PRIVACY STATEMENT
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JJ Fox Ltd’s Privacy Statement refers to our commitment to our compliance to data protection legislation including the Irish Data Protection Acts and the EU General Data Protection Regulation.
At JJ Fox Ltd (referred to in this document as "we", "us" or “James Fox”), we are committed to maintaining the trust and confidence of our customers, website visitors, newsletter subscribers and anyone else we work or interact with. This policy refers to all parties whose personal data is processed by us.
We collect and process personal data of you in the course of business to sell our products to you and to provide after sale services. This personal data includes any offline physical data or online data that makes a person identifiable.
We process data for the following groups of individuals (current and former):
Job candidates,
Customers,
Contractors,
Outsourced service providers whose personal data is processed by us, and
Other parties whose personal data is processed by us.
JJ Fox Ltd’s is the controller for the personal information we process, unless otherwise stated.
There are many ways you can contact us, including by phone, email, and post. More details can be seen on this page.
Our postal address is:
James Fox Cigar & Whiskey Bonders
119 Grafton Street
Dublin 2, D02 E620
Ireland
You agree that any data you provide to us will be true, complete and accurate in all respects and you agree to notify us immediately of any changes to it. We will only collect personal information from or about you which is necessary for the following purposes:
General
Provide this website to you and respond to your queries
To comply with all relevant law
To manage the safety and security of you while on our premises
To facilitate the prevention, detection and investigation of crime and the apprehension or prosecution of offenders
To investigate, exercise or defend legal claims or other claims of a similar nature
Sales Leads and Customers
Provide this website to you
Provide quality products and after sales services to you
Set up and administer your account as a customer with us
To maintain our relationship with you whilst you are a customer and investigate any complaints or disputes or accidents
Contact you for direct marketing purposes, subject to restrictions under the relevant laws, including the right to opt out of such marketing
Provide you with information relating to our services
To provide essential communication with you, including to respond to information requests submitted
To obtain your feedback on our products and services
To notify you about changes to contracted services relevant to you
Verify the customer is over 18 – we have a legal duty to ensure our age-restricted products are not sold to individual customers under the age of 18.
Where a new customer purchases age-restricted products and we have not verified the customer’s age, we will check the billing and/or shipping details against the local edited voting register – if the name and address match the register, the account can be marked as verified and the order processed. If the information does not match, we will email you and seek ID information to verify your age.
Outsourced Service Providers
Set up, avail of your services, contact you and administer our account as a customer
Candidates for Jobs
To select suitable candidates for employment with us
We collect your data based on the following legal bases:
Consent – where you have explicitly agreed to us processing your information for a specific reason such as marketing or explicit consent for us to process any special category of data about you
Contract – where you have purchased goods and therefore agree to our terms and conditions and the processing is necessary to perform this service
Compliance – where the processing is necessary for compliance with a legal obligation we have, such as keeping records for revenue or tax purposes, or providing information to a public body or law enforcement agency; where the processing is necessary for the establishment, exercise or defence of legal claims. We are required by law to process that data in order to ensure we meet our 'anti-money laundering' obligations
Legitimate interest – where the processing is necessary for the purposes of a legitimate interest pursued by us to safeguard the safety and security of our employees, property, and clients, buildings, information located or stored on the premises and assets, and those of service providers, consultants, and advisors that assist us in carrying out its functions. To provide our services to you. To ensure that our client services are well-managed or to ensure that complaints are managed effectively, to prevent fraud, to enhance our service offerings and to keep you and your clients informed about the service we are currently providing to you. To inform recruitment decisions taken about appointments and new hires. To operate our business generally and manage and administer our services to clients, suppliers and potential candidates. From time to time we may conduct customer satisfaction surveys to enhance our service delivery.
Where lawful basis is a statutory or contractual requirement, if individual is obliged to provide the personal data, failure to provide this information may result in use being unable to provide our services.
Where consent is relied upon as a basis for processing of any personal data, you will be presented with an option to agree or disagree with the collection, use or disclosure of personal data. Once consent is obtained, it can be withdrawn at any stage.
Email Marketing
We also offer to deliver email marketing newsletters to people who have subscribed to them. You may opt in using different methods: by submitting your email address through a "Newsletter" form on our pages, ticking the "Keep me up to date on news and exclusive offers" box at checkout or, if you have an account on our website, do so in your customer panel. To ensure explicit consent, we'll initially send you a message asking to confirm that you wish to subscribe.
Once subscribed, you may opt out (unsubscribe) at any time using the option provided in any previously received marketing email, or by getting in touch with us directly on info@jamesfox.ie.
As part of our services, we need to obtain and process data. This data includes any offline physical data or online data that makes a person identifiable.
We need to obtain and process personal data as required where necessary to provide our services such as names, business and/or home addresses, phone numbers, Eircodes/postcodes, email addresses, IP addresses, and CCTV on our premises. While we may require credit or debit card details for payment, we do not store these details on our systems, except for the card type, the last four digits of the card number and the card expiry date.
In online/phone purchases, where required for compliance on sales of age-restricted products (e.g. tobacco or alcohol), we may require additional verification of customer's age. To this effect, we may request and process an electronic copy of customer's ID (passport, passport card, national ID card, age card, driver’s licence, or other forms of government-issued ID showing the full name and date of birth) as proof of age, recommending to redact any information other than the name and date of birth.
All processing is conducted in a secure manner via a third-party portal. We also collect any other personal information that you choose to provide to us when you complete our online contact forms or otherwise make contact with us. This also applies to any information provided by or about you through our website including comment boxes, forms, links, website usage or any other means.
If any person contacts us via phone, email, post, through our website or otherwise, we may keep a record of that correspondence.
Where you purchase any products or services from us, we collect your data in relation to that product or service as set out in this policy and our contract with you for that product or service. Where the order is to be delivered to a third party (e.g. as a gift), we will also hold and process the recipient data you provide to us (name, address, phone number).
We collect this data in a transparent way and only with the full knowledge of interested parties. Once this information is available to us, the following rules apply.
The data will be:
Accurate and kept up-to-date
Collected fairly and for lawful purposes only
Processed by us on the basis of either a valid contract, consent, legal compliance or legitimate interest
Protected against any unauthorised access or illegal processing by internal or external parties.
The data will not be:
Communicated to any unauthorised internal or external parties
Stored for longer than required for the purpose obtained
Transferred to organisations, states or countries outside the European Economic area without adequate safeguards being put in place as required under Data Protection law.
Our commitment to protect your data:
Restrict and monitor access to sensitive data
Develop transparent data collection procedures
Train employees in data protection and security measures
Build secure networks to protect online data from cyberattacks
Establish clear procedures for reporting privacy breaches or data misuse
Include contract clauses or communicate statements on how we handle data
Establish data protection practices (document shredding, secure locks, data encryption, frequent backups, access authorisation etc.).
Your personal information may also be processed by other organisations on our behalf for the purposes outlined above. We may disclose your information:
* To other employees, Revenue, Data Protection Commission, Recruitment agencies, auditors, financial institutions, consultants, IT providers, service review partners, couriers, shredding companies, printing companies, insurers, agents or subcontractors and to possible successors to our business.
* In the course of transmission of personal data within a group of undertakings for internal administrative purposes including the processing of clients’ or employees’ personal data.
Some of third parties we share your data with may reside outside the European Economic Area (which currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein). If we do this, your information will be treated to the same standards adopted in Ireland and include the following data protection transfer mechanisms:
* Model Clauses (also known as Standard Contractual Clauses) are standard clauses in our contracts with our service providers to ensure that any personal data leaving the EEA will be transferred in compliance with EU data-protection law. Copies of our current Model Clauses are available on request.
* Transfers to countries outside the EEA which have an adequate level of protection as approved by the European Commission (such as the United Kingdom).
* Transfers permitted in specific situations where a derogation applies as set out in Article 49 of the GDPR. For example, where it is necessary to transfer information to a non-EEA country to perform our contract with you.
We do not share or disclose any of your details outside of the scope outlined in this Privacy Statement other than for the prevention and detection of crime and to protect the interests of JJ Fox Ltd or others, or if required to do so by law or other binding request.
We will only retain personal data for as long as necessary for the purposes for which it was collected; as required by law or regulatory guidance to which we are subject or to defence any legal actions. Different kinds of information may be retained by us for various periods of time. See below:
* Customer account and order information – we will hold basic contact details for the duration of you as a customer and hold financial details as required for 7 years.
* History of invitations to service and product reviews collected via TrustPilot – 3 years.
* Google Analytics data – 38 months.
* Newsletter subscription data – as long as your consent is valid. You may withdraw your consent at any time by choosing to unsubscribe and/or delete your profile entirely. We also reserve the right to remove subscriptions we consider inactive – for example, if our reports show you haven’t opened any of our newsletters in over a year, or if we’re notified that our messages have been bouncing back.
* Electronic copies of personal ID (passport, passport card, national ID card, age card, driver’s licence, or other forms of government-issued ID showing the full name and date of birth) provided as proof of age – 14 days
* CCTV footage recorded on our premises – 30 days.
Please click/tap on the titles below to show the relevant information.
When have I the right to all my personal data being deleted by JJ Fox Ltd?
You have the right to have your personal data deleted without undue delay if:
* The personal data is no longer necessary in relation to the purpose(s) for which it was collected/processed
* You are withdrawing consent and where there is no other legal ground for the processing
* You object to the processing and there are no overriding legitimate grounds for the processing
* The personal data has been unlawfully processed
* The personal data must be erased so that we are in compliance with legal obligation
What happens if JJ Fox Ltd has made my personal data public?
If we have made your personal data public, we, taking account of available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform those who are processing your personal data that you have requested the erasure.
What happens if JJ Fox Ltd has disclosed my personal to third parties?
Where we have disclosed your personal data in question to third parties, we will inform them of your request for erasure where possible. We will also confirm to you details of relevant third parties to whom the data has been disclosed where appropriate.
When can I receive my personal data in machine readable format from JJ Fox Ltd?
You will receive your personal data concerning you in a structured, commonly used and machine-readable format if:
* processing is based on consent or contract
* processing is carried out by automated means.
Would JJ Fox Ltd transfer the personal data to another service provider if I requested this?
We can transfer this data to another company selected by you on your written instruction where it is technically feasible taking account of the available technology and the feasible cost of transfer proportionate to the service we provide to you.
Under what circumstances can JJ Fox Ltd refuse?
You will not be able to obtain, or have transferred in machine-readable format, your personal data if we are processing this data in the public interest or in the exercise of official authority vested in us.
Will JJ Fox Ltd provide me with my personal data if the file contains the personal data of others?
We will only provide you with your personal data, ensuring we protect the rights and freedoms of others. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.
Contact us at info@jamesfox.ie.
What are my rights in respect of Automated Decision Making?
JJ Fox Ltd does not have any automated decision-making processes. Where any such processes are introduced, we will provide you with the relevant information required under the “General Data Protection Regulation”.
Have I already been informed about my right to object?
We have informed you of your right to object prior to us collecting any of your personal data as stated in our privacy notice.
When can I object to JJ Fox Ltd processing my personal data?
You can object on grounds relating to your situation. JJ Fox Ltd will stop processing your personal data unless:
* we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms,
* the processing is for the establishment, exercise or defence of legal claims.
What are my rights to object for direct marketing purposes?
Where your personal data is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where you object to processing for direct marketing purposes, we will no longer process this data for such purposes.
Contact us at info@jamesfox.ie.
When can I restrict processing?
You may have processing of your personal data restricted:
* While we are verifying the accuracy of your personal data which you have contested
* If you choose restricted processing over erasure where processing is unlawful
* If we no longer need the personal data for its original purpose but are required to hold the personal data for defence of legal claims
* Where you have objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and we are considering whether our legitimate grounds override.
What if JJ Fox Ltd has provided my personal data to third parties?
Where we have disclosed your personal data in question to third parties, we will inform them about the restriction on the processing, unless it is impossible or involves disproportionate effort to do so.
How will I know if the restriction is lifted by JJ Fox Ltd and/or relevant third parties?
We will inform on an individual basis when a restriction on processing has been lifted.
Contact us at info@jamesfox.ie.
What can I do if JJ Fox Ltd is holding incorrect personal data about me?
Where you suspect that data we hold about you is inaccurate, we will on demand rectify any inaccuracies without undue delay and provide confirmation of same.
What happens if JJ Fox Ltd has disclosed my personal to third parties?
Where we have disclosed inaccurate personal data to third parties, we will inform them and request confirmation that rectification has occurred. We will also provide you with details of the third parties to whom your personal data has been disclosed.
Contact us at info@jamesfox.ie.
Under what circumstances could I withdraw consent?
You can withdraw consent if we are processing your personal data based on your consent.
When can I withdraw consent?
You can withdraw consent at any time.
If I withdraw consent what happens to my current data?
Any processing based on your consent will cease upon the withdrawal of that consent. Your withdrawal will not affect any processing of personal data prior to your withdrawal of consent, or any processing which is not based on your consent.
Contact us at info@jamesfox.ie.
Can I lodge a complaint with the Data Protection Commission?
You can lodge a complaint with the Data Protection Commission in respect of any processing by or on behalf of JJ Fox Ltd of personal data relating to you.
How do I lodge a complaint?
Making a complaint is simple and free. All you need to do is write to the Data Protection Commission giving details about the matter. You should clearly identify the organisation or individual you are complaining about. You should also outline the steps you have taken to have your concerns dealt with by the organisation, and what sort of response you received from them. Please also provide copies of any letters between you and the organisation, as well as supporting evidence/material.
What happens after I make the complaint?
The Data Protection Commission will then take the matter up with JJ Fox Ltd on your behalf.
Contact us at info@jamesfox.ie.
When do I have the right to access my personal data from JJ Fox Ltd?
Where JJ Fox Ltd process any personal data relating to you, you have the right to obtain confirmation of same from us, and to have access to your data.
What information will JJ Fox Ltd provide to me?
If we are processing your personal data, you are entitled to access a copy of all such personal data processed by us subject to a verification process to ensure we are communicating with the correct person. We will provide any of the following information:
* why we are processing your personal data
* the types of personal data concerned
* the third parties or categories of third parties to whom the personal data have been or will be disclosed; we will inform you if any of the third parties are outside the European Economic Area (EEA) or international organisations
* how your personal data is safeguarded where we provide your personal data outside the European Economic Area or to an international organisation
* the length of time we will hold your data or if not possible, the criteria used to determine that period
* your rights to:
** request any changes to inaccurate personal data held by us
** have your personal data deleted on all our systems
** restriction of processing of personal data concerning you
** to object to such processing
** data portability
* your right to lodge a complaint with the Data Protection Commission
* where we have collected your personal data from a third party, we will provide you with the information as to our source of your personal data
* any automated decision-making, including profiling which includes your personal data; we will provide you with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
What information is not provided:
Business information pertaining to your role as an employee
How long will it take to receive my personal data from JJ Fox Ltd?
We will provide you with a copy of the personal data we are currently processing within one month of request. In rare situations if we are unable to provide you with the data within one month we will notify you, within 30 days of your request, explaining the reason for the delay and will commit to delivery within a further two months.
How much will it cost me to receive my personal data?
We will not charge for providing your personal data unless we believe the request is excessive and the cost of providing your data is disproportionate to your services provided.
Can I receive my personal data electronically?
You can request your personal data by electronic means and we will provide your personal data in a commonly used electronic form if technically feasible.
What will JJ Fox Ltd do if another person’s personal data is shared with my personal data?
We will only provide you with your personal data, ensuring we protect the rights and freedoms of others. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.
Contact us at info@jamesfox.ie.
If you're thinking of sending us your CV to apply for a job with JJ Fox Ltd (be it in response to a job vacancy posted by us, or as an unsolicited application), please see our policy for processing personal data obtained this way:
Using email to communicate
Any information you send to JJ Fox Ltd via email may be sent via an unsecured email link. Due to the nature of the internet, there is a possibility that unsecured (unencrypted) email could be intercepted and read by third parties. JJ Fox Ltd assumes no responsibility for interception of confidential information (including in a CV) that you send in an unsecured (unencrypted) email message.
Right to hire
Any employment agency, person or entity that submits an unsolicited Curriculum Vitae (CV) to JJ Fox Ltd does so with the understanding that JJ Fox Ltd will have the right to hire that applicant at its discretion without any fee owed to the submitting employment agency, person or entity.
Application for an unsolicited job
If you are interested in applying for an unsolicited job within JJ Fox Ltd, you may provide us with your CV. We will then match your qualifications and experience to the position you applied for, or any other current job opportunity. If your profile corresponds to our requirements, we will contact you.
Application for a solicited job
If you are interested in applying for a solicited job within JJ Fox Ltd, you may provide us with your CV. We will then match your qualifications and experience to the position you applied for, or any other current job opportunity. If your profile corresponds to our requirements, we will contact you.
Verification
Verification checks are required for specific roles and will be identified in the job advertisement where relevant. Verification checks such as:
• Reference checks
• Proof of Identity
• Proof of Residency
• Proof of the Right to Work
• Garda Vetting (only in limited circumstances)
The purpose of personal data processing
JJ Fox Ltd collects and processes name and contact details and other personal data which you have provided in your CV and job application.
Deletion and retention of your personal data
Personal data processed because of unsolicited job applications, where the job applicant is not offered a job, will be deleted 1 week after the rejection of application has been sent to the job applicant (in some cases, no communication may take place), unless the job applicant accepts the storage for a longer period. In such cases, the application will be stored for 6 months. Unsuccessful candidates personal data for solicited jobs will be held for a maximum of 13 months.
Sensitive personal data
JJ Fox Ltd endeavours not to collect “sensitive personal data” via CVs. By “sensitive personal data” is meant personal data relating to race or ethnic origin, political opinions, religious or philosophical beliefs, membership of trade unions, or health or sex life.
JJ Fox Ltd will continue to review the effectiveness of this policy to ensure it is achieving its stated objectives on at least an annual basis and more frequently if required considering changes in the law and organisational or security changes.
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