Privacy Policy

Cowan & Associates, incorporated under the laws of Ireland, registered office at 13 Adelaide Road, Dublin 2, D02 P950, Ireland (“us”, “our”, “we”, “Cowan & Associates”) are committed to protecting and respecting your privacy.

This privacy policy (the “Privacy Policy”) sets out the types of personal data we collect and use when you access and visit https://cowan-associates.com (the “Website”) and how we may use that data.

When you supply any personal data to us we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Privacy Policy into several sections:

Introduction
What is personal data and what do we collect?
How and why do we use/share your personal data?
For how long do we keep your personal data?
Security
Your Rights
Contact Details

1. Introduction

This Privacy Policy covers our collection, processing and use of personal data when you use any of our Website.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.

This Privacy Policy supplements other notices including our Website Terms and Conditions and our Cookies Policy and is not intended to override or replace them.

By visiting or otherwise using our Website, you are agreeing to the practices set out in this Privacy Policy. If, for any reason, you do not agree to the terms of this Privacy Policy, please stop using this Website.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let users of the Website know. However, it is your responsibility to check this Privacy Policy before each use of the Website – for ease of reference the top of this Privacy Policy indicates the date on which it was last updated.

Please note that our Website is not directed at children under the age of 13 (each “Child” together “Children“) and we do not knowingly collect personal data about Children.

2. What is Personal Data and what do we collect?

What is personal data?

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

By law, all organisations in the EU are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

Data we collect from you when you use the Website

Voluntary Provision of Data

When you voluntarily supply your personal data to us, for example where you; use the Website to upload or send personal data (by filling out a form, uploading your CV and cover letter, or similar activities in which you volunteer data about yourself); contact us by post, telephone or e-mail; report a problem with a Website; we may collect, store and use the personal data that you disclose to us.

The personal data we collect from you may include your title, name, address, e-mail address, company, job title, birthday, and phone number – but will depend on precisely what details you volunteer to us as you interact with the Website.

Automated Collection of Data

We may also collect personal data about you when you visit the Website through the use of technologies such as cookies. The following are examples of data we may collect:

information about your device, browser or operating system;
your IP address;
information about links that you click and pages you view on our Website
length of visits to certain pages;
page response times;
records of download errors and/or broken links;
page interaction information (such as details of your scrolling, clicks, and mouse-overs);
methods used to browse away from the page; and
the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).

We use the data described above for several different reasons. Firstly we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.

Third-Party Resources

Where we use cookies to deliver these kinds of services, the delivery of those cookies will be subject to your consent and you will be given the opportunity to refuse those cookies prior to them being delivered to your computer. You are also able to remove cookies from your computer at any time.

For details of the cookies that we use on the Website, what those cookies do, and the privacy policies of the third parties which provide them (where relevant) please see our Cookies Policy.

Please note that, while you have the option to consent to specific individual cookies that, unless specifically set out in our Cookies Policy, we rely on our legitimate interests as our condition for processing your personal data on the basis set out in this section (specifically that we have a legitimate interest in optimising the Website content and ensuring that you are served with relevant commercial communications as you use them).

3. How and why do we use/share your personal data

Lawful basis and purposes of processing your personal data

The primary purpose for which we collect information about you is to enable us to perform our business activities, functions and services and to provide customer service effectively. We collect, hold, use and disclose your personal information for the following purposes:

to provide products and services to you;
to provide you with information about our existing and new products and services (including for direct marketing purposes);
to communicate with you including by email, mail or telephone;
to manage and enhance our products and services;
to personalise and customise your experience with our products and services;
to verify your identity;
to provide as part of business data to third parties if you have authorised us to do so;
to investigate any complaints about, or made by, you;
to investigate any suspected breach of any of our terms and conditions or unlawful activity engaged in by you; and
as required or permitted by any law.

If you do not provide us with the personal information described in this policy:

we may not be able to provide you with information about the products and services that you requested;
we may not be able to provide you with the products or services you requested;
we may be unable to tailor the content of the Website to your preferences and your experience of the Website may therefore not be useful.

We will only use your personal information when the law allows us to, i.e. when it is necessary to:

comply with our legal and regulatory obligations;
pursue our legitimate interests (see ‘Automated Collection of Data’ for further information) and where your interests and fundamental rights do not override these interests.

If you have provided us with your individual contact details (for example, your personal email address), we will rely on your consent to send you electronic communications such as our newsletters and emails with information about our products and/or services. If we hold your business contact details (for example, your work email address), we will rely on the legitimate interests of the business to send you electronic communications, but we will always provide you with an option to opt-out from future communications of this kind.

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

we may share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
with selected third parties who we sub-contract to provide various services and/or aspects of the Website’s functionality (see “Service Providers” below); and
with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.

We may also disclose your personal data to third parties in the following events:

if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that sale;
if Kaiser or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
in order to enforce or apply our Website’s terms of use or terms and conditions; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject.

The following is a list of the major service providers which we use to deliver our website to you:

MEDIA TEMPLE – which is our provider of cloud hosting services. Media Temple’s servers hold the various files that make up our website and enable them to be delivered to you when you visit.
GOOGLE ANALYTICS – Google’s Analytics service allows us to use cookies on our website to monitor the overall number of visitors who access our website, and to better understand how users navigate around it.
HUB SPOT – We use Hubspot’s CRM software to manage our web marketing activity, letting us understand how individual customers engage with us and which of our services they may be interested in.

Links to third-party sites

Where we provide links to third-party websites that are not affiliated with our Website (or any of our others domains) such sites are out of our control and are not covered by this Privacy Policy. If you access third-party sites using the links provided, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.

4. For how long do we keep your personal data?

We will hold your personal data on our systems only for as long as required to provide you with the services you have requested or to perform the purpose for which that data was collected.

Where you sign up to receive e-mail marketing from us we will retain your e-mail address on file should you ever ‘opt out’ of receiving e-mails from us. We will retain your e-mail address in this way in order to ensure that we continue to honour and respect that opt-out request.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.

5. Security

We take the protection of your personal data very seriously. We use encryption (SSL) to protect your personal data when appropriate, and all the data provided to us is stored on secure servers once we receive it.

We may store your personal data on secure servers either on our premises or in secure third-party data centres.

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. If you would like more information about how the mechanism via which your personal data is transferred, please contact privacy@cowan-associates.com

6. Your Rights

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you that you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Privacy Policy which explain how and why we use your information you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

We may process your data on the basis of a legitimate interest in the following ways:

Optimised website content

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to stop receiving communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).

Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at privacy@cowan-associates.com and telling us which communications you would like us to stop sending you.

Your Right to object to automated decision-making and profiling

You have the right to be informed about the existence of any automated decision-making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

7. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us at:

Cowan & Associates, 13 Adelaide Road, Dublin 2, D02 P950, Ireland

Tel. +353 (1) 539 2192

privacy@cowan-associates.com

Last updated: 02 July 2024