Our Privacy Policy

True SEO commitment to data privacy

At True SEO we take your privacy very seriously and we are committed to protecting your privacy. At True SEO we are fully committed to maintaining the privacy of any information that you provide to us. We commit to ensuring that such data is held securely, used appropriately and only retained for as long as is necessary.

At True SEO we aspire to comply to the fullest extent possible with applicable data protection regulations. At True SEO we comply with our obligations under the new European Union’s General Data Protection Regulation (GDPR).

What information True SEO collects and process about you

We may collect and process the following data about you:

• Personal Data

Personal Data, as defined under the European Union Directive 95/46/EC, means any information relating to an identified or identifiable natural person (Data subject). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

• Non – Personal Data

Non-Personal Data comprises information such as demographic information regarding, for example, user IP addresses, browser types and other anonymous statistical data involving the use of our website. This information cannot be used to identify or contact you. This information will be used for statistical purposes only.

How True SEO collects your data

When you visit our websites, get in contact with the business or use our services, we collect and process information about you. We use different methods to collect data about you including through:

• Information that you provide to us directly:

Some data are collected when you provide it to us. When you visit and use our websites and our services, we might ask you to provide personal data to us. You may give us information about you by completing enquiry forms or general contact form on our website, when you sign up to our newsletter on the website or by corresponding with us by phone, email or otherwise. The information you give us may include your name, address / location, email address and phone number. You are not required to provide us with personal information however this may prevent us from providing our products and services to you.

• Information that we collect automatically:

We collect some information about you automatically when you visit our websites or use our services. We may collect the following information from you when you visit our website:

• information about your visit, how you use our website or our services the full URL (Uniform Resource Locators), pages you visit, length of visits to certain pages, page response times, services you viewed or searched for, how frequently you visit the website, website errors, where you were referred from to reach our website, page interaction information, clickstream to, through and from the Site (including date and time).
• technical information: the IP (Internet protocol) address used to connect your computer to the internet, time zone setting, browser type and version, browser plug in types and versions, operating system and platform.

Some of this information is collected using cookies, web beacons and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please read our Cookie Policy.

How long will True SEO keep your data

The General Data Protection Regulation (GDPR) states that personal data must be kept no longer than is necessary for the purposes for which the personal data are processed. The GDPR states that personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes.

We only hold on your personal data for as long as we actually need it for the purposes, we acquired it for in the first place. The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested, or to comply with applicable legal, tax or accounting requirements). In most cases, this means we will keep your information for as long as we have a relationship with you or as you continue to use our services, and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our internal data retention policies and practices. After that period, we will delete it other than where we lawfully can keep any data for audit or legal reasons.

How True SEO will use the data about you

Purposes for which we will use Personal data

We will only use your personal data for any lawful purpose in accordance with GDPR legislation. All personal data will be processed fairly and in keeping with the purposes for which it was obtained.

If you choose not to provide us with your personal information, we may not be able to provide the information or the service you may require, or to fulfil one or more other purposes of collection of your personal information. You can browse our website without submitting any personal information about yourself, but if we don’t collect your personal data, some functions and features on our websites may not be available to you.

We will only process your personal information where we have a lawful purpose to do so. Under GDPR, our main grounds for processing your personal information are the following:

1. Legitimate interest

Under GPDR regulation there is a concept of “legitimate interests” as a justification for processing your personal information.  We will need to process your personal information for the purposes of our legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal information protected. We have also identified what our legitimate interests are where appropriate.

We may collect, use and process some of your personal information, where we have sensible and legitimate business grounds for doing so, which include some or all of the following:

1. to communicate with you about our service
2. to make information available regarding products and services offered by True SEO
3. to enable you to access and use our website and other digital tools we may provide as part of our service
4. to protect our website, to enhance the security of our network and information systems, so that we can detect and prevent any malicious activity, and make sure that everyone is using our websites and services fairly
5. to enable us to enhance, modify, personalise or otherwise improve the website, our services and communications for the benefit of you
6. better understand how our website is performing and how you interact with our website
7. to determine the effectiveness of promotional campaigns and advertising
8. to administer our website and carry out data analysis, troubleshooting and testing
9. to provide statistics to third parties for the purposes of improving and developing the website and the services, but these statistics will not include information that can be used to identify you

2. Contract

We require your personal data for fulfilment our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested.

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 the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may be unable to fulfil the contract without your personal data and we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

3. Consent

Where necessary we will only collect and process your personal information if you have consented for us to do so. If we are unable to rely on legitimate interests or any other ground set out in the GDPR to process your personal data, we will obtain consent from you to the processing.

Where we require consent, we will explain why, and provide sufficient information to allow you to make an informed decision. When we receive consent to perform such activities, that consent may be withdrawn at any time by contacting us.

4. Compliance with a legal obligation

We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your Information to a regulatory body or law enforcement agency (see “Disclosure of data to third parties” for more information).

We also use your personal data for other lawful purposes, which may include the following:

1. to communicate with you
2. to maintain relationships with you
3. to notify you of changes and updates to our services and products
4. to understand your requirements and avoid conflicts of interest
5. to notify you of products and services we offer that are similar to those you have purchased or enquired about
6. to send you newsletters and marketing information if you have consented to us doing so
7. to support you, which may include assisting with the resolution of technical support issues or other issues relating to the websites or services we provide, whether by email, phone or otherwise.
8. to fulfil our obligations under any contract we have entered into with you and to provide you with information, products and services you have requested
9. to produce aggregated and anonymised analytics and reports, which we may share with third parties.
10. to detect and protect against fraud and criminal activity
11. to meet legal and regulatory requirements
12. to enforce this Privacy Policy and the Terms & Conditions
13. to maintain up to date database of clients, which enable us to communicate with you more easily and to perform the services requested by you more efficiently
14. for any other purpose described in this Privacy Policy or that we describe to you at the time of collection

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purposes for which we will use Non-personal Data

When you visit our website, we gather statistical and other analytical information on an aggregate basis of all visitors to our website. This Non-Personal Data (non-identifying information) comprises information that cannot be used to identify or contact you. We use the Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where visitors were referred from to reach our website, how visitors interact with our website and to help us better design and organise our website.

We may use non-personally identifiable information and aggregate information for any lawful purpose, including, but not limited to:

1. continually improve and develop our website, our services and our business
2. better understand how our website is performing and how you interact with our website
3. for technical analysis of our websites and services so that we can optimise your user experience and provide you with more efficient tools
4. monitor our website usage
5. determine the effectiveness of promotional campaigns and advertising
6. protect our website, enhance the security of our network and information systems, so that we can detect and prevent any malicious activity, and make sure that everyone is using our websites and services fairly
7. for analysis purposes
8. enhance our websites and services and develop new ones by tracking and monitoring your use of our websites and our services
9. provide general statistics regarding use of our website
10. provide statistics to third parties for the purposes of improving and developing the website and the services, but these statistics will not include information that can be used to identify you

Your legal rights in respect of your personal data

In the situation where you have directly provided personal information to us and in the situation where we collect personal data automatically, you have a number of rights regarding the personal data that we hold.

You have rights under GDPR in relation to your personal data as follows:

1. Right to be informed

You have the right to be informed about the collection and use of your personal data. You have the right to know what data is being collected, purposes for processing data, how it’s being used, how long it will be kept and whether it will be shared with any third parties. This is a key transparency requirement under the GDPR.

2. Right of access information

You have the right to access your personal data and to request a copy of the information that we may hold about you.

You have the right to obtain the following from us:

• confirmation that we are processing your personal data
• a copy of your personal data
• other supplementary information

We will process your request to access your information and we will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you. We will provide the information you request as soon as possible and in any event within one month of receiving your request. The one-month period may be extended by 2 further months, where necessary, taking into account the complexity and number of requests. We provide this information to you free of charge. However, if your request is manifestly unfounded or excessive or repetitive, we may charge a reasonable fee or refuse to act on your request. We may also charge if you request more than one copy of the same information.

The right to access your personal data cannot be used to access the personal data of other persons, i.e. third parties.

If you would like a copy of your personal information, please send an email to hello@trueseo.ie. Please quote your name, address and brief details of what information you want a copy of (this helps us to more readily locate your data).

3. Right to rectification

You have the right to have inaccurate personal data rectified and you have the right incomplete personal data completed.

We will process your request to make the necessary changes to the information we hold about you and we will take all reasonable steps to confirm your identity before we make the necessary changes to the information, we hold about you on our database.

We will comply with your request within one month of receiving it.  The one-month period may be extended by 2 further months, where necessary. We will let you know if we need more time to comply with your request. We provide this information to you free of charge. However, if your request is manifestly unfounded or excessive or repetitive, we may charge a reasonable fee or refuse to act on your request.

We want to ensure that your personal information is accurate, complete and up to date. If you wish to make any changes to your information, please email us at hello@trueseo.ie.

4. Right to erasure

You have the right to have your personal data erased, without undue delay. The right is not absolute and only applies in certain circumstances. This is also known as the right to be forgotten.  There are certain scenarios in which we are entitled to refuse to comply with a request. If any of those apply, we’ll let you know.

You have the right to ask us to delete personal data we hold about you, if one of the following grounds applies:

1. Where we have unlawfully processed your personal data (e. we have failed to comply with GDPR)
2. Where we have collected your personal data on the grounds of consent, and you withdraw that consent to the processing and there is no other lawful basis for processing the data.
3. Where your personal data are no longer necessary for the purpose for which we collected and processed it.
4. Where you object to the processing and we do not have any overriding legitimate grounds for continuing the processing (see below point g).
5. Where you object to the processing and your personal data are being processed for direct marketing purposes (see below point g).
6. Where your personal data have to be erased to comply with a legal obligation.
7. Where we have collected and processed your personal data in relation to the offer of information society services (e.g. social media) to a child.

We will process your request and we will take all reasonable steps to confirm your identity before we delete personal data, we hold about you on our database.

If you wish to delete personal data, we hold about you, please email us at hello@trueseo.ie.

5. Right to restrict processing

You have the right to restrict the processing of your personal data in certain circumstances. You have the right to restrict the processing of your personal data where you have a particular reason for wanting the restriction.

You have the right to obtain from the True SEO restriction of processing where one of the following applies:

1. You can request restriction of the processing of personal data is unlawful. ln these cases, if you do not want us to delete your information, you can request restriction of the personal data instead.
2. You can request the restriction of processing personal data, if you believe the personal data, we hold is not accurate. In these cases, the restriction applies until we have determined the accuracy of the data.
3. You can request the restriction of processing personal data, even where we no longer need the data, but you would like us to keep it because you need it to establish, exercise or defend a legal claim.
4. You can request the restriction of processing personal data, if you have objected to us processing the data. In these cases, the restriction applies until we have determined the outcome of your objection and until we have determined whether our legitimate interests override your objection.

We will process your request and we will take all reasonable steps to confirm your identity before we restrict the processing of your personal data. We will stop actively processing your personal data, but we do not have to delete it. Where the processing of your data is restricted, it can be stored by us, but most other processing actions, such as deletion, will require your permission.

If you wish to restrict the processing of your personal data, please email us at hello@trueseo.ie.

6. Right to data portability

In certain circumstances, you have the right to receive your personal data then you have provided to True SEO in a structured, commonly used and machine-readable format so that you are able to transmit this personal data to another data controller of your choosing without hindrance, in certain circumstances.

This right to data portability only applies:

1. where the processing of personal data is carried out by automated means
2. where the processing of personal data is based on your consent to the processing
3. where the processing of personal data is conducted on the basis of a contract (i.e. the right does not apply if we process your personal data on the grounds of legitimate interests)

We will process your request.  We will respond to your request as soon as possible and in any event within one month from the date of receiving your request. We will let you know if we need more time to comply with your request.

7. Right to object processing of personal data

You have the right to object to the processing of your personal data at any time. An objection may be in relation to all of the personal data we hold about you or only to certain information. It may also only relate to a particular purpose we are processing the data for. The objection must be justified.

You have the right to object us to the processing of your personal data in certain circumstances:

1. where the processing is for research purposes (unless the processing is necessary for the performance of a task carried out in the public interest)
2. where this processing is carried out in connection with tasks in the public interest, under the official authority or in the legitimate interests of others
3. where the processing relates to direct marketing (including profiling)

Where you have made a valid objection, we will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is for the establishment, exercise or defence of legal claims.

If you wish to object to the processing of your information, please email us at hello@trueseo.ie.

8. Rights in relation to automated decision making, including profiling

You have the right to not be subject to a decision based solely on the automated process, including profiling. You have the right to request a review of the processing if you believe the rules are not being followed.

Automated individual decision-making is a decision made by automated means without any human involvement. Automated individual decision-making does not have to involve profiling, although it often will do. Profiling is any kind of automated processing of personal data that involves analysing or predicting your behaviour, habits or interests.

Disclosure of data to third parties

True SEO do not distribute, share or sell your personal data with any other services or third parties for their own use.  True SEO do not share your information with third parties without your prior knowledge and consent, only if required and permitted to do so by law or in the good faith belief that such action is necessary.

True SEO may need to disclose your personal information:

1. if required or permitted to do so by law or in the good faith belief that such action is necessary:
2. to protect and defend the rights or property of True SEO
3. if it is requested by a court, government agency, law enforcement bodies regulators or other third parties where we think it’s necessary to comply with applicable laws or regulations
4. if it is requested by other regulatory body or organisation, to protect or enforce our legal rights or the rights of any client, or a third-party, or in the detection and prevention of fraud (including credit card or identity fraud) and other crimes
5. in the event that we undergo re-organisation, or we sell any or all of our business to a third party or we buy another business. In which case you agree that any personal information we hold about you may be transferred to that re-organised entity or third party for the purposes and subject to the terms of this Privacy Policy.

We may share your information with relevant third parties so that they can provide services to us. To ensure we provide you with a better experience and to continue to improve our services, we may share your information with third parties who we need to engage with to enable us to perform our services to you.

True SEO may share your information with selected third including:

• our web hosting technology supplier Blacknight Solutions, who provide the physical server infrastructures that our website operates on
• defiant Inc, the providers of the Wordfence™ security software that protects our website. Only limited, technical data (such as device IP address, browser type/version, language etc) are transmitted
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you and where there are adequate technical, organisational and legal safeguards in place, along with appropriate legal bases to protect this sharing of data
• third party service providers and partners who assist and enable us to use the personal data to (for example, support delivery of or provide functionality on the website, services, or to market or promote our goods and services to you)
• trusted partners to help us perform statistical analysis that assists us in the improvement and optimisation of our website
• employees of True SEO
• other people where we have your consent