Privacy Policy - Health Freedom Ireland

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site: https://healthfreedomireland.com.

By providing us with your data, you warrant to us that you are over 13 years of age.

Irish Vaccination Awareness is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Full name of legal entity: Irish Vaccination Awareness trading as Health Freedom Ireland.

Email address: info@healthfreedomireland.com

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@healthfreedomireland.com.

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy. Please see section 12 for more details on how we use Google Analytics.

Marketing Data that includes data about your preferences in receiving newsletters from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how visitors to our site use our products/services, to develop them, to grow our audience and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our audience. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our audience).

Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details 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 information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@healthfreedomireland.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

For data specific to the vaccination adverse reactions survey see section 13.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you when you provide the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our section 11 for more details on cookies.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators. See our more detailed section on the data we collect using Google Analytics in section 12.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our audience).

[Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.]

We never share your personal data with any third party for their own marketing purposes. If a need arises to share your personal data with third parties for other reasons, for example with a solicitor for legal advice, we will get your express consent.

You can opt out of any communications from us at any time by following the opt-out links on any emails sent to you OR by emailing us at info@healthfreedomireland.com at any time.

If you opt out of receiving communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers
Government bodies that require us to report processing activities.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).

We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. DATA RETENTION

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

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at: https://www.dataprotection.ie/en/individuals

If you wish to exercise any of the rights set out above, please email us at info@healthfreedomireland.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

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 other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Data Commission, the Irish supervisory authority for data protection issues (https://www.dataprotection.ie/en/individuals/exercising-your-rights/raising-concern-commission). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

This site uses cookies - small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping baskets, and provide anonymised tracking data to third party applications like Google Analytics. Section 12 below contains detailed information on cookies used for Google Analytics as well as information on how to opt out. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

If you submit a form on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you submit another form. These cookies will last for one year.

For details on the cookies used when you complete our COVID-19 Adverse Reactions Survey form, please see sub section A on the ‘Data we collect about you’ in section 13. Details on the cookies used when you complete our T-Cell booking form can be found in subsection A of section 14.

12. ANALYTICS

We use a popular plugin called MonsterInsights to implement Google Analytics. Google Analytics is a service which transmits website traffic data to Google servers in the United States. We use reports provided by Google Analytics to help us understand website traffic and web page usage. This helps us better understand how our users are using the site and improve it.

In order to have this functionality a number of cookies are used. You can see more details on which cookies are used by Google Analytics here along with a description of each one. (Note: we do not have google adverts on the site so the cookies associated with this described in the link above are not used). We have enabled an additional feature to further protect users' privacy to anonymise IP addresses. This means that the last portion of the IP address is not stored so it gives us a sense of where in the world our visitors are coming from but not exact locations.

By using this website, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. Click here to opt-out of Google Analytics in one click. Alternatively, if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google. Learn more about how Google uses this data, what data is collected and instructions on how to opt out of Google Analytics here.

13. COVID-19 ADVERSE REACTIONS SURVEY

Participants will provide Health Freedom Ireland with their contact information. We refer to this contact information as Participant Data and responses as Survey Data. We remain data controllers of the Data and we will process that in the form of anonymised reports.

Our questionnaire asks a series of predefined questions that retain a minimum amount of personal information. This section will explain the following in relation to the COVID-19 Adverse Reactions survey:

The information we collect about you
How we use your information
Who we share your information with
Your rights as a data subject
How long we keep your information
Security of your information
International transfers of information

A. The information we collect about you

We collect the following information about you:

Participant Data: The personal data that we collect is your name, email address and phone number (which is optional). The personal data is collected only for the purpose of contacting you if you should wish and will not be used for any other purpose, unless you consent otherwise. It will not be associated with the Survey data when we process it. We also use your email address to send you a copy of your responses. We do not save your login details (if you are logged into the website) or your IP address into our database.

Survey Data: we collect your survey responses for example:

Health data – whether you have had COVID19, or been given a vaccination.
Your location
Your age range
Your ethnicity
Your education level
Details of symptoms experienced and information about doctor/hospital visits

Technical information: Please see the section 12 on Google Analytics for more information on information we collect relating to your interaction with our website. We do not link this information to your Questionnaire Data.

Cookies: the online survey uses a minimal amount of cookies. Predominantly it is used for functions like captcha/recaptcha, action after submission and is not used to store user data or responses to the survey. Our tracking service - Google Analytics - does set some cookies relating to your interaction with the website. Please see section 12 for more details on this. This is not linked to your survey responses.

B. How we use your information

We use the information that we hold about you in the following ways:

Survey Data: We will use the Survey to create reports on adverse reactions to the COVID-19 vaccine. We may post these on our websites or on social media or other channels/platforms. However, these will never include personal data such as your name, email address or phone number. We only use your Questionnaire Data for our own purposes if required to do so by law, and/or if you consent to us doing so.

Technical information – for analysis: we will use your information in accordance with our legitimate interests of administering and analysing questionnaire feedback. We may also use this information in aggregate form for our legitimate interests of improving our services.

C. Who we share your information with

Questionnaire Data: The data is treated anonymously.

Unless we are required to do so by law, we will not disclose your Participant Data to any other third parties unless you give us consent. For example if you contact us after filling out the survey for help or support and we send the details to a third party, with your permission, that may be able to help.

D. Your rights as a data subject

If you wish to access, correct, or delete your Data, or exercise any of the other rights described below in relation to your Data, let us know. You may have the right to exercise the following additional rights:

Right to Access: At any point, you can request copies of Questionnaire Data you entered into our system. Our response will be given free of charge. Contact us at info@healthfreedomireland.com and we will, having verified your identity, send you a CSV file of available data, providing it does not impact on other participants' rights to anonymity.

Right to Rectification: If at any time we have Participant Data incorrectly entered you have the absolute right to request that we amend it. With regards to Survey Data your opportunity to rectify it is limited as the survey form functionality does not support editing replies once the survey has been submitted. However, we will assist where possible, if you email us at info@healthfreedomireland.com.

Right of Erasure (Right to be forgotten): in certain circumstances you have the right to erasure of personal information held about you, although this may be qualified where e.g. it is necessary for that information to be retained for record keeping purposes or compliance with our obligations.

Right to Object: you have the right to object to our processing of your personal data for purposes based on our legitimate interests. In some cases, we may be able to demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

Right of Restriction: you have the right to request that we restrict the processing of your personal data (e.g. where you believe that the personal data we hold about you is inaccurate or unlawfully held).

Right to Data Portability: You may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information provided by you to another data controller. Providing this does not compromise:

Our specific business IP
Compromise someone's right to anonymity (offered by our service)

If you would like to exercise such rights, please contact our Data Controller, on info@healthfreedomireland.com. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

You also have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

You also have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. In Ireland, this is the Information for Data Protection Commission: https://www.dataprotection.ie/en/individuals.

E. How long we keep your information

Participant Data: As a standard we hold data for 5 years. We hold the survey data (which does not contain any personal data) indefinitely.

Aside from Survey Data we are likely to hold only very limited information about you. We typically retain technical information for no longer than a year from the date we collect it and will retain your contact information for no longer than 5 years after we have resolved your enquiry (unless we have a specific reason to retain it for longer, for example to comply with a legal requirement)

F. Security of your information

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information.

While we use appropriate technical and operational measures to keep your personal information secure, the transmission of information via the internet is not within our control and is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your personal information sent to us or to you by email. Any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to try to prevent unauthorised access.

G. International transfers of information

We are subject to the provisions of the General Data Protection Regulations (GDPR) that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data.

The Health Freedom Ireland website is hosted in the EU, therefore responding to our survey does not involve transferring your data out of the EEA. However, if in the process of analysing the survey responses, HFi team members may save it to Dropbox or upload them to Google sheets - this would mean the data would be stored on US servers. This means the data would be transferred outside the EEA. We will take precautions in this case such as deleting Participant Data first (e.g. name, email address & phone number before using such services)

14. T-CELL BOOKING FORM

This form is to collect information in order to facilitate booking a T-Cell test with a doctor. We also optionally collect some additional survey data. We refer to this contact information as Booking Data and responses to the additional questions as Survey Data. We remain data controllers of the Data and we will process that in the form of anonymised reports.

The information we collect about you
How we use your information
Who we share your information with
Your rights as a data subject
How long we keep your information
Security of your information
International transfers of information

A. The information we collect about you

We collect the following information about you:

Booking Data: The personal data that we collect is your name, email address and phone number. The personal data is collected for the purpose of providing it to a doctor in order to facilitate booking the T-Cell test. It is also collected so that Health Freedom Ireland can contact you if you consent to this. It will not be associated with the Survey data when we process it. We also use your email address to send you a copy of your responses. We do not save your login details (if you are logged into the website) or your IP address into our database.

Survey Data: we collect your survey responses for example:

Health data – whether you have had COVID19, or been given a vaccination.
Your location
Your age range

Cookies: the online booking form and survey uses a minimal amount of cookies. Predominantly it is used for functions like captcha/recaptcha, action after submission and is not used to store user data or responses to the survey. Our tracking service - Google Analytics - does set some cookies relating to your interaction with the website. Please see section 12 for more details on this. This is not linked to your survey responses.

B. How we use your information

We use the information that we hold about you in the following ways:

Booking Data: We will use this data to provide it to the doctors surgery in order to book your T-Cell Test. The doctors office will contact you to arrange a time/date to carry out the test.

Survey Data: We will use the Survey to create reports on whether people that have received a vaccine had tested for COVID-19 prior to that or afterwards and whether the results were different using the PRC test (if this was done) and the T-Cell test (if you consent to us contacting you about the result). We may create other reports that may be of interest from the Survey Data. We may post these on our websites or on social media or other channels/platforms. However, these will never include personal data such as your name, email address or phone number. We only use your Survey Data for our own purposes if required to do so by law, and/or if you consent to us doing so.

C. Who we share your information with

Questionnaire Data: The data is treated anonymously.

We will share your Booking Data with the Health Practitioner that will carry out the T-Cell Test for the purpose of booking the test. Unless we are required to do so by law, we will not disclose your Participant Data to any other third parties unless you give us consent. For example if you contact us after filling out the survey for help or support and we send the details to a third party, with your permission, that may be able to help.

D. Your rights as a data subject

Right to Access: At any point, you can request copies of Booking Data you entered into our system. Our response will be given free of charge. Contact us at info@healthfreedomireland.com and we will, having verified your identity, send you a CSV file of available data, providing it does not impact on other participants' rights to anonymity.

Right to Rectification: If at any time we have Booking Data incorrectly entered you have the absolute right to request that we amend it. With regards to Survey Data your opportunity to rectify it is limited as the survey form functionality does not support editing replies once the survey has been submitted. However, we will assist where possible, if you email us at info@healthfreedomireland.com.

Our specific business IP
Compromise someone's right to anonymity (offered by our service)

E. How long we keep your information

Booking Data: As a standard we hold data for 5 years. We hold the survey data (which does not contain any personal data) indefinitely.

F. Security of your information

G. International transfers of information

certain safeguards are in place to ensure a similar degree of security for your personal data.

15. CHANGES TO OUR PRIVACY POLICY

We may change this privacy policy from time to time. We will ensure our most up to date copy is available to you.

Last updated 03 May 2021