Privacy Policy

Towercom Limited (“the Company”, “we”, “us”, “our”) takes its responsibilities under applicable data protection law, including the General Data Protection Regulation and implementing legislation (“Data Protection Law”) very seriously.

The purpose of this notice is to inform you of the data relating to you that we may collect and use and the uses (including disclosures to third parties) we may make of your data in connection with this website.

The Company is the controller in respect of employee data and is registered under registration number 438951 and has its registered office at 6th Floor 2 Grand Canal Square, Dublin, D02 A342, Ireland.

If you have any questions about our use of your personal data please contact us at
info@towercom.ie

1. Personal Data that we collect and process

We collect and process personal data relating to you in connection with your use of this website and our relationship with you. This personal data may include the following information that we collect directly from you:

• your name and contact details, including your email address;
• username and login details; and
• any other personal data relating to you that you provide to us or that we generate about you in connection with your use of this website.

2. Website Usage Data
We use a monitoring application to collate and analyse certain statistical information about the use of this website. When you visit our website, the following information is retained about that visit:

• your IP address; and
• your cookie preferences;

No attempt is made to identify individual users or to associate the technical details listed above with any individual.

3. Purposes of processing and legal bases

We will use personal data relating to you for the purpose of:

• communicating with you following your submission of a query via the ‘Contact Us’ function on our website; and
• creating an account which you can use to login to the website.

The legal basis on which we process your personal data in this circumstance is our legitimate interests in conducting our business in a commercially prudent manner, facilitating access to the private areas of the website, and responding to queries submitted to us through our website.

We will not process your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms.

4. Recipients of Data
We may disclose your personal data to other organisations in connection with the above purposes,

including:
• to other members of our corporate group;
• to third parties who we engage to provide services to us in connection with this website, such
as outsourced service providers, IT services providers, professional advisers and auditors;
• to third parties, their agents and professional advisors, subject to confidentiality obligations,
for the purpose of a due diligence exercise by third parties in connection with any proposed
financing or change of control arrangements relating to our business; and
• to competent regulatory authorities and bodies as requested or required by law.

5. Retention
We will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this notice, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.

6. Transfers Abroad
In connection with the above we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union.

We currently only transfer personal data to the UK, which the EU Commission has deemed has adequate protection.

If and to the extent that we make further transfers, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or transferring your personal data pursuant to binding corporate rules.

Further details of the measures that we have taken in this regard are available from
info@towercom.com

7. Your rights and how to update your information
You have the following rights, in certain circumstances and subject to certain restrictions, in relation
to your personal data:

• Right to access the data – You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.

• Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.

• Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.

• Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.

• Right to data portability – You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.

• Right to withdraw your consent – Where our processing of your personal data is based on you having provided your consent, you have the right to withdraw such consent.

Please note that these rights are not absolute, and are subject to certain restrictions and
exemptions. For example, the right to erasure of personal data will not apply where we have a legitimate reason to continue to hold such data.

In order to exercise any of the rights set out above, please contact info@towercom.ie
The Company is required to keep all data accurate and up to date. To enable us to do this more easily, please ensure that you keep us up to date with any changes to your personal data.

Complaints
If you are not happy with the way we have used your information or addressed your rights, you have
the right to make a complaint to the Irish Data Protection Commission
(https://forms.dataprotection.ie/contact )