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Updated 13th July 2018

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At Camino Society Ireland clg (the Company) we recognise that protecting your privacy is a responsibility we take very seriously. We have prepared this privacy policy to help you understand how the Company collects, uses and seeks to safeguard the personal data you provide to us on our websites, mobile applications, via email and through our service providers and distribution partners. This Privacy Policy does not address, and the Company is not responsible for, the privacy and information gathering of any third-party operating any site to which our website provides a link. By downloading, accessing or using the Company’s website or content or using the Company’s application (the “Application”) on a mobile phone, tablet or similar device (the “Device”), or providing information to the Company in connection with its websites, mobile applications or other sites or services, you acknowledge that you have read and understood the terms and conditions of this Privacy Policy.

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We detail below the following;

1. Who we are.

2. Collection of your personal data.

3. How we use your personal data.

4. Marketing and how we may contact you.

5. With whom we share your personal data.

6. How long we will retain your personal data.

7. Cookies and other web technologies.

8. Your rights.

9. How we protect your personal data.

10. Information concerning minors.

11. External Links.

12. International transfers

13. Changes to our privacy policy.

14. How you can contact us.

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1.Who we are.

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The Company, Camino Society Ireland c.l.g, is the successor to The Irish Society of the Friends of St. James and was incorporated as a company limited by guarantee in Ireland (without share capital)on the 18th February 2015 with number 557712.Its registered office is situate at 8, Priory Hall, Stillorgan Road, Blackrock, Co. Dublin A94 EE95 and has its business address at 36,Upper Baggot Street, Dublin, Co. Dublin D04 R6Y6 (postal address only).

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The Company’s principal objects include;

• To inform the public by whatever means the Company deems fit on all matters relating to the practice, art, history, music and usage of the various pilgrim routes (the “Pilgrim Routes”) within Europe to and from Santiago de Compostella, Spain.

• To bring together for the mutual exchange of experiences and ideas those expressing an interest in the pilgrimage (“Pilgrimage”) along the “Pilgrim Routes” and to encourage and assist those contemplating a “Pilgrimage” along the “Pilgrim Routes”.

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The Company’s subsidiary objects include;

• To undertake and promote research into the history of the “Pilgrim Routes “and the “Pilgrimage”.

• To identify, preserve and maintain works of art, literature and music associated with the “Pilgrim Routes” and the “Pilgrimage”.

• To identify, preserve and maintain monuments, building and structures associated with the “Pilgrim Routes” and the “Pilgrimage”.

• To provide practical information (by way of publication or otherwise) to those undertaking the “Pilgrimage” along the “Pilgrim Routes”.

• To assist in identifying, and where deemed appropriate by the Company, to assist in creating, repairing, re-opening and maintaining “pilgrim Routes” throughout Europe.

• To identify, acquire by purchase, lease, licence, receive by way of gift in whole or in part or otherwise obtain any building or structure anywhere in Europe for use by the Company and/or for use by persons (“Pilgrims”) embarked upon the “Pilgrimage” (whether as Members of the Company or not) as a refuge, place of shelter or rest and to provide therein such catering and sanitary facilities and such other facilities as the Company may deem necessary for those Pilgrims.

 

In pursuance of the Company’s principal and subsidiary objects it makes available, through its website and mobile application, its complete range of products and services to Members of the Company and to non-Members.

 

2.Collection of your personal data.

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In the course of the Company’s business, it collects and processes personal data in different ways. It may collect personal data you give to the Company directly, but data is also collected by logging how you interact with the Company’s services; for example by using cookies on the Company’s website. We may also receive personal data about you from third parties.

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The personal data that we collect about you may include, but is not limited to, your name, email address, residential postal address. business address, phone number (both mobile and land line), billing information, booking details for our events and such other information as you may provide to us. Our systems also collect your IP address and your web browser software.

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You may choose not to provide personal data to us, but in general some personal data about you is required in order for you to receive, from time to time, relevant offerings, products and services from us and for those who are Members of the Company to enjoy the benefits of Membership. 

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Information that you furnish to us. We receive and store any personal data that you enter on our web sites or give us in any other way. For example, in order to purchase our products, services or Membership, it is necessary for you to disclose personal data, including your name, email address, postal address, phone number (mobile and/or land line) debit/credit card details and other personally identifying details. If you do not provide personal data when purchasing our products, services or Membership we cannot fulfil the purchase. In some instances we may seek information about your Pilgrim journey. For example to be issued with our Certificate of Completion of an Irish Pilgrim Route you will have to provide us with documentary evidence of the route you have covered. Or if you wish your name to be entered in the Company’s “Book of Pilgrims” you will have to provide us with evidence of the pilgrimage that you have undertaken.

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Information about others. You may have the occasion to provide contact information to us relating to other people through our website. For example, you may wish to purchase some of our products, services or Membership for persons other than yourself. You must obtain that other person’s consent before furnishing their personal details to us.

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Information from other sources. We may periodically obtain personal data about you from affiliated entities, business partners and other independent third-party sources and add it to other information about you. For example, if you have found on a website, other than our website, a link to our website then personal information that you have furnished to that other website may be shared with us. As another example, if you access third-party services, such as social media services, through our website or before coming to our website, we may collect information such as your user name and other information available to us through those services. However, we will always work to ensure that this sort of information will have the protections afforded you by this Privacy Policy.

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Automatic Information. We automatically collect certain information from your computer or mobile device when you visit our website. For example we collect your IP address, web browser software or where you have found us through a link in another website details of that other website. This helps us to analyse the use of our website and how we might better improve it and the services it offers.

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Location Information and other information from your Devices. When you use an application on a mobile device we will collect and use information about you in generally similar ways and for similar purposes you use our website. In addition, we may collect information about your location with your consent if your Device has been configured to send this location information via the privacy settings on the Device or you have uploaded photos tagged with location. You can turn off at any time the sharing of your location or that attached to uploaded photos in the privacy settings of you Device. If you do not know how to do this contact you Device manufacturer or service provider.

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3.How we use your personal data.

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We use the personal data that we collect about you for specific purposes. This includes, but is not limited to;

• To offering our products, services ,events and Membership to you;

• If you are a Member of the Company, to managing your registration as a Member during your Membership of the Company; to notifying you of any changes to our constitution; to notifying you of any meetings of Members; to furnishing you with financial information relating to the Company.

• To publishing on our website any data (including uploaded photos) that you have expressly authorised us to publish;

• To communicating with you regarding your use of our website.

• To responding (whether by email, phone, social media or postal correspondence) to any queries, comments or suggestions raised by you.

• To notifying you of any changes to this Privacy Policy.

• To notifying you about events which we think may be of interest to you whether such event is run by the Company or by a third-party.

• To inviting you to submit your entry to any competition being run by the Company.

• To seeking donations for any causes which the Company considers worthy of support.

• To exchange information between us as to how we can best guard against fraud, illegal activity and can best protect the Company and you.

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We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests and your interests and fundamental ridhts do not override those interests.

• With your consent.

• Where we need to comply with a legal or regulatory requirement.

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4. Marketing and how we may contact you:

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We may send to you marketing emails with information about our products, services, events or competitions and special promotions which we think will interest you. You will receive from us such marketing information if you have given your consent, if you have requested it, or if you have purchased goods or services and you have not opted out of receiving marketing information from us.

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If you are no longer interested in receiving marketing information from us you may unsubscribe by following the link which accompanies each marketing email and selecting “unsubscribe”. Please note that even if you unsubscribe from future marketing emails we will continue to send emails to you regarding your bookings and purchases requested after you have unsubscribed but only arising out of and in connection with those bookings and purchases.

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For so long as you are Member of the Company we reserve the right to send you emails and other communications, including service announcements, administrative messages, changes to the Company’s constitution and General Meetings relating to your Membership without offering an opportunity to opt out from receiving them.

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5. With whom we share your personal data.

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We may store contributions and submissions that you make to us including, but not limited to your photos, public profile and comments (“your Content”) on our website and Applications, display “your Content” to other users, and use it for our promotional purposes. Note particularly, if you include personal data in “your Content”, it can be used and viewed by others. We are not responsible for the information you include in “your Content”.

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We may share your personal data with other parties such as service providers who work on our behalf.If we are legally obliged to do so, we will share your personal data to protect our Members and customers, the Company and our website ,and our rights and property.

 

(a) Social media services. If you connect to us using Facebook, (or any social media sites), we may show you photos and events friends have posted, shared or saved. Note, if you have Facebook friends who are using our sites, they may also share personal data about you with us through Facebook. If you wish to prevent that sharing, please restrict sharing on your Facebook (or any social media sites ) privacy settings. You can also choose to access third-party social media sites and services (such as Twitter, Instagram, G+Google+, Pinterest) through our site. When you do so you are sharing your personal data with those sites and the personal data you share is governed by their privacy policies. You may be able to modify your privacy settings on those third-party social media sites.

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(b) Third-party service providers. We may share your personal data with third parties who provide services or functions on our behalf, such as payment providers (Paypal), anti-fraud and virus protection service providers. We may also authorise third-party service providers to have access to our website or Applications to facilitate the delivery of online advertising of our products, services and events tailored to your interests. Third parties have such access only as needed to perform their functions and are not permitted to share or use your personal data for any other purpose. We currently contract with a number of third-party service providers to help manage and optimise our internet business and communications.

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(c) Referring websites. If you were referred to us from another website, we may share your registration information, such as, your name, email address, postal address phone number with the referring site. We have not placed limitations on the referring websites use of your personal data and we encourage you to review the privacy policies of any website that referred you to us.

 

We may also share or disclose personal data if we believe,at our sole discretion, this to be necessary:

• To comply with legitimate court orders or other legal processes:

• To establish or exercise our legal rights to defend against legal claims

• To investigate, prevent, or take action regarding illegal or suspected illegal activities:

• To protect and defend our rights and property and those of our Members and customers:

• To assist with law enforcement agencies and other governmental bodies if we are legally obliged to do so:

 

 

6. How long we will retain your data.

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

To determine the appropriate retention period for personal data we consider all or any of the following:

• the amount, nature and sensitivity of the personal data,

• the potential risk of harm from unauthorised use or disclosure of your personal data

• the purposes for which we process your personal data and whether we can achieve those purposes through other means the applicable legal requirements:

 

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7. Cookies and other website technologies.

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We collect personal data via cookies and similar technologies .”Cookies” are pieces of information that are stored by your web browser on your computer’s hard disc or solid state drive for record-keeping purposes.

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You will find more details about “Cookies” at the end of this Privacy Policies.

 

8. Your rights.

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Subject to the exception, set out below in this paragraph, relating to the Company’s Pilgrim Book, you can check, supplement and update the information you have provided to us, or you can close your account/Membership at any time. If you decide to close your account/Membership we will deactivate it and delete your profile information. We will send you an email to confirm your request for closure. Remember that once your account/Membership is closed you will no longer be able to login and access your personal information. You can however open a new account or apply for new Membership at any time.

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You can change such marketing preferences as you have selected at any time. 

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We may offer customers and Members the option to save information related to their name, delivery address and method of payment on our website. If you save such details on our website you will be able to add, delete or modify that information at any time in your account settings.

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In accordance with applicable law you may also have right of access, right to rectification, right of erasure, right to restriction of processing, right to data portability and the right to object. You will find below details and information on how and when you may be able to exercise these rights. Where such rights exist we will respond to your request within one month but we have the right to extend this period to two months. We will notify you within the first month if we are seeking an extension to two months.

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In accordance with the law you have the following rights with regards to your data:

• The right to request access to your personal data held by us. This enables you to check that we are lawfully processing it.:

• The right to request us to correct data if it is inaccurate. You may supplement any incomplete data we hold taking into account the purposes of the processing:

• The right to request deletion of your personal data if (a) your personal data is no longer necessary for the purposes for which we collected or processed it; or(b) you withdraw your consent if the processing of your personal data is based upon your consent and no other legal ground exists preventing us from acceding to your request; or (c) you object to the processing of your personal data and we do not have an over-riding legitimate grounds for processing; or(d) your personal data is unlawfully processed; (e) your personal data has to be deleted in compliance with a legal requirement:

• The right to object to the processing of your personal data. We will comply with your request unless we have a compelling, overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim:

• The right to restrict the processing of your personal data if (a) the accuracy of your personal data is contested by you: or (b) the processing is unlawful and you oppose the deletion of your personal data and request restriction; or(c) we no longer need your personal data for the purpose of processing but your personal data is required by you for a legal claim: or (d) you have objected to the processing, for the period in which we have to verify overriding legitimate grounds:

• The right to data portability. You may request us to receive the personal data that relates to you. You may also request us to send this personal data to a third-party where feasible. You only have this right if;(a) it relates to personal data that you have furnished to us;(b) the processing is based upon consent or necessary for the performance of a contract between you and us: (c) and the processing is done by automated means.

 

You may exercise your rights by sending us an email at info@caminosociety.ie marked “Exercise of Rights for immediate attention”.

You do not have to pay a fee to access your personal data or to exercise any of your rights. However, we have a right to charge a reasonable fee if your request/s is/are clearly unfounded, repetitive, vexatious or excessive.

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your rights. This is to ensure that no one other than you has access to your personal information. We may decide to contact you by other means (e.g. by txt or phone) to satisfy us that it is you.

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Exception relating to the Company’s Book of Pilgrims.

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The Book of Pilgrims was created some years ago by the Company and its predecessor to provide a permanent record of “Pilgrimages” undertaken by Members of the Company and by non-Members. The data entered in the Book, shows the Pilgrim’s name, the date of his/her “Pilgrimage” and the “Pilgrimage” completed (the Data). The Data entries are written in Celtic script by calligraphers engaged by the Company. As the Book is intended to provide a valuable, historical record for present and future generations it is regarded by the Company as a record which will be useful to researchers in future. The Company believes that once entries are made in the Book to remove or alter those entries would seriously damage the visual impact of the Book and the Data. Accordingly, if you request the entry of your Data in the Book it will be subject to the conditions that (a) you consent to your Data being furnished to the calligraphers retained by the Company and(b) you waive any and all rights that you otherwise might have to have your Data removed or altered. If you do not accept these conditions you should not request that your Data be entered in the Book.

 

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9. How we protect your personal data.

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We seek to maintain the integrity and safety of your personal data. We have implemented and maintain appropriate physical, administrative, technical and organisational measures to protect the personal data that you have given to us against unauthorised or unlawful access or disclosure and against accidental loss, damage, alteration or destruction.

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We seek to store your personal data in secure operating environments that are not accessible to the public and to have security measures in place at our physical facilities to protect against accidental loss, misuse or alteration of your personal data by our Members, officers, employees or third parties.

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However, no data transmitted wirelessly (or by mobile device with services provider’s sim) via the internet can be guaranteed 100% secure. Therefore, we cannot give an absolute assurance that personal data you provide to us will be secure at all times. We rely on you to tell us immediately if you experience any unusual events that may indicate a breach in your information security. We will then seek to ascertain if this was related to any transmission to/from us and let you know what steps can be taken and have been taken to rectify the problem.

 

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10. Information concerning minors.

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We do not offer any or our products or services or Membership to anyone under eighteen years of age. If we do identify that such a person (or someone on behalf of such a person) has furnished personal data to us we shall immediately have it deleted.

 

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11. External links.

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Our sites may include links to third-party sites, plug-ins and applications. If you access other sites from the links provided on our sites, the operators of these sites may be able to collect or share your personal data. This information will be used by them in accordance with their privacy policies which may be different from our policies. We do not control those third-party sites and we strongly recommend that you review their privacy policies and familiarise yourself with those policies and understand their collection and dissemination of personal information.

 

12. International transfers.

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We do not usually transfer personal date outside the European Union. But where it does prove necessary to so transfer we will do so in accordance with applicable law and will ensure a similar degree of protection by taking the following steps:

• The transfer is to a country recognised by the European Union as providing an adequate level of protection: or

• The transfer is to a country which does not offer adequate protection but whose transfer procedure has been governed by the standard contractual clauses of the European Commission: or

• The transfer is governed by other appropriate cross-border transfer solutions to provide adequate protection.

 

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13. Changes to our Privacy Policy.

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Our business will, from time to time evolve, and so we may need to review our Privacy Policies to ensure they meet with current business requirements and reflect any changing legal requirements. Accordingly, we reserve the right to change our Privacy Policies as circumstances require. We will post any changes to our website and will notify our Members of any significant changes in Policy by email to the address furnished by the Member. Amendments to this Privacy Policy and future Policies will be signified by a “Last Updated” note appearing at the top of the Privacy Policies. We recommend that you check periodically to see if you are up to date with any changes.

 

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14. How you Can contact us.

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If you have any complaints or questions about the processing of your personal data, please contact our privacy officer at:

Camino Society Ireland clg, 36, Upper Baggot Street Dublin, Co. Dublin, Ireland, D04 R6Y6.or

info@caminosociety.ie

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You also have a right to lodge a complaint with the supervisory body (the Data Protection Commission at www.dataprotection.ie ) about the way we process your personal data. We would however, wish to have an opportunity to deal with your complaint or query before you seek assistance from the regulatory authority so please contact us in the first instance at:

 

The Privacy Officer,

Camino Society Ireland c.l.g 36, Upper Baggot Street, Dublin, Co. Dublin, Ireland DO4 R6YS or email info@caminosociety.ie