Privacy & Cookie Policy

  • Home
  • Privacy & Cookie Policy

Privacy & Cookie Policy

Updated 05/06/2024

 

This privacy notice explains how we, ExpandNow Limited, (Expand Now) collect, use, and manage your personal data within the Expand Now organisation and for what purposes. Where we refer to “personal data” in this privacy notice, this means data which relates to you as an individual and which personally identifies you either directly or indirectly.

Please read this privacy notice carefully and as this Privacy Notice may change and evolve in the future, we recommend you check back periodically to see if we have made any changes.

Data Processing

There are different definitions of the types of processor of your personal data which are highlighted below for clarification: –

  • A data processor is an organisation that processes personal data on behalf of another company that is the data controller.
  • A data controller is an organisation that collects, uses, and manages personal data and has responsibility for determining how the personal data is collected, used, and managed.
  • A data protection officer is the person in an organisation who has responsibility for monitoring compliance with data protection law and for ensuring that personal data is protected within an organisation.

Expand Now uses information gathered from you when you use our website, contact us directly, or sign up to our marketing lists and as such is a Data Controller in these circumstances as it is determining how the data is being processed. Expand Now also acts as the Data Processor in circumstances where it is legitimately processing data on behalf of another business or company to provide goods or services on their behalf.

ExpandNow Limited is registered in Ireland under company number 747757 with its registered office at 4th Floor, Carlton House, Henry Street, Limerick, V94 FD80, Ireland and its website being www.expandnow.com.

How Do We Use Your Personal Data

We collect personal data when you visit our website and request information by submitting a form on one of our webpages or when you make contact directly via the website, telephone, email, or post directly.

Typically, this information consists of the following, but is not limited to: –

  • Name
  • Address
  • Email Address
  • Business Name
  • Telephone Number
  • Reason for the contact or other relevant information pertaining to the enquiry.

This personal information is used in the following ways: 

  • To allow contact following an enquiry for further information or services and to then support the delivery of any subsequent services.
  • For marketing purposes to allow us to send you promotions or information on additional services that we may provide. This may also include levels of profiling or to create specific audiences to ensure we market to you about relevant products and services.
  • For research and statistical purposes. This includes collecting data about how you use the Site including the content you look at and the monitoring and analysis of your engagement with us. This information is used to identify patterns which we can use in our marketing to help us improve our services and promote Expand Now and to allow Expand Now to develop, manage and administer its relationship with its business contacts and customers.
  • To comply with any legal or regulatory obligations which our business is subject to.

By using the Expand Now website www.expandnow.com and accessing any services we offer through the website you are agreeing to be bound by this Privacy Notice in respect of the information collected about you via this Site.

We will also collect personal data when you voluntarily submit information to the Company directly, or via a third party, by way of a job application and/or their submission of a curriculum vitae. Typically, in this instance the mandatory information captured is name, address, email address, telephone number, date of birth with the right to work/visa status also captured further into the recruitment process. All personally identifiable information captured will only be held for as long as it is legitimately required for the purpose of the recruitment assessment, after which point it will then be deleted. The information captured during this process will not be used by the Company for any other purpose, albeit it may be shared with third parties such as recruitment agencies, or HR consultants, who are assisting with the recruitment assessment process.

We may also obtain, collect, and process your Personal Data to provide services directly to yourself as a Data Controller or on behalf of a Third Party, where we are acting as the Data Processor. In this instance we will only capture the information required to process the transaction or provide the goods or services. Typically, the information captured or provided at this point is your full name, contact details, full address, and payment details (if required). We may also verify your age to prevent any unlawful purchases of age restricted products or services.

Why We Need Your Personal Data

We need to process your personal data for a number of varied reasons, and these are our legal bases for processing. We also need to keep your personal data for as long as is necessary for us to operate our business and to comply with legal and regulatory obligations.
We rely on one or more of the following legal bases for processing personal data:

  • To perform our contract with you or to enter into a contract with you
    We need to process your personal data to fulfil our contract with you or to assess whether to enter into a contract with you, whether this is providing goods or services or responding to queries or enquiries.
  • To fulfil our legitimate interests or the legitimate interests of a third party
    When we process personal data to fulfil our legitimate interests, we will use it in a way in which you would reasonably expect, and which will have a minimal privacy impact. When we or third parties are relying on legitimate interests to process your data, we will balance our interests against your interests and the privacy impact of the processing on you and we will process your personal data responsibly.
    Examples of our legitimate interests are direct marketing, fraud prevention, preventing and investigating crime, IT security and development by us and third parties of new products and services.
  • To comply with legal obligations to which our business is subject.
    We have to comply with relevant law and regulations in order to provide goods and services and we will need to process your personal data in order to comply with these legal obligations.
  • Consent
    If we are relying on your consent as our legal basis to process your personal data, you have the right to withdraw consent at any time.

Where we are relying on your consent as our legal basis for processing your personal data, you have a right to withdraw this consent at any time. (please see the section below on “Your Rights” for further information)

We take reasonable risk-based measures to protect the data provided via our services which may include pseudonymising or anonymising the personal data. If personal data is pseudonymised, this means it is de-identified so you are no longer identifiable, but we can re-identify you if we have a requirement to do so. If personal data is anonymised, it is de-identified, but can never be re-identified in the future.

However, no internet or email transmission is ever fully secure or error free. Therefore, you should take particular care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to us via the internet.

Who We Transfer Personal Data To

Transferring personal data to other organisations needs to take place with appropriate safeguards and you can be assured that we will only share the personal data that is needed for these organisations to be able to provide the right service or support us in doing so.
We may transfer your personal data to the following third parties:

  • Other companies within The Brave Capital Group of Companies – for support or the provision of other products or services.
  • Product service providers – our partners who provide financial products and services including payment facilities.
  • Research service providers – our partners who collaborate with us to provide research and data analysis services.
  • Marketing service providers – our partners who collaborate with us to send you information about products, services, and exclusive offers that we or they believe are of interest to you.
  • Regulators and other governmental agencies or law enforcement agencies.

We will only transfer your personal data to third parties who adhere to appropriate data security standards and controls. This may include transferring your personal data to third parties who become joint controllers of the data such as payment processors or delivery companies. For more information about third parties with whom we have joint controller status, please contact us at DPO@expandnow.com

Cookies and tracking

Like many websites, we use “cookies” to enable us to personalise your visits to this website, keep track of your preferences and to track the usage of this website. Cookies are small pieces of information that are stored on your computer by your browser. Your browser will have the option to prevent websites using cookies (your browser’s help screen or manual will tell you how to do this), but please note that this may reduce the functionality of this Site and other websites. 

Like all websites, our servers automatically record ‘log files’ containing information about the volume and characteristics of our website traffic e.g. numbers of pages viewed, length of time spent on site. We use log files to build pictures of how our site is used that help us to monitor and improve the service we provide.

Who has access to the information?

The appropriate employees at Expand Now, and where legitimately required relevant partners, suppliers and other companies in the Brave Capital Group of Companies have access to the information, including personal information that we have collected from you.

If our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners. We will not otherwise disclose, sell, or distribute your information to any third party without your permission unless we are required to do so by law.

How long is my data held?

We store Personal Data only for as long as it is necessary for the fulfilment of the purpose for which the Personal Data was collected, unless otherwise required or authorised by applicable law or a regulatory requirement. We take measures to destroy or permanently de-identify personal information if required by law or if the Personal Data is no longer required for the purpose for which we collected it.

How do I change my permissions?

You have certain rights in respect of your personal data, and we have processes to enable you to exercise these rights.

Right of Access

This is known as a Subject Access Request. If you would like to know if we are processing personal data relating to you and you would like to have access to any such personal data, then please email DPO@expandnow.com.

Right to Rectification

If you believe that we hold inaccurate personal data about you, then you can request that we carry out a review and rectify any incomplete or inaccurate personal data we hold about you by contacting our Data Protection Officer at DPO@expandnow.com. Depending on the type of personal data you believe is inaccurate, we may ask you for further proof to ensure that the personal data is being corrected properly. If we are satisfied that the personal data is inaccurate, we will make the necessary changes.

Right to Erasure

You have a right to ask for your personal data to be erased. However, we are not required to erase your data where we need your personal data to comply with a legal obligation or for the establishment, exercise, or defence of legal claims. If you do wish for your personal data to be deleted, please contact our Data Protection Officer at DPO@expandnow.com. Please note that if you opt out of marketing communications or have previously opted out of marketing communications, we must keep a record, of such opt out to ensure that we do not contact you in the future.

Right to Restriction

You have a right to request that processing of personal data is restricted in certain circumstances. Where we restrict your data, we are permitted to store your data, but we cannot process in any other way apart from for the establishment, exercise, or defence of legal claims or with your consent. If this is required, please contact our Data Protection Officer at DPO@expandnow.com.

Right to Object

Where we are relying on legitimate interests as a legal basis to process your data, you have a right to object to such processing on grounds relating to your situation.
If you object to our use of your personal data for direct marketing purposes, or no longer wish to be a part of our community, please email DPO@expandnow.com and let us know. You may ask us to make changes and we will action these as promptly as possible. You can also unsubscribe from receiving emails from us by clicking on the “unsubscribe” link in our emails. Your details will be immediately removed, and we will not contact you again.
You may also object to other processing when we rely on our legitimate interests as the basis for processing, but we do not have to stop the processing if we can demonstrate compelling legitimate grounds for the processing (taking into account our processing activities, the nature of our business and our legitimate interests) and that these grounds override your interests, rights and freedoms or in the event that we need the personal data for the establishment, exercise or defence of legal claims. To enable us to consider any objection we will need to know what specific interests, rights or freedoms relating to your situation you believe will potentially be put at risk by our processing. If we do stop processing your personal data (apart from for direct marketing purposes), this may affect our ability to trade with you.

Automated Processing/Profiling

From time to time, we may use automated processing in relation to the information we hold about you to make recommendations of products and services we think you would be interested in and to improve your experience when you visit our website by making it relevant and tailored to you.
If you object to our use of your data for targeting through cookies, we will opt you out. You can do this by contacting the Data Protection Officer at DPO@expandnow.com.

Right to Portability

In certain circumstances, you can request that we provide to you your personal data in a commonly used format. If you wish to make such a request, you can contact the Data Protection Officer at DPO@expandnow.com.

Right to Complain to the Regulator

Dependent on which country you reside you have the right to lodge a complaint with the Regulator in that Country e.g. for Ireland this is the Data Protection Commission. Prior to lodging a compliant to the Regulator please contact the Data Protection Officer at DPO@expandnow.com or write to us for more information to the Expand Now Data Protection Officer, 4th Floor, Carlton House, Henry Street, Limerick, V94 FD80, Ireland. All complaints are taken seriously and will be investigated thoroughly and through to resolution.

Changes to our Privacy Notice

Our services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Notice. We reserve the right to update or modify this Privacy Notice at any time and from time to time without prior notice. Please review this notice periodically, and especially before you provide any Personal Data. This Privacy Notice was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Notice shall indicate your agreement with the terms of such revised Privacy Notice.

More Information

If you do have queries about how we use your information or on data protection generally, then please email DPO@expandnow.com or write to us for more information to the Expand Now Data Protection Officer, 4th Floor, Carlton House, Henry Street, Limerick, V94 FD80, Ireland.