PRIVACY POLICY

This privacy notice describes how BES Management DAC collects and processes personal information about you; how we use and protect this information, and your rights in relation to this information.

This privacy notice applies to all personal information we collect about you. Personal information is information, or a combination of pieces of information that could reasonably allow you to be identified.

1 INFORMATION WE COLLECT

We may collect your personal information from a variety of sources, including information we collect from you directly (e.g. when you contact us and provide services to us), and information we collect about you from other sources, including commercially available sources, such as public databases (where permitted by law).

Certain personal information is required as a consequence of any contractual relationship we have with you or your employer, to enable us to carry out our contractual obligations to you or your employer. Failure to provide this information may prevent or delay the fulfilment of these obligations.

1.1 Information we collect directly from you
The categories of information that we may collect directly from you include the following:
(a) personal details (e.g. name, age, date of birth, PPS number, photo ID);
(b) contact details (e.g. phone number, email address, postal address or mobile number);
(c) employment details (e.g. job title; employer name);
1.2 Information we collect from other sources
The following are examples of the categories of information we may collect from other sources:
(a) personal details (e.g. name, age, date of birth);
(b) contact details (e.g. phone number, email address, postal address or mobile number);

2 HOW WE USE YOUR PERSONAL INFORMATION AND THE BASIS ON WHICH WE USE IT

We use your personal information to:
(a) carry out background checks prior to accepting you as a client;
(b) contact you with questions and other information regarding the services we are providing to you;
(c) ensure that our records are kept accurate and up to date where you, your employees or contractors work on or visit our facilities;
(d) ensure we issue accurate invoices for our services;
(e) send you messages about products and services which we think will be of interest to you;
(f) comply with legal obligations to which we are subject
We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
(a) to fulfil our contractual obligations to you, for example to ensure that invoices are issued correctly, and for ensuring you are able to access our premises when required;
(b) to comply with our legal obligations to you, for example health and safety obligations while you are on our premises, or to a third party ( e.g to comply with a court order);
(c) to meet our legitimate interests so that: we are able to provide the services you request; our services function correctly in relation to your business; any complaints or concerns can be promptly relayed to you; we can respond to any questions or concerns you might have; we may carry out research and analysis to ensure products and services we offer are relevant to you, and; our records are kept up to date and accurate; and
(d) send you direct electronic marketing messages to the extent you have consented to receiving such messages in accordance with applicable law.

3 YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

Please let us know if any of the personal information that we hold about you changes so that we can correct and update the information on our systems.

In certain circumstances you may object to specific processing activities, require us to restrict how we process your personal information and ask us to share your personal information in a usable format with another company. Where you have given your consent to a particular type of processing, you may withdraw that consent at any time.

To exercise any of the above rights, please contact us using the contact details set out below.

4 INFORMATION SHARING

In general, we do not share your personal information with third parties (other than service providers acting on our behalf) unless we have a lawful basis for doing so.

We rely on third-party service providers to perform a variety of services on our behalf, such as website hosting, electronic message delivery, payment processing, data analytics and research. This may mean that we have to share your personal information with these third parties. When we share your personal information in this way, we put in place appropriate measures to make sure that our service providers keep your personal information secure.

Other situations in which we may disclose your personal information to a third party, are:
(a) perform other services we request from service providers;
(b) in the course of a sale or an acquisition of BES Management DAC;
(c) where permitted by law, to protect and defend our rights and property; and
(d) when required by law, and/or public authorities;
We may also share aggregated information that cannot identify you for general business analysis, e.g. we may disclose the number of visitors to our websites or services.

5 INFORMATION SECURITY

We have implemented generally accepted standards of technology and operational security to protect personal information from loss, misuse, alteration or destruction. We require all employees and directors to keep personal information confidential and only authorised personnel have access to this information. We will retain your personal information in accordance with our data retention policy.

We will retain your personal information in accordance with our data retention policy which sets out data retention periods required or permitted by applicable law.

6 INFORMATION TRANSFER

Your personal information may be transferred to, stored, and processed in a country other than the one in which it was provided. When we do so, we transfer the information in compliance with applicable data protection laws. Where the transfer is to a country outside the EEA we use the [European Commission's approved Standard Contractual Clauses.

7 CONTACT US

If you have questions or concerns regarding the way in which your personal information has been used, please contact the Data Protection Officer at besinfo@bes.ie.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of Ireland using their website https://dataprotection.ie/

8 CHANGES TO THE PRIVACY NOTICE

You may request a copy of this privacy notice from us using the contact details set out above. We may modify or update this privacy notice from time to time. You will be able to see when we last updated the privacy notice because we will include a revision date. Changes and additions to this privacy notice are effective from the date on which they are posted. Please review this privacy notice from time to time to check whether we have made any changes to the way in which we use your