AdMailer, a service offered by An Post (“we” or “us”), will collect and process your Personal Data, and other information in relation to your dealings with us, in connection with this Website. This Privacy Statement explains how we will manage your Personal Data obtained via this Website, why we use it, and how you may contact us. Separate privacy statements may apply to specific products or services provided to you by the An Post Group.
Where we need to process your Personal Data in connection with your application for a product or service provided by the An Post Group, or where we have a legal obligation to collect certain Personal Data relating to you (for example, in order to comply with our AML obligations), we will not be able to provide you with the product or service which you have requested if you do not provide this information to us.
Types of Information we Collect through this Website
Where you register to create an AdMailer account, we will collect the following Personal Data (to the extent that it is provided by you): your name; email address; address (including Eircode); password; business name and contact number. Where you contact An Post, for example by email, we will collect Personal Data relating to you to the extent that you provide this to An Post. Through your use of this Website we may also collect information such as identification IP addresses, cookie identifiers and online identifiers. We refer to the above Personal Data as “Personal Data Relating to the User” in this Privacy Statement.
We may also collect certain statistical and other analytical information collected on an aggregate basis relating to all visitors to our Website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of our Website. We collect this information to help us monitor traffic and enhance your experience of our Website.
Terms Used in this Privacy Statement
Capitalised terms used in this Privacy Statement have the meanings given to them in the Service Terms and Conditions to the extent not defined elsewhere in this Statement. For ease of reference, key terms used are summarised below:
Database Uploader Service means a facility made available by AdMailer, in accordance with the Service Terms and Conditions, whereby the User may upload a User Address Database.
Personal Data means any personal information, such as name and address, from which a living individual can be directly or indirectly personally identified. This may include your personal information where relevant.
Personal Data Relating to the User means Personal Data relating to the User obtained by An Post in connection with use by the User of his or her registered AdMailer account, including (as relevant): the User’s name; email address; address (including Eircode); password; business name; contact number; and other Personal Data relating to the User provided by the User to An Post, for example by email. Through your use of this Website we may also collect information such as identification IP addresses, cookie identifiers and online identifiers.
User means a registered user of the Service using the AdMailer registration process on this Website.
User Address Database means a file containing a copy of a list of names and addresses, uploaded to this Website by the User, for the purpose of utilising the Database Uploader Service.
User Address Database Personal Data means any Personal Data provided by the User to An Post by uploading a User Address Database.
User Personal Data means (as relevant) the User Generated Content Personal Data and / or the User Address Database Personal Data.
User Generated Content means a facility made available by AdMailer, in accordance with the Service Terms and Conditions, whereby the User may upload his or her own content, including but not limited to, images, logos, and phrases.
User Generated Content Personal Data means any Personal Data that the User includes in User Generated Content.
How we obtain your Information via this Website
We will obtain your Personal Data (‘Personal Data Relating to the User’) directly from you, such as when you register with AdMailer to create a campaign, where you choose to give us Personal Data through online feedback forms, or where you send us a communication.
See Where we process your Personal Data for Other People below for information in relation to the processing of User Personal Data.
Why we hold and how we use your Information
We will use Personal Data Relating to the User, but only to the extent necessary:
- for the purposes of performing a contract you have entered into with An Post, such as:
- for the purposes of setting up and administering your AdMailer account where you register as a user to create a campaign;
- to facilitate you in accessing your AdMailer account online in a secure manner where we have agreed to give you access to our online service;
- to contact you if required in connection with, or to deal with queries, complaints or suggestions in relation to, the services we provide to you, and your AdMailer account; and
- to facilitate payment by you for your use of the AdMailer Service; or
- to contact you if required in connection with, or to deal with queries, complaints or suggestions you make to us via this Website;
- where you have otherwise consented to our use for a particular purpose, such as for marketing (see Marketing preferences below).
If you do give your consent for us to use your Personal Data for a particular purpose, you have the right at any time to withdraw your consent to our future use of your Personal Data for some or all of those purposes by writing to us at the address set out under “Contact Us” below;
- where our use is for a legitimate purpose of AdMailer, including:
- subject to AdMailer’s terms and conditions, where we have agreed to give you access to our online service and you have created a campaign, continuing to provide you with access to your AdMailer account and content added to it by you, in order to facilitate the creation by you of future campaigns. See Retention of your Personal Data below for more information;
- for day to day operational and business purposes, including board and An Post group reporting and management purposes;
- taking advice from our external legal and other advisors;
- to help us improve our services and systems, and to improve your experience on our web and online services;
- to undertake market research, statistical and product development analyses;
- to provide you with information in relation to the An Post Group and certain selected third parties, where we are permitted to do so (please see “Marketing preferences” below for further information); and
- in deciding what marketing information to send to you and to make it more relevant to you (please see “Making Marketing Relevant to You” below for further information).
- where necessary to establish, exercise or defend An Post Group legal rights or for the purpose of legal proceedings; and
- for such other purposes as were notified to you at the time you provide the information to us.
When we disclose your Information
We will not disclose any Personal Data Relating to the User to any third party, except as outlined above and / or as follows:
- to anyone providing a service to us or acting as our agents, which may include either companies within the An Post Group or third party service providers, on the understanding that they will keep your Personal Data confidential. Please see the Service Terms and Conditions for more information;
- where you purchase a Service and pay using a debit or credit card, you will be transferred to the An Post payment page, which uses the services of third party payment processors (“Payment Processors”) to process your payment. An Post will process your payment information and related personal data solely for purposes of facilitating such payment and performing payment-related activities (eg, facilitating chargebacks);
- where we need to share your Personal Data within the An Post Group or with our auditors, and our legal and other advisors; and
- if the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators.
We will not otherwise share Personal Data Relating to the User with any third party unless we receive your prior written consent to do so.
Where we process your Personal Data for other people
Where we receive User Personal Data (see Terms Used in this Privacy Statement), we act as a data processor for the User (see Terms Used in this Privacy Statement) that has provided that User Personal Data to An Post (referred to as a data controller under relevant data protection laws).
In cases where we are acting on behalf of a data controller (other than ourselves), we will act only on their instructions in relation to processing your Personal Data. In these cases, it is that third party which is responsible to you for complying with your rights in relation to your Personal Data. If you send any request to us to exercise your rights, we will send it on to the data controller as soon as possible.
Recipients of your Personal Data
In any case where we share your Personal Data with a third party data controller, the use by that third party of your Personal Data will be subject to the third party’s own privacy policies.
Personal Data may be transferred outside of Ireland in connection with your use of the An Post Websites where you have explicitly consented, and / or as otherwise required or permitted by law.
Many of the countries will be within the European Economic Area (the “EEA”), or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in Ireland.
However, some transfers may be to countries which do not have equivalent protections, and in that case, we will use reasonable efforts to implement contractual protections for the Personal Data. While this will not always be possible where we are required to transfer the Information in order to comply with and perform our contract with you or where we have a legal obligation to transfer the Personal Data, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.
Where you provide us with Personal Data relating to other people
Where you provide us with Personal Data relating to other people, such as your spouse, children, mail recipients (if you use the postal service or for the administration of postal services), partners, directors, officers, employees, advisors or other related persons, you represent and warrant that you will only do so in accordance with applicable data protection laws. You will ensure that before doing so, the individuals in question are made aware of the fact that we will hold information relating to them and that we may use it for any of the purposes set out in this Privacy Statement and the Service Terms and Conditions, and where necessary you will obtain their consent to our use of their information. We may, where required under applicable law, notify those individuals that you have provided their details to us.
Without limiting the above, where you provide us with User Personal Data you acknowledge and agree in particular that clauses 6, 8, 16, 17 and 19 (An Post as Data Processor) of the Service Terms and Conditions apply, and you acknowledge and agree to comply with sub-clause 19.e. (User’s Representations, Warranties and Undertakings as Controller) of the Service Terms and Conditions. For the avoidance of doubt, all clauses of the Service Terms and Conditions will at all times apply to and bind the User as set out in those terms.
Security of data
An Post takes its security obligations in respect of your Personal Data seriously under applicable data protection laws to prevent unauthorised access to, or alteration or destruction of Personal Data in our possession.
Retention of your Personal Data
We are obliged to retain certain information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes.
If Personal Data is disclosed to us by you in connection with a general enquiry through this Website, for example where you enter your details into a Website form or you send us an email, that Personal Data will be retained for a period of 13 months, unless we have a legal obligation to hold this information for longer.
Where you register your contact details to create a campaign, subject to AdMailer’s terms and conditions we will retain your contact details and other content uploaded by you for a period of 3 years from your last use of the AdMailer service, unless we are required to hold this information to comply with our legal obligations.
Other information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes. In general, we (or our service providers on our behalf) will hold this information for a period of seven years, unless we are obliged to hold it for a longer period under law or applicable regulations.
A cookie is a small piece of information which is transferred to your computer’s hard disk from a website. Cookies can store information about your preferences and other information which you need when you visit a website.
Your rights in relation to your Personal Data
Updating and correcting your Personal Data
If we hold incorrect Personal Data about you, you have the right to have your Personal Data amended. While we will use reasonable efforts to keep your Personal Data up to date, you will need to notify us without delay in the event of any change in your personal circumstances, so that we can keep your Personal Data up to date.
You can update your Personal Data by writing to the Data Privacy Office, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2 or firstname.lastname@example.org together with:
1. Your name and address; and
2. A description of the specific Personal Data you wish to be rectified.
Right of erasure
You have the right in some circumstances to have your Personal Data, which we hold, erased. If you request an erasure of your Personal Data, all your data will be erased subject to the following important notice.
We will not be required to erase your data where to do so would prevent us from meeting our respective contractual obligations, or where we are required to process (including retaining) your Personal Data in order to comply with a legal obligation, or if your Personal Data is necessary to establish, exercise or defend our or An Post Group legal rights or for the purpose of legal proceedings.
To request that we erase your Personal Data which we hold please send your request to us in writing at Data Privacy Office, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2 or email@example.com together with:
1. Your name and address; and
2. A description of the specific personal data you wish rectified.
Right of Access
You have a right to be given a copy of your Personal Data on request, subject to certain exceptions. Please note that we have the right to require that you identify yourself before we will respond to any access request.
For more information, see our Data Access Policy.
Your Other Rights
You also have the right, in certain circumstances, to request restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your Personal Data can be obtained by writing to us at the address set out under “Contact Us” below.
In any case where we rely on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to us at the address set out under “Contact Us” below.
Where we rely on a legitimate purpose of ours or of a member of the An Post Group or a third party recipient of your Personal Data, in order to use and disclose your Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do so, we will cease to use and process your Personal Data for that purpose, unless we can show there are compelling legitimate reasons for us to continue or we need to use your Personal Data for the purposes of legal claims.
In limited circumstances, you may also have the right to data portability in respect of certain of your Personal Data, which means you can request that we provide it to you in a structured, commonly used and machine-readable format, or transmit it to your third party nominee where this is technically feasible.
You have the right to lodge a complaint about our processing of your Personal Data with the Data Protection Commissioner at firstname.lastname@example.org.
Where you request Information about the An Post Group
Where you choose to give us Personal Data, such as where you enter your details into our Website forms, we will use this information to send you an acknowledgement e-mail and to provide you with the information you have requested. We may also send you subsequent emails, SMS messages or contact you by phone to follow up on your initial query.
Where you have agreed, we may also contact you in relation to other marketing (see Other Marketing by AdMailer).
Other Marketing by AdMailer
Where you have agreed via this Website to receive marketing from AdMailer, we will use this information to contact you with news and special offers from AdMailer.
We may use your Personal Data as part of general market, statistical and product development analyses in relation to our business generally. ou can object to us analysing your Personal Data in this way by writing to us at the at the address set out under “Contact Us” below.
Opting out of Marketing
You can change your marketing preferences at any time by contacting AdMailer, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2.
Each time we send you marketing information, we will give you the option to change your mind about receipt of marketing (eg SMS: text STOP).
Use of Non-Personal Data from our Website
We use the Non-Personal Data gathered from visitors to our Website in an aggregate form to understand the demographics of the users of our Website, to help us better design and organise our Websites and mobile applications. We use these analytics tools to assist in gathering and analysing Non-Personal Data for the reasons described above.
Our analytics solutions may also collect your IP address as part of this analysis. No other form of Personal Data is gathered by these analytics services.
Except as explained above in relation to your IP address, by simply visiting our Website, you do not disclose, nor do we collect, Personal Data on you. The information collected about your visit may be limited to technical data which is used for administrative and statistical purposes, for example whether you reached the Website using a search engine or if you clicked a link on another website; the type of web-browser you used; or the type of device you used to access the Internet. We will use this information to help us to improve our Website.
We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of the AdMailer Website. For example, we may inform third parties regarding the number of unique visitors to the AdMailer Website, the demographic breakdown of users of our Website, or the activities that visitors to the AdMailer Website engage in while online. The third parties to whom we may provide this information may include our Website design, development, digital, support and hosting contractors.
Any queries or complaints regarding our use of the Personal Data and / or the exercise of your individual rights should be addressed to the Data Privacy Office, An Post, GPO, O’Connell Street, Dublin 1, D01 F5P2 or email@example.com.
Last updated on 16 August 2018.