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BOLD CRAFT MARKETING & SOCIAL JAM PRIVACY POLICY

Bold Craft Marketing LTD understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits our websites, www.boldcraftmarketing.com and www.socialjam.ie (“Our Sites”), and will only collect and use personal data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of Our Sites. If you do not accept and agree with this Privacy Policy, you must stop using Our Sites immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

2. Information About Us

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Sites. Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

As a data subject, you have the following rights under the GDPR, which this Policy and our use of personal data have been designed to uphold:

If you have any cause for complaint about our use of your personal data, please contact us using the details provided in section 14 and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the Data Commissioner of Ireland.

For further information about your rights, please contact the Data Commissioner’s Office of Ireland or your local Citizens Advice Bureau.

5. What Data Do We Collect?

Depending upon your use of Our Sites, we may collect some or all of the following personal and non-personal data (please also see section 13 on our use of Cookies and similar technologies):

6. How Do We Use Your Data?

All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with our obligations and safeguard your rights under the [Data Protection Act 1998] OR [GDPR] at all times. For more details on security see section 7, below.

Our use of your personal data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your personal data (e.g., by subscribing to emails), or because it is in our legitimate interests. Specifically, we may use your data for the following purposes:

[Market research;]

[Analyzing your use of Our Sites [and gathering feedback] to enable us to continually improve Our Sites and your user experience;]

With your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by [email] AND/OR [telephone] AND/OR [text message] AND/OR [post] with information, news, and offers on our AND/OR

. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the [Data Protection Act 1998] OR [GDPR] and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Third parties (including <>) whose content appears on Our Sites may use third-party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that we do not control the activities of such third parties, nor the data they collect and use, and advise you to check the privacy policies of any such third parties.

You have the right to withdraw your consent to us using your personal data at any time and to request that we delete it.

We do not keep your personal data for any longer than is necessary for light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

7. How and Where Do We Store Your Data?

We only keep your personal data for as long as we need to in order to use it as described above in section 6, and/or for as long as we have your permission to keep it.

[Your data will only be stored in the ROI.] OR 7.2 [Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).] OR 7.2 [Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Sites and submitting information to us. If we do store data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the [Data Protection Act 1998] OR [GDPR] including:

7.3 Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through Our Sites.

7.4 Steps we take to secure and protect your data include:

8. Do We Share Your Data?

[Subject to section 8.2, We will not share any of your data with any third parties for any purposes.

8.2 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal obligations, a court order, or a governmental authority.] OR

8.1 [[We may share your data with other companies in Our group [for <>]. This includes [Our subsidiaries] AND/OR [Our holding company and its subsidiaries].]

8.2 [We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.]

8.3 [We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.]

8.4 [The third-party data processors used by us and listed below are located] OR [We may sometimes use third party data processors that are located] outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the [Data Protection Act 1998] OR [GDPR] including:

8.5 In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.]

9. What Happens If Our Business Changes Hands?

9.1 We may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of our business. Any personal data that you have provided will, where it is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

9.2 In the event that any of your data is to be transferred in such a manner, you will

[not]

be contacted in advance and informed of the changes. [When contacted you will [not, however,] be given the choice to have your data deleted or withheld from the new owner or controller.]

10. How Can You Control Your Data?

10.1 [In addition to your rights under the GDPR, set out in section 4, when] OR [When] you submit personal data via Our Sites, you may be given options to restrict our use of your data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details [and by managing your Account]).

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you from receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.

11. Your Right to Withhold Information

11.1 You may access [certain areas of] Our Sites without providing any data at all. [However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.]

11.2 You may restrict our use of Cookies. For more information, see section 13

12. How Can You Access Your Data?

You have the right to ask for a copy of any of your personal data held by us (where such data is held). [Under the Data Protection Act 1998, We require the payment of a small fee which will not exceed £<>.] OR [Under the GDPR, no fee is payable and we will provide any and all information in response to your request free of charge.] Please contact us for more details at info@boldcraftmarketing.com or using the contact details below in section 14. [Alternatively, please refer to Our Data Protection Policy <>.]

13. Our Use of Cookies

13.1 [Our Sites may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our AND/OR [services]. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.2 By using Our Sites you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Sites for <>. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Sites will not be impaired by refusing consent to them.

13.3 All Cookies used by and on Our Sites are used in accordance with current Cookie Law.

13.4 Before Cookies are placed on your computer or device, you will be shown a <> requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended. [You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.]

13.5 [Certain features of Our Sites depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Sites may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.]

13.6 The following first party Cookies may be placed on your computer or device:

Name of Cookie Purpose Strictly Necessary

_ga Used to distinguish users. No

_gid Used to distinguish users No

  1. Our Use of Cookies

13.1 [Our Sites may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our AND/OR [services]. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

13.2 By using Our Sites you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Sites for <>. For more details, please refer to section 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Sites will not be impaired by refusing consent to them.

13.3 All Cookies used by and on Our Sites are used in accordance with current Cookie Law.

13.4 Before Cookies are placed on your computer or device, you will be shown a <> requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended. [You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.]

13.5 [Certain features of Our Sites depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.6. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.10, but please be aware that Our Sites may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.]

13.6 The following first party Cookies may be placed on your computer or device:

Name of Cookie Purpose Strictly Necessary

NONE

13.7 Our Sites use analytics services provided by <>. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Sites is used. This, in turn, enables Us to improve Our Sites and the AND/OR [services] offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable Us to continually improve Our Sites, making it a better and more useful experience for you.

13.8 The analytics service(s) used by Our Sites use(s) Cookies to gather the required information.

13.9 The analytics service(s) used by Our Sites use(s) the following Cookies:

Name of Cookie Purpose Strictly Necessary

_ga Used to distinguish users. No

_gid Used to distinguish users No

13.10 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

13.11 You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalisation settings.

13.12 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]

OR

[Our Sites may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve Our AND/OR [services]. By using Our Sites you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Sites for <>. In addition, Our Sites use analytics services provided by <>, which also use Cookies. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Sites. For more details, please refer to Our Cookie Policy <>.]

14. Contacting Us

If you have any questions about Our Sites or this Privacy Policy, please contact Us by email at info@boldcraftmarketing or by telephone on 098 30300, or by post at Altamont Industrial Estate, Westport. Co.Mayo, F28 A318. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you (as under section 12, above).

15. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date.