The use of any website owned by Implemented Certified Security Ltd is possible without any indication of personal data; however, if a data subject wants to make an inquiry or order a service via our website, processing of personal data will become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject will always be compliant with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable.
As the controller, Implemented Certified Security Ltd has implemented numerous technical and organisational measures to ensure protection of personal data processed through our business. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by mail or telephone.
a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as “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.
b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation, or set of operations, which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
The controller, or the controller responsible for the processing, is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.
Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Name and Address of the Controller
Data controller for the purposes of the General Data Protection Regulation (GDPR) is:
Implemented Certified Security Ltd
Unit G7, Riverview Business Park,
Nangor Road, Dublin 12, Ireland. D12 E440
Phone: +353 1 7076011
Name and Address of the Data Protection Officer
The data protection officer of the controller is:
Alan Donohoe Redd,
Unit G7, Riverview Business Park,
Nangor Road, Dublin 12, Ireland. D12 E440
Phone: +353 1 7076011
Each data subject may at any time contact our data protection officer directly with all questions and suggestions regarding data protection.
1.0 – Cookies
can provide the users of its websites with more user-friendly services that would not be possible without the cookie setting.
The data subject may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our websites may be entirely usable.
2.0 – Collection of General Data and Information
The websites of Implemented Certified Security Ltd collect certain general data and information, when a data subject or an automated system logs on to a particular website. This general data and information is stored in the log files of the server. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, which are controlled by an accessing system on our website, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When using these general data and information, Implemented Certified Security Ltd does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and the technology of our website, and (4) provide the law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, Implemented Certified Security Ltd analyzes this anonymously collected data and information statistically with the aim of increasing the data protection and data security of our enterprise and, ultimately, to ensure an optimal level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.
3.0 Registration Of Personal Data
Personal data entered by the data subject is collected and stored exclusively for internal use by the controller and for his or her own purposes. The controller may request the transfer to one or more processors, for example, for a delivery or fitting service, who also uses the personal data for an internal use, which is attributable to the controller.
By registering on the website of the controller, the IP address assigned by the Internet service provider (ISP) and used by the data subject, date and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services and, if necessary, to make it possible to investigate committed offenses. This data is not passed to third parties, unless there is a statutory obligation to pass on the data or the transfer serves the aim of the criminal prosecution.
The controller shall at any time provide information on the request to each data subject as to what personal data is stored about the data subject. In addition, the data controller shall rectify or erase personal data on the request or at indication of the data subject, insofar as there are no statutory storage obligations. A data protection officer particularly designated in this data protection declaration and the entirety of the employees of the controller are available to the data subject in this respect as contact persons.
3.0 – Routine Erasure or Restriction of Processing of Personal Data
The controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of the storage or as far as this is granted by the legislator or by other legislators in laws or regulations, to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely erased in accordance with legal requirements.
4.0 – Rights of the Data Subject
4.1) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to avail themselves of this right of confirmation, he or she may at any time contact our data protection officer or another employee of the controller.
4.2) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European legislator grants the data subject access to the following information:
the purposes of the processing;
the categories of personal data concerned;
the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.Furthermore, the data subject shall have a right to obtain information as to whether personal data has been transferred to a third party or to a location outside the E.U.. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may at any time contact our data protection officer or another employee of the controller.
4.3) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may at any time contact our data protection officer or another employee of the controller.
4.4) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies and as long as the processing is not necessary:A data subject who wishes to request the erasure of personal data stored by the Implemented Certified Security Ltd, may at any time contact our data protection officer or another employee of the controller. The data protection officer of Implemented Certified Security Ltd or another employee shall promptly ensure that the erasure request is complied with immediately.Where the Implemented Certified Security Ltd has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, Implemented Certified Security Ltd, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The data protection officer of the Implemented Certified Security Ltd or another employee will arrange the necessary measures in individual cases.
4.5) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
The data subject has objected to processing pursuant to Article 21 (1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.If one of the above mentioned conditions is met and a data subject wishes to request the restriction of the processing of personal data stored by Implemented Certified Security Ltd, he or she may at any time contact our data protection officer or another employee of the controller. The data protection officer of the Implemented Certified Security Ltd or another employee will arrange the restriction of the processing.
4.6) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided as long as the processing is based on consent pursuant to point (a) of Article 6 (1) of the GDPR or point (a) of Article 9 (2) of the GDPR or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.Furthermore, in exercising his or her right to data portability pursuant to Article 20 (1) of the GDPR, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible and does not adversely affect the rights and freedoms of others.In order to assert the right to data portability, the data subject may at any time contact the data protection officer designated by the Implemented Certified Security Ltd or another employee.
4.7) Right to object
Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6 (1) of the GDPR. This also applies to profiling based on these provisions.Implemented Certified Security Ltd shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.If Implemented Certified Security Ltd processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to Implemented Certified Security Ltd to the processing for direct marketing purposes, Implemented Certified Security Ltd will no longer process the personal data for these purposes.In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by Implemented Certified Security Ltd for scientific or historical research purposes or statistical purposes pursuant to Article 89 (1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.In order to exercise the right to object, the data subject may directly contact the data protection officer of Implemented Certified Security Ltd or another employee. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
4.8) Automated individual decision-making in specific case, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.If the decision (1) is necessary for entering into, or performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, Implemented Certified Security Ltd shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our data protection officer of Implemented Certified Security Ltd or another employee of the Collector.
4.9) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may at any time directly contact our data protection officer of Implemented Certified Security Ltd or another employee of the controller.
5.0 – Data Protection Provisions for about the Application and Use of Google Analytics (with Anonymization Function)
Implemented Certified Security Ltd websites have integrated the component of Google Analytics (with Anonymization function). Google Analytics is a web analytics service. Web Analytics is the collection, gathering and analysis of data about the behavior of visitors to websites. A Web analysis service collects, inter alia, data about from which website a person has come to another website (the so-called referrer), which sub-pages were visited or how often and for what duration a sub-page was viewed. Web Analytics are mainly used for the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.The operation company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.For the web analytics through Google Analytics the Controller uses the application “_gat. _anonymizeIp”. By means of this application the IP address of the Internet connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.Google Analytics places a cookie on the information technology system of the data subject. What cookies are is explained above. With the setting of the cookie Google is enabled to analyze the use of our website. With each call-up to one of the individual pages of this Internet site, which is operated by the controller and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject will automatically submit data through the Google-Analytics component for the purpose of online advertising and the settlement of commissions to Google. In the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks and subsequently create commission settlements.The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America.
6.0 – Data Protection Provisions for about the Application and Use of Google-AdWords
Implemented Certified Security Ltd have integrated Google AdWords. Google AdWords is a service for Internet advertising that allows the advertiser to place ads in Google search engine results and the Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords with the help of which an ad on Google’s search results only then displayed, when the user utilizes the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the ads are distributed on relevant web pages using an automatic algorithm, taking into account the previously defined keywords.The operating company of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant advertising on the websites of third parties and in the search engine results of the search engine Google and an insertion of third-party advertising on our website.If a data subject reaches our website via a Google ad, a so-called conversion cookie is filed on the information technology system of the data subject through Google. What cookies are is explained above. A conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the cookie has not expired, the conversion cookie is used to check whether certain sub-pages, for example, the shopping cart from an online shop system, were called up on our website. Through the conversion cookie, both us and Google can understand whether a person who reached an AdWords ad on our website generated sales, that is, executed or canceled a sale of goods.
The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are used by us in order to determine the total number of users who have been served through AdWords ads to ascertain the success or failure of each AdWords ad and to optimize our AdWords ads for the future. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the data subject.The conversion cookie stores personal information, for example the Internet pages visited by the data subject. Each time we visit our Internet pages, personal data, including the IP address of the Internet access used by the data subject, are transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/.
7.0 – Data Protection Provisions for about the Application and Use of YouTube
Implemented Certified Security Ltd has integrated components of YouTube on many of its web sites. YouTube is an Internet video portal that enables video publishers to set video clips and other users free of charge, which also provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of videos, so you can access both full movie and TV broadcasts, as well as music videos, trailers or videos made by users via the Internet portal.The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, United States. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a YouTube component (YouTube video) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding YouTube component of YouTube.
Further information about YouTube may be obtained under https://www.youtube.com/yt/about/en/. In course of this technical procedure, YouTube and Google gain knowledge of what specific sub-page of our website was visited by the data subject. If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject. YouTube and Google will receive information through the YouTube component that the data subject has visited our website, if the data subject at the time of the call to our website is logged in on YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a transmission of this information to YouTube and Google is not desirable for the data subject, the delivery may be prevented if the data subject logs off from their own YouTube account before a call-up to our website is made.YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google
Last edited on: 05-01-2019