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Updated: 13 September 2023
2.1 Kinsale Connect and our website comply with the DPA (Data Protection Act 1998) and GDPR (General Data Protection Regulation). For the purposes of data protection law, we are the data controller of your personal data. There are legal bases under data protection law for processing your personal data.
2.2 Kinsale Connect is based in the Republic of Ireland. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to other EU countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. In certain circumstances, your personal data may be transferred to countries outside the European Economic Area (EEA) as outlined below. For more information, visit www.dataprotection.ie.
3.1. Personal data is information that identifies you as an individual or is capable of doing so. To allow us to provide our products and services and to run our business, we collect and process various categories of personal data throughout your relationship with us, including information such as your name, contact details, online booking and seat reservation details, payment card details, your Internet Protocol (IP) address and enquiry information.
4.1. We may obtain your data from a variety of sources, including information you give to us via email, phone, application forms, social media, newsletter subscriptions or information that we gather or learn from how you use our services (i.e. via our website’s online booking system and seat reservation system).
4.2 We also collect data via cookies (See Section 5).
6.1 We only use your data when necessary for our lawful business activities, such as providing products and services, complying with laws and regulations, ensuring the day-to-day operation of our business, managing security and improving our offerings.
6.3 We also process your personal data where necessary for purposes such as obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, for auditing and tax purposes, or for the establishment, exercise or defence of legal claims whether in court proceedings or in an administrative or out-of-court procedure. We may process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another person.
6.4 Under data protection law, there are legal bases for processing your data:
a) Usage Data: We may process data about your use of our website, including your IP address, geographical location, browser type, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use. This information helps us analyze website usage and improve it.
b) Service Data: We may process your personal data that is provided in the course of the use of our services. The service data may be processed to provide you with the products and services you request in relation to your bus journey (including the reservation of seats and where it is necessary in terms of our contractual obligation to supply you with tickets you have booked for Kinsale Connect services), for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the proper administration of our website and business. We will process your data to the extent required to deliver the service requested.
c) Transaction Data: Information related to transactions, such as purchases of services – including payment details, contact details, payment method, card details, transaction details and purchase history – is processed to supply purchased services and maintain transaction records as part of the contract between you and us. We will process your data to the extent required to deliver the service requested.
d) Correspondence & Enquiry Data: Information in communications or enquiries sent to us may be processed for communication, relevant marketing and recordkeeping purposes. The correspondence and enquiry data may include the communication content and associated metadata. Our website will generate the metadata associated with communications made using the website contact forms. When you contact us, we may request your affirmative, positive consent to use your contact information for marketing or other business purposes. In the event you do not consent to the use of your contact information for marketing or other business purposes, your data will not be used for those purposes.
e) Notification Data: If you subscribe to our email notifications and newsletters, we process this data to send you relevant notifications and newsletters with your consent.
f) Customer Relationship Data: Information concerning customer relationships, including contact details and communication records, is processed for managing relationships, communication, recordkeeping and promoting services.
6.5 Your authorization allows us to retain and use your data for the above-quoted purposes and to transmit it to our own offices. In doing so, we make every effort to ensure the safety of your personal data.
7.1 We will not sell, share, trade, rent or give away your personal data, excepting disclosure as described below.
b) We may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another person. We may provide information when obliged to do so under data protection law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime and the apprehension or prosecution of offenders. We may also provide information for the purpose of safeguarding national security. In addition, we may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
c) Social media: You may be able to access third-party social media services through our website or before coming to our website. When you are registered with your social media account, we will obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalize your use of our website. We may also use social media plugins on our website. As a result, your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the policies of these third-party social media providers to find out more about these practices.
7.4 We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Irish and EU law on data protection rules.
7.5 While we try our best to safeguard your information once we receive it, no transmission of data over the internet or any other public network can be guaranteed to be 100% secure. We cannot prevent the use (or misuse) of such personal data by others.
8.1 We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means. We must also consider periods for which we might need to retain personal data in order to meet our legal obligations, for taxation purposes or to deal with complaints and queries, and to protect our legal rights in the event of a claim being made.
8.2 We will securely delete or destroy your personal data when we no longer need it. We will also consider if and how we can minimize over time the personal data that we use and if we can anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
9.1 Users contacting us through our website or via email do so at their own risk. Users provide all personal details requested at their own risk. We will never ask you for any passwords.
9.2 If you actively opt-in to receive marketing communications from us via our newsletter subscription, you consent to the processing of your data to send you such communications, which may include adverts for our services, special announcements, surveys, relevant information about Kinsale Connect and industry news, and links to third-party websites. We retain a record of your consent.
9.3 Marketing emails may contain tracking beacons / tracked clickable links or similar technologies in order to track user activity. Where used, these technologies may record a range of user data relating to engagement, demographics and geographics.
9.4 Users can unsubscribe to these emails at any time through the contact form or by emailing us directly or by other means specified in the footer of marketing emails (i.e. by clicking “unsubscribe” at the bottom of the marketing emails). If you unsubscribe, it may take up to five business days for your new preferences to take effect.
10.1 Precautions have been taken to ensure only genuine downloads are available to users on our website. However, any downloadable documents, files and software are downloaded and used by our website users at their own risk. In addition, we accept no responsibility for downloads provided by advertisers on our website or other external third-party websites; we advise users to verify their authenticity using antivirus software or similar applications.
12.1 Kinsale Connect maintains official profiles on social media platforms. You are advised to verify the authenticity of such profiles before engaging with, or sharing information with, such profiles. We will never ask you for your passwords on these platforms. Users are advised to conduct themselves appropriately when engaging with us on social media.
12.2 Our website features social sharing buttons, which enables the sharing of content from the web pages of our website directly to social media platforms. You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page. You should familiarize yourself with the privacy and usage policies of the social media platforms you use.
13.1 We follow strict security procedures in the storage and disclosure of your personal data and to protect it against accidental loss, destruction and damage. The data you provide us for the purpose of completing bookings and payments is protected using SSL (Secure Sockets Layer) technology. SSL is the industry-standard method of encrypting personal information and credit card details so they can be securely transferred over the internet. All payment details are transmitted over SSL across dedicated network infrastructure (Multiprotocol Label Switching – MLPS) and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).
14.1 We respect your rights to privacy and to the protection of your personal data. You have rights over your personal data under data protection law and can exercise these rights. You should familiarize yourself with the relevant laws and guidance from the regulatory authorities for a full explanation of these rights (visit https://www.dataprotection.ie/).
14.2 You have certain legal rights to control your data and the manner in which we process it. This includes:
a) a right to get access to your personal information;
b) a right to request us to correct inaccurate information or update incomplete information;
c) a right to request that we restrict the processing of your information in certain circumstances;
d) a right to receive the information you provided us in a portable format;
e) a right to object to us processing your personal information in certain circumstances (for example, if you believe we are not using your information in a lawful manner or for the purposes for which it was provided);
f) where we have requested your permission to process your information, a right to withdraw your consent at any time (we will always make it clear where we need your permission to undertake specific processing activities);
g) a right to object to us processing your information for direct marketing purposes, including profiling you for the purposes of direct marketing.
14.3 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. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
14.4 There are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
14.5 Please note that in some cases, if you do not agree to how we process your information, it may not be possible for us to continue to operate your account and/or provide certain products and services to you.
14.6 If you would like a copy of the personal data we hold on you, please contact us in any of the following ways:
14.7 If you wish to raise a complaint on how we have handled your personal data, please contact us in any of the following ways:
14.8 We hope we can address any concerns you may have, but you can always contact the Data Protection Commissioner in any of the following ways:
16.1 If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties, and all other provisions shall remain in full force and effect.
16.2 This policy shall be governed by and construed in accordance with the law of the Republic of Ireland. For all matters related to the interpretation of this policy and disputes arising from it, you agree to submit to the exclusive jurisdiction of the Irish courts.