1. Introduction
1.1 The following is the privacy and cookies policy (“Privacy and Cookies Policy”) for the Website operated and Service provided by Bogadh. This Privacy and Cookies Policy, together with the terms and conditions that apply to your use of the Website and our Service (the “Terms”), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.2 Bogadh has created this Privacy and Cookies Policy to demonstrate our commitment to respecting your privacy and protecting your personal data. Bogadh recognises that its customers, users and visitors who use the Website value their privacy. The following applies to the Service and the information gathering and dissemination practices of Bogadh in connection therewith
1.3 Your use of the Website and the Service and any personal information you provide in connection therewith is subject to the terms of this Privacy and Cookies Policy and the Terms. If you do not agree with this Privacy and Cookies Policy and/or the Terms, please do not use, or discontinue
your use of, the Website.
1.4 For the purpose of the Data Protection Acts 1988 to 2018 (the “Data Protection Acts”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the data controller is Bogadh.
2. Interpretation of this policy
Words and expressions defined in the Terms shall, except where otherwise expressly provided herein or unless the context otherwise requires, have the same meaning in this Privacy and Cookies Policy.
3. Information collection an use
3.1 General
3.1.1 Bogadh is committed to protecting your privacy rights under GDPR and other applicable privacy legislation, including the Data Protection Acts.
3.1.2 Bogadh collects personal information when you register to join our mailing list.
3.1.3 Additionally, we collect details of your visits to the Website including, but not limited to, traffic data, location data and other communication data and the resources that you access.
4. Purposes for which we will use your personal data
4.1 We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
4.2 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
i. Purpose/Activity
To process and deliver the Service:
(a) Mailing List
Type of data
To process and deliver the Service:
(a) Identity
(b) Contact
(c) Marketing and Communications
(d) Profile Data
(e) Usage Data
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
ii. Purpose/Activity
To manage our relationship with you which will include:
(a) Notifying you about changes to our Terms or Privacy and Cookie Policy
(b) Asking you to leave a review or take a survey
(c) Sending you communications about our Service
(d) In the interests of security and to improve the Service, telephone calls you make to us may be monitored and recorded
Type of data
To process and deliver the Service:
(a) Identity
(b) Contact
(c) Marketing and Communications
(d) Profile Data
(e) Usage Data
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our Service)
(d) Necessary for our legitimate interests (in the management and operation of the user group)
iii. Purpose/Activity
To enable you to complete a survey
Type of data
To process and deliver the Service:
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our Service, to develop them and grow our business)
Purpose/Activity
To administer and protect the Website (including troubleshooting, data analysis, testing, System maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Technical
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
v. Purpose/Activity
To deliver relevant Content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to study how customers use our Service, to develop them, to grow our business and to inform our marketing strategy)
vi. Purpose/Activity
To use data analytics to improve our Website, Service, marketing, customer relationships and experiences
Type of data
(a) Technical
(b) Usage
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers for our Service, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
5. Information sharing and disclosure
5.1 Bogadh does not rent, trade or share your personal information with third parties except to provide the Service you have requested, when we have your permission or under the following circumstances:
5.1.1 we may use other third parties such as email service providers to send out emails on our behalf. When you sign up for our email list, we will share the necessary amount of personally identifiable information for the third party to provide that service, including your name and email address. These third parties are prohibited from using your personally identifiable information for promotional purposes;
5.1.2 we use your information to improve the quality and design of the Website and to create new features, promotions, functionality and services by storing, tracking and analysing your preferences and trends to enable us to improve the Service;
5.1.3 subject to the provisions of clause
5.2 of this Privacy and Cookies Policy, we use your information to provide you with both general and tailored information about opportunities, services, products, offers or other useful information from us or providing you with information that you have requested;
5.1.4 we reserve the right to disclose your information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, or legal process served on Bogadh;
5.1.5 we may share your information if we believe that it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms or as otherwise required by law; and/or
5.1.6 in the event that Bogadh goes through a business transaction, such as a merger, acquisition by another company or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email or post of any such change in the event that this occurs.
5.2 We use your personal information in pursuance of our legitimate business interests outlined above but we will not do so where our interests are outweighed by your interests, rights and freedoms. You may unsubscribe from our marketing communications by contacting us via email at info(at)Bogadh.com
6. If you fail to provide personal data
Where we need to collect personal data by law, or under the Terms, and you fail to provide that data when requested, we may not be able to perform the Service. In this case, we may have to cancel the Service, but we will notify you if this is the case at the time.
7. Where we store your personal information
The information that we collect from you may be transferred and stored by us. It may also be processed by staff engaged in providing the Service, including (without limitation) the preparation of Content and the provision of customer care services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is processed securely and in accordance with this Privacy and Cookies Policy. All information you provide to us is stored either on our own servers or on third party systems contracted to us. We shall not transfer your personal data outside the European Economic Area.
8. Confidentiality and security
We follow generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use means that meet or exceed generally accepted industry standards to protect your personal information, we cannot guarantee its absolute security.
9. External links
This Website may contain links to other websites. Bogadh is not responsible for the privacy practices or the content of other such websites.
10. How long do we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements, or earlier when you inform us that you wish all your data to be deleted. You can object to our use and storage of your personal information at any time or tell us that you no longer wish to be contacted by us.
11. Your rights
You have a number of rights in relation to your personal information.
These rights include the right to:
11.1.1 request information regarding the personal data that we hold about you and the source(s) of that information. You can also request a copy of any personal data we hold about you. This service is usually free of charge, although we have the right to charge a reasonable fee in certain circumstances;
11.1.2 request that we rectify without undue delay any inaccuracies in relation to the personal data we hold;
11.1.3 we use your information to improve the quality and design of the Website and to create new features, promotions, functionality and services by storing, tracking and analysing your preferences and trends to enable us to improve the Service;
11.1.4 request restriction of processing of your personal data in some circumstances;
11.1.5 object to any processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom;
11.1.6 in some circumstances, request that your personal data be transferred to you or a new provider if the data is processed automatically;
11.1.7 if we are processing any data for which you have given consent, you may withdraw consent to us processing your personal data. This will not affect the processing already carried out with your consent; and
11.1.8 lodge a complaint with a regulatory authority.
Any enquiries regarding the above rights or if you wish to exercise any of these rights or any other rights provided for in this Privacy and Cookies Policy please contact our Data Protection Officer by email at info(@)bogadh.com or. If you are not satisfied with any response you receive in relation to the way we handle your personal information you may complain to the Data Protection Commissioner’s Office.
12. Cookies
12.1 What are Cookies?
12.1.1 Certain sections of the Website use cookies. These are small pieces of data sent by the Website’s server to your computer that allow the Website to retrieve your user preferences, to personalise your visits and to simplify any sign-in procedures. It consists of anonymous information, including a unique user identifier. When you revisit a site or navigate between pages, this data is passed from your browser to the Website’s server. With this data, the Website is able to ‘remember’ your browser, enabling it to retrieve your user preferences, to personalise your visits and to simplify any sign-in procedures. We can then use this information to improve the Website for all our visitors.
12.1.2 Cookies are intended to improve your user experience by making it faster and easier to navigate through a website. For example, some websites require that you log in to gain access. If such websites did not use cookies, then you would be required to enter your login details every time you navigated to a new page because the website would not be able to remember that you had already logged in.
12.1.3 All of the information a cookie collects can only be retrieved by the website server that sent the cookie to your browser. Cookies are necessary for the Website to provide certain features and functions. Cookies are meant to improve the user experience, but some users prefer to set restrictions on the types of cookies that can be stored on their computer or mobile phone.
12.2 Cookies used on the Website
12.2.1 All of the cookies on the Website are set by us. We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration, to record aggregate information, to record session information and/or to assist you in answering questions in connection with our Service. This may in some instances only be statistical data about how you browse the Website.
12.2.2 For the same reason, we may obtain information about your usage of the Website by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. Cookies help us to improve the Website and to deliver a better and more personalised service. For example, they enable us to estimate usage numbers and patterns and recognise you when you return to the Website.
12.2.3 The cookies used on our Website include:
Name of cookie
Session ID cookies
Purpose of cookie
To maintain a user’s session on the Website.
Reason for use
This cookie ‘remembers’ the user from page to page.
Name of cookie
Google Analytics cookies
Purpose of cookie
Used for web analytics and marketing purposes.
Reason for use
This cookie ‘remembers’ different types of data used by each user of the Website for the aforementioned purposes.
12.2.4 By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. However, it is important to note that you will lose some functions of the Website if you choose to restrict or disable its cookies. It may also impact your browsing experience.
12.3 Third Party Functions
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
13. Changes and updates to this privacy and cookies policy
13.1 We reserve the right, from time to time, to change this Privacy and Cookies Policy (whether in response to any change in applicable law or regulation or otherwise) and the terms thereof that are applicable to your use of the Service will be the version that is displayed on our Website at each date you access the Service.
13.2 Without prejudice to 13.1, we will strive to notify you of any significant changes in the way we treat your personal information by sending a notice to the primary email address you have specified for such purpose and/or by placing a notice on the Website.
14. General
The provisions of clause 11.8 (Governing Law and Jurisdiction) of the Terms shall apply to this Privacy and Cookies Policy.