This Policy This policy explains how we may process your personal data.

This policy may be amended or updated from time to time, so please check it regularly for updates.

This policy is issued by Ray of Sunshine, its subsidiaries and its affiliates and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our web sites, users of our Apps, and other users of our services. For the purposes of this policy, Ray of Sunshine is the Data Controller. This policy covers the information practices relating to our company web sites and services offered now or in the future. This policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in Irish or European Union law. We encourage you to read this policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this policy.

Collection of Personal Data We may collect personal data about you from the following sources: –

Data you provide: We may obtain your personal data when you provide it to us e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card.

Relationship data: We may collect or obtain your personal data in the ordinary course of our relationship with you e.g., if you purchase a service from us.

Data you make public: We may collect or obtain your personal data that you manifestly choose to make public, including via social media e.g., we may collect information from your social media profile(s), if you make a public post about us.

App data: We may collect or obtain your personal data when you download or use any of our Apps.

Web site data: We may collect or obtain your personal data when you visit our web sites or use any features or resources available on or through a web site.

Registration details: We may collect or obtain your personal data when you use, or register to use, any of our web sites, Apps, or services.

Content and advertising information: If you choose to interact with any third-party content or advertising on a web site or in an App, we may receive personal data about you from the relevant third-party.

Third party information: We may collect or obtain your personal data from third-parties who provide it to us e.g., credit reference agencies; law enforcement authorities; etc. Creation of Personal Data We may also create personal data about you, such as records of your interactions with us, and details of your purchase history for internal administration purposes and analysis. Categories of Personal Data we may Process We may process the following categories of personal data about you: –

Personal details

  • given name(s)

Demographic information

  • salutation
  • gender
  • date of birth or age
  • nationality
  • job title
  • industry
  • language preferences

Contact details

  • correspondence address
  • telephone number(s)
  • email address
  • details of your public social media profile(s)

Consent records

  • records of any consents you may have given o the date and time
  • the means by which we obtained your consent

Purchase details

  • records of purchases
  • prices paid

Payment details

  • invoice records
  • payment records
  • billing address
  • payment method
  • bank account number
  • credit card number
  • cardholder or account holder name
  • card or account security details
  • card ‘valid from’ date
  • card expiry date
  • BACS details
  • IBAN details
  • SWIFT details
  • payment amount
  • payment date
  • records of cheques

Data relating to our web sites and Apps

  • device type used
  • operating system
  • browser type
  • browser settings
  • IP address
  • language settings
  • dates and times of connecting to a web site
  • App usage statistics
  • App settings; dates and times of connecting to an App o location and other technical communications

Legitimate interests:

We may process your personal data where we have a legitimate interest in carrying out the processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms. Sensitive Personal Data We do not seek to collect or otherwise process your sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on one of the following legal bases:

Compliance with applicable law:

• We may process your sensitive personal data where the processing is required or permitted by applicable law e.g. to comply with our diversity reporting obligations Detection and prevention of crime:

• We may process your sensitive personal data where the processing is necessary for the detection or prevention of crime, including the prevention of fraud. Establishment, exercise or defence of legal rights:

• We may process your sensitive personal data where the processing is necessary for the establishment, exercise or defence of legal rights. Consent:

• We may process your sensitive personal data where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your sensitive personal data. This legal basis is only used in relation to a process that is entirely voluntary – it is not used for data processing that is necessary, legal or obligatory in any way. Purposes for which we may Process your Personal Data The purposes for which we may process personal data, subject to applicable law, include:

• Provision of services to you: – o providing our web sites, Apps and services to you o communicating with you in relation to those services and providing you with promotional items at your request or in connection with those services or similar services.

• Our web sites and Apps: –

  • operating and managing our web sites and our Apps
  • providing content to yo
  • displaying advertising and other information to you
  • communicating and interacting with you via our web sites and our Apps o identifying issues with our web sites and Apps and planning improvements to or creating new web sites and Apps
  • notifying you of changes to any of our web sites, our Apps, or our services.

• Communications:

  • communicating with you via any means (including via email, telephone, text message, social media, post or in person) for news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law o maintaining and updating your contact information where appropriate
  • obtaining your prior ‘Opt-In’ consent where required.

Communications and IT operations:

    • management of our communications systems
    • operation of IT security systems
    • IT security audits.

Health and safety:

  • health and safety assessments
  • record keeping
  • compliance with related legal obligations

• Financial management

  • sales; finance
  • corporate audit
  • vendor management

• Surveys: –

  • engaging with you for the purposes of obtaining your views on our services

• Security: –

  • physical security of our premises
  • records of visits to our premises
  • CCTV recordings
  • electronic security: – including login records & access details

Investigations: – detecting, investigating and preventing breaches of policy, criminal offences in accordance with applicable law

Legal proceedings: – establishing, exercising and defending legal rights

Legal compliance: – compliance with our legal and regulatory obligations under applicable law

Improving our web sites, Apps, services: – identifying issues with our web sites, our Apps, or our services o planning improvements to our web sites, our Apps, or our services o creating new web sites, Apps, or services

Disclosure of Personal Data to third parties

We may disclose your personal data to other entities within the company group, for legitimate business purposes, including operating our web sites and our Apps, and providing services to you, in accordance with applicable law. In addition, we may disclose your personal data to legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation • outside professional advisors, accountants, auditors, or lawyers, subject to binding contractual obligations of confidentiality • third party processors, e.g. payment services providers, data centres; etc., located anywhere in the world, subject to the requirements noted below. • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights • any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security • any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets, including in the event of a reorganisation, dissolution or liquidation. • any relevant third-party provider, where our web sites and our Apps use third-party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your personal data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content. If we engage a third-party processor to process your personal data, the processor will be subject to binding contractual obligations to: a) only process the personal data in accordance with our prior written instructions; b) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. International transfer of Personal Data Because of the international nature of our business, we may need to transfer your personal data within the company or group, and to third-parties as noted in the ‘Disclo