Last updated: September 2020
Who We Are
The European Consumer Centre Ireland (‘ECC Ireland’) is a company limited by guarantee (company registration number 367035) and registered charity (number 20048617 – CHY14708), with a registered office at ICONIC, The Masonry, 151-156 Thomas St, Usher’s Island, Dublin, D08 PY5E.
The European Consumer Centre Ireland (‘ECC Ireland’) (‘us’, ‘we’ or ‘our’) is committed to protecting and respecting your privacy. This document, together with our website’s Terms of Use, our Cookies Policy, and all documents referred to therein, sets out the way we process any personal information provided to us and which allows us to identify you (‘Data’) in connection with the services we provide through our website (eccireland.ie), e-mail marketing and communications, social media and via our query and complaint handling system (‘our Services’).
Please read what follows carefully so as to ensure you understand how we process your data and for what purpose.
Our Functions
ECC Ireland is part of the European Consumer Centres Network, a pan-European network established by the European Commission and the European Union Member States. We are co-funded by the European Commission and the Competition and Consumer Protection Commission of Ireland. We are also under the aegis of the Department of Enterprise, Trade and Employment in respect of our designation as Online Contact Point in the State. ECC Ireland’s functions are to provide consumers with information on their rights with respect to cross-border transactions within the EU and some EEA countries. We do this by:
- Assisting consumers with their disputes with traders based in EU/EEA countries by encouraging and helping them to make contact with the trader, where appropriate, and assisting in the process of handling complaints and disputes;
- Promoting out-of-court dispute resolution options such as Alternative Dispute Resolution;
- Informing the public and raising awareness on the services provided by the European Consumer Centres Network via our website, publications, events and the media;
- Cooperating with consumer protection stakeholders, such as enforcement authorities, trade associations and professional bodies;
- Collecting and analysing information deriving from consumer queries and complaints received by us for statistical and policy-making purposes;
- Contributing to relevant consultations in the field of consumer protection at national and European level;
- General information on the requirements applicable in other Member States relating to access to and exercise of service activities, particularly those relating to consumer protection;
- General information on redress options for cross-border consumer-trader disputes;
- Contact details of associations or organisations (including partner offices from within the European Consumer Centres Network) that can provide service recipients with practical assistance.
As of 2018, the governing legislative frameworks on (e)privacy in Ireland is the Data Protection Act 2018 and the Data Protection Commission is the national authority responsible for enforcing the current applicable laws in the Republic of Ireland.
ECC Ireland is the ‘Data Controller’ of the ‘Data’ you, the ‘Data Subject’ provide to us, when you access our ‘Services’, and in the context of how we process your data, as described in this document.
ECC Ireland acts as ‘Data Processor’ of data you provide to us, when your consumer query or complaint is registered and processed within and by our case handling and management system used by our office, as part of the European Consumer Centres Network, supplied and operated by the European Commission. In this context, ECC Ireland acts as ‘Processor’ and the European Commission acts as ‘Controller’ of your data, pursuant to a separate Privacy Statement provided here and which details the purposes and means of how your data is processed.
Any data ECC Ireland processes outside the aforementioned case handling management system is performed in accordance with the purposes and in the manner set out below.
Why We Collect Data
We will only process your Data in order to comply with a legal obligation; to protect the vital interests of a natural person; to perform a task carried out in the public interest or in the exercise of official authority; and to pursue a legitimate interest. We process your Data in the course of delivering our service when it is necessary, we have a legal basis to do so and for these specific purposes listed below only.
Service Provision
We only collect and process Data that enables us to:
- discharge our service provision duties on request by you;
- communicate with you in order to address your questions and provide you with the information sought;
- assist you with a consumer issue;
- perform an assessment of your query;
- request and confirm details and requirements necessary to process your complaint/dispute
- follow up on your inquiry, if necessary.
Note that we may need to disclose and otherwise transfer your data if and when:
- we need to contact the trader that is the object of your complaint directly
- we need to liaise with the trader that is the object of your complaint, indirectly:
- we need to liaise with the staff and through communications systems of the European Consumer Centres Network (for example, the staff of the office in the country where the trader is based)
- we need to liaise with an Alternative Dispute Resolution entity or National Enforcement Body that are part of the dispute resolution process
In these cases, we may have to disclose to the trader and any of the entities above, some details of the complainant’s/your identity and, where necessary, provide them with the relevant details of the transaction and supporting documentation associated with your complaint.
Internal Management
Data we collect helps us build operational capacity and improve our Services. Therefore, Data we collect from you may be processed for the purposes of:
- monitoring and quality assurance vetting of our work processes;
- statistical and analytical reports of our activities;
- internal training.
Statistics and Reports
We also collect and publish case studies and operational statistics on the number and type of cases we process, but all information is anonymised and does not identify any individual. Please note that we do not perform data profiling.
What Data We Collect
We collect and process certain Data about you when you seek information or advice from us via e-mail, or telephone and when you use our website or make contact with us via social media.
For the purposes listed above in the section ‘Why We Collect Data’, we collect the following primarily:
- your name
- your country of residence
- your email address
- telephone number (if supplied)
- your message describing your query request or consumer complaint
Other personal details we collect, where necessary only, for the purpose of processing your complaint only, are:
- postal address
- bank details
- supporting documentation
In a very limited amount of cases, supporting documentation may include sensitive data required to prove the veracity of a consumer complaint (for example, a medical certificate). Such data will only be processed with your explicit consent and for the strict purpose of progressing your request.
We may also collect information in the form of cookies, this is detailed in our Cookies Statement.
How We Collect Your Data
We collect Data from you as part of our service delivery, marketing activities and communications, which are all listed below.
In addition, our website, marketing e-mails and social media posts includes links to other websites or web platforms operated by third parties, subject to their own privacy and cookie policies. In your interactions with these, it is your responsibility to check their privacy and cookies statements before you submit any personal data to them. ECC Ireland accepts no liability or responsibility for these.
Communications
We receive your data when we deliver our services to you, following your request. This may involve any one or more of the following types of communications:
- calling our helpline;
- making a submission through our website contact form;
- writing an e-mail to our complaints e-mail address;
- Sending us a letter and/or documentation by post.
Events
ECC Ireland may also receive Data in the context of promotional and educational activities, such as conferences, seminars and workshops. This Data may include:
- Your name
- Your contact details: e-mail address, phone number, postal address (as chosen by you)
Subject to express consent, requested from you and provided by you, we may use your contact details to inform you about other closely-related activities, e.g. future events. We may also deal with some publication requests where we may process the necessary data for the purposes of sending out the publications.
Website Visits and Analytics
When someone visits eccireland.ie, we may collect information in the form of cookies. A cookie ID is an identifier that is included within most cookies when set on a user’s browser. It is a unique ID that allows your website to remember the individual user and their preferences and settings, when they return to your website. In the case of cookies used to store preferences of users on the domain for the duration of the session or for a reasonably short period, processed based on a legitimate interest, these are processed for a defined period of time after the end of the last user’s session. Cookies are processed on the basis of strictly necessary. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. Or require consent, we use a cookie management tool to obtain consent. You can control what types of cookies are set by using the cookie settings tool which is available on our cookie policy page
Our third-party Google Analytics tool collects standard internet log information and details of visitor behaviour patterns. We collect this type of data to compile statistics on our site usage so that we may serve our visitors with the right information. For more information, see the most up-to-date Google Analytics Privacy Policy here. You can opt out of Google Analytics completely by using the Google Analytics Opt-out Browser Add-on. In addition, you can use the “Incognito “or “Private” mode to browse our site in Chrome, Edge, Firefox, Opera, Safari and any other browser available.
Search Engine
Our website search and decision notice search are powered by Google Tag Manager. Search queries and results are logged anonymously to help us improve our website and search functionality. No user-specific Data is collected by either ECC Ireland or any third-party service or tool.
E-Mail Marketing
We use a third-party e-mail marketing tool, MailChimp, to deliver our occasional newsletters and updates. Mailchimp compiles statistics on how many of our e-mails opened and how many clicks we receive following our campaigns. It uses industry standard technologies that gives us insight into our audiences’ behaviour and help us monitor and improve our marketing.
When you sign up to receive our e-mail communications, you complete a GDPR-compliant online form that asks you for the following details:
- First name
- Last name
- E-mail address
If you decide to sign up by completing and submitting this form here (for press and media) and here (for the general public), you acknowledge that your information will be transferred to Mailchimp for processing. You are asked to opt in to receive any or all the following by ticking the boxes of your choice or none:
- Direct Mail
- Customized Online Advertising
After you have signed up and started receiving our communications by e-mail, you can still unsubscribe at any time by clicking the link in the footer of all our e–mails.
We may also use Mailchimp to send the consumers who contacted us with a request or a complaint a survey on the quality of our services. For information about Mailchimp’s privacy terms and practices, please visit:
- mailchimp.com/legal/privacy
- mailchimp.com/legal/cookies
- mailchimp.com/legal/data-processing-addendum
Social Media
We use Twitter here to promote ECC Ireland’s activities, share information of consumer interest and interact with the public and journalists. Detail on the handling of your Data by Twitter can be found in the Privacy Policy here.
When you browse our website, you have the option of sharing our content, should you wish to do it, via a widget called AddToAny whereby you can share content through a social media or communications service of your choice from this list here. AddToAny is compatible GDPR and does not store personal data. You can read the privacy policy for this service here.
How We Use Your Data
Depending on the type of interaction between us, ECC Ireland, and you, as a customer of our service or user of our website and social media, etc. we use your data for the following purposes below.
Service Provision
We use your Data in order to:
- Respond to your requests for information and e-mail or postal correspondence you submit to us;
- Provide you with information or services that you request from us;
- Carry out statistical analysis;
- Improve the services that we provide to you (for example, via our customer satisfaction survey);
- Send you e-mail marketing communications (if you have subscribed to receive our newsletter);
- Allow you to participate in interactive features of our website, when you choose to do so (via our contact form, for example);
- Carry out activities necessary to the running of ECC Ireland, including staff training, monitoring and quality control
- Notify you about changes to our website, services or policies.
When we receive a request for information or a complaint from a consumer via e-mail or postal communication, we create a digital or physical file containing the details of the complaint. This normally contains the identity of the complainant and of any other individuals and businesses involved in the complaint.
In order to process your request, we may require additional information from you, such as details or documentation to confirm your identity.
The information you provide is uploaded and registered in the European Consumer Centres Network query management system, operated by the European Commission. This is subject to a separate Privacy Policy, available here and which details the purposes and means of the processing.
We will only use the personal information we collect to process the request or complaint and to check what level of service we provide. Additionally, any and all requests/complaints we receive are included in our operational and service statistics, where all data is anonymised.
We keep personal information contained in complaint files in line with our retention policy, which specifies a period of 2 years, starting from the date we close a file. Your data will be stored in a secure digital and/or physical environment, and access to it will be restricted only to the entities and persons that need to access this data for the purposes listed under our service provision. All data entered into the European Consumer Centres Network query management system operated by the European Commission are kept as long as a case remains open, and up to 1 year after it has been closed. This is to allow follow-up if there are new developments after the closure of the case. Once the retention period expires, the information is anonymised and kept for statistical purposes only.
If a consumer does not want information identifying him/her to be collected/processed, it will not be possible for us to handle their query/complaint. We are unable to deliver our services to consumers on an anonymous basis.
Disclosure of Data
Some of our cases include collaboration with the staff of our partner offices within the European Consumer Centres Network. This is required to assist with a complaint and means that, if necessary, some or all data in your file will be shared, with your express consent, with the staff of our partner office in the country of the trader with whom you have a dispute is based in or, where appropriate, with other dispute-resolution bodies that may be able to help resolve your complaint, such as an Alternative Dispute Resolution or a National Enforcement Body in Ireland or in one of the countries of the EU/EEA.
Some other cases we handle will involve us and/or our counterparts in other ECC offices, if and when required, to make contact with a trader in order to pursue your complaint. In such cases, data and records that you provide to us may be shared, insofar as it is necessary, to resolve the issue, and only with your express consent.
Details on the European Consumer Centres Network query management system operated by the European Commission are provided in the latter’s Privacy Statement.
Safeguarding Your Data
We take reasonable and appropriate measures to protect your Data against loss, misuse, unauthorised access and disclosure.
All data in electronic format processed within the European Consumer Centres Network query management system operated by the European Commission is stored either on the servers of the European Commission or of its contractors (bound by contracts in line with European Commission Decision C(2006) 3602 concerning the security of information systems). Read the European Commission Privacy Policy here.
Your Data Protection Rights
Under current Irish and European Union data protection law, subject to certain restrictions, data subjects have these rights:
- The right to be informed about the processing of your personal data;
- The right to access your personal data;
- The right to rectification of your personal data;
- The right to the erasure of your personal data;
- The right to data portability;
- The right to object to the processing of your personal data;
- The right to restrict processing of your personal data;
- Rights in relation to automated decision-making, including profiling.
According to the above, you can:
- Request information on whether we hold Data about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a “data subject access request”) and receive a copy of the Data we hold about you, and check that we are lawfully processing it.
- Request correction of the Data that we hold about you, check if this is incomplete or inaccurate, and correct it, if needed.
- Request deletion of your Data by us where there is no good reason for us continuing to process it.
- Object to a request for data processing if there is something about your particular situation that makes you object to our grounds for the processing.
- Object to an automated decision-making request to use your personal information or profiling. Note that we do not perform data profiling.
- Request a restriction of data processing, such as if you want us to suspend the processing of your Data until ascertaining the reason for it.
- Request for data portability. This enables you to obtain your data from us in electronic format and transfer to another party.
- Withdraw your consent for us to process your Data at any time.
There is no fee to exercise any of these rights. However, we may either seek to recover the administrative cost of taking the action requested or refuse to act on the request if the request is manifestly unfounded or excessive.
If you wish to exercise your data protection rights, as above, please submit your request to The Manager, European Consumer Centre Ireland, by post at ICONIC, The Masonry, 151-156 Thomas St, Usher’s Island, Dublin, D08 PY5E, Ireland or by e-mail at: info@eccireland.ie.
Changes to Our Privacy Statement
This Statement may change from time to time, and any changes will be posted on ECC Ireland’s website and will be effective when posted. This is a live document, under regular review.
