This Privacy Policy sets out how we, CLS Recruitment Ltd., collect, store and use information about you when you use or interact with our websites, www.clsrecruitment.ie, (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective 10/05/2018.

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
  • Data controller: CLS Recruitment Ltd.
  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us and by signing up to our jobseekers form)
    • from your use of our website, using cookies, and
    • occasionally, from third parties.
  • Information we collect: name, contact details, date of birth, payment information, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable) and VAT number (if applicable).
  • How we use your information: for administrative and business purposes (particularly to contact you and process your CV for job applications), to improve our business and website, to fulfil our contractual obligations, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.
  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you and where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, and only granting access to your information where necessary.
  • Use of cookies and similar technologies: we use cookies including functional, analytical and advertising cookies. For more information on which cookies we use on each of our websites, please visit our cookies policy here.
  • Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place,e.g. the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
  • Use automated decision making and profiling:we do not use automated decision-making on our website but we do use profiling through our use of Google Analytics and YouTube cookies. For further information, please see the section below entitled Our use of automated decision-making and profiling
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

Our details

The data controller in respect of our website is CLS Recruitment Ltd. (company registration number 527508) of Unit 2, First Floor, Glenrock Business Park, Ballybane, Galway. You can contact the data controller by writing to CLS Recruitment Group Ltd, Unit 2, First Floor, Glenrock Business Park, Ballybane, Galway or sending an email to info@clsrecuirtment.ie. If you have any questions about this Privacy Policy, please contact the data controller.

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

We use a third party server to host our website called Heaventree, the privacy policy of which is available here. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Use of website server log information for IT security purposes

Our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.


Cookies are data files which are sent from a website to a browser to record information about users for various purposes. We use cookies on our website, including functional, analytical and advertising cookies. For further information on how we use cookies, please see our cookies policy which is available here. You can reject some or all of the cookies we use on or via our website by changing your browser settings by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features.You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

MWe store emails you send us on our third-party website server in Germany. Emails you send us will be transferred and stored outside the European Economic Area on our third-party email provider’s (Google, Inc.’s) servers in the United States of America or any of their other data centres around the world. Their privacy policy is available here.
For further information and information on the safeguards used when your information is transferred outside the European Economic Area, please see the section of this privacy Transfers of your information outside the European Economic Area.


When you contact us using our contact form, we collect your name, email address, phone number and any information you provide in the ‘query’ field. We also collect any other information you provide to us when you complete the contact form.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored inside the European Economic Area on our third party servers in Germany.


When you comment on the blog on our website, we collect any information you insert in the comments section on our blog.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): Information you submit in the message field on our blog is processed by our Facebook plugin and is therefore processed by Facebook. Facebook’s privacy policy is available here.

Facebook may transfer your information outside the European Economic Area. For further information on the safeguards used, please see the section below entitled Transfers of your information outside the European Economic Area.


When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by one of our telephone providers and stored within the European Economic Area in Ireland or the United Kingdom.


If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

When you complete our jobseekers form we collect your name, date of birth, mobile phone number and email address, the counties you are interested in finding a job in, the categories of job you are interested in and your CV (and any information contained in your CV), you will be added to our mailing list for relevant job opportunities.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you give your consent to us sending you relevant job opportunities by inputting your details on our Jobseekers Form using the steps set out above.

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, called MailChimp. You can access their privacy policy here.
Information you submit to subscribe for our e-newsletter will be stored on our servers in the European Economic Area but your name and email address will also be transferred and stored outside the European Economic Area on our third party mailing list provider’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Information we collect when you place an order

We collect and use information from individuals purchase services we provide on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

When you pay for our services, we take payment by card and this involves us processing the following information: your company name, address, email address, card number, card expiry, security code and card type.If you do not provide this information, you will not be able to purchase goods or services from us or enter in to a contract with us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).


Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions.


This section sets out how we obtain or collect information about you from third parties.
Information recieved from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include group companies, affiliates or business partners.

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include group companies, affiliates or business partners.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation). Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us. Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

Where we recieve information about you in error If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.


Information obtained by us from third parties.

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one).
In certain circumstances will also obtain information about you from private sources, both EU and non-EU.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly. Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests:in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement or for direct marketing purposes.

Our use of automated decision-making and profiling

We do not use automated decision-making but we do use profiling.

You have the right to object to our use of profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here.

Profiling

Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

Our web analytics service, Google Analytics uses and collects information such as your location (based on your IP address) and your behaviour (based on cookies) when you access our website (such as the pages you visit and what you click on).
We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy.

Logic involved: by automatically analysing and categorising information such as the location (based on IP address) as well as the behaviour and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website (unless you have opted out from receiving such cookies by using our cookie control tool) and your location will be analysed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behaviour on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: we have a legitimate interest in getting to know our website visitors’ preferences and improving our website’s effectiveness.


YouTube uses cookies when you watch videos to track what you watch and on which websites across the internet. You can find out more about how YouTube uses information collected from cookies in their privacy policy which is available here.
Information collected by YouTube cookies is transferred by Google outside the European Economic Area. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Logic involved: YouTube can improve the relevance of the advertisements and suggested videos it shows you by collecting information on what videos you watch, allowing them to improve their YouTube service for you.

Significance and envisaged consequences: cookies will be used to track and store information about your behaviour and device on our website where you have allowed cookies using our cookie tool and this information will be added to information that YouTube has about you.

How to object: You can stop YouTube collecting this information by using our cookie tool on our website (if you turned on the use of YouTube cookies using this tool). You can also block such cookies by blocking third party cookies in your browser settings.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

Consent: you consent to YouTube collecting this information and using it for these purposes by turning on YouTube cookies using our cookie control tool.


We use profiling to advertise on Facebook. Information collected by Facebook in relation to its advertisements and the Facebook Pixel on our website is transferred by Facebook outside the European Economic Area. For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Logic involved: by targeting individuals based on criteria such as what they have liked on Facebook, we are able to more effectively advertise our services to those who we think are most likely to be interested in purchasing them, making our advertising more cost-effective and relevant.

Significance and envisaged consequences: advertisements will be displayed to you on Facebook if you meet the relevant criteria which form the basis of our advertising campaign. If you click on any relevant advertisements displayed to you on Facebook, your behaviour will be tracked using the code (Facebook Pixel) which we have installed on our website (if you have consented to the use of such technologies on our website) and your actions on our site will be tracked and the information shared with Facebook (you can access Facebook’s Privacy Policy here.

How to object: you can opt-out of Facebook processing your information by changing your ad settings in your Facebook account here. You can opt out of Facebook and other companies that participate in the Digital Advertising Alliance in Europe from showing you interest based ads by visiting http://www.youronlinechoices.com, selecting your country, clicking ‘Your Ad Choices’, then locating Facebook (and any other companies you want to block) and selecting the ‘Off’ option.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: amarketing our goods and services effectively (direct marketing).

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:
  • Telephone providers,
  • Email provider,
  • IT service provider,
  • Web developer,
  • Hosting provider,
  • Payment processor,
  • Payroll provider,
  • Accounting softawre provider,

Apart from our email service providers, which are located in the US, our service providers are located in the UK or the Republic of Ireland.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.


We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/,

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: meeting our contractual obligations to Google under our Google Analytics Terms of Service https://www.google.com/analytics/terms/us.html You can opt out of Google Analytics by installing the browser plugin here,

Transfer and storage of your information Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers.
Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): running and managing our business effciently.

Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are located in the Republic of Ireland.

Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
Our advisors are located in the Republic of Ireland.

Business partners
Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
Our business partners are located in the Republic of Ireland.

Independent contractors
Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.
Our independent contractors are located in the Republic of Ireland.

Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.
Our insurers are located in the Republic of Ireland.
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.


We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to third parties such as Google Inc.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service https://www.google.com/analytics/terms/us.html You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners, independent contractors, and insurers.
Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: running and managing our business efficiently.  

Accountants We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts. Our accountants are located in the Republic of Ireland. 

Advisors Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public relations professionals. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice. Our advisors are located in the Republic of Ireland.  

Independent contractors Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.
Our independent contractors are located in Republic of Ireland  

Insurers We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them   Our insurers are located in the Republic of Ireland.
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests preventing crime or suspected criminal activity (such as fraud). In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).


Legitimate interest: running and managing our business efficiently.  

In connection with a legal or potential legal dispute or proceedings We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
For ongoing compliance with laws, regulations and other legal requirements We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation(s): legal obligations to disclose information which are part of the laws of the Republic of Ireland or if they have been integrated into Ireland’s legal framework (for example in the form of an international agreement which the Republic of Ireland has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into Ireland’s legal framework, we have a legitimate interest in complying with these obligations.

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Server log information: we retain information on our server logs for 45 days.
Order information: when you place an order for goods and services, we retain that information for 6 years, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and then a further 6 months, after which point we will delete your information.
E-Newsletter: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions you make on or via our website.

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is Gmail. You can access their privacy policy here
Countries of storage: United States, Taiwan, Singapore and/or Chile. These countries are not subject to an adequacy decision by the European Commission. You can find out more about Google’s data centres: here

Safeguard(s) used: Google transfers your information outside the EEA to entities which have either self-certified themselves as compliant under the EU-U.S. Privacy Shield or have put EU-approved model contract clauses are in place.The EU-U.S. Privacy Shield is available here here.

The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. you can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here
EU-approved model clauses are standard data protection clauses adopted by the European Commission in accordance with its committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(b) of the General Data Protection Regulation.


Information you submit to us when you sign up for our jobseekers form is transferred outside the EEA and backed up on our third party cloud service provider’s servers. Our third party cloud service provider is MailChimp and you can access their privacy policy here For further information on the countries of storage and safeguards used by Google, see ‘Email’ below.

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used : MailChimp has self-certified its compliance with the EU-U.S. Privacy Shield.
Google has self-certified its compliance with the EU-U.S. Privacy Shield
The EU-U.S. Privacy Shield is available here: hereThe EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. you can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: here


Google Analytics Google transfers information collected by its Google Analytics service (your IP address and information about you use our website) outside the EEA and stores that information on its servers in the United States of America. You can view Google’s privacy policy here and how the use the information collected by cookies here

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used : Google transfers your information outside the EEA to entities which have self-certified themselves as compliant under the EU-U.S. Privacy Shield.
The EU-U.S. Privacy Shield is available here: hereThe EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. you can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: here


When you make payment for our services by card over the phone, information processed in connection with your payment may be transferred outside the European Economic Area.


AIB Merchant Services may transfer information they process about your order outside the EEA. Where they do so, they will ensure appropriate safeguards are in place. You can access AIB Merchant Services’ privacy policy here


Facebook transfers information it collects from its advertisements and the Facebook Pixel on our website outside the EEA.

Country of storage: United States of America and other countries. These countries are not subject to an adequacy decision by the European Commission.

Safeguard(s) used : where Facebook transfers your information outside the EEA they will ensure EU-approved model contract clauses are in place, obtain your consent for such transfers or adopt other means under European Union law. EU-approved model clauses are standard data protection clauses adopted by the European Commission in accordance with its committee examination procedure under Article 93(2) of the General Data Protection Regulation. This is permitted under Article 46(2)(b) of the General Data Protection Regulation. Transfers on the basis of your explicit consent are permitted under Article 49(1)(a) of the General Data Protection Regulation.

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to CLS Recruitment Group Ltd, Unit 2, First Floor, Glenrock Business Park, Ballybane, Galway or sending an email to info@clsrecruitment.ie:
  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation. For the purposes of Ireland, the supervisory authority is the Office of the Data Protection Commissioner (An Coimisinéir Cosanta Sonraí) (the DPC), the contact details of which are available here: here

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the DPC’s website:
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here


Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so. These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information. If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information. We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to CLS Recruitment Group Ltd, Unit 2, First Floor, Glenrock Business Park, Ballybane, Galway or sending an email to info@clsrecruitment.ie
  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests , including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an email to galway@clsrecruitment.ie, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here.

Sensitive Personal Information

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation. We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation.
We will use and process your sensitive personal information for the purposes of deleting it.

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.


Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

Children’s Privacy

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet.
We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers.

If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@clsrecruitment.ie.

California Do Not Track Disclosures


“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as web beacons, and other similar technologies, to track visitors to the website.
Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here.
The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software.
All intellectual property rights in this document are reserved.