SoftTrace Ltd - Privacy Notice

SoftTrace Ltd is committed to the security and protection of our website visitors and of the contact data we collect via newsletter subscriptions and information requests. We are compliant with the General Data Protection Regulation (GDRP) effective from 25th May 2018. We seek approval for data we collect in line with GDPR regulations. We are committed to protecting personal data and implementing the technical, organisational and security measures necessary to protect against unauthorised processing, destruction or damage.

We encourage you to review this policy before agreeing to it. This privacy notice will be reviewed regularly to ensure that we continue to meet our obligations in processing and protecting your personal data. We therefore reserve the right to update, modify and amend this policy as necessary. However, we will not make any significant changes to this notice without informing you.

1.0 Introduction

SoftTrace Ltd is a company registered in Ireland with a registered office at Unit 3, Carrigtwohill Business Centre, Carrigtwohill, Co. Cork, Ireland. SoftTrace is a leading developer of Manufacturing, Quality Management and Traceability software for the Dairy and Food industries. Our software has been developed in direct response to our customers’ evolving challenges and the increased legislative drive for product traceability, quality management and control. We focus specifically on addressing the quality, traceability, product safety, yield and risk management challenges of our target industries. We combine in-depth industry knowledge with cutting-edge manufacturing software and a range of expert implementation and support services.

Given the high value we place on relationships with our customers we aim to be completely transparent about the personal data we collect, store and process in the course of providing technology, product and service updates to our target markets.

Our data protection representative can be contacted at:

Contact: SoftTrace GDPR Representative

Email: gdpr@soft-trace.com

Tel:             + 353 21 4533781

US Toll Free   1866 739 0913

1.1 Consent

Our legal basis for processing your personal data is your consent. By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. To do this we collect, store and process some data (name, company, position, email address, postal address, phone number) with the consent of individuals via online forms, email requests, or hard copy details provided during formal meeting and industry events.

You may inform SoftTrace if you wish to withdraw consent at any time by emailing the GDPR Representative. In addition, you can easily unsubscribe, if you no longer require general, commercial, and marketing communications.

1.2 Disclosure

In the event that SoftTrace sell or buy any business or assets, in this case we may disclose your personal data to the prospective seller or buyer of such business or assets. If SoftTrace Ltd, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

We are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms and other agreements; or to protect the rights, property or safety of SoftTrace Ltd, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

1.3 Retention period

SoftTrace employ 3 retention policies for handling personal data. These policies are described below:

Lifetime of consent: we will retain your personal data until consent is explicitly withdrawn.

Intended purpose: we will retain your personal data for the time required to complete the process for which it was originally collected.

Legal or business requirements: we will retain your personal data for the time required to fulfil legal obligations and business / contractual requirements.

1.4 Your rights as a data subject

The General Data Protection Regulation (GDPR) provides individuals (data subjects) with numerous legislative rights. In the context of this privacy notice, you, the data subject, have the following rights:

Right to access: you have the right to request a copy of the personal data we hold about you and to be aware of how we process your data.

Right of rectification: you have a right to correct inaccurate of incomplete data that we hold about you.

Right to be forgotten: you have the right to request deletion of your personal data when there is no compelling reason (e.g., Legal obligation) for us to continue processing it.

Right to restriction of processing: you may request restrictions on how we process your personal data in circumstances such as: you contest the accuracy of the information; challenge our basis for processing; wish us to retain/store data while you establish, exercise or defend a legal claim.

Right of portability: you have the right to request a copy of your personal data in a transferrable format.

Right to withdraw consent: you have the right to withdraw consent for data processing activities to prevent further processing.

Right to object to automated processing:  you also have the right to avoid being subjected to profiling unless it is necessary for initiating or fulfilling a contract authorised by EU or member state law, or based on your explicit consent

Right to judicial review: you have the right to lodge a complaint as outlined in 1.5 below, where you believe your rights to privacy have been violated.

You may access one or more of your rights by issuing SoftTrace Ltd with a data request via gdpr@softrace.com. We will respond to data requests within one month of the receipt of your request or inform you of any circumstances that may warrant this response time to be extended.

1.5 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by SoftTrace, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and SoftTrace’s data protection representative. The details for each of these contacts are outlined below:

Supervisory authority contacts details

Ireland

Data Protection Commissioner
21 Fitzwilliam Square
Dublin 2
D02 RD28, Ireland
Email: info@dataprotection.ie
Tel: + 353 57 8684800

UK

ICO helpline
Telephone: 0303 123 1113 (varying call charges may apply)

GDPR Owner contact details

Contact: SoftTrace GDPR Representative
Email: gdpr@soft-trace.com
Tel: + 353 21 4533781

2.0 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.”

2.1 Data Processing

SoftTrace may collect, store and use the following types of data:

• Information about your computer and about your visits to and use of this website (including IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, website navigation.
• Information that you provide to us for the purpose of registering with us (including name, company, position, postal address, phone number, email address).
• Information that you provide to us for the purpose of subscribing to our website services, email notifications and/or newsletters.
• Any other information that you choose to provide to us.

2.2 Personal Data Security

SoftTrace will take all necessary technical and organisational precautions to prevent the loss, misuse or alteration of your personal data. We will store all the personal data you provide on our secure (password and firewall protected) servers. All electronic transactions you make to or receive from SoftTrace will be encrypted using SSL technology. We recommend that you also ensure you are using a secure browser when accessing our website. Once we have received your information we will use strict procedures to prevent unauthorised access. SoftTrace will not share your personal data with any third party.

2.3 Using Personal Data

SoftTrace will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and we will not keep it for longer than is necessary. Personal data submitted to SoftTrace via this website will be used for the purposes specified in this privacy notice or in relevant parts of the website. We may use your personal information to:

• Enable your use of the services available on the website.
• Improve your browsing experience.
• Send you general commercial communications.
• Send you email notifications which you have specifically requested.
• Send you our newsletter and other marketing communications relating to our business which we think may be of interest to you (where you have agreed to this) by email or similar technology. You can inform us at any time, and easily unsubscribe, if you no longer require marketing communications.
• Deal with enquiries or complaints made by or about you relating to the website.

SoftTrace will not sell or supply your personal information to any third parties for the purpose of direct marketing. Our email newsletter uses cloud-based software (Mail Chimp – www.mailchimp.com) to send personalised emails to subscribers. This requires us to transmit, store and process our subscriber list using the provider’s cloud servers residing outside the EU, which Mail Chimp certified using the Privacy Shield standard. We do not permit Mail Chimp to share or access your personal data, while security policies also exist in the data processing agreement between SoftTrace and Mail Chimp to reduce the risk of unauthorised access and/or misuse.

SoftTrace use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. This is statistical data and patterns and does not identify any individual. Google stores this information and Google’s Privacy Policy is available at http://www.google.com/policies/privacy.

2.4 Accessing Your Personal Data

SoftTrace, at your request, can confirm the information we hold about you and how it is processed. If SoftTrace does hold personal data about you, you can request the following information:

• Contact details of the data protection representative.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of SoftTrace, 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.

SoftTrace accepts the following forms of ID when information on your personal data is requested:

• Passport
• National Identity Card
• Driver’s License

2.5 Contact details

Our data protection representative can be contacted at:
Contact: SoftTrace GDPR Representative
Email: gdpr@soft-trace.com
Tel: + 353 21 4533781