Privacy Policy
This Data Protection Notice (“Notice”) sets out how Tirlán Co-Operative Society Limited (the “Society”) or its subsidiaries (including Tirlán Limited and its subsidiaries) (“Tirlán”, “we”, “us”), use personal information collected about you in the context of www.tirlan.com and your dealings with us.
Tirlán may amend its Notice from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes made by Tirlán. This Notice was last updated on 02 April 2023.
If you are a member or shareholder in the Society or engage in trading activity with the Society or its subsidiaries (including Tirlán Limited and its subsidiaries), the following Notice will govern how we use and disclose your personal data. This Notice will also outline how Tirlán uses the personal data collected on our websites including www.tirlaningredients.com, www.tirlanfarmlife.com, www.countrylife.ie, www.avonmore.ie and www.trulygrassfed.com (the “Tirlán Websites”).
For the purposes of this Notice, Tirlán is the controller of your personal data, and you can direct questions about this Notice to:
Full name of legal entity: Tirlán Limited
Email address: dataprotection@tirlan.ie
Post address: Data Protection, Tirlán Limited, Abbey Quarter, Kilkenny, R95 DXR1, Ireland
Telephone number: +353 56 779 6300
Tirlán is committed to ensuring that your rights under data privacy laws are protected and your personal data are kept secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect and process in accordance with data privacy laws. The purpose of this Notice is to tell you more about what we do with your personal data in the context of your engagement with us.
- DATA WE COLLECT
Tirlán may collect or generate the following categories of personal data about you:
- Identity data including first name, middle name(s), surname.
- Identity verification data including date of birth, PPS number and, in certain cases, certified copies of proof of identity such as passport or utility bills.
- Contact details including address, telephone number and e-mail address.
- Financial information such as your bank account details to facilitate payments to you by Tirlán, your card details to facilitate payments from you to Tirlán and, where applicable, other financial information such as your credit limit, Society dividend and shareholding.
- Details of your supplier or customer/trading account including supplier number, customer/trading number, herd number and other personal data related to your milk supply or customer/trading account.
- Details of your compliance with your milk supply agreement, Tirlán’s milk purchasing policies and applicable health and safety legislation.
- Details about you needed to participate in various Tirlán schemes such as the Reserve Pool Scheme and Voluntary Peak Supply Reduction Scheme.
- Technical data that we may collect about your device when you access Tirlán Websites. This may include your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform.
- Competition or promotion data when you enter into a competition or promotion run by Tirlán.
We may also receive personal data about you (for example, about your herd, sustainability of your farm and/or compliance with legislation) from third party sources such as:
- State and semi-state authorities such as Bord Bia, Teagasc and the Department of Agriculture, Food and the Marine.
- Industry stakeholders such as the Irish Cattle Breeding Federation (ICBF).
- Other entities connected to your milk supply such as Corporate Members of Tirlán Co-operative Society Members if applicable.
- WHAT WE DO WITH THE INFORMATION WE COLLECT
We use this information to provide you with a comprehensive service as a Society member, supplier and / or individual trading with Tirlán and to ensure that our services are managed in the most efficient manner for you. We use your personal data for a number of purposes including:
- for internal record keeping purposes to support purchases and the delivery of services outlined.
- to carry out our obligations arising as a result of your interest in Tirlán including:
- milk supplier agreements.
- grain supplier agreements.
- customer sales and account management; and
- shareholder / member data management and maintenance.
- to notify you about changes and updates to our products or services or other relevant information.
- to contact you by electronic means (e-mail or SMS) with information which will be of interest to you as a member of the Society, supplier or individual trading with Tirlán.
- to use the information provided through our online channels to customise Tirlán Websites according to your interests.
We primarily process your personal data based on our legitimate interests but, in certain instances, we may process your personal data based on another legal basis where it is more appropriate to do so. Our legal basis for processing your personal data include:
- legitimate interest: we primarily process your personal data pursuant to our legitimate business interests, including, but not limited to internal record keeping purposes to support and maintain your supplier, customer or trading relationship with Tirlán. You have a right to object at any time to the processing of your personal data on this ground and details on how to exercise your right to object are contained in section 7 of this Notice. When we process your personal data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
- entering into or performance of a contract: it may be necessary for us to process your personal data in order to enter into and perform our contract with you. For example, where you enter into a milk supply, grain supplier or other agreement with Tirlán. If you do not provide your personal data for these purposes, we will not be able to perform our contract with you.
- compliance with a legal obligation: it may be necessary for us to process your personal data in order to comply with legal obligations to which we are subject to under Irish and EU law.
- legal claims: it may be necessary for us to process your personal data to establish, investigate, exercise, or defend a legal claim.
In certain limited circumstances, we may process your personal data based on your freely given consent. For example, when we send you promotional or direct marketing material, we do so on the basis of your consent. You can withdraw your processing consent at any time by contacting us on the details set out in section 7 of this Notice. In the case of direct marketing, we will ask you in each marketing communication whether you want to “unsubscribe” or “opt-out”. Please note that any processing carried out before you withdraw your consent will remain valid.
- RETENTION OF YOUR DATA
Tirlán will retain your data for the duration required to fulfil the purposes outlined in this Notice, to meet any legal and regulatory requirements and for shareholder / member maintenance. We also retain your data to maintain a trading history for reporting and member benefits for a period not less than 7 years beyond your association with Tirlán.
- CHANGE OF PROCESSING PURPOSES
We will only use your personal data for the purposes for which we collected it, a legal or regulatory requirement or legitimate interest to use it for another reason that is compatible with the original purpose. Where we need to use your personal data for unrelated purposes, we will notify you and explain the legal basis that allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- SHARING AND DISCLOSURE OF DATA
We may disclose some or all of your personal data to the following parties:
- Computershare: We may from time to time disclose your personal data to enable shares in Glanbia plc to be issued to you in exchange for a portion of your Society shares where Society members approve a “spin out” of shares in Glanbia plc in exchange for Society shares.
- Revenue Commissioners: As required by any legal or statutory obligations. Subject to your specific approval and the provision of your PPS details, we may disclose details of your transactions in Society shares in order to pay the relevant stamp duties on your behalf.
- Regulatory / government agencies such as Bord Bia and Department of Agriculture, Food and the Marine involved in the governance of dairy, agriculture and consumer food chain services.
- External testing laboratories directly sub-contracted by Tirlán, including Teagasc, as an extension of in-house laboratory services and to fulfil legal obligations
- Industry stakeholders such as the Irish Cattle Breeding Federation (ICBF).
- Other entities connected to your milk supply such as Corporate Members of Tirlán Co-operative Society Members if applicable.
- Professional advisers including lawyers, bankers, financial service providers, auditors and insurers who provide banking, financial, legal, insurance, consultancy and accounting services to us.
- IT and technical service providers that provide IT and technical services to Tirlán.
- Service providers such as payment service providers, mail delivery and marketing service providers.
- Third parties, to whom we may choose to sell, transfer or merge parts of our business or our assets.
- TRANSFERS OF YOUR DATA
We may transfer your personal data outside the European Economic Area (“EEA“). Certain recipients, for example, some of our third-party service providers, may process your personal data outside the EEA to a country that does not provide an adequate level of protection for your personal data. Where such transfers occur, it is our policy to put in place an appropriate transfer agreement such as the European Commission’s standard contractual clauses. If you would like to find out more about any such transfers, please contact us on the details set out in section 7 of this Notice.
- CONTROLLING YOUR PERSONAL INFORMATION
You have a number of rights in relation to your personal data, which are set out below. Please note that in certain circumstances these rights may not be absolute. You have the:
- right of access: you are entitled to receive a copy of your personal data which we hold. We will only charge you for such a request where we feel your request is manifestly unfounded or excessive.
- right to rectification: you can request that we amend any inaccurate personal data that we have about you.
- right to erasure: you can request us to erase the personal data we hold about you in certain circumstances.
- right to restriction of processing: you can request that we restrict our processing of your personal data in certain circumstances.
- right to data portability: you can request your personal data be provided to you in a structured, commonly used, and machine-readable format and have your personal data transmitted to another controller in certain circumstances where it is technically feasible.
- right to object: you can object at any time where we process your personal data on the legal basis of our legitimate interests or where we process your personal data for direct marketing purposes. Please note Tirlán does not engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
If you would like to exercise any of these rights or have any questions or concerns about how we use your personal information, please contact us at the above contact details.
We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this up to 2 months if necessary; however, we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights. You also have the right to lodge a complaint with the Data Protection Commission. For further information, see www.dataprotection.ie.
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