1. Introduction

This privacy notice provides you with details of how we collect and process your personal data you may provide through our site when you purchase a product or service, or register or re-register for our various hallmarks, or by using our website, www.assay.ie.

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

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

The Data Protection Officer is David Brady, Assay Master & CEO, Company of Goldsmiths of Dublin, Assay Office.

Contact Details

Our full details are:

Full name of legal entity: Company of Goldsmiths of Dublin, Assay Office
Email address: hallmark@assay.ie
Postal address: Dublin Castle, Dublin 2, D02 X766, Ireland
Telephone number: +353 1 475 1286

If you are not satisfied with any aspect of how we collect and use your data, you have the right to complain to the Data Protection Commission, Ireland’s supervisory authority for data protection issues (www.dataprotection.ie. 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.

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 hallmark@assay.ie.

2. What Data Do We Collect

Listed below is the information we keep on our records:

• Company, business or personal, name
• Company, business or personal, address (including branch address)
• Company, business and or personal, contacts (management/ accounts/ operations etc.)
• Telephone numbers including mobile numbers, as supplied by you
• Addresses for email contact as supplied by you
• Declaration and identification documentation that accompany the application for registration of a sponsors or makers mark
• Registration number, makers mark allocated and copy of registration
• VAT Number where supplied
• Bank Account details where supplied
• Copy assay dockets in respect of articles submitted for assay and hallmarking

Information about your company/ business is backed up and stored for security and loss prevention purposes and we are the only party with access to the data.

Where you have registered for a sponsors’ mark, we use your data to facilitate maintaining the register of sponsors’ marks in accordance with our obligations under Section 9 (3) of the Hallmarking Act 1981. Further, we use data relating to your company/ business to facilitate the provision of the statutory service of assay and hallmarking and associated ancillary services to you and your company/ business and for general correspondence with you and your staff on a regular basis.

Company/ business/ personal information is only provided to our staff to facilitate the provision of our statutory service of assay and hallmarking and associated ancillary services required in respect of articles submitted by you and information is never passed on or sold to any third party, other than identified in paragraph below.

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, for example, during the markers mark registration process, we may not be able to perform the contract (for example, to deliver goods or services to you). If you do not 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.

3. How We Collect Your Personal Data

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• Order our products or services;
• Register or re-register to have hallmarks created by DAO;
• Create an account on our site;
• Subscribe to our service or publications;
• Request resources or marketing be sent to you;
• Enter a competition, prize draw, promotion or survey; or
• Give us feedback.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. As noted on our website, we may collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources.

4. How We UseYour Personal Data

We will only use your personal data when legally permitted. The most common uses of your personal data are:

• Where we need to perform the contract between us
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal or regulatory obligation

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at hallmark@assay.ie.

Purposes for Processing Your Personal Data

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at hallmark@assay.ie if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing Communications

You will receive marketing communications from us if you have:

1. Requested information from us or purchased goods or services from us; or
2. If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
3. In each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at hallmark@assay.ie at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at hallmark@assay.ie.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

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

5. Disclosures of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Revenue & Customs, regulators and other authorities based in Ireland and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
• Email Service Providers such as Microsoft and MailChimp
• 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

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, 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; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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.

Please email us at hallmark@assay.ie if you require further information. Our overriding general policy is not to transfer data outside the EEA.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

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

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.

To determine the appropriate retention period for personal/ company data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from fraudulent or unauthorised use, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

Company of Goldsmiths of Dublin

Goldsmiths Hall
Assay Office
Dublin Castle
Dublin 2
Ireland