data by you to us is at your own risk. We take all reasonable measures to protect your personal data by putting appropriate technical and operational security measures in place.

When we disclose your personal data to trusted third parties (for the purposes set out in this Privacy Notice and our list of Data Sub-Processors), we require all third parties to have appropriate technical and operational security measures in place to protect your personal data, and we work with them to ensure that your data privacy rights are respected. Where your personal data is shared with a third party, it must only be used for the purposes for which it was supplied.

In the unfortunate event of a personal data breach, we will notify you and any applicable data protection authority when we are legally required to do so.

We will not keep your personal data for longer than is necessary and when we no longer need to keep it, we will securely destroy, delete or anonymise it in line with our Data Retention policy.

Having obtained your consent (or other legal basis) to contact you, we will retain your personal data for marketing and analysis purposes until you withdraw your consent or unsubscribe. If you choose to withdraw your consent or unsubscribe from marketing, we will delete your personal data from our systems, unless we have another legal basis to retain it, which may include performance of our contract with you or to maintain your contact details on an 'unsubscribed list' to ensure we do not send you further communications.

We may need to retain your personal data to satisfy our legal obligations, to deal with complaints and queries, in order to resolve, litigate or defend a dispute and to prevent fraud and abuse.

Our servers are located in the European Union.

However, the personal data we collect from you may be transferred to, and stored at, destinations outside the European Economic Area ("EEA") using legally provided mechanisms to lawfully transfer data across borders. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the provision of our services to you. We will take all steps necessary to ensure that your data is treated securely and in accordance with this privacy notice.

Please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when transferring your personal data outside the EEA – info@namedown.ie

You have rights under data privacy laws and NameDown is committed to you being able to freely exercise your Rights. Where possible, we have incorporated automated tools on our website that enable you to facilitate your rights in real-time. Use the NameDown Privacy Center to access and manage your personal data that we process and manage your preferences. You are not required to pay any charge for exercising your rights. Your rights include, under certain circumstances, the right to:

· Be informed: you have the right to be informed if and how your personal data is being processed.

· Access, rectification, or erasure: you have the right of access to personal data we hold about you in our records. You are also entitled to have your personal data corrected if it is inaccurate, or to have it erased if we do not have a legitimate reason for retaining your data.

· To request data portability: for personal data which you have provided to a controller, where processing was based on your consent, or where processing is done by automated means, you have the right to obtain a digital copy of your personal data, request the transfer of your personal data to another company or request to move your data from one IT system to another in a safe and secure way.

· To request restriction of processing: you have the right to restrict the processing of your personal data where you are contesting the accuracy of that information, you have objected to processing (as described below), or where the processing is unlawful. Where processing is restricted, we are may need to retain sufficient information about you to ensure that the restriction is respected in future.

· To object to automated decision-making including profiling: you have the right not to be the subject of any automated decision-making or profiling by us.

· To withdraw consent: in cases where we are relying on your consent for the processing of your personal data, you have the right to withdraw your consent at any time. In respect of the e-marketing we conduct, an unsubscribe option is included with every e-marketing communication we send.

· To object to processing: where your personal data is being processed based on the legitimate interests of a data controller or third party, you have the right to object to that processing.

· To complain to the relevant supervisory authority: should you have any concerns or complaints regarding the way in which we process your data, you also have the right to make a complaint to the relevant European Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach a Supervisory Authority, so please do contact us in the first instance info@namedown.ie. The contact details of European Supervisory Authorities can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en

· Cookies Preferences: you can accept or reject cookies by navigating to the ‘Cookies Preferences’ Area in our Privacy Center on our website. You can also do so by adjusting your web browser controls. Please consult our Cookie Policy for more information about our use of cookies on the website and how to accept and reject them.

We may update this privacy notice from time to time and we will inform all our paying Schools and users subscribed to receive communications from us of any changes.

We welcome feedback and are happy to answer any questions you may have about your data. You can contact us at:

Email: info@namedown.ie

Address: NameDown

Kilkenny Research & Innovation Centre,
Burrell’s Hall,
St. Kieran’s College,
College Road,
Kilkenny

R95 TP64

Effective Date: June 12th, 2023

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