Privacy Policy

INTRODUCTION

1.1 NATHAN TRUST ( in this privacy notice, “we”, “us”, “our”) is strongly committed to protecting your Personal Data (as defined below). This Privacy Notice sets out how we collect, use and protect your Personal Data. Please read the following carefully to understand our practices regarding your Personal Data and how we treat and safeguard it. In the event you wish to withdraw your consent to the data practices described in this Privacy Notice that are based on consent, please contact us through the “Contact us” section below.

1.2 This notice (“Notice”) has been developed to ensure our website users, vendors/suppliers, other third parties and all other Data Subjects whose Personal Data is processed under the control of NATHAN TRUST (save as set out at section 1.3 below) feel confident about the privacy and security of Personal Data, and to meet our obligations under the Data Protection Acts 1988 to 2018 and the EU Regulation 679/2016 General Data Protection Regulation (“GDPR”) (together “Data Protection Law”). Under Data Protection Law, Personal Data is information that identifies you as an individual or is capable of doing so (“Personal Data”).

1.3 This Notice does not apply to the processing of Personal Data by NATHAN TRUST in the context of the provision of legal, accounting and tax services to our clients. Such processing is governed by and subject to the terms of NATHAN TRUST’s privacy statement for clients, which we send to all clients upon our engagement by clients to provide legal, accounting and tax services. If you are a client of NATHAN TRUST and cannot locate this privacy statement, please contact your usual NATHAN TRUST contact or cork@nathantrust.com.

1.4 We must comply with the data protection principles set down in Data Protection Law and, save as set out at section 1.3 above, this Notice applies to all Personal Data otherwise collected, processed and stored by us that is subject to the laws described above. By providing us with information, you accept and agree to the practices described in this Notice.

1.5 For the purposes of the Data Protection Law, NATHAN TRUST is the Data Controller of your Personal Data. You will find our contact details in the “Contact Us” section below.

1.6 The terms “Data Subjects”, “Data Controller”, “Data Processor” and “process”, when used in this Notice, have the meanings given to them in Data Protection Law unless otherwise indicated.

1.7 This Notice applies to individuals located in the European Union and to the processing of Personal Data by NATHAN TRUST in the context of the activities of its establishment in the European Union.

WHAT KINDS OF PERSONAL DATA DO WE COLLECT?

2.1 We may collect the following types of Personal Data:

(a) NATHAN TRUST vendors/suppliers:

(i) contact details of such vendors/suppliers or such vendor’s/supplier’s employees (including name, title, phone number, email address, etc.); and

(ii) financial information (such as bank account details);

(b) browsers of NATHAN TRUST’s website(s) and/or subscribers for NATHAN TRUST’s updates/newsletters:

(i) name, title, phone number, email address, etc.;

(ii) information collected automatically from Data Subjects when browsing NATHAN TRUST’s website(s) via cookies or other device identifiers, such as IP addresses or other identifiers constituting Personal Data (see further at sections 2.2 to 2.4 below); and

(c) other:

(i) any information you provide to us via our social media pages; and

(ii) any other information you may provide to us in your interaction with us.

2.2 As noted above, even if you do not explicitly provide us with data when you interact with NATHAN TRUST’s website(s) (which include www.Nathan Trust.ie and www.Nathan Truststartups.ie) (the “Websites” and each a “Website”), we may collect certain data. For example, the Websites may use cookies and our servers may keep an activity log that tracks all visitors to the Websites. The information collected will often be anonymous and therefore may not identify you individually, however such information, or such information in conjunction with other information that we hold, may be capable of identifying you and so may constitute Personal Data (“Website Data”). Website Data may include among, other data:

(a) the country in which you reside;

(b) referring/exit URLs and other information that does not identify you directly or indirectly but may correspond with you or a particular device; and

(c) information about your browser type, device type and unique device information as well as your operating system, websites you visited before and after visiting the Websites, standard server log information and IP address.

2.3 We collect this Website Data passively using technologies such as cookies (see NATHAN TRUST’s cookie policy here). We use Website Data to administer, operate, and improve the Websites.

2.4 If any Website Data constitutes Personal Data (whether directly or through linking or associating any Website Data with any other information), the terms of this Notice will apply. Otherwise, we use and disclose Website Data in a non-personally identifiable form.

2.5 The Websites interact with other sites, including social media websites such as LinkedIn, (and may use social media plugins) to facilitate social media functions. We have no control over the information that other websites or social media websites or plugins collect, store, or use. Before you choose to access other websites or social media platforms from a Website, please be certain that you review the privacy notice of that social media platform or website.

LEGAL BASIS FOR PROCESSING

3.1 We rely on the following legal bases under GDPR in processing Personal Data:

(a) performance of a contract with you (in the case of vendors/suppliers);

(b) consent (in the case of collecting data directly from individuals, such as at conferences or via a Website when you input information); and

(c) legitimate interests (for example, in the event of a complaint or legal action being taken against us).

HOW WE COLLECT DATA AND PERSONAL DATA

We collect Personal Data from your interaction with us, for example:

(a) when transacting with vendors/suppliers or other third parties;

(b) when browsing a Website, via cookies, device identifiers or other technologies; or

(c) when you otherwise contact us through, for example through the Websites or via email.

HOW WE MAY USE YOUR PERSONAL DATA

5.1 Except as set out in this Notice, we will not disclose Personal Data that we collect to any parties other than those with whom we partner or are affiliated, without your consent. Except as set out below, we will not sell, share, trade, rent, or give away your Personal Data.

Information you directly provide

5.2 We may use your Personal Data in the conduct of our business with you, for example, in order to fulfill our contract with you (including the provision of services to us by you or in addressing any queries you may have) or upon your consent for the purposes of contacting you regarding any of our services or more generally.

Information you do not directly provide

5.3 As noted in section 2.3 above, we use Website Data to administer, operate, and improve the Websites.

DO WE DISCLOSE PERSONAL DATA TO ANYONE ELSE?

6.1 We shall disclose your Personal Data to third parties only when it is necessary as part of any contract with you, for the conduct of business or when there is a legal or statutory obligation to do so. Whenever we disclose your Personal Data to third parties, we will only disclose that amount of your Personal Data necessary to meet such business need or legal requirement. Third parties that receive your Personal Data from us must satisfy us as to the measures taken to protect the Personal Data such parties receive, in accordance with Data Protection Law and as stated in this Notice. Appropriate measures will be taken to ensure that all such disclosures or transfers of your Personal Data to third parties will be completed in a secure manner and pursuant to contractual safeguards.

6.2 We may employ other companies and individuals to perform functions on our behalf, including professional advisors, outsourced services providers and contractors. These third-party service providers are authorised to use Personal Data only as needed to perform their functions on our behalf and are required to maintain the security of your Personal Data. Categories of such third parties include primarily organisations and other entities providing services to us, including financial, legal, organisational, etc.

6.3 We may transfer your Personal Data to another firm with which we have merged, or which has acquired all or some of our assets. We will advise you if such a change of ownership or change of corporate structure takes place and we will update this Notice accordingly.

6.4 We may provide your Personal Data when obliged to do so under relevant Data Protection Law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide your Personal Data for the purpose of safeguarding national security. In the case of any such disclosure, we will do so only in accordance with relevant Data Protection Law.

6.5 We may also provide your Personal Data when required to do so by law, for example under a court order, and may transfer data to legal counsel where same is necessary for the defence of legal claims.

TRANSFERS OUTSIDE OF THE EEA

7.1 Your Personal Data may be processed by NATHAN TRUST or its trusted third-party partners outside of the European Economic Area (“EEA”). Data privacy laws in the countries to which your Personal Data is transferred may not be equivalent to, or as protective as, the laws in the EEA.

7.2 We will implement appropriate measures to ensure that your Personal Data remains protected and secure when it is transferred outside of the EEA, in accordance with applicable Data Protection Law. Because many countries to which Personal Data may be transferred have not received an “adequacy finding” regarding their privacy laws from the European Commission, NATHAN TRUST will either rely on Standard Contractual Clauses or derogations in Article 49 of the GDPR to transfer your Personal Data to such countries.

7.3 NATHAN TRUST continues to monitor all developments regarding the legal bases for the international transfer of Personal Data and shall update its processes as necessary.

HOW LONG DO WE KEEP PERSONAL DATA?

8.1 The period for which we retain Personal Data varies according to the use of that information. In some cases, there are legal requirements to keep Personal Data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will retain Personal Data no longer than is necessary for the purposes for which the Personal Data were collected and processed (as described above).

8.2 Personal Data of vendors/suppliers and other third parties will be retained for no longer than is necessary for the purposes for which it was collected. We will retain your Personal Data for as long as we continue to provide our services to you. Following termination of the provision of the services to you, your Personal Data shall be retained for as long as is necessary and permissible in accordance with statutory limitation periods.

HOW YOU CAN EXERCISE YOUR RIGHTS IN RESPECT OF THE PERSONAL DATA WE HOLD ABOUT YOU?

Your rights

9.1 We shall vindicate all rights under the Data Protection Law. You have the right to request that we:

(a) provide you with information as to whether we process your data and details relating to our processing, and that we provide you with a copy of your data (‘access right’);

(b) rectify and/or update any inaccurate data we might have about you without undue delay (‘right to rectification’);

(c) the right to object to the processing of data relating to you (‘right to object’);

(d) under certain circumstances, be restricted from processing your data (‘right to restriction’);

(e) under certain circumstances, erase your personal data without undue delay (i.e. the “right to erasure”); and

(f) under certain circumstances, furnish you with the personal data that you provided us with in a structured, commonly used and machine-readable format (‘right to data portability’).

9.2 Vindication of these rights shall not affect any rights that we may have under Data Protection Law.

Exercising your rights and managing Personal Data

9.3 You can exercise any of your rights by making a request to us at the contact information provided below. If, for some reason, these rights are denied, we will provide an explanation of why this is the case.

9.4 We will process your request within 30 days of receipt.

SECURITY OF YOUR PERSONAL DATA

10.1 We are committed to ensuring that all of your information, including Personal Data, is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical and organisational measures to safeguard and secure your Personal Data.

10.2 Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.

10.3 Unfortunately, the transmission of information through the Websites is not completely secure. Although we will do our best to protect your Personal Data and apply appropriate safeguards, we cannot guarantee the security of your data transmitted through the Websites and any transmission is at your own risk.

HOW CAN YOU MAKE A COMPLAINT ABOUT THE USE OF PERSONAL DATA?

11.1 Complaints on the use, retention and disposal of Personal Data can be submitted via email to cork@nathantrust.com.

11.2 Under the Data Protection Law, you also have the right to lodge a complaint with the relevant supervisory authority of your country.

REVIEW

12.1 This Notice will be reviewed and updated from time to time to consider changes in the law and the experience of the Notice and NATHAN TRUST’s processing of Personal Data in practice. Any and all changes will be advised to you and, if necessary, we will obtain your consent prior to applying any changes to any Personal Data collected from you prior to the date the change becomes effective. We encourage you to periodically review this Notice to stay informed about how we collect, use, and disclose Personal Data.

CONTACT INFORMATION

13.1 If you have questions about this Notice or our treatment of the Personal Data provided to us, please contact us at:

Name: NATHAN TRUST

ATTN: Data Privacy

Address: First Floor, Penrose Dock 2, Cork, Ireland

E-mail: cork@nathantrust.com

Last updated: November 2023