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Marksystem Privacy Policy

Relating to the use of Marksystem’s Website and Services.

Effective on September 25, 2018

 

At Marksystem we are committed to providing you with the highest level of protection for your data and privacy.

Our existing customers us with their data and we ensure that the highest safety standards for data storage and processing are always met. We only collect data when it’s truly necessary, and in our customers’ best interests.

The following outlines how we are applying the guidelines as set out by the new General Data Protection Regulation (GDPR).

Our Privacy Policy is intended to describe what personal data we collect, how we process it and why we use your personal data. It also describes options we provide for you to access, update or otherwise take control of your personal data that we process.  We hereby fulfil our statutory obligations under the EU General Data Protection Regulation (EU-GDPR, EU 2016/679).

In this document we also explain how we use cookies and analysis tools throughout our websites and in our products and services.

Please note that further information may be added to our Data Protection Policy depending on the product or service concerned.

Please read this Privacy Policy carefully and make sure that you understand it. If you have any further questions or there is something you do not understand, please contact us at info@marksystem.ie.

We comply with relevant privacy laws and this Privacy Policy at all times. We only share data with others as described in these provisions.

Activity data

Data stored about the user’s activities.

 

Analytical tools

Programs allowing analyses of user behaviour.

 

Cookies

Cookies are small text files that are stored on your computer or in your browser.

 

GDPR

General Data Protection Regulation, revision of data protection regulations for the European Union.

 

IP address

An address within the computer network based on the Internet Protocol (IP). This address is assigned to the device and thus allows the device to be addressed and so accessed.

 

Personal data

This information relates to a specific or identifiable natural, living person.

We process different data when you visit our website, buy and use our services and products. The collected data may directly or indirectly identify you (“personal information” or “personal data”).

Information when you visit our websites:

When you visit one of our websites, we may process information on the region you are visiting us from, your IP address, information on your device, its operating system and browser, your user behaviour on our site during the current session, the pages you view, and whether you have visited us before. For this, we use cookies (click here for further information).

Registration information:

To activate or use some of our products or services, you need to create an account. During the process of setting up your Account, we will ask you for certain personal information such as your name, email, and IP addresses, your telephone number and address details.

Support inquiries:

If you contact us for support inquiries, we will store your data in connection with this particular inquiry, such as contact details, information on your hardware and software, and log data.

Contact forms:

Complete contact forms or request newsletters or other information from us (ex: email).

However, we also collect additional information when delivering our Services to you to ensure necessary and optimal performance.  These methods of collection may not be as obvious to you, so we wanted to highlight and explain below a bit more about what these might be (as they vary from time to time) and how they work:

Account related information is collected in association with your use of our Services, such as account number, purchases, when products renew or expire, information requests, and customer service requests and notes or details explaining what you asked for and how we responded.

Cookies and similar technologies on our websites and our mobile applications allow us to track your browsing behaviour, links clicked, items purchased, your device type, and to collect various data, including analytics, about how you use and interact with our Services. This allows us to provide you with more relevant product offerings, a better experience on our sites and mobile applications, and to collect, analyse and improve the performance of our Services. We may also collect your location (IP address) so that we can personalize our Services. For additional information, and to learn how to manage the technologies we utilize, please visit our Cookie Policy.

 

Data about Usage of Services is automatically collected when you use and interact with our Services, including metadata, log files, cookie/device IDs and location information. This information includes specific data about your interactions with the features, content and links (including those of third-parties, such as social media plugins) contained within the Services, Internet Protocol (IP) address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data, information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and error data, and some of this data collected might be capable of and be used to approximate your location.

We store this data we collect in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.

We process your data, whether it can be traced back directly or indirectly to a natural person or not, for the following purposes:

To fulfil our contractual obligations to you.

For correct operation of our products and services.

For convenient and straightforward use of our products and services.

To improve and optimize the features, security, and stability of our products and services.

For administrative purposes.

To offer you optimized product information.

Depending on the service and the business process involved, we can process your personal data based on the following lawful basis:

Contract initiation and performance.

we only store personal data needed to fulfil our contractual obligations to you.

Consent.

Your consent is required for the processing of certain data. In these events we will inform you expressly about the situation and provide you with the opportunity to allow us to process this data (e.g. newsletters, information about product and services)

In these cases, we will inform you about the purpose of the data processing and about your right of revocation.

Legitimate interest.

It is also possible to process data on the basis of our legitimate interest. Thereby, we are obliged to disclose our interest and take both your and our interests into consideration (e.g. when registering on our website, we need your personal data to be able to allow you the authentication).

We store personal data only to the extent required to fulfil the purpose. The storage period depends on the duration of the contractual relationship and legal requirements.

Should the data no longer be used, it will be deleted in accordance with legal requirements.

Should you wish to have your data deleted, please note that we are able to block your data immediately. Further, please note that after the confirmation of your deletion request it is not possible to restore your data.

When you use a product or service, cookies are uploaded to your browser. Cookies may be used to identify your browser so that our website is displayed correctly. We also use cookies at various points on our website to analyse the use of our website and thereby optimize it. For additional information, please visit our Cookie Policy.

In addition to our own systems, we also use the following third-party tools for marketing purposes and to make your visit to our websites or the use of our products/services more user-friendly

Google Analytics 360

We use Google Analytics 360, a web analysis service from Google (Google Inc.). Google Analytics uses cookies that enable us to analyse your use of our websites. The data generated by cookies about your use of our website is generally processed on European servers in accordance with GDPR guidelines. Google may transfer the data to a server in the USA and store it there. Prior to this, however, Google will shorten your IP address if it originates in a member state of the European Union or in other signatory states to the Agreement on the European Economic Area and thus make it anonymous (Google’s anonymizeIp process). The entire IP address is transferred to a Google server in the USA and saved there only in exceptional cases. This anonymization ensures that your IP address cannot be traced back to you. Google uses this data to evaluate your use of the website, to generate reports on website activities for Marksystem, and to provide other services associated with website and internet use. Google can transfer this information to third parties, where appropriate, if legally mandated or if Google contracts with third parties to process such data. Google will not associate your IP address with other Google data.

You still have the option to prevent Google from collecting data generated by cookies and relating to your use of the website (including your IP address) as well as from processing this data by downloading and installing a browser plug-in provided by Google.

Further information on Google Analytics can be found here.

We do not share or sell your data to third parties for advertising purposes. Your personal data will not be transmitted to third parties for reasons other than those listed below.

We will only disclose your personal data to third parties, if:

  • You have expressly given us your consent for this,
  • it is legally permissible and necessary for the execution of our contractual relationships with you,
  • data transmission is based on a legal obligation, as well as
  • data disclosure is justified by a particular interest and there is no reason to assume that you have an overriding legitimate interest in the non-disclosure of your data at this time.

We share personal data with the following recipients or categories of recipients for the aforementioned reasons:

  • Employees (internal and external)
  • IT infrastructure service providers
  • Payment processors
  • Providers of analysis tools

Here are a few examples:

  • Enom – domain registrar.
  • 2CheckOut and Paypal – payment gateways.
  • Google analytics – we use this tool for track and analyze website traffic.
  • SurveyMonkey (SurveyMonkey Europe UC) – we use this platform to conduct surveys such as on your product satisfaction. For your protection, personal data is processed in a pseudonymous form.

We enter into contracts with carefully selected third parties (sub-processors) so that they can assist us in servicing you. Our contracts with such third parties prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.

 

If you purchase a product or service from a third party through our website, we will pass your personal information to such third party in order for them to fulfil your order.

We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third-party processors whose use of your personal information is governed by their privacy policy. We use third party payment processors, such as PayPal and 2 Checkout for all payments. For more details of your payment data processing, please refer to the Privacy Policy of the Payment provider you choose while placing the order. Marksystem does not store credit card details and instead relies on its processors for this.

Marksystem is a processor based in EU and uses, generally, third-parties service providers also based in the European Union. However, to be able to deliver specific services, such as domain name registration, we might use trusted service providers based outside European Union or European Economic Area (EEA). An example is ‘’Enom’’ which is a provider based in Canada.

Marksystem does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Marksystem through the Services, please contact us, and we will endeavour to delete that information from our databases.

You have the following rights in connection with your personal data, subject to possible legal restrictions:

 

The right to be informed, rectification, erasure, restriction of processing, portability, and objection to processing.

At this point we expressly point out that we reserve the right to perform an identity check of the individual submitting the inquiry, in accordance with legal requirements, and to also take further measures to clearly verify the inquirer’s identity.

Right to information

You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. If you would like to know what personal data we hold on you, login to your client area at https://marksystem.company/clientarea.php . Here you will find an overview of the records stored by us, such as your name, email address, and postal details.

You can receive these data also on request via email. The provision of this information may take some time, depending on the scope of the activity data.

 

Right to rectification:

You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. If you find that the personal data we hold on you is incorrect, you can change it yourself by logging in to your Marksystem account or contact us in writing at info@marksystem.ie.

 

Right to erasure:

You may request that we erase the personal information we hold about you in the following circumstances:

 

  • where you believe it is no longer necessary for us to hold the personal information;
  • we are processing it on the basis of your consent and you wish to withdraw your consent;
  • we are processing your data on the basis of our legitimate interest and you object to such processing;
  • you no longer wish us to use your data to send you marketing; or
  • you believe we are unlawfully processing your data.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure.

Should you wish to delete your data, please contact us and we will then erase your data in accordance with legal requirements.

Additionally, we would like to point out that we are able to block your data immediately but due to technical restrictions it may take up to 72 hours to permanently delete your data, provided there are no legal obligations and statutory rights preventing deletion.

Further, please note that after the confirmation of your deletion request it is not possible to restore your data.

Right to restriction of processing:

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances:

  • You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate;
  • We wish to erase the personal information as the processing we are doing is unlawful, but you want us to simply restrict the use of that data;
  • We no longer need the personal information for the purposes of the processing, but you require us to retain the data for the establishment, exercise or defence of legal claims; or
  • You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information.

To this end, please inform us of the categories of data affected by your request and the reasons for your request. We will examine the facts immediately and inform you of the result.

 

Right to data portability:

Please let us know in text form via email which data you would like to transfer to whom. We will examine your request immediately and inform you of the result.

Objection

You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose.

 

Right to lodge a complaint:

If you are dissatisfied with our efforts in connection with data protection, you have the right to lodge a complaint with the data protection supervisory authority responsible in your country.

Marketing communication from Marksystem via email.

 

You always have the opportunity to opt out of our marketing communications with you or change your preferences by following a link in the footer of all non-transactional email messages from us or by emailing us at infoy@marksystem.ie. Some communications from us are considered transactional or service communications (for example, important account notifications and billing information). You must cancel your account if you do not wish to receive any transactional or service communications.

Marksystem takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email

Information kept by us in our business is protected using industry standard security measures. Though we reserve the right to keep the information covered in this Privacy Policy indefinitely, our employees are required to keep this information confidential – unless disclosure is authorized in this Privacy Policy or by Users. No means of communication, information transmission, or storage is totally secure. Because of this we are not responsible for loss corruption or unauthorized acquisition and use of information covered by this Privacy Policy, or for any resulting damages, including unauthorized acquisition and use. Please keep this in mind when disclosing any Personal Data to Marksystem via the Internet.

In the event that you wish to make a complaint about how we process your personal information, please contact our team at info@arksystem.com. This is without prejudice to your right to raise a complaint with the Irish Supervisory Authority (Data Protection Commission).

Data Protection Commission contact details:

Telephone +353 57 8684800

+353 (0)761 104 800

Lo Call Number 1890 252 231

Fax                        +353 57 868 4757

E-mail                  info@dataprotection.ie

Postal Address  Data Protection Commission

Canal House

Station Road

Portarlington

R32 AP23 Co. Laois

The Services and our business may change from time to time. As a result, at times it may be necessary for Marksystem to make changes to this Privacy Policy. Marksystem reserves the right to update or modify this Privacy Policy at any time and from time to time. If we do this, we will post the changes to this Privacy Policy on this page and will indicate at the top of this page the date these terms were last revised. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Service after the date any such changes become effective constitutes your acceptance of the new Privacy Policy.

Last modified September 25, 2018