Gem, a registered brand of Gem Pack Foods Limited (in this document, “Gem“,  “we”, “our” or “us” refers to Gem Pack Foods Limited) registered in the Republic of Ireland under company number 182913, takes the protection of your personal data very seriously and respects your right to privacy. Maintaining the security of your data and ensuring that you are in control of how your data is handled is a priority for us. We are dedicated to ensuring transparency about the data we collect about you through our website (the “Site”), how we use it and the conditions whereby we may disclose your data to others. If you do not wish to accept this Policy, please do not continue to use this website.

This Online Privacy Statement (Privacy Policy) describes how we collect and process any personal data when you visit the Site. This will help your decide how you want to use our Site. In line with our responsibilities under the General Data Protection Regulation (GDPR), which came into force on the 25th May 2018, this Privacy Policy also describes options available to you regarding our use of information and your rights regarding access to, correction of and deletion of data held by us.

Non-personal data we collect and how we use it

In line with our commitment to provide visitors to the Site with a pleasant experience, certain information will be collected for the purposes of data analytics. Information is anonymous and collected on an aggregate basis from all visitors to our Site. Such information cannot be used to identify you. Information will be used to improve the efficiency of the Site as well as problem diagnosis, analysis and resolution. No attempt is made or will be made to identify individual visitors.

Cookies and similar technologies and analytics

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely. Your web browser should allow you to delete any you choose. It should also allow you to prevent or limit their use. We may use data to analyse trends, administer the Site, track users’ movements around the Site and to gather demographic information about our user base as a whole.

Our Site uses first party cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use. When you first visit our Site, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose. If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our Site.

We use cookies in the following ways:

  • to register your visit to our Site;
  • to track your privacy preference settings (i.e. your cookie consent); and
  • to analyse how you use our Site.

Categories of cookies used

Functional (Always Switched On) – These cookies are vital for the Site to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences or accessing the Site. You can set your browser to block or alert you about these cookies, but some parts of the Site may not then work. These cookies do not store any personally identifiable information.

Marketing (Option to Switch Off) – These cookies allow us to monitor visits and traffic sources so we can analyse and improve the performance of our Site. They tell us which pages are the most and least popular and allow us to see how visitors move around the Site. A unique identifier is assigned to each registered user, which enables us to recognise visitors to our Site anonymously. If you do not allow these cookies, we will not know when you have visited our Site, and will not be able to monitor its’ performance.

When you visit our Site for the first time you will be presented with a ‘Manage Consent’ notice with a link to this policy explaining the use of cookies by us, our partners and third parties. This will provide you with information about the specific cookies we use and how to control them. We will remember the preferences you select and may ask you to confirm these preferences from time to time. You can change your preferences at any time by scrolling to the bottom right hand side of the Site page you are visiting and clicking on ‘Manage Consent’.

Managing your consent preferences

Most internet browsers are set to accept cookies automatically, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether.

Personal data we collect and how we collect it

We only collect personal information from you through the Site that you have explicitly consented to give – when you subscribe to our newsletter, fill out a form or login to any private sections of the Site. Such data is voluntarily provided by visitors to our Site (data subjects) to us for legitimate business-related activities.

This may include:

Contact Data: Various forms and enquiry sections allow you to provide us with contact data for the purposes of contacting you for legitimate business-related activity. This may include your name, home address, email address and telephone contact details.

Identity Data: When you complete a form or other entry on the Site, it may include identity data. This could include first name, last name, title, date of birth and gender.

Marketing and Communications Data: This includes your preference in receiving marketing materials from us and our third parties and your communication preferences.

Usage Data: Analytical data is gathered for digital marketing purposes and can include information about how you use our Site.

Technical Data: Cookie information is gathered on visiting the Site. This includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Site.

Interactions Data: Information about your interactions with us, including correspondence and phone calls between you and us.

We only retain contact information provided by our online query forms for as long as is reasonably necessary to answer those queries, after which time they are deleted. We also retain contact information for those who subscribe to our email newsletter but data subjects can unsubscribe at any time, at which time their details will be deleted.

We do not ask for or intentionally or knowingly collect any Special Categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). If you store any Special Categories of Personal Information with us, you are solely responsible for that information and we will not process it other than to store it for you.

Legal basis for processing of personal data

Any information about an individual from which that person can be identified is referred to as personal data.

We use personal data which we collect to process any inquiries, to follow up on your feedback and to resolve any complaints. This processing is necessary for our legitimate business interests in improving our customer service and our business operations and providing a better experience for you and others who use our products and services. We may provide you with the opportunity to participate in surveys on our Site, to measure customer satisfaction. If you participate, we may request certain personal data from you. Participation in these surveys, sweepstakes, or contests is completely voluntary and you, therefore, have a choice whether or not to disclose this information. The requested information typically includes name, email address and mailing address.

We use this information to notify contest winners and award prizes, to monitor Site traffic or personalise the Site, and/or to send participants an email newsletter.

We may use a third party service provider to conduct these surveys or contests and, in those circumstances, that company or service provider will be prohibited from using our users’ personal information for any other purpose. We will not share the personal information you provide through a contest or survey with other third parties unless we give you prior notice and choice.

You may choose not to provide us with personal data or you may turn off cookies in your browser by changing its settings. If you make these decisions, you may continue to use the Site and browse its pages. However, we cannot process orders or provide you with services without your personal data.

We will only use your personal data when the law allows us to. Depending on the processing we are carrying out (which is described in this Privacy Policy), our legal basis for processing your personal information will be:

  • to fulfil our obligations under a contract with you (for example, providing the services you have requested);
  • where the processing is necessary to pursue the legitimate interests of our business in improving our customer service and our business operations and providing a better experience for you and others who use our products and services and in your interests and fundamental rights do not override those interests;
  • to comply with a legal obligation; or
  • where you have given your consent to the processing of personal data.

We use consent as the basis for sending the newsletters, emails and information you request. We obtain this consent at the point when you request this information. Where we process your personal data on the basis of your consent, we will retain your personal data until you withdraw your consent. We may, in other circumstances, ask for your consent to collect and use other personal data. If we do so, you may withdraw your consent at any time by contacting us at [email protected].

Disclosure of information to third parties

We may provide non personal data to third parties where such information is amalgamated with similar information of other users of our Site. For example, we might inform third parties regarding the number of unique users to our Site, the demographic breakdown of our community of users or the activities that visitors to our Site engage in whilst on our Site.

We will not disclose any personal data to third parties unless you have explicitly consented to such disclosure. We will disclose your personal data if we are required to disclose it by law such as in response to a subpoena, a lawful request by a public authority or similar legal process and when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a legal request or Court Order.

Third-party sites

Our Site contains links to websites that are not maintained by us and their activities are outside of our control. Please be aware that that dissimilar terms and conditions of use and privacy standards may apply to you as a user of such websites. We do not, and will not, accept any responsibility for the privacy statements or terms and conditions of use of any such third party websites. Users of these websites are advised to check the privacy statements of these websites before submitting any personal data to those sites.

Security

We recognise the importance of safeguarding the security and confidentiality of personal data. We take all reasonable steps to protect your personal data online. We have taken, and will continue to take, necessary measures to improve existing security, integrity, and accuracy of personal data. Unfortunately, no data transmission is guaranteed to be 100% secure and we, therefore, cannot guarantee or warrant the security of information that you transmit to or from the Site from your desktop or portable device before it reaches us, which is outside of our control and, as such, is provided entirely at your own risk. We can only take all reasonable steps (including appropriate technical and organisational measures) to protect your personal data.

Accordingly, we disclaim liability for the theft, loss, or interception of, or unauthorised access or damage to, your personal data or communications by using the site. You acknowledge that you understand and assume these risks. If you believe your privacy has been breached through use of our site please contact us immediately at [email protected].

Data retention

We follow our statutory obligations and best practice in the retention and deletion of personal data. Through the Site, we will retain personal information (e.g. contact details that you have supplied to us through our online query forms or via our customer service email ([email protected]) only for as long as is reasonably necessary to respond to those queries. In all cases, we will delete personal information, if requested, within one month.

Data subject rights and complaints procedure

As outlined in GDPR and relevant data protection legislation in Ireland and the EU, you have the following rights regarding the use of your personal data:

  • To be informed about and to access your personal information that we have collected and/or retain;
  • To request copies of your personal information we hold about you and information about how we process it;
  • To restrict the ways in which we can use your personal information;
  • To request that inaccurate or incomplete information about you is rectified;
  • To request the erasure of your personal information where there is no reason for us to retain it;
  • To request the restriction of the use of your personal information, and to object to certain uses (such as for marketing purposes);
  • To lodge a complaint with your data protection regulator about use of your personal information; and
  • To withdraw any consent you have given to processing of your personal information.

Should you wish to exercise any of these rights, or if you would like to request the personal information we hold about you under a Subject Access Request (“SAR”), you may do so at any time by contacting us at info@gempackfoods.ie or by writing to us to the following address:

Gem Pack Foods Limited, Damastown Way, Damastown Industrial Estate, Dublin 15, Ireland.

If you would like more details about your rights or to exercise your rights, you should contact us at one of the given contact details above. You also have the right to escalate and complain to the Data Protection Commission, which is the relevant supervisory authority in Ireland for GDPR and which also has functions and powers related to other important regulatory frameworks including the Irish ePrivacy Regulations (2011) and the EU Directive known as the Law Enforcement Directive (www.dataprotection.ie).

Changes to this online privacy statement

Any changes to this Online Privacy Statement will be posted on this Site so that you are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If, at any time, we decide to use your personal data in a manner that is significantly different from that stated in this Statement or otherwise disclosed to you at the time it was collected, we will notify you and you will have the choice as to whether or not we can use your personal information for that new purpose. Of course, this does not in any way alter our obligations under relevant data protection legislation and GDPR. We encourage you to periodically review this page for the latest information on our privacy practices.

We periodically review this Privacy Policy and our compliance with it to verify that both are accurate. We encourage you to contact us with any concerns, and we will investigate and attempt to resolve any complaints and disputes about our privacy practices.

Contact

If you have any questions or comments regarding this Privacy Policy, email us at [email protected] or call us on +353 (1) 811 9466.

Updated on September, 2022