Eila Connect – Privacy Policy
This is the Privacy Policy of Eila Connect and is to be read in conjunction with our Cookie Policy.
Eila Connect is committed to protecting and respecting your privacy. This policy (together with our terms of use) and any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat your data.
Contents:
1. Who are we?
2. Why we collect information about you.
3. The information we process about you.
4. Why we use your information.
5. Who we share your data with.
6. How long we hold your information.
7. Processing your information within and outside of the EEA.
8. What are my rights when you process my data?
9. Contact us
10. Eila Connect App
1. Who are we?
For the purposes of the General Data Protection Regulation (EU) 2016/379 [‘GDPR’] and the Data Protection Act 2018, the data controller is Crothers Security Ltd. trading as Eila Connect, of 139 St. Peter’s Road, Walkinstown, Dublin 12. This policy sets out how we, as a data controller, collect and process personal data about:
- visitors to our websites
- business referrals passed to us (with the consent of the referred person)
- individuals who we communicate or interact with in the course of our business
- individuals such as Elia Connect users’ nominated contacts (nominated family and friends of an Eila Connect user) whose personal data is provided to us in connection with the provision of our Services
- employees.
If you are already an Eila Connect user, please refer to the privacy policy provided to you on sign up to our Services. Our “websites” includes this website, all our associated sites (such as our knowledge sites and blogs) and our social media pages. This statement also sets out information about data subject rights and our obligations under data protection law.
We may optional cookies to enabling user movement around our website, to optimise site functionality and give you the best possible experience. We only set strictly necessary cookies by default and you can accept optional cookies if you wish. For more information, please see our Cookie Policy.
2. Why we collect information about you
In order to carry out our business functions, we need to collect and use personal information about the individuals who come into contact with us. Most of the personal information we process is provided to us directly by you or referred to us with your consent by the referrer, for one of the following reasons.
- to enter into, or at your request taking steps to enter into, a contractual relationship for services and or products.
- to respond to any enquires made by you.
- to provide (with your consent) monitoring and or home care at a user’s premises.
- to provide assistance to a user.
- to respond to emergency alarms or situations (in order to provide assistance).
- to contact (with your consent) nominated family and friends as part of your nominated contact network.
- to contact (with your consent) medical professionals in the case of a user requiring assistance.
- to investigate any suspected or actual unauthorised use of our services and or products.
- to prevent, monitor, investigate and or report any suspected criminal activities to An Garda Síochána.
- to protect the vital interests of user on a case-by-base basis.
- to provide reasonable accommodation, where applicable, under the Equal Status Acts on a case-by-case basis.
- to comply with a legal obligation to which we are subject to, e.g. mandatory reporting of any vulnerable adult in harm, etc.
- for the purpose of any legitimate interest pursued us on a case-by-case basis.
Please note that all calls to Eila Connect, including calls made via the Eila Connect Control Panel (which is activated when a user requires assistance or emergency help) of Care app, are recorded for training and quality purposes and also to protect the legal interests of a user and Eila Connect.
Your personal data is collected by us when:
- You voluntarily provide us with your personal data throughout any interaction with us, e.g.
- when you contact us with a query or request.
- when you visit our offices.
- when you write, email or phone us.
- when you contact us via our website.
- when you contact us via the Eila Connect App.
We also receive personal information indirectly in the following scenarios:
- Any referrer who refers you to us (with your consent) in order for us to contact you.
- Any information provided by a user’s legal representative (e.g. power of attorney), carer or nominated point of contact, in order to provide services or assistance to a user.
- Retail market monitoring and reporting activities.
- Where a client or employee of ours gives your contact details as an emergency contact, nominated point of contact or a referee.
3. The information we process about you
Identity – Name, surname, title, and other identifying information provided by you
Details left in voicemails or in call recordings to Eila Connect Sales & Enquiries and or to the Eila Connect monitoring control centre, and records of these discussions,
Details provided when you contact us through our webform on our websites or Eila Connect App.
Contact information – Address, email address, phone number.
Nominated contacts, or persons a user nominates to provide assistance or to contact in cases of emergency, to include details of successors, assignees or those with power of authority or other authorised legal representatives.
Details of a client’s health and habitation status – illnesses, medical conditions, health status, living status, cohabitation status, medications, emergency contacts, daily routines, etc. in order to provide monitoring and care and or in order to make reasonable accommodation under the Equal Status Acts.
Biometric data – We only process this when explicitly instructed to by a user or their legal representative for the purposes of monitoring the weight or temperature of a user (which, on the instruction of the user, may be shared with medical practitioners). We do not process any other biometric data.
Supplier details – Contact information, bank details, VAT details and tax clearance information.
Stakeholder details – Contact information, role, meeting minutes / notes.
Licence & Authorisation Applicant details – Contact information, Names of company directors, Engineers.
Website user statistics (Google Analytics) – Location, time, date and details of your visit to our website (as anonymous statistics) Please see our Cookie Policy for more information.
Other personal information – Telephone recordings (made to our Eila Connect control centre).
CCTV images at our offices.
Information in relation to subject access requests (including proof of identity if required);
Responses to surveys.
Recruitment details – Applicant CV’s, credentials, references etc, tax and bank details of successful applicants.
Marketing information – If you have consented to receiving marketing information, or requested updates, we will contact you with relevant information until such time as you opt-out of communications.
4. Why we use your information
We fully respect your right to privacy and, in addition to the above, will only collect or process your personal data, where required, for one or more of the following purposes (or lawful basis for processing):
To run our organisation on a day-to-day basis including to:
- Contact stakeholders: Business contact information relating to stakeholders (e.g. business card information, contact details, role/position in company, etc) are processed for legitimate business-related purposes.
- Compile and process your information for audit, statistical, reporting or research purposes (including, in some instances, making your data anonymous) in order to help us understand market trends.
- Protect our business, reputation, resources and equipment and manage our network systems, and information.
- Provide security and prevent and detect crime including using CCTV at our premises.
- Manage and administer our legal and compliance affairs.
- Managing and responding to complaints about us.
- Effectively manage the functionality and usability of the website.
We will only process your personal data for the purposes for which they were originally collected, and it will only be processed further for the following closely related business purposes:
- Transferring the personal data to an archive.
- Conducting internal audits or investigations.
- Implementing business controls.
- Conducting statistical analysis or research as required.
- Preparing for or engaging in dispute resolution.
- Using legal or business consulting services; or
- Managing insurance issues.
To enter into a contract, or to take steps to enter into a contract, or to fulfil the terms of a contract:
- To provide information to prospective clients on our products and services.
- To provide our products and services to a client on foot of a contract with Eila Connect for products and or services.
- To provide follow up services, aftercare, repairs, review of products and services, to a client on foot of a contract with Eila Connect.
- To ensure payment to Eila Connect of any monies due.
- Engaging service providers and suppliers and for the provision of and payment for goods and services.
- Filling vacant positions and for the engagement and payment of employees.
- Monitoring and recording the conversations when you speak on the telephone to our Eila Connect Control Centre (to analyse, assess and improve customer service experience and for quality, training, and contract management purposes).
Complying with our legal obligations, such as:
- Preparing returns to relevant authorities including preparing income tax, VAT3 and other revenue returns.
- Making reasonable accommodation, where applicable and on a case-by-case basis, under the Equal Status Acts.
- Making reasonable accommodation, where applicable and on a case-by-case basis, under the Employment Equality Acts.
- Complying with your data protection rights under GDPR.
- Complying with legal requests or investigations from regulatory bodies, e.g. the Data Protection Commission.
- Facilitating employees making of a protected disclosure(s) under the Protected Disclosures Act 2014.
- To investigate or report a notifiable incident as mandated by the Health and Safety Authority and or the Health, Safety and Welfare at Work Act 2005.
- To prevent, monitor, investigate and or report any suspected criminal activities to An Garda Síochána.
- Complying with any court order.
- Any other legal obligation not stated here.
To protects the vital interests of a person and or Eila Connect, such as:
- In order to protect the health, safety and wellbeing of a client.
- To contact emergency services in case of an accident or emergency to seek aid for a person.
- To report any suspected criminal activity to An Garda Síochána.
- To initiate, continue with or defence any legal claim or prospective legal claim.
- To obtain legal advice on a specific matter.
- To investigate, monitor or prevent any unauthorised or illegal use of Eila Connect’s products or services.
Special categories of personal data.
We process special categories of personal data in accordance with Article 9 of the General Data Protection Regulation on the following basis:
- Explicit consent of the data subject, or their legal representative, in order to provide contracted monitoring and or support products and services to the data subject.
- Where processing is necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on us or the data subject in connection with employment, social security, or social protection, e.g. reporting of any criminal offences to An Garda Síochána.
- For the establishment, exercise, or defence of legal claims.
- Where processing is necessary to protect the vital interests of the data subject or of another natural person, e.g. in the event of an emergency in order to contact emergency services.
5. Who we share your information with?
We only share your information when it is necessary for a lawful purpose under GDPR. We will not share your information with any third parties for the purposes of direct marketing. Sharing can occur in the following circumstances and with the following organisations.
- A user’s nominated contact persons (i.e. people who the user has explicitly nominated and consented to disclosing/sharing the user’s personal data with).
- A client’s medical professionals (with the explicit consent of the client).
- Mandated bodies under statute, e.g. An Garda Síochána, etc.
Data processors who are third parties who provide services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us unless instructed to do so. They will hold it securely and retain it for the period we instruct.
Website Analytics: When you visit www.eilaconnect.ie we use a third-party service, Google Analytics, to collect standard statistical information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the site. This information is only processed in a way that does not directly identify anyone. Please see our Cookie Policy for more information.
6. How long we hold your information
We will keep your personal data for as long as it is necessary to fulfil the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. The length of time we hold your personal data depends on several factors such as:
- The type of data we hold about you.
- Whether there is a legal obligation to hold the data for a minimum specified period.
- Where there is a sound evidence-based reason to hold the data for a specified period.
Generally speaking, Eila Connect has a personal data retention period of seven years after a user or client ceases to be a user or client.
The seven-year data retention policy is based on legal advice received by Eila Connect, HSE National Records Retention Policy (Nov. 2023) by the Health Service Executive and Processing of Patient Personal Data: A Guidelines for General Practitioners v2.3 by the Irish College of General Practitioners.
7. Processing your information within and outside of the EEA
We store your data on EU based servers that are based in other EU countries and are still protected by GDPR by application of the Data Protection Commission’s “One Stop Shop Mechanism” with the Irish Data Protection Commission as the lead National Supervisory Authority.
In order to protect the integrity of our data, some back-up is stored outside of the EU, in the USA and Israel, but still subject to the same protections under GDPR by application of the EU-US Data Privacy Framework, Standard Contractual Clauses and an EU adequacy decision (relating to Israel).
For more information on the Data Protection Commission’s “One Stop Shop Mechanism”, EU-US Data Privacy Framework, Standard Contractual Clauses and EU adequacy decisions, please visit the Data Protection Commission’s website at www.dataprotection.ie.
8. What are my rights when you process my data?
You have a number of rights in relation to your personal data. You may request access to your data, correction of any mistakes in our files, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data or the basis for any international transfers.
Eila Connect does not engage in any automated processing, automated decision making or profiling of data subjects or clients.
In order to request your personal data, or to object or correct any error, please put your request in writing to:
Data Protection
Eila Connect
Crothers Security
139 St. Peter’s Road
Walkinstown
Dublin 12
Or email your request to info@crothers.ie.
You also have the right to complain to the Data Protection Commission at www.dataprotection.ie or:
Data Protection Commission
21 Fitzwilliam Square
Dublin 2
D02 RD28
We would kindly ask you to email us first at info@crothers.ie before contacting the Data Protection Commission so we can try to resolve any issue to your satisfaction.
9. Contact Us
The primary point of contact for all issues arising from this Policy, including requests to exercise data subject rights, is our Data Protection Officer. You can get in touch by emailing us at info@crothers.ie.
Once we receive an enquiry or request from you, we will try to complete it within a month.
10. Eila Connect App
The Eila Connect App is an optional app for a user’s phone or smart device that provides a secure link to the Eila Connect Control Centre (monitoring centre) that allows a user, their legal representative, or on the instructions of a user their nominated contact(s), to access activity dashboard (a user’s activity logs, sensor logs second logs and where explicitly instructed by a user, health or biometric data).
The Eila Connect App needs the following permissions on a user’s phone or smart device in order to function:
- Allow Elia Connect App to appear on top of a user’s phone screen or smart device screen.
- Allow Elia Connect App use push notifications on a user’s phone or smart device.
- Allow Elia Connect App to access files on a user’s device in order to allow a user share files with the Elia Connect Control Centre, or any nominated point of contact, at the request of the user.
The reason the Elia Connect App requires the above access to a user’s phone or smart device is to allow the user to do the following activities via the Elia Connect App:
- Access and use the Elia Connect App on their phone or smart device.
- Notify the user of any activities, notifications, events or communications on via the Elia Connect App from the Elia Connect Control Centre, user’s legal representative, carer, nominated point of contacts or emergency contacts, or on a case-by-case basis to facilitate emergency services.
- On a case-by-case basis, and only on the instruction of a user, send and receive files to the Eila Connect Control Centre, nominated contacts and or medical practitioners, for the purposes of monitoring or facilitating health care.
Upon installation of the Elia Connect App, or upon using the app for the first time, a user will be promoted to allow or reject access to the above permissions by their phone or smart device. The Elia Connect App cannot function without the above access. As such, access is necessary to provide ongoing care and support to a user via a user’s phone or smart device.
Cookies used on the Eila Connect App
The Eila Connect App does not use cookies but allows users access the internet and websites. Eila Connect is not responsible for the content or cookies used on any non-Eila Connect website.
Last review: February 2024
This Policy may be updated without further notice users are encouraged to review all Eila Connect’s privacy policies regularly.
This Privacy Policy was drafted by Argent Business Consultants and used by licence by Eila Connect.
www.argentbusinessconsultants.ie
