Privacy Policy

Data Protection Officer (DPO) / EU Representative : hristopher McNamara

2. 💾 Personal Data We Collect

We collect various types of information from and about users of our Service, including:

• **Identity Data:** Name, username, date of birth.
• **Contact Data:** Email address, postal address, telephone number.
• **Technical Data (Often collected via Meta/Tracking Tools):** IP address, browser type and version, time zone setting, operating system, and platform.
• **Usage Data (Often collected via Meta Pixel/Tools):** Information about how you use our Service, pages viewed, time spent, clickstream data, referral sources.
• **Marketing and Communications Data:** Your preferences in receiving marketing from us and our third parties and your communication preferences.
• **Social Media Data (If using Meta/Social Login):** Information from your Meta (Facebook, Instagram) account if you use their tools or features on our site (e.g., the Meta Pixel, 'Login with Facebook' or 'Share' buttons), which may include your public profile, friend list, and email address, subject to your settings on that platform.

3. ✅ How We Use Your Data and Legal Basis (GDPR)

We will only process your personal data when we have a legal basis to do so. The purposes and corresponding legal bases are:

4. 🌐 Sharing Your Personal Data

We may share your personal data with the following parties:

• **Service Providers:** Third parties who perform services on our behalf (e.g., payment processing, hosting, analytics).
• **Meta Platforms Inc. and their products (Facebook, Instagram, etc.):** We use the **Meta Pixel** and other Meta Business Tools. When you interact with our Service, Meta may collect information to provide measurement services and targeted ads. **Meta and [Your Company Name] may be joint controllers** for this processing, with responsibilities outlined in separate agreements (Meta's Terms).
• **Other Third-Party Advertisers/Partners:** [List specific partners or categories, e.g., Google Ads, TikTok].
• **Legal Requirements:** If required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5. 🌍 International Data Transfers

Your data may be transferred to and stored in countries outside the European Economic Area (EEA), including the United States, where privacy laws may not offer the same level of protection.

Where we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by implementing one of the following safeguards:

• Transferring data to countries deemed to provide an adequate level of protection by the European Commission.
• Using **Standard Contractual Clauses (SCCs)** or similar mechanisms approved by the European Commission, combined with additional security measures.
• Relying on an adequacy decision like the **EU-U.S. Data Privacy Framework**, where applicable.

6. 🗑️ Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, and the applicable legal requirements.

7. 🛡️ Your Data Protection Rights (GDPR)

Under the GDPR, you have the following rights regarding your personal data:

• **The Right to be Informed:** To receive clear, transparent, and easily understandable information about how we use your data.
• **The Right of Access:** To request a copy of the personal data we hold about you.
• **The Right to Rectification:** To request that we correct any information you believe is inaccurate or incomplete.
• **The Right to Erasure ("Right to be Forgotten"):** To request that we erase your personal data, under certain conditions.
• **The Right to Restrict Processing:** To request that we restrict the processing of your personal data, under certain conditions.
• **The Right to Object to Processing:** To object to our processing of your personal data, under certain conditions (e.g., direct marketing).
• **The Right to Data Portability:** To request that we transfer the data we have collected to another organization, or directly to you, under certain conditions.
• **The Right to Withdraw Consent:** Where processing is based on consent, you have the right to withdraw your consent at any time.
• **The Right to Lodge a Complaint:** You have the right to complain to your local supervisory authority (e.g., the Data Protection Commission in Ireland).

To exercise any of these rights, please contact us using the details in Section 1.

8. 🍪 Cookies and Tracking Technologies

We use cookies, the Meta Pixel, and similar tracking technologies to track the activity on our Service and hold certain information.

• **What they are:** Cookies are small files stored on your device. The Meta Pixel is a piece of code placed on our website that allows us to measure, optimize, and build audiences for advertising campaigns.
• **Purpose:** To analyze website traffic, personalize content, and provide targeted advertising, including to users on Meta platforms.
• **Your Control:** We use a **Cookie Consent Management Platform (CMP)** to obtain your explicit consent before setting non-essential cookies (including the Meta Pixel). You can manage or withdraw your consent at any time via the [Link to your Cookie Settings/CMP].

9. 🔄 Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

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© 2025 Christopher McNamara. All rights reserved.