Privacy Notice

Who are we?

How can you contact us?

“We” are the Brockley Group Limited,(“ Brockley Group”) one of Ireland’s largest independent distributors of chemical products to key sectors of Irish industry, including pharmaceuticals & healthcare, electronics & surface coatings, and the automotive sector. Let’s discuss please.

This Notice applies to the Brockley Group Ltd and all associated companies defacto within the Brockley Group structure

We are a limited liability company registered at the Companies Office, with company no. 58263, and our registered offices are at Unit 3, Block 5.1, Woodford Court, Woodford Business Park, Santry, Dublin 17, D17 CY84

The DATA CONTROLLER for the purposes of the General Data Protection Regulation EU2016/679, and the Data Protection Acts 1988 – 2018 is the “Brockley Group Limited.

For data protection issues, please email gdpr@brockley.eu

Or write to us at:

The Brockley Group,
Unit 3 Woodford Court
Woodford Business Park,
Dublin D17 CY84
Tel: +353 1 839 2016
E: info@brockley.eu

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What information about me do you collect & use? Where do we get your personal data from?

We collect Data from you which you volunteer when you provide such Data to us, or via our services with which you interact. We may also be given other Data relating to you by other persons, or we may obtain such other Data about you as may be provided to us in the course of our legitimate business activities.

We may collect and process Data, including the following in the course of providing services to you, which could contain your personal data including your special category data:

“ Data” is data that can identify you, either directly or indirectly, as an identified or identifiable individual.

We also collect data directly from you when you or your firm become a customer of The Brockley Group,

The personal data we collect includes but limited to the following:

• Your full name;
• Home address;
• Your full name;
• Work address;
• Email addresses;
• Home and work phone numbers;
• Mobile numbers;
• Status in employer’s firm;
• Length of time in role;
• Details of Indemnity insurance (suppliers);
• Financial information about you, including;
• Your bank account details;
• Credit card details, and;
• Other payment details.
• Details of contracts you have entered with third parties for us to provide services to you;
• Any other data which you ask us to process on your behalf, or which is necessary for us to process in order to fulfil our role in providing our products or services to you; and
• Images and video data via security cameras located on the premises.

We may also process other data, which is not personal data. When you access our website your device’s browser provides us with information such as your IP address, browser type, access time and referring URL which is collected and used to compile statistical data. This information may be used to help us to improve our website and the services we offer, and to offer services to you.

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Do you collect information from children (under 16yr olds)?

Our products or services are not directed to children under the age of 16 years and we request that such individuals do not provide personal date to us.

We do NOT collect any data from children and if we discover that we inadvertently have such data we will immediately delete it.

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How and why do use my personal information?

We will process your information for the purposes as set out in this Notice, in particular:

• to provide to you our full range of products and services.
• carry out any contractual obligations we have towards you.
• to promote and organise our business and interests.
• to operate the Brockley Group website and deliver the response, product, or service you have requested.
• to inform you of other products or services available from the Brockley Group and its affiliates.
• to contact you directly or via surveys to conduct research about your opinion of our existing products or services or possible new offerings that we may be considering.
• to contact you on behalf of other business partners about offers or services we believe may be of interest to you (we will not disclose your personal data without your consent).
• to share data with Brockley Group trusted suppliers in order to assist us operate our business, provide customer support, to provide logistical services, provide computer and other services to us, to provide security services to us, to perform statistical analysis, to contact you via email or by post and to arrange for deliveries.
  • All such third parties are prohibited from using your personal information except to provide these services to the Brockley Group, and they are required to maintain the confidentiality of your information.
• to process your data to comply with any legal obligation to which we may be subject, and to obey any Court Order.

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Do you share my information?

Your data is shared as necessary within the Brockley Group for business purposes such as internal administration, invoicing, providing you, your organization or company with our products, and as set out below.

We do not sell, rent, or otherwise share personal data with unaffiliated entities for their independent use except as expressly described in this Privacy Notice or with your prior consent.

We share data with our third-party service providers that perform services on our behalf, such as our logistical service providers, web-hosting companies, mailing vendors, information technology providers, IT service providers, cloud storage providers and our CCTV monitoring partners.

We would also share with service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged with another company or association, or we sell, liquidate, or transfer all or a portion of our assets

Such sharing takes place only to the extent necessary to perform the services carried out for or on our behalf and making sure that they comply with data protection law.

All such third parties are prohibited from using your personal information except to provide these services to the Brockley Group and they are required to maintain the confidentiality of your information.

The Brockley Group will otherwise disclose your personal information, without notice to you, only if required to do so by law or in the good faith belief that such action is necessary to:

• (b) conform to the edicts of the law or comply with legal process served on the Brockley Group or the website.
• (b) protect and defend the rights or property of the Brockley Group and its staff; and
• (c) act under exigent circumstances to protect the personal safety of staff or users of the services or facilities of the Brockley Group or the public.

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Is my information sent outside the European Union?

We will, from time to time, make use of services provided by 3rd parties for the delivery of our services which may necessitate the transfer of personal data outside the EU/EEA. For example, we use a variety of cloud-based tools such as Microsoft Office 365. Where data needs to be transferred or processed outside the EU/EEA, we chose providers who process data on the basis of

SCCs

An Adequacy Decision from the European Commission

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What is the legal basis for you collecting and processing my information?

Irish and EU law sets out the grounds upon which data controllers such as the Brockley Group can rely on to lawfully process personal data.

We rely on the following grounds:

Where you have given, us consent to the processing of your data for a specific purpose.

The processing is necessary for the Brockley Group to fulfil our contract with you.

The processing is necessary for compliance with a legal obligation, for example to comply Revenue requirements;

The processing is necessary in order to protect the vital interests of a staff member or another person, for example, an attendee at a training course in a medical emergency;

The processing is necessary for the purposes of the legitimate interests pursued by the Brockley Group or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Some marketing might take place under this heading, but never to children.

The legal bases for the processing of your special category data or sensitive data (for example health data) are:

• That you have explicitly provided consent.
• Processing necessary for compliance with a legal obligation to which we are subject.

Processing necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes

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What are my rights, and how do I exercise them?

As an individual, under EU law you have certain rights to apply to us to provide information or make amendments to how we process your Data. These rights apply in certain circumstances and are set out below: -

The right to access data relating to you (‘access right’).
The right to rectify/correct data relating to you (‘right to rectification’).
The right to object to processing of data relating to you (‘right to object’).
The right to restrict the processing of data relating to you (‘right to restriction’).
The right to erase/delete data relating to you (i.e., the ‘right to erasure’).
The right to ‘port’ certain data relating to you from one organisation to another (‘right to data portability’).

These rights are not absolute and only apply in certain circumstances. You may exercise any of the above rights by contacting us accompanied by all necessary information via:

an e-mail to gdpr@brockley.eu
or a written request to the following address:
The Brockley Group,
Unit 3 Woodford Court
Woodford Business Park
Dublin D17 CY84

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie

We would ask that you contact us first at gdpr@brockley.eu , to enable us to try to deal with the matter to your satisfaction.

Where our processing of your personal data is based on your consent to that processing, you have the right to withdraw that consent at any time but any processing that we have carried out before you withdrew your consent remains lawful.

If you are receiving marketing from us, you may opt out. If you no longer wish to be contacted for marketing purposes, please contact us as set out in this Notice to request to “opt out" of marketing.

The exercise of Data Subjects’ rights as some other “interactions” requires the univocal identification of the person submitting such request as being, in fact, the Data Subject to whom such Personal Data pertains to, hence we may have to set in place a process or mechanism that allows it to document having undergone such assertive identification.

We would ask that you contact us first at gdpr@brockley.eu, to enable us to try to deal with the matter to your satisfaction

DATA PROTECTION COMMISSION contact details are:

Phone +353 57 868 4800 or +353 761 104 800
LoCall 1 890 25 22 31
Fax +353 57 868 4757
email: info@dataprotection.ie

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Can I stop getting emails, text messages and other communications from you?

Yes!

If you no longer wish us to contact you in a particular way, for example, to no longer send you text messages, just advise us of that and we will respect your wishes.

As a customer of the Brockley Group it is necessary for us to contact you from time to time in connection with services, for example to ensure your data is correct.

MARKETING
If you no longer wish to receive marketing communications by electronic means, just use the opt-out facility in any of our communications, OR advise us at gdpr@brockley.eu

You may also write to us or telephone us at:
The Brockley Group
Unit 3 Woodford Court
Woodford Business Park
Dublin D17 CY84
Tel: +353 1 839 2016
E: gdpr@brockley.eu

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Is my information secure?

We are committed to protecting the security of your Data. We use a variety of security technologies and procedures to help protect your Data from unauthorised access and use. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. We will continue to revise policies and implement additional security features as new technologies become available.

The transmission of information via the internet is not completely secure and may involve the transfer of data to countries outside of the European Economic Area (EEA). This occurs typically through use of cloud solutions for web hosting, email hosting or proprietary software solutions delivered to us through the Cloud. We do not however authorise any third party to use your Data for their own purposes. Non-EEA countries may not provide an adequate level of protection in relation to processing your personal data. By submitting your data, you agree to this transfer, storing and processing.

Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to us. Any transmission of data is at your own risk. Once we receive your Data, we use appropriate security measures to seek to prevent unauthorised access.

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How long do you keep my information?

We keep your Data for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your Data to provide this service to you, you can request that we erase your Data. Please note that if you request the erasure of your Data:

We may retain some of your Data as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety.

We may retain and use your Data to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting, and auditing obligations.

Because we maintain our records to protect from accidental or malicious loss and destruction, residual copies of your Data may not be removed from our backup systems for a limited period of time.

A detailed Retention Schedule has been drawn up, and if you would like further information in respect of a particular category of data relating to you, please contact:

gdpr@brockley.euor contact us at :

The Brockley Group,
Unit 3 Woodford Court
Woodford Business Park
Dublin D17 CY84
Tel: +353 1 839 2016

In line with this Policy and our Data Subjects’ Rights Policy, we aim to respond to all such requests within 1 month.

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How do I contact the Data Protection Commission?

You have the right to complain to the Data Protection Commission if you feel that we are in breach of any of your rights. Full contact details are provided below.

We would ask that you contact us first, to enable us to try to deal with the matter to your satisfaction.

Please contact us atgdpr@brockley.eu
Or:

The Brockley Group,
Unit 3 Woodford Court
Woodford Business Park
Dublin D17 CY84
Tel: +353 1 839 2016

If you wish to exercise any of the rights you have in respect of your data, please contact us gdpr@brockley.eu

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Miscellaneous

Where we process your Data based only on your consent, you may withdraw your consent.

You have the right to bring a complaint to a supervisory authority if you have any complaints about the processing of your Data. In Ireland the Data Protection Commission is the supervisory authority. In circumstances where the provision of your Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, we will advise you at the point of collecting your Data whether the Data is a required field, and the consequences of not providing the Data.

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Links to other sites

Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies/notices and that we do not accept any responsibility or liability for those policies/notices. Please check those policies/notices before you submit any data to those websites

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Changes to this Notice

We reserve the right to change this Notice from time to time in our sole discretion. If we make any changes, we will post those changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or our services or otherwise provide data after we post any such changes, you accept and agree to these terms.

This Notice is effective from August 6th 2021.

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