Data Protection Policy Statement
This Data Protection Policy Statement provides information about the ways in which Journey Protector will collect, store and use personal data relating to individuals (data subjects). This Data Protection Statement relates to personal data received by Journey Protector Ltd. (‘Journey Protector’) where data subjects contact, or request information from Journey Protector directly, and also personal data received by Journey Protector indirectly, and as set out below. By providing contact information, you agree to be contacted by these means.
Journey Protector Limited
Journey Protector is an Ireland tech start-up company established in 2017.
Journey Protector have developed an autonomous system for the real time remote monitoring of conditions within a designated area such as container, trailer, truck or building. The system provides visibility for our customers through our bespoke IoT hardware and Machine Learning software which monitor and assess conditions and issue alerts should it deem one necessary. Customised dashboards are accessed by our clients and all data is visible real-time. The data stored in the Microsoft Azure cloud is encrypted.
Controller Contact Details
Journey Protector is the controller for the personal data it processes. You can contact Journey Protector as set out on the contact page of our website.
In the case of service providers or suppliers to Journey Protector where Journey Protector uses data processors to provide certain services to them, Journey Protector will require such processors to abide by certain terms to protect any personal data which is processed by the service provider/supplier during the course of providing the service, as set out in Article 28(3) of the GDPR.
Is any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
DPO Contact Details
In accordance with Article 37 of the GDPR, Journey Protector has appointed our Snr Operations Manager as the Data Protection Officer. If you wish to contact our Data Protection Officer in relation to the processing of your personal data by Journey Protector, you can do so by e-mailing firstname.lastname@example.org.
Data Protection Legislation
Journey Protector processes personal data under the regulations of the GDPR and the E-Privacy frameworks.
The GDPR came into force on 25 May 2018 and is designed to give individuals more control over their personal data.
Journey Protector recognise that the key principles relating to the processing of personal data under the GDPR are lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability.
In Ireland, the national law, which amongst other things, gives further effect to the GDPR, is the Data Protection Act 2018.
Journey Protector is also responsible for monitoring and enforcing compliance with the E-Privacy Regulations (S.I. No. 336 of 2011 – the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011). The E-Privacy Regulations relate to the processing of personal data in the context of certain electronic communications. From 25 May 2018, processing of personal data in this context (including, amongst other things, unsolicited electronic communications made by phone, e-mail, and SMS) is subject to both the general laws set out in the GDPR and the specific laws set out in the E-Privacy Regulations.
Processing of Personal Data by Journey Protector
Journey Protector will not share, sell or rent your personal information to third parties. However, we may disclose your personal information to third party suppliers who provide services on our behalf.
Journey Protector may disclose aggregate statistical information about our web site visitors in order to describe our services to prospective partners, advertisers and other reputable third parties, and for other lawful purposes, but these statistics will not include personally identifying information.
Journey Protector processes personal data for a number of different purposes:
- For sales and marketing purposes, via our website or directly to email@example.com
to provide you with information you request from us relating to our products or services or to provide information on other products which we feel may be of interest to you, where you have consented to receive such information.
- For Information that you provide by filling in forms on our website, such as when you registered for information or to make a purchase.
- To meet our contractual commitments to you.
- To notify you about any changes to our website, such as improvements or service/product changes, which may affect our service.
- For queries and concerns where personal data is received from individuals who have raised queries or concerns with Journey Protector.
- For complaint handling – including personal data received from a data subject directly (or through his or her legal representatives) where the data subject makes a complaint to Journey Protector; personal data relating to a data subject received by Journey Protector from an organisation about which Journey Protector has received a complaint.
- For inquiries and investigations – including personal data received from data subjects directly; and personal data received from an organisation, which is the subject of an inquiry or investigation.
- For service providers and suppliers – including personal data obtained from service providers or suppliers engaged by Journey Protector.
- For job applications – including personal data received from persons applying for roles within Journey Protector.
- For conferences and events – including personal data relating to attendees at events that may be organised by Journey Protector.
Journey Protector may send you details of our products and services which we think may be of interest to you. If at any time you do not wish to receive these details, please e-mail us at firstname.lastname@example.org stating your name and request
The Data that Journey Protector Processes
This includes, as detailed above, personal data received by Journey Protector where data subjects contact, or request information from Journey Protector directly, and personal data received by Journey Protector indirectly.
The personal data that we process may include (i) basic personal information, such as a data subject’s name / surname; date of birth; the company or organisation a data subject works for; (ii) contact information, such as a data subject’s postal address, email address and phone number(s); and (iii) any other personal data that is provided to Journey Protector during the course of the performance of its functions.
Special category data
Journey Protector will not process special category data. Special category data is defined as personal data relating to racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data for the purpose of uniquely identifying a natural person; data concerning health; and data concerning a natural person’s sex life or sexual orientation.
How Journey Protector collects Personal Data
Phone Calls to Journey Protector Sales and Marketing team:
Journey Protector will only audio record or retain audio recordings of phone conversations for training and quality purposes, where notified.
Where an individual contacts Journey Protector by phone, caller numbers are automatically stored on the CRM System recipient phone at Journey Protector for a limited period of time in a list of inbound and outbound calls, but no further processing of this data (caller numbers) is carried out by Journey Protector.
During the course of dealing with a query, complaint or other matter, Journey Protector may record personal data received during the course of phone calls in the form of notes made on the relevant file.
All emails sent to Journey Protector are recorded and stored for the purposes of the matter to which the email relates. The sender’s email address will remain visible to all team members tasked with dealing with the query.
All post received by Journey Protector is forwarded to the relevant team in Journey Protector and stored for the purpose of the matter to which the post item relates. Original hard copy versions of post items are retained for a period of six weeks and are then confidentially destroyed thereafter.
Journey Protector also receives personal data through its social media interactions on Twitter, Meta and LinkedIn. Journey Protector has social media accounts on these platforms in support of its sales and marketing activities. Messages or posts received by Journey Protector on these social media platforms are viewed by Journey Protector, but the personal data contained in the messages/posts is not logged or stored other than on the relevant social medial platform or on the Journey Protector CRM system.
Journey Protector does not currently operate CCTV. However, it is envisaged that Journey Protector may operate CCTV for safety and security purposes in the future once the company has established its supply chain management program, and if so, this would be done to process personal data on the basis that it is necessary for Journey Protector’s legitimate interest of safety and security. In such future cases, CCTV footage would be retained by Journey Protector for a maximum period of 14 days.
The recipients of Personal Data processed by Journey Protector
Disclosure to Third Parties
Personal data collected by Journey Protector is held confidentially and is not shared by Journey Protector with any third parties, with the following exceptions:
- For the purpose of legal proceedings:
- In the event that a matter or complaint is brought before the Courts the materials, including any information, documents or submissions provided by an individual, may be made public in open court.
- In the case of service providers or suppliers Journey Protector:
- Journey Protector may use data processors to provide certain services to Journey Protector. Journey Protector requires such processors to abide by certain terms to protect any personal data which is processed by the service provider/supplier during the course of providing the service.
Retention period for Personal Data
The retention periods for personal data held by Journey Protector are based on the requirements of the data protection legislation and on the purpose for which the personal data is collected and processed. We would normally retain data for a period of 7 years. However, you can request removal of your personal data at any time.
Data Protection Rights
Under data protection law, data subjects have certain rights.
The data subject rights are:
- The right to be informed about the processing of your personal data
- The right to access your personal data
- The right to rectification of your personal data
- The right to erasure of your personal data
- The right to data portability
- The right to object to processing of your personal data
- The right to restrict processing of your personal data
- Rights in relation to automated decision making, including profiling
Your Right to Complain
If you have any concerns in relation to the manner in which we process your personal data, you can contact us at email@example.com.
If you are dissatisfied with how we process your personal data, you have the right to complain to the Irish Data Protection Commission at https://www.dataprotection.ie.
Changes to our Data Protection Policy Statement
This Data Protection Statement is kept under regular review and is therefore subject to change. If you have any comments or queries in relation to this Data Protection Policy Statement, contact firstname.lastname@example.org.