1. Scope of Policy

The http://www.freedemliving.com website (the “Site”) is provided by Trinity College Dublin, College Green, Dublin 2, Ireland (“Trinity College”/“we”/“us”) and was developed by Trinity College Dublin with funding from GENIO for the purpose of allowing Users access to information and inactive content to promote brain health. This Privacy & Cookie Policy (together with the Terms and Conditions) (together the “Policies”) apply to your (“you” or the “User”) use of the Site and the FreeDem services provided or made available on or in connection with the Site (the “Services”). This Privacy & Cookie Policy sets out the basis on which any personal data which we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. The Site and the Services are intended for users who are aged 16 and over and therefore if you are not aged 16 or over you should not use or provide any personal data to the Site. The Site may contain links to other third-party websites.  Trinity College accepts no responsibility for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy & Cookie Policy.

2. Who we are

Trinity College Dublin (“Trinity College”, “we” or “us”) is the data controller for the purposes of compliance with the Data Protection Acts 1988 and 2003 as well as the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (together “Data Protection and Privacy legislation”). We engage the services of third party data processors including 360 (http://360production.com/), who may process your personal data in line with the consents you provide in this Privacy & Cookie Policy.

3. Statement of Data Protection and Privacy

This Privacy & Cookie Policy sets out the basis on which any personal data you provide to us or our operating partners, or collected from you through the Site, our applications and services will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.  By visiting and using the Site, whether as a registered user or otherwise, you are accepting and consenting to the practices described in this Privacy & Cookie Policy. If you do not agree with this Privacy & Cookie Policy, you should not use the Services or Site. The Site would not be made available to Users in the absence of the limitations, restrictions and conditions set out in the Terms and Conditions and this Privacy & Cookie Policy. Trinity College is committed to safeguarding the privacy and security of the information we collect.  TCD will take appropriate measures to ensure confidentiality of all information, both paper and electronic required for the operation of our organisation and the provision of the services that we offer. We will take appropriate steps to protect data stored or transmitted against accidental or unlawful destruction, accidental loss or alteration, and unauthorised or unlawful storage, processing, access or disclosure. Your personal data will be retained and maintained in accordance with applicable Data Protection and Privacy laws and regulations.

4. Information we collect

The information we receive and collect from Users (or prospective users) is strictly related to the services we provide and execute.  The information we collect may include personal health data and other information.  Trinity College understands that such information is sensitive and takes appropriate steps to protect the confidentiality and security of all information collected in accordance with this Privacy & Cookie Policy. Trinity College accepts no responsibility for any use made of information that you submit to public webpages or otherwise is in the public domain.

4.1 Information you give us. You may give us information about you by registering an account (an “Account”), by filling in online forms on the Site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use the Site, use the Services offered on the Site or submit content (“User Content”) and when you report a problem with the Site.

4.2 Information we collect about you. With regard to each of your visits to the Site or our contractors and business partners who help us operate the Site may automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the internet, the domain and host from which you access the internet, your Account login information, browser type and version, time zone setting, browser plug-in types and versions, type of device, operating system and platform.  We may also employ location services to determine your approximate location and use Google Analytics. .

5.  Uses made of the Information

5.1 We use information held about you in the following ways:

a. to carry out our obligations and to provide you with the information and services that you request from us;

b. to provide you with information about the Site and other services we offer that are similar to those that you have already used or enquired about (any marketing contact will be subject to us having the level of consent required by law);

c. to prevent fraudulent or malevolent use and to ensure a better user experience;

d. to notify you about changes to our Site or the Services; and

e. to ensure that content from the Site is presented in the most effective manner for you and for your computer.

6. Disclosure of your Information

6.1 We will not disclose your personal data to third parties save as set out in paragraph

6.2 or if we are required to do so by law or regulation. However, aggregated or de-identified information may be made available to limited third parties such as our sub-contractors who help us operate the Site (including 360Production and web developers SMILE www.wearesmile.com)

6.2 We may disclose your personal information to third parties in the following circumstances:

a. To any successor or assign of Trinity College;

b. If we are acquired by or merge with a third party, in which case personal data may be transferred to the new entity;

c. If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions of Use and or to protect the rights or property of us or others.

7. Retention

Trinity College must comply with a number of statutory and regulatory requirements in relation to the retention of data. Your personal data must be retained for a period of up to six years following the closure or your account with us, or six years from the date of the last transaction, whichever is the later. We will not sell or rent your personal information to any third parties for marketing purposes.

8. Where we store your personal data

8.1  The data that we collect from you will be primarily stored with the European Economic Area (“EEA”) but may be transferred to, and stored at, a destination outside the EEA. It may also be processed by staff operating outside the EEA working for us or for one of our suppliers. Such staff maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is managed in accordance with this Privacy Statement.

8.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use appropriate security measures to seek to prevent unauthorised access.

9. Changes to this Privacy & Cookie Policy

We continue to review our controls and processes to assure that they are effective in meeting our commitments to our customers. Trinity College reserves the right to change this Privacy & Cookie Policy without notice at any time and from time to time, including as needed to comply with the laws and regulations of the jurisdictions within which we operate.

10. Accessing and Correcting your Personal Information

Under the Data Protection Acts 1988 and 2003 (as amended), you have a right to seek access to personal information which we hold about you. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. You also have the right, in certain circumstances to request that we delete your personal information. Any such request should be made to us in writing by post to: Information Compliance Officer, Secretary’s Office, West Theatre, Trinity College Dubin, Dublin 2, Ireland. The current fee for processing a Data Access Request is €6.35.  We will ordinarily provide you with a print-out of the relevant personal information from our current databases, or with photocopies of records which are held only on current paper files.  Your request will be dealt with as soon as possible and in any event within 40 days.

11. Cookies

The Trinity College Site uses cookies to distinguish you from other users of the Site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. This helps us to provide you with a good experience when you browse the Site and also allows us to improve the Site. Please note that third parties (including our contractors and business partners who help us operate the Site advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Site.

12. Governing law

This Privacy & Cookie Policy is governed by Irish law and all issues relating to this Privacy & Cookie Policy regarding the Site are governed exclusively by Irish law and are subject to the exclusive jurisdiction of the Irish courts. This Privacy & Cookie Policy Terms is applicable from 1st October 2013