Last updated: (Nov 2024)

 

Introduction

Fenero respects the privacy of its customers, suppliers and partners. We have therefore formulated and implemented a policy on complete transparency regarding the processing of personal data, its purpose(s) and the possibilities to exercise your legal rights in the best possible way. For employees, we have formulated a separate privacy policy, available upon employment and upon request.

 

Definitions

  • Party responsible for processing personal data: Fenero; with registered address at Block D, Tyrrelstown Plaza, Dublin 15 in Ireland and company registration number 493351 (the “Controller”).
  • Data Protection Authority: The Data Protection Authority of Ireland. Data Protection laws:
    • For European citizens or residents, the EU GDPR 2018; the EU e-privacy directive 2002 (soon to be replaced by the EU e-privacy regulation);
    • For UK citizens or residents, the UK GDPR 2020 and the UK Data Protection Act 2018 and/or the national laws of Ireland.

 

Collection of data

  • Your personal data will be collected by Fenero and its data processors.
  • Personal data means 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.

 

The types of personal data we may process:

policy table 2024

 

Purposes

Fenero processes personal data for one or more of the following purposes:

  • Customer, employee, contractor, partner or supplier management Business and financial administration
  • Direct marketing
  • Delivery of goods or services Work planning

 

How we collect, store or otherwise process your data:

The following business processes describe how we may collect, store or otherwise process the types of personal information set out in the table above:

  • Collection of cookies, subscription to newsletter or filling out the contact form on the website(s); Analyse trends and profiles, for our legitimate interest to aim to enhance, modify, personalise and improve our services and communications for the benefit of our customers;
  • Process and respond to support requests, enquiries and complaints received from you through use of business email;
  • Provide services and products requested and/or purchased by you and to communicate with you about such services and/or products. We do this as necessary in order to carry out a contract with you and in accordance with our legitimate interest to operate a business;
  • Carry out administrative activities such as invoicing and collecting payments either locally on devices or using cloud-services;
  • Store and exchange personal information contained in documents through email and cloud-services; Marketing and customer acquisition through email or using cloud-services.

 

Sharing data with third parties

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your Personal Data outside Ireland. If we do, you can expect a similar degree of protection in respect of your Personal Data.

We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.

International data transfers

The third parties we have engaged for business process may transfer your personal information to outside of Ireland. Fenero’s third party processors take all necessary measures to ensure the confidentiality, availability and integrity of personal data and to comply with the GDPR with regards to international data transfers. The international nature of its compliance certifications, as well as far-reaching technical security measures (including but not limited to encryption of the personal data, making the data  illegible to an unauthorised recipient) are sufficient to ensure that the data subjects continue to benefit from the fundamental rights they are entitled to under the GDPR.

Fenero relies on processing agreements with these sub-processors that include the model clauses (or “Standard Contractual Clauses”) which have been tested on the adequacy of its protection with regards to the specific sub-processing activities carried out in this particular sub processing relationship.

Additional security measures are taken to safeguard the international data transfers:

  • Encryption
  • Anonymisation
  • Pseudonymisation

Storage and protection of data

Your data is protected by Fenero and its processors in pursuance to all legal requirements set by the relevant data processing laws. Fenero has taken technical and organizational security measures to protect your data and requires its data processors to meet the same requirements. Fenero has signed processing agreements with its processors to ensure an adequate level of data protection.

Organisational security measures

Staff

Fenero staff members are required to conduct themselves in a manner consistent with Fenero’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards. All staff members undergo appropriate background checks prior to hiring and sign a confidentiality agreement outlining their responsibility in protecting customer data.

We continuously train staff members on best security practices, including how to identify social hacks, phishing scams, and hackers.

 

Access controls

Fenero maintains your data privacy by allowing only authorized individuals access to information when it is critical to complete tasks for you. Fenero staff members will not process customer data without authorization.

 

Data hosting

As a rule, data is hosted within Ireland, but it is possible that we might transfer personal data to countries within the EEA, to the UK or in exceptional circumstances outside of those areas. We ensure that we comply with the GDPR and the DPA when sending data overseas by relying on data processing agreements containing standard contractual clauses with our sub processors or by taking additional measures to secure this data transfer, such as anonymisation.

 

Physical security

The data centres on which personal data is hosted are secured and monitored 24/7 and physical access to facilities is strictly limited to select staff.

Technical security measures

All devices which are used to access personal data for which we are responsible are secured with antivirus software, firewalls, encryption and access management. We regularly update operating systems and software to ensure vulnerabilities cannot be exploited.

We carry out regular vulnerability scanning of our website and have engaged credentialed external auditors to verify the adequacy of our security and privacy measures.

Your rights regarding information

Each data subject has the right to information on and access to, and rectification, erasure and restriction of processing of their personal data, as well as the right to object to the processing and the right to data portability.

You can exercise these rights by contacting us at the following email address: dataprotection@fenero.ie. Each request must be accompanied by a copy of a valid ID, on which you put your signature and state the address where we can contact you. Ensure that you write “Data Request” in the subject line of your email.

Within one month of the submitted request, you will receive an answer from us. We will not charge you for submitting your request unless the request is manifestly unfounded or otherwise unreasonable in its nature. Depending on the complexity and the number of the requests this period may be extended to two months.

Marketing

  • You may receive commercial offers from Fenero. If you do not wish to receive them (anymore), please send us an email to the following address: dataprotection@fenero.ie and ensure that you write “Data Opt-Out” in the subject line of your email.
  • Your personal data will not be used by our partners for commercial purposes.
  • If you encounter any personal data from other data subjects while visiting our website, you are to refrain from collection, any unauthorized use or any other act that constitutes an infringement of the privacy of the data subject(s) in question. The collector is not responsible in these circumstances.

Data retention

The collected data are used and retained for the duration determined by law. You may, at any time, request your data to be deleted from any Fenero account, system or other data processing medium in accordance with the process described above.

Applicable law

These conditions are governed by Ireland legislation. The court in the district where the collector has its place of business has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.

 

Contact

For questions about this privacy policy, product information or information about the website itself, please contact: dataprotection@fenero.ie.

 

Safeguards for international data transfers

Fenero’s third party processors take all necessary measures to ensure the confidentiality, availability and integrity of personal data and to comply with the GDPR with regards to international data transfers. The international nature of its compliance certifications, as well as far-reaching technical security measures (including but not limited to encryption of the personal data, making the data illegible to an unauthorised recipient) are sufficient to ensure that the data subjects continue to benefit from the fundamental rights they are entitled to under the GDPR.

Fenero relies on processing agreements with these sub-processors that include the model clauses (or “Standard Contractual Clauses”) which have been tested on the adequacy of its protection with regards to the specific sub-processing activities carried out in this particular sub processing relationship.

Additional security measures are taken to safeguard the international data transfers: Encryption;

  • Anonymisation;
  • Pseudonymisation where possible.
    • Where Pseudonymisation is used by this third-party processor, they ensure that the personal data can no longer be attributed to a specific data subject without the use of additional information.
    • This additional information is kept separately; and
    • Technical and organisational measures are taken to ensure that the personal data cannot be attributed to identifiable persons (encryption; database and data separation; access controls; and logging).