ATLANTIC BRIDGE WEBSITE PRIVACY STATEMENT
The www.abven.com website (the "Website") is operated by Atlantic Bridge Services Limited ("Atlantic Bridge" “we” or “us”) of 22 Fitzwilliam Square, Dublin 2, D02 FH68. Atlantic Bridge respects your right to privacy and this Privacy Statement (the "Statement") sets out the basis on which we use, process, store or disclose any personal data detailed below ("Personal Data") that we collect from you or that you provide to us through the Website. The information provided by you will be held by us as a controller. This Statement, together with our website disclaimer (www.abven.com/disclaimer) (the “Disclaimer”) applies to your use of the Website.
1. OVERVIEW OF THIS STATEMENT We collect Personal Data from you when you use the Website and process this Personal Data for the purposes of providing you with access to the Website. You can also choose to provide us with additional Personal Data via email or application forms available on the Website which we will process for the purposes of responding to your queries including any investment proposals. Responding to these queries is necessary for the purposes of our legitimate business interests. We store your Personal Data on servers located in Ireland. We share your Personal Data within the other entities in the Atlantic Bridge group of companies (the "Atlantic Bridge Group") and with third parties. We will also share your Personal Data with law enforcement agencies or public bodies if we are required by law to do so. 2. THE PERSONAL DATA WE PROCESS We will collect and process the following Personal Data from you: Device Information When using the Website or availing of services related to the Website, personal information may be collected from you by Atlantic Bridge. This includes information about: • your device browser including your IP address and other information derived from cookies used on the Website. • details of your visits to the Website such as traffic data, location data and the resources, advertisements and other websites that you access through the Website.
You can choose to provide us with the following Personal Data: Query and Form Information You may choose to give us additional information such as your first name, last name, e-mail address and other details when contacting us and submitting enquiries through the Website by e-mailing email@example.com or by filling in our Website contact form. Submit a Proposal Form • Where you use the "Submit a Proposal" form on our Website, you may provide us with some personal and non-personal data when filling in and submitting the "Submit a Proposal" form. Such personal data may include first names, last names, email addresses, phone numbers and other details. CV Information • You may choose to give us additional information such as your name, gender, address, email address, university education, professional qualifications, previous employment and other details when applying for vacancies advertised on the Website by emailing your CV to firstname.lastname@example.org. • If you provide us with this information, we will keep a record of this information for as long as is necessary to deal with your application.
We may obtain the following Personal Data about you from other third parties: Third Party Information • We may receive information about you from social media platforms, such as Twitter, LinkedIn and YouTube, when you interact with us via such platforms. This includes information such as first names, last names, email addresses, phone numbers and other details.
3. HOW AND WHY WE USE YOUR PERSONAL DATA The following table details the legal bases and the purposes for which we process your Personal Data: LEGAL BASES & PURPOSES
Legal Basis Purpose(s) Personal Data Processed Legitimate Interests It is necessary for the purpose of our legitimate interests to collect and process these Personal Data for the purposes of improving and monitoring website efficiency and enhancing your use of the Website, and to respond to any queries or requests submitted by you regarding the Website or to process and respond to CVs and/or job applications submitted by you to Atlantic Bridge.
Improving Website Functionality & Efficiency • To provide, improve, test and monitor the effectiveness of the Website • To monitor metrics such as total number of visitors, traffic data and demographic patterns
Complaints, Questions and Cancellations • To process and respond to any enquiries or requests you submit to us by emailing email@example.com.
Responding to Proposal Applications • To process and respond to proposal applications you submit to us using the "Submit a Proposal" form on the Website.
Responding to Job Applications • To process and respond to any CVs and/or job applications you submit to us by emailing firstname.lastname@example.org.
Promotional or Marketing materials • To provide you with information in relation about our events programme, general news from Atlantic Bridge and other communications from Atlantic Bridge deemed to be of probable interest (please note that you may opt-out of receiving such marketing information by contacting us at email@example.com ). • Device Information • Query Information • CV Information
4. WHO WE SHARE YOUR PERSONAL DATA WITH We will disclose your Personal Data to some or all of the following recipients: RECIPIENT(S)
Atlantic Bridge Group Companies • Members and shareholders of the Atlantic Bridge Group. • Internal business units within the Atlantic Bridge Group. Other Recipients • Prospective buyers of business assets (to facilitate the acquisition of Atlantic Bridge or a substantial portion of Atlantic Bridge assets by a third party). • Regulatory authorities and law enforcement agencies (where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request). • External advisors e.g. lawyers, accountants and auditors (as necessary to protect Atlantic Bridge's legitimate and legal interests).
5. TRANSFERS OF YOUR PERSONAL DATA Your Personal Data may be stored and transferred outside the European Union ("EU"). We only transfer your Personal Data outside the EU where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards or there are appropriate safeguards in place to protect your Personal Data. If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact our Data Protection Representative Des Shiels at 22 Fitzwilliam Square, Dublin 2, Ireland, by phone at +353 1 603 4450, or by email at firstname.lastname@example.org. Where we transfer Personal Data to other entities of the Atlantic Bridge Group, we do so on the basis of Standard Contractual Clauses which are a form of data processing contract approved by the European Commission, or another legal basis. You can find a copy of the Standard Contractual Clauses here If you would like to find out more about any such transfers, please contact our Data Protection Representative Des Shiels (contact details above). Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your Personal Data, we cannot guarantee the security of any information you transmit to us; any transmission is at your own risk. Once we have received your information, we will endeavour to use strict procedures and security features to try to prevent unauthorised access. 6. HOW LONG WE KEEP YOUR PERSONAL DATA FOR In general, we expect to keep your Personal Data for as long as is necessary for the purposes for which it was obtained from the date of collection or, where you enter into a contractual arrangement with us, following the end of the performance of our contract (which may be up to 7 years). Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data. 7. YOUR RIGHTS AND HOW TO EXERCISE THEM You have a number of rights in relation to your Personal Data, which are set out in this section 7. In particular these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that in certain circumstances these rights might not be absolute. Right Further Information Right of Access You have the right to request a copy of the Personal Data held by us about you and to access the information which we hold about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive. Right to Rectification You have the right to have any inaccurate Personal Data which we hold about you updated or corrected.
Right to Erasure In certain circumstances, you may also have your personal information deleted, for example if you exercise your right to object (see below) and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this Statement.
Right to Restriction of Processing You have the right to ask us to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data we hold about you is inaccurate or our use of your information is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved.
Right to Data Portability You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where: (1) we process your Personal Data with your consent or where it is necessary to perform our contract with you; and (2) the processing is carried out by automated means.
Right to Object You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.
You can exercise any of these rights by submitting a request to our Data Protection Representative Des Shiels in writing, at 22 Fitzwilliam Square, Dublin 2, Ireland. We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within 1 month of receiving your request. We may extend this up to 2 months if necessary however we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights. You also have the right to lodge a complaint with the Data Protection Commission. For further information see www.dataprotection.ie. 8. CHANGES TO THIS STATEMENT & QUESTIONS If we amend this Statement, in whole or part, any changes will be posted on this page and, where appropriate, notified to you by email or when you use the Website. The new Statement may be displayed on-screen and you may be required to read and accept it to continue your use of the Website. If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Statement, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail, and you will have a choice as to whether or not we use your Personal Data in the new manner. If you have any questions, comments or concerns about the way your Personal Data are being used or processed by Atlantic Bridge, please submit your question, comment or concern in writing to our Data Protection Representative Des Shiels at 22 Fitzwilliam Square, Dublin 2, Ireland.