At enet we endeavour to ensure that the personal data of all our customers is collected and managed in line with the requirements of the GDPR and that our customers understand how their personal data is managed.
1. The Data Protection Officer at enet is responsible for ensuring that this notice is made available to customers prior to enet collecting and/or processing their personal data.
2. All Employees and Staff of enet who engage with customers are responsible for ensuring that the customer is aware of this notice and that the customer’s consent to the processing of their data has been secured and documented.
Who are we?
enet is a wholesale only service provider of choice for licensed carriers.
What is Personal Data?
Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person ('data subject'); 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”.
What Personal Data does enet hold about me?
The personal data that we may collect or process about you, our customer, can include the following:
• Contact Details e.g. Name, Address, Email, Phone Number
• End User Details e.g. Name, Address, Email, Phone Number
• Company Information e.g. Job Role,
• Technical Information e.g. IP address or MAC address
Where does enet get my data?
Much of the information we hold will have been provided by you, the customer. Other sources of information may include internet searches, or the recording of other publicly available information about you.
Why does enet need my personal data?
enet collects and uses your personal data to deliver the services which you have requested or subscribed to.
All personal data given to us by you will be used only for the purpose for which you supply it and will be treated in accordance with General Data Protection Regulations.
We will only use your personal information to fulfil the terms of service as agreed with you, from time to time we may need to use your data to;
• to notify you of problems
• to respond to your requests
• to ensure that the correct charges are applied to your account
• to improve our level of service
• to seek your views on our services
At enet we strive to improve the services and communications that we provide to our customers through the ongoing development of our IT systems and software. At times we use customer personal data to facilitate that development as follows:
• to gain a better understanding of our services, and to allow new product and service development;
• to tailor our services to allow us to meet customer needs
• to allow us to predict trends and produce market insights;
• to undertake modelling to identify improvements customer reporting and service delivery efficiencies;
• to store, access and backup information.
If you have given your consent to receive marketing material from us, we aim to provide you with information that is relevant and personal.
By providing your personal data, and where you have agreed to receiving communications from us, we may also use the information as follows:
• to personalise the marketing information that we issue;
• to send information that we consider may be of interest to you;
• to collate data gleaned from surveys or to produce market insights;
• to segment and distribute targeted marketing materials;
• to follow up with attendees of our events
• to ask for opinions about our products or services.
Please notify us immediately of any changes in relation to your personal data so that we can ensure the accuracy of your personal data (eg change of address or telephone number)
Does enet need all this personal data about me?
We only collect the data that we need to provide the service(s) that you have requested. We must collect sufficient personal data in order to identify you as an individual. The GDPR prevents us from collecting data which we do not need for legitimate purposes. We aim not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimise the risk of unauthorised access, disclosure or loss.
Lawful Basis for Processing Personal Data
Our legal basis for processing for your personal data is that you have given your consent to us. This consent can be given at the time when you initially seek our services or having read the company’s Customer Privacy Notice, that you provide consent to allow us to continue to use the personal data you have supplied to us.
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes of providing a communications service to you and for the management and administration of our business.
Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by contacting our Data Protection Officer to request our Consent Withdrawal Form.
If you do not provide us with your data, we may be prevented, in some circumstances, from complying with our obligations. If that is the case, we will tell you about the implications of your decision to withhold consent.
There are different types of cookies, and they are used for different purposes.
Below you can read about what a cookie is, the difference between first and third party cookies and session cookies vs. persistent cookies and what types of cookies we use on our website and why.
What is a cookie?
A cookie may contain information about the website itself, a unique identifier that allows the site to recognise your web browser when you return to the website, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.
The word "cookies" or "cookie data" also covers information about IP and MAC addresses and other information about your device collected by said technologies.
Cookies are used to enable certain features (e.g. logging in), to track site usage (e.g. analytics), to store your user settings (e.g. timezone, notification preferences), and to personalise your content (e.g. advertising, language).
Session cookies vs. persistent cookies
Session cookies only last as long as your online session. This means that they will disappear from your computer or device when you close your browser. They are therefore also sometimes referred to as temporary cookies. Typically, session cookies are used to remember what a user put in their basket when they are browsing a website.
Persistent cookies are different. These cookies are sometimes called permanent cookies. They will stay on your computer or device after you close your browser. These types of cookies will expire according to the time specified in the cookie. You can see the specific duration of each persistent cookie below.
Types of cookies and how we use them
Necessary cookies are required for the basic functionality of our website to work. We use necessary cookies to make it possible for you to only have to enter your username and password once during a visit to our website.
We also use necessary cookies to help with ensuring that you are given the option to accept or reject cookies, block non-necessary cookies from working until you give consent, and remember your cookie settings and choices. The cookies also help keep track of, if, and when, you gave consent to analytical cookies, T&Cs and email marketing.
Necessary cookies are also used for payment processing.
Who will enet share my personal data with?
To fulfil our contractual obligations, and for the administration and management of company business, enet may have to pass your personal data on to third parties. These third parties may include, but not be limited to, our Suppliers, Subcontractors, Payment Engine Provider (to process payments), Accountant, Solicitor, Insurance brokers / companies, IT Providers and other Business Advisors, Consultants or Professional Services providers.
There may be occasions when it is necessary for us to transfer information about you to other group companies or third parties for purposes connected with your contract or the management of the company’s business.
From time to time we may need to share your data to pursue our legitimate business interests, for example to prevent fraud, for administrative purposes (including financial, legal and insurance purposes) or reporting potential crimes. We may need to share your personal data to enable us to comply with any legal requirements and to protect our legal position in the event of legal proceedings.
All Third Parties engaged by enet are must comply with the General Data Protection Regulations. When they no longer need your data to fulfil a service, the third parties will dispose of your personal data in line with enet’s requirements. If we wish to pass your sensitive personal data onto a third party we will only do so with your consent, unless we are legally required to do otherwise.
Your personal data will not be shared for marketing purposes without your consent.
In limited and necessary circumstances, your information may be transferred outside of the
EEA or to an international organisation to comply with our legal or contractual requirements. enet has safeguards in place to ensure the security of your data in the event that such a transfer takes place.
How long will enet keep my personal data?
enet will only retain personal data for as long as it is needed for the purpose for which it was collected. Once the retention period for a record has passed, that record is deleted from our systems. In some instances, enet is required to retain information in accordance with the law, such as information needed for revenue and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
What are my rights in relation to my personal data once I give it to enet?
At any point whilst we are storing or processing your personal data, you as the data subject, have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling.
• Right to judicial review: in the event that enet refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in the complaints section below.
All requests will also be forwarded to any third party who is in the processing or storage of your personal data.
How can I find out the personal data enet holds about me?
enet at your request, can confirm what information we hold about you and how it is processed. If enet does hold personal data about you, you can request the following information:
• Identity and the contact details of the person or organisation that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of enet or a third party, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority.
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
What forms of ID will I need to provide in order to prove that I am the data subject?
enet accepts the following forms of ID when information on your personal data is requested:
Passport, Driving license, Public Services Card, Birth certificate, Utility bill (not older than 3 months), Current vehicle registration document, Bank statement (not older than 3 months), Rent book (not older than 3 months), Revenue / Social Welfare documentation (not older than 3 months)
How do I make a complaint?
If you wish to make a complaint about how your personal data is being processed by enet, by third parties engaged by enet, or how your request has been handled, you have the right to lodge a complaint directly with the supervisory authority and enet’s Data Protection Officer.
Data Protection Commissioner
Office of the Data Protection Commission
Telephone +353 761 104 800 or LoCall 1890 25 22 31
enet Data Protection Officer
If you have any queries or concerns about your personal data, our Data Protection Officer can be contacted in the following ways:
enet Data Protection Officer
Hamilton House, National Technological Park, Plassey, Limerick, V94 TRW8