Privacy Policy – trulyfamilyfarms.com

This privacy statement (together with our terms of use and any other documents referred to in it) (“Privacy Policy / Notice”) sets out how Tirlán Limited and it’s affiliates (Tirlán, we, us) uses and processes any personal information that you provide to Tirlán when you use this website. Please read the following carefully to understand Tirlán’s views and practices regarding your personal information and how we will treat it.

Tirlán is committed to ensuring that your privacy is protected when using this website. Our Privacy Policy sets out the basis on which any personal information that we collect from you, or that you provide to us, will be processed by us. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with our Privacy Policy.

Tirlán may amend its Privacy Policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes made by Tirlán. This policy is effective from 24 April 2024.

 

Notice at Collection For US Residents

The Categories of Personal Data that We Collect. We collect (1) Identifiers and personal data categories listed under applicable US Privacy Laws (as defined below), such as the California Customer Records Statue (Cal. Civ. Code §1798.80(e)); and, (2) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the website. Please see below for further information.

The Categories of Sensitive Personal Data that We Collect. We do not collect sensitive personal data (within the meaning of the California Privacy Rights Act (CPRA)). Please see below for further information.

The Purposes for which We Collect and Use Personal Data. We use personal data to maintain the website, make it better and continue developing it, to protect us and the website from misuse and law violations, and for our marketing activities.  Please see below for further information.

Selling and Sharing Personal Data. We do not sell or share (within the meaning of US Privacy Laws (as defined below)) personal data. However, we engage third parties to provide us with services such as analytics, marketing automation, and user experience and, for these purposes only, we allow them to collect personal data on the website. The categories of personal data collected by these third parties in the preceding 12 months include identifiers, online activities, and inferences drawn from such activities. These third parties do not pay us for collecting such information, but the right granted to them to collect personal data may be considered as disclosure for the purpose of sale or share for cross-context behavioural advertising. At any time, you can opt-out of the collection and / or selling of personal data by our service providers by contacting us. Please see “Controlling your Personal Information” section below for further information.

Retention. We retain personal data to provide the website and for legitimate and lawful purposes, for as long as such data is required to achieve these purposes.  Please see below for further information.

 

Data Protection

We are committed to ensuring that your rights under data privacy laws are protected and personal information is secure.  In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online in accordance with (1) the EU General Data Protection Regulation (EU) 2016/679. (“GDPR”) and, (2) United States (US) acts and regulations governing consumer privacy and data protection, including without limitation the CPRA and any regulations issued pursuant thereto (“US Privacy Laws”).

For services provided into EU countries and to EU citizens, Tirlán is committed to observing the rights of the individuals whose personal data we collect and process by following the relevant obligations under the GDPR. Where our processing activities are governed by US Privacy Laws, Tirlán is committed to observing the rights of the individuals whose personal data we collect and process by following the relevant obligations under US Privacy Laws.

Tirlán has established internal processes to meet the company’s obligations and responding to data subject requests and verifiable consumer requests and complaints.  Please refer to the individual sections of this Privacy Policy (this Notice) for additional information. For the purposes of this Notice, Tirlán is the controller of your personal data, and you can direct questions about this Notice to:

Full name of legal entity: Tirlán Limited

Email address: dataprotection@tirlan.ie

Post address: Data Protection, Tirlán Limited, Abbey Quarter, Kilkenny, R95 DXR1, Ireland

Telephone number: +353 56 779 6300

In this Notice, the term “personal data” also includes the term “personal information”, as defined under the CPRA, and any similar term under US Privacy Laws.

 

Legal Basis for data processing

We primarily process your personal data based on our legitimate interests but, in certain instances, we may process your personal data based on another legal basis where it is more appropriate to do so.  Our legal basis for processing your personal data include:

• legitimate interest: we primarily process your personal data pursuant to our legitimate business interests, including, but not limited to internal record keeping purposes to support and maintain your supplier, customer or trading relationship with Tirlán. You have a right to object at any time to the processing of your personal data on this ground and details on how to exercise your right to object are contained in “Controlling your Personal Information” section of this Notice. When we process your personal data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
• compliance with a legal obligation:it may be necessary for us to process your personal data in order to comply with legal obligations to which we are subject to under Irish and EU law.
• legal claims:it may be necessary for us to process your personal data to establish, investigate, exercise, or defend a legal claim.

In certain limited circumstances, we may process your personal data based on your freely given consent. For example, when we send you promotional or direct marketing material, we do so on the basis of your consent. You can withdraw your processing consent at any time by contacting us on the details set out in the “Controlling your Personal Information” section of this Notice. In the case of direct marketing, we will ask you in each marketing communication whether you want to “unsubscribe” or “opt-out”. Please note that any processing carried out before you withdraw your consent will remain valid.

 

What we collect

We may collect the following information:

• Your name
• Your contact information such as email address
• Demographic information such as preferences and interests
• Other information relevant to customer surveys and/or offers
• Any information you provide by filling in forms on our website
• Details of any transactions you carry out through our website and the fulfilment of your orders
• Details of your visits to our website and the resources that you access
• Technical information including your Internet Protocol (IP) address, browser type and version, operating system and device type. This is collected in an anonymous manner and helps us optimize the site for our users.

Within the meaning of US Privacy Laws, the above information that we collect includes the following categories of personal data:

• Identifiers and personal data categories listed under applicable US Privacy Laws, such as the California Customer Records Statue (Cal. Civ. Code §1798.80(e)).
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with the website.

We obtain the above categories of personal data from the following categories of sources:

• Directly and indirectly from you and your interaction with the website.
• Third parties such as reliable service providers.

 

What we do with the information we gather

We use this information to provide you with online services and to ensure that our website is presented in the most efficient manner for you, and in particular for the following reasons:

• For internal record keeping purposes to support the delivery of services outlined in this Privacy Policy.
• To improve products and services directly related to this website / supported services.
• To provide you with information and promotional material about products, special offers or other information which you request from us or we think you may find interesting using the email address which you have provided and where you have freely consented to be contacted for such purposes.
• To send you promotional information about third parties which we think you may find interesting where you have freely consented to be contacted for such purposes.
• To allow you to participate in interactive features of our service, when you chose to do so.
• To notify you about changes to our products or services that relate to your subscribed services.
• We may use the information to customise our website according to your interests.
• If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services covered under your customer agreement or purchases within the previous 12 months.
• If you are a new customer, and where we permit selected third parties to use your personal information, we (or they) will contact you by electronic means only if you have freely consented to this.

If you do not want us to use your personal information, provided under consent, in this way, or to pass your details on to third parties for marketing purposes, please refer to the ‘Controlling your Personal Information’ section below.

 

Who We Disclose, Share, or Sell Personal Data To

Personal data related to you is disclosed to certain members of our staff, as well as external consultants and to our affiliates, who all process personal data in accordance with this Notice.

We also disclose personal data related to you to our agents worldwide and to third-party service providers which process personal data related to you on our behalf. Such agents and service providers will be contractually bound to keep personal data related to you confidential and appropriately secure.

A merger, acquisition or any other structural change will require us to transfer personal data related to you to another entity, as part of the structural change, provided that the receiving entity will comply with this Notice.

We do not sell or share (within the meaning of US Privacy Laws) personal data. However, we engage third parties to provide us with services such as analytics, marketing automation, and user experience and, for these purposes only, we allow them to collect personal data on the website.

The categories of personal data collected by these third parties in the preceding 12 months include identifiers, online activities, and inferences drawn from such activities, as further detailed below.

These third parties do not pay us for collecting such information, but the right granted to them to collect personal data may be considered as disclosure for the purpose of sale or share for cross-context behavioural advertising. At any time, you can opt-out of the collection of personal data by our service providers by following the instructions in the “Controlling your Personal Information” section below.

We will also need to disclose personal data related to you in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

Children

We do not knowingly sell or share personal data related to children, as such term is defined under applicable US Privacy Laws.

 

Sensitive Personal Data

The website is not intended to collect sensitive personal data (within the meaning of US Privacy Laws), we do not knowingly collect sensitive personal data, and require you not to provide us with any such data.

 

Security

Tirlán is committed to maintaining the highest levels of Information Security across our business functions and electronic business channels.

To ensure that we communicate and trade with our customers in a secure manner, the following safeguards are implemented across our services:

• We apply digital certificates to our official corporate websites to secure communications and also provide assurance that you are connected to approved resources
• All our customer, supplier and accounts payable / accounts receivable functions all use Tirlán branded email addresses and never use 3rd party email addresses
• We will treat all your queries in relation to potentially fraudulent activity with the highest urgency
• We maintain in-house and external Information Security services to provide website security analysis and identify areas of website security improvement

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

Transfers of your Data

We may transfer your personal data outside the European Economic Area (“EEA“). Certain recipients, for example, some of our third-party service providers, may process your personal data outside the EEA to a country that does not provide an adequate level of protection for your personal data. Where such transfers occur, it is our policy to put in place an appropriate transfer agreement such as the European Commission’s standard contractual clauses. If you would like to find out more about any such transfers, please contact us dataprotection@tirlan.ie.

 

Controlling your Personal Information

You have a number of rights in relation to your personal data, which are set out below. Please note that in certain circumstances these rights may not be absolute. You have the:

• right of access:you are entitled to receive a copy of your personal data which we hold. We will only charge you for such a request where we feel your request is manifestly unfounded or excessive.
• right to rectification:you can request that we amend any inaccurate personal data that we have about you.
• right to erasure:you can request us to erase the personal data we hold about you in certain circumstances.
• right to restriction of processing:you can request that we restrict our processing of your personal data in certain circumstances.
• right to data portability: you can request your personal data be provided to you in a structured, commonly used, and machine-readable format and have your personal data transmitted to another controller in certain circumstances where it is technically feasible.
• right to object: you can object at any time where we process your personal data on the legal basis of our legitimate interests or where we process your personal data for direct marketing purposes. Please note Tirlán does not engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• opt-out rights: You have the right to opt-out of the sale or sharing of US Privacy Laws-governed personal data related to you by us, or otherwise the use of such information for targeted advertising or profiling for the purpose of making decisions that produce legal or similarly significant effects concerning you. As detailed above, we allow our service providers to collect personal data related to you. Under some US Privacy Laws, such activity may constitute sharing or selling (within the meaning of US Privacy Laws) of personal data related to you. Accordingly, you have the right to request to opt-out of such third parties’ collection of personal data by following completing the following form.
• non-discrimination. You have the right not to receive discriminatory treatment by us for exercising your privacy rights detailed in this Notice.

If you would like to exercise any of these rights or have any questions or concerns about how we use your personal information, please contact us at dataprotection@tirlan.ie .

We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request (or within a different timeframe if required under applicable US Privacy Laws). We may extend this up to 2 months if necessary and permitted under the GDPR or US Privacy Laws, as applicable; however, we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights. You also have the right to lodge a complaint with the Data Protection Commission. For further information, see www.dataprotection.ie.

When submitting your request with respect to US Privacy Laws-governed personal data, note that your verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with the requested personal data if we cannot verify your identity or authority to make the request and confirm the personal data related to you. We will only use the personal data provided in your request to verify your identity or authority to make the request.

Any disclosures we provide regarding US Privacy Laws-governed personal data will only cover the 12-month period preceding receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will inform you of the reasons for such decision and provide you with a cost estimate before completing your request.

We will not require that you create an account in order to exercise your rights under this Notice and we will not increase the cost, or decrease the availability, of the website based solely on the fact that you have chosen to exercise one of your rights under the GDPR or US Privacy Laws.

After receiving our reply, you can appeal against our decision by contacting us. We will review your appeal and provide you with our answer and our explanation of the reasons for our decision(s) within 60 days of receiving it (or within another timeframe if required otherwise under applicable US Privacy Laws). We will also provide you with a link (to the extent that we are required to do so, and only where such link is available) where you can submit a complaint with the relevant Attorney General.

 

How long do we retain personal Data?

We retain different types of personal data related to you for different periods, depending on the purposes for processing the data, our legitimate business purposes, and pursuant to legal requirements under applicable law.

We may maintain your contact details to help us stay in contact with you, in case such information was provided to us by you.

At any time, you can contact us at the email address detailed in this Notice and request to delete your contact details. Note that we will keep your details without using them if necessary, and for the necessary period of time, for legal requirements and proceedings.

We may retain personal data related to you after you have terminated your use of the website, if retention is reasonably necessary to resolve disputes between our users, to prevent fraud and abuse, or to enforce this Notice.

We will keep aggregated non-identifiable data without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

In any case, we will keep data about you for as long as you use the website, unless applicable law requires us to delete it, or if we decide to remove it at our discretion, according to the terms of this Notice.