Privacy Statement

A Playful City

This is the privacy notice of A Playful City. In this notice, "we", "our", or "us" refer to A Playful City.

Our registered office is at Tara Buildings, Tara Street, Dublin 2

Our website is - aplayfulcity.com

Data Protection Officer:

The Data Protection Officer is Neasa Ni Bhriain, Director. Any queries regarding Data Protection issues should be addressed to him at:

Email: Neasa@aplayfulcity.com

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through our website and through social media platforms.

We do not share, or sell, or disclose to a third party, any information collected through our website.

Personal data we process

1. How we obtain personal data

The information we process about you includes information:

you have directly provided to us
as a result of monitoring how you use our website or our services

2. Types of personal data we collect directly
When you use our website or our services we may ask you to provide personal data. This can be

categorised into the following groups:

personal identifiers, such as your first and last names, your title and your date of birth
contact information, such as your email address, your telephone number and your postal addresses
images which you have sent to us via email or a third party service provider such as ChangeX or Lego Foundation

3. Types of personal data we collect from your use of our services

By using our website and our services, we process:

your username and password and other information used to access our website and our services information you contribute to our community
your replies to polls and surveys
technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your geographical location, your browser type and version and your device’s operating system.
usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

4. Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

5. Special personal data

Special personal data is data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

We do not collect any special personal data about you.

6. If you do not provide personal data we need
Where we need to collect personal data by law, or under the terms of a contract we have with you,

and you fail to provide that data when requested, we may not be able to perform that contract.

In that case, we may have to change the service we provide to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

The lawful bases for processing are set out in Article 6 of the GDPR. At least one of these must apply whenever you process personal data:

(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).

(d) Vital interests: the processing is necessary to protect someone’s life.

(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.

(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interest

7. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our services, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at neasa@aplayfulcity.com However, if you do so, you may not be able to use our website or our services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

8. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of

doing so.
Where we process your information on this basis, we do after having given careful consideration to:

whether the same objective could be achieved through other means
whether processing (or not processing) might cause you harm
whether you would expect us to process your data, and whether you would, in the round,
consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

improving our services
record-keeping for the proper and necessary administration of our organisation responding to unsolicited communication from you to which we believe you would expect a response
preventing fraudulent use of our services
exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property
insuring against or obtaining professional advice that is required to manage organisational risk
protecting your interests where we believe we have a duty to do so

9. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

How and when we process your personal data

10. Your personal data is not shared

We do not share or disclose to a third party any information collected through our website.

11. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date. This contact will only be in relation to a future job opportunity.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

Use of information we collect through automated systems

12. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

We use cookies in the following ways:

to track how you use our website
to record whether you have seen specific messages we display on our website
to record your answers to surveys and questionnaires on our site while you complete them

Embedded content from other websites
Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

13. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are

recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Other matters

14. Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the

processing and control of your personal data.
We do this now, by requesting that you read the information provided at

http://www.knowyourprivacyrights.org

15. Use of our services by children

While we do not provide services for children directly, nor do we market to children under 13, certain areas of our website may be used by children, such as the community activity section.

If you are under 18, you may use our website only with consent from a parent or guardian.

We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.

16. What data breach procedures we have in place

These are set out in our Personal Data Breach Policy and Procedures for addressing data breaches

17. What third parties we receive data from

We use ChangeX as an online platform to manage the collection of personal data. Any registrations and associated data provided by the user on the ChangeX platform is held by both A Playful City and ChangeX.

18. Encryption of data sent between us

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt

any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

19. Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before taking any action. This is important to safeguard your information.

If you wish us to remove personally identifiable information from our website, you should contact us to make your request.

This may limit the service we can provide to you.

20. Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our organisation.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

21. Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Data Protection Commission (DPC). This can be done at https://www.dataprotection.ie/docs/complaints/1592.htm. We would, however, appreciate the opportunity to talk to you about your concern before you approach the DPC.

22. Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

to provide you with the services you have requested
to comply with other law, including for the period demanded by our tax authorities
to support a claim or defence in court

23. Compliance with the law

Our privacy policy complies with the law in Ireland, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.

24. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.

25. Data Controller

Neasa Ni Bhriain

A Playful City, Tara Buildings, Tara Street, Dublin 2, Ireland

neasa@aplayfulcity.com

aplayfulcity.com