European Sales & Marketing Association is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are accountable with the GDPR in relation to not only processing your data but ensuring you understand your rights as a client.
It is the intention of this privacy statement to explain to you the information practices of ESMA in relation to the information we collect about you.
For the purposes of the GDPR the data controller is:
W91 Y066, Co.Kildare,
Please read this Statement carefully as this sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
Who are we?
- The European Sales and Marketing Association (ESMA) was formed in 1976.
- Over the past 40 years, we have become Europe’s most prominent distributor organization for consumer goods.
- As a non-profit run by members on behalf of members, we stimulate the exchange of ideas, build connections, and leverage our contacts to drive export sales.
- A large part of our success has been through the collaboration of our international network.
- We aim to increase the scope of our enterprise, and continually work towards the improvement of resources and knowledge available to members.
Our GDPR Owner and data protection representatives can be contacted directly here:
Purpose for processing your data
As set out in our Terms of Business the data which you provide to us will be held on a computer database and paper files for the purpose of arranging transactions on your behalf and in order to provide the highest standard of service to you. The data will be processed only in ways compatible with the purposes for which it was given. We may need to collect sensitive personal information relating to you or anyone to be named on your policy or residing in your household to process your application. It is your responsibility to ensure that you have obtained the permission of that person to allow us to process their sensitive personal data as part of your application and to explain our Data Protection policy to them.
We may use your information for the purpose of complying with regulatory or legislative requirements, offering renewals, for research/statistical analysis and crime prevention. There may also be requirements to contact you by Email, Post, Phone, SMS Text for the purposes of discussing terms of an existing policy with us or any other query directly relating to an existing policy with us. When you request a quote from us, you may receive a phone call or text message and/or email in relation to that quote.
Why we are processing your data? Our legal basis.
In order for us to provide you with the service and the insurance products that you require, ESMA need to collect your personal data.
Our reason (lawful reason) for processing your data under the GDPR is:
- Legal basis – ESMA needs to process your data as this is necessary in relation to a contract of insurance to which the individual has entered into or because the individual has asked for something to be done so they can enter into a contract.
In any event ESMA are committed to ensuring that the information we collect and use is appropriate for this purpose and does not constitute an invasion of your privacy.
How will ESMA use the personal data it collects about me?
ESMA will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary.
What is a cookie?
A cookie is a small file which is placed on your computer, just like an image or a web page file. The difference with a cookie is that it contains information which allows a website to identify you as you click from one page to the next, or when you return to the website. It can also be used to allow personalisation of a website.
The cookies used and the information held within them have no personal information and cannot be used to identify you as a person. For this reason, we consider our cookies to be completely non-intrusive.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website and could prevent you from completing some purchases through our site.
We may partner with or receive services from third parties which you can visit from our website. We may also embed external content and features from such third parties within our website. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
The cookies we use do not contain any sensitive information such as your name, address or any payment details. Sensitive information which you choose to provide to us as part of the quotation process is stored securely and is not collected in the form of a cookie. Only information which is relevant to your visit to our website is stored in the form of a cookie, for example if you have visited our site previously.
We use Google Analytics cookie (_ga _gid gwcc) to help us understand how our customers interact with our website and we use this information to continue to improve the user friendliness of our website.
Types of Cookies
Necessary cookies: These are used to manage your website visit, they provide features such as encryption for data and user login plus e-commerce shopping cart choices.
Analytical cookies: These cookies track user statistical visit data such as country, browser type and pages visited.
Targeting cookies: These cookies remember which features or Ads you were presented with and can display the same or related content to provide you with a content that may be of more interest to you.
Functionality cookies: These cookies allow your browser to operate more effectively i.e. your language choice or menu preferences. They can also be used to provide services you request, such as viewing videos or social media integration.
Disabling cookies if you wish to All browsers have the ability to restrict or completely disallow cookies.
You may find your internet experience is disrupted if you do this, but it is entirely within your control. If you wish to change your cookie settings, the following website provides useful information: www.aboutcookies.org
This cookie is essential to the functionality of our website and is used to enable site search.
This cookie expires at the end of a session e.g. when the web browser is closed and no personal data is stored.
Google Analytics (_utma, _utmb, _utmc, _utmz)
Google Analytics cookies are used in order to collect information about how visitors use our website. All data collected via this cookie is anonymous and non user specific.
Information includes the number of visitors to the site, where the visitors have come from and which pages they have viewed.
This information is important as it helps us to improve the performance of our website and monitor our visitor levels.
The _utma and _utmb cookies expire after a maximum period of 2 years, unless cookies are cleared before this date.
The _utmc cookie is no longer set and the _utmz cookie expires after 6 months, or less if cookies are cleared prior to this date.
Special Categories of personal data
If we collect any special categories of personal data (e.g. health, religious beliefs, racial, ethnic origin – financial information is not classified as special categories of personal data) – we will ensure the below
- we will obtain your explicit consent
Who are we sharing your data with?
We may pass your personal data on to third-party service providers contracted to ESMA in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide on your behalf. When they no longer need your data to fulfil this service, they will dispose of the details in line with ESMA procedures.
If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your explicit consent, unless we are legally required to do otherwise.
The third parties that we pass your personal data to are:
- Insurers & Product Providers with who we hold a letter of appointment
- Third-party service providers contracted to ESMA
- Insurance industry databases for fraud prevention purposes.
- Regulatory or legislative bodies
We have issued all our third-party processors with a Data Processor checklist asking them GDPR specific questions
If we transfer personal data to a third party or outside the EU we as the data controller will ensure the recipient (processor or another controller) has provided the appropriate safeguards and on condition that enforceable data subject rights and effective legal remedies for you, the data subject, are available.
Data Subjects Rights:
ESMA facilitate you, our clients, rights in line with our data protection policy and the subject access request procedure. This is available on request.
- Right of access – you have the right to request a copy of the information that we hold about you.
- Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
- Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to certain types of processing such as direct marketing.
- Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
- Right to judicial review: in the event that ESMA refuses your request under rights of access, we will provide you with a reason as to why.
All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.
Retention of your personal data
Data will not be held for longer than is necessary for the purpose(s) for which they were obtained. ESMA will process personal data in accordance with our retention schedule. This retention schedule has been governed by our regulatory body (Central Bank of Ireland) and our internal governance.
In the event that you wish to make a complaint about how your personal data is being processed by ESMA or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and ESMA representatives GDPR Owner.
Failure to provide further information
If we are collecting your data for a contract and you cannot provide this data the consequences of this could mean the contract cannot be completed or details are incorrect.