Placeholder

Our Privacy Policy


Privacy Policy and Data protection at Mediate Travel and its entities

1. Privacy policy

This privacy policy (the “policy”) was last updated on 04 March 2019 and refers to the websites; https://www.kilura.com – https://www.mediate.ie/, https://www.mediate.travel/ and any other websites operated by Mediate Travel, whose principal place of business is at Enfield Co Meath – Ireland.

This policy (together with our Terms & Conditions and any other documents referred to in such terms and conditions) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us, and applies to all of your personal data irrespective of the medium or method by which we obtained/received your data.

In this policy, the term “personal data” means data relating to a living individual who is or can be identified either from the data, or from the data in conjunction with other information, that is in, or is likely to come into, our possession, and includes personal data as described in data protection legislation (as defined below).

Please read the following carefully. Entering into this website and providing your consent to our use of your data by the terms of this policy indicates that the user (either “user” or “you”) has reviewed this policy and has agreed to be bound by it as well as our Terms of Use. You will be required to expressly accept and consent to this policy before we process your data. If you do not agree to these terms, you must leave the website immediately. We will keep a record of your consent in this regard. If you no longer consent to our processing of your data, you may request that we cease such processing by contacting us via the ‘How to contact us’ facility referred to below.

2. What information do we collect?

We fully respect your right to privacy about your interactions with the website, and we endeavour to guarantee to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use individual user details where we are legally entitled to do so. Information about personal data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commissioner (“DPC”).

We will handle your data by data protection legislation. “Data protection legislation” means the Data Protection Acts 1988 and 2003 and Directive 95/46/EC, and any other applicable law or regulation relating to the processing of personal data and to privacy (including the E-Privacy Directive), as such legislation shall be amended, revised or replaced from time to time, including by operation of the General Data Protection Regulation (EU) 2016/679 (“GDPR”) (and laws implementing or supplementing the GDPR).

We only collect and use individual user details where we are legally entitled and/or required to do so under the Tourist Traffic Acts 1939 to 2016 and data protection legislation. Where you have provided your consent to our collection and use of your data, you are entitled to withdraw such consent by notice to us.

You may provide various types of personal information, including:
• For business purposes, we will require personal and/or business contact information (such as name, billing address, postcode, phone number, job title, email address, social media handles, areas of expertise).
• We may ask you for personal information to supply travel arrangements or clothing/dietary information for activities/tours/ trips and promotions.
• For consumer information and promotions we may receive names, email addresses and areas of interest to determine your preferences.
• We may require images and video footage for marketing purposes and may seek special offers about your business for business development and marketing purposes.
• Bank details/account numbers, credit/debit card numbers (for secure processing third-party payment services), digital wallet, or other payment service information.
• Depending on the service we are providing to you, we may also require business performance information such as room rates, occupancy, employment figures etc. We may also require other information such as location/GPS data, language, Tax/PRSI no., or dietary preferences. We will also request this information directly from you.
If you submit any personal information about other people to us or our service providers and partners (e.g. business colleagues), you represent that you have the authority to do so and to permit us to use their personal information by this privacy policy.

Images and visual content

This is particularly relevant to the provision of images/footage and material which may promote your business or your area but also contain pictures of people. If you submit such content, you are doing so in the full acknowledgement that you have and can provide Mediate Travel with evidence of the required copyright allowing us and our partners to use the content.

You also acknowledge that you can provide Mediate Travel and its entities/partners with evidence of the necessary waivers and permissions from persons in the images/footage for you to share such content with our partners and us.

Mediate Travel, on occasion, takes photographs of participants at its own and partner events (such as sales and promotions events, activities, tours, training and networking events). We will endeavour to check you are happy to feature in a photo wherever possible, however often photos are of large groups and it is not possible to check with you in advance. Part of the terms of conditions of your acceptance to attend these events is your acceptance to be included in photographs, and in doing so, you permit us to use these photos for legitimate business purposes such as providing evidence that the event took place, local or internal publicity or promoting similar events.

How we collect personal data

We and our service providers may collect personal information from a variety of sources, including:
• From you or someone acting on your behalf: We may receive personal information you or someone acting on your behalf shares with us such as your name and contact details.
• Through Mediate Travel services: We may collect personal information about you when you use our services, for example, when you sign up for or open a newsletter, make a purchase, click through a mail, avail of a promotion, attend an event or avail of our other services whether paid or unpaid.
• Offline: We may collect personal information you provide to us offline, such as when you attend one of our events, place a verbal order over the phone, or contact customer services.
• We do not knowingly collect personal information from children without proper parental consent. If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to us. Users without this consent are not allowed to provide us with personal information. If you are under 13, then we will need approval from your parent/guardian before you can use some of our services. If you believe that we may have collected personal information from someone under the age of 18 without parental permission, please let us know using the methods described in the Contact Us section and we will investigate and address the issue promptly.

3. How do we collect information from you?

We and our third-party service providers may collect and automatically process this information in a variety of ways, including:
• When registering with us, you will be asked whether or not you consent to us sending you electronic communications/direct marketing. If you provide your email address and consent for email marketing, some information is collected about when/if the email was opened and what links were clicked. This information is used to assess the engagement and success of an email campaign.
• Clicking on a link in any of these emails may cause you to be personally identified on our site and may cause some part of your past browsing history on our site to be available to our personnel so we may more effectively engage with you and improve our site. If you do not wish for this tracking to occur, you can unsubscribe from our mailings or use private browsing mode to avoid monitoring.
• If you fill out a web form on any of the Mediate Travel websites for either leisure tourism or business tourism (MICE) reasons, your information will be stored in our CRM system and some amount of your prior browsing on our site may be available to us to determine your interests. We may use this information to engage with you and improve our site more effectively. If you do not wish for us to have your personal information, please do not register or fill out any of the web forms on this site.
• If you contacted us directly for news stories or media related content.
• If you contacted us about developing MICE business: for example, if you submitted to a buyer or prospect list or business research service or attended an event to research, identify and source MICE (business tourism) business in Ireland for business purposes.
• To register as a user of our business services we need to collect information such as your name and email address, the name and address of your company, your job title and the services you have an interest in. We may ask different questions for different functions, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• To register as a user of our consumer information and promotional services we need to collect information such as your name and email address.
• Provide us with images: part of our Content Management System (CMS) is a service provided by OutdoorActive to allow businesses and entities to promote themselves to visitors. If you avail of this service, you may be required to provide specific business information, including images. These images may contain people. You must have full documented copyright, marketing usage rights and permissions of all related parties to use and to share all photos relating to your listing.
• Through your browser or device: most browsers and landing pages collect specific information automatically, for example, type and version of operating system, screen resolution, device manufacturer and model, language, internet browser type and version, and the name. We use this information, for example, to make sure that the Mediate Travel services function properly, analyse the performance of our products, and to improve and maintain the services.
• IP address: IP addresses are automatically transmitted as part of any internet communication, and collecting IP addresses is a common practice; many websites, applications and other Mediate Travel services collect IP addresses automatically. We use IP addresses for purposes such as communicating with your device, calculating usage levels of our services, helping diagnose server problems, security and administering our services.
• Location data: We may collect the physical location of a connected device, for example, using satellite, cell phone tower, and WiFi signals. We may use your device’s physical location to provide you with location-based Mediate Travel services and content. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you wish to reject such methods and/or sharing, we and/or our marketing partners may not be able to provide you with the relevant Mediate Travel services and content.
• Applications: developed in connection with the website for mobile devices will operate and capture information as set out above and are also subject to this policy. Applications developed by/for us but deployed on other platforms such as social media channels may provide feedback to us on activity and usage specific to a user.
• Attendance at events: we may take photographs at certain events whether promotional, networking or supplier events. These images are for business use to demonstrate participation and the ongoing promotion of our services and events. You may be identifiable in these images. We also endeavour to use images with the utmost discretion and for business use only. You have the option to ‘opt-out’ of photo use at these events if you do not wish to be photographed.
• Our websites participate in affiliate programs of the network https://www.lead-alliance.net (operator: lead alliance GmbH). When displaying or clicking on advertising material, cookies (URL https://glaskugel.lead-alliance.net) can be set on your device. These cookies contain IDs that provide information about website operators, the advertising material, the contact time and the advertising clients. This information is used to process the claims for a commission of the website operator in the case of a logged conversion (for example, a sale, or a registration, etc.). Besides, information about the device (anonymised IP, operating system, browser version) is collected in order to improve the service and to prevent abuse. You can set in your browser whether and to what extent cookies should be allowed. However, we point out that a restriction may be associated with loss of use of websites. For more information and the option to opt-out, visit https://www.lead-alliance.net/dataprotection

4. Meeting our legal and regulatory obligations

Mediate Travel provides a digital platform for travel experiences, activities, tours and attractions. We reserve the right to use your information lawfully where;
• It is necessary for the performance of a contract (i.e. data subject accepts Mediate Travel Terms & Conditions related to the provision of our services).
• It is necessary for us to comply with our legal obligations under the Tourist Traffic Acts 1939 to 2016 (e.g. Listing of a Hotel or Activities Partner).
• It is necessary to protect the vital interest of the data subject or another natural person.
• Performing a task in your interest is necessary.
• You have provided us with your consent.
• It is necessary for the legitimate interest pursued by us except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
To meet our regulatory and legal obligations, we collect some of your personal information, verify it, keep it up to date through regular checks, and delete it once we no longer have to keep it. We may also gather information about you from third parties to help us meet our obligations. If you do not provide the information we need, or help us keep it up to date, we may not be able to provide you with our products and services.

5. How do we use the information we collect?

We may use personal information:
• To enable Mediate Travel and its entities to provide our services to you.
• To provide you with information about our services, activities or online content. You should only receive e-newsletters or similar correspondence and updates from us if you have agreed to in response to any contact you have made with us, e.g. on our website, by email or via the ‘Contact us’ facility. It will be made clear to you where you have these choices, for example, by providing tick boxes for you to decide whether you wish to receive e-newsletters.
• For administration reasons related to the service to which you have signed up (e.g. to provide you with password reminders or to notify you that particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us).
• To invite you to participate in surveys, contests or similar promotions about our services (such participation is always voluntary).
• To carry out any legal obligations arising from your interaction with the website, and to allow you to participate in interactive features of our service when you choose to do so.
• We may ask you for personal information such as clothing sizes, next of kin to facilitate trips and mechanise for operators, media, partners, etc.
• To complete and fulfil your purchase, for example, to process your payments, complete your order, communicate with you regarding your purchase, provide you with related customer service, and establish and manage your Mediate Travel accounts.
• To help promote your business/entity and tourism destinations across Ireland and internationally. We do so by providing information to visitors in Ireland and overseas and prospective buyers. We also provide promotional information and offers to visitors and may channel this information via our partners and websites.
• For our business purposes, such as data analysis, economic and business performance tracking, audits, security, developing new products, testing, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities.
• Perform accounting, auditing, billing, reconciliation, and collection activities. To send administrative information and service notifications to you, for example, information regarding the Mediate Travel services and changes to our terms, conditions, and policies.
• Perform other activities consistent with this policy. Where we wish to use your personal information in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of your personal information for purposes other than those listed in this policy.
Personal information may be shared or disclosed:
• To public bodies with a related remit about the promotion of the island of Ireland as a tourist destination (such as Tourism Ireland and Tourism Northern Ireland) and subsidiaries plus other destinations around the world for the purposes described in this privacy policy.
• To our authorised service providers and suppliers who provide services to us such as event organisation, website hosting, data analysis, payment processing, order fulfilment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services.
• To relevant buyers, channel intermediaries and businesses/organisations, such as international leisure and business tourism partners, to generate sales, growing business and increasing economic activity.
• When we share personal information with a Mediate Travel/Entities service provider, we require that they first contractually agree to comply with reasonable and appropriate privacy and security standards.
• Mediate Travel and its entities do not share or sell your personal information with non-affiliated third parties for their own marketing or commercial use.
International transfer of personal information;
• The personal data that we collect from you may be transferred to and stored by us. It may also be processed by our staff. By submitting your personal data, you agree to this transfer, storing or processing of your personal data by us for the purposes set out in this policy.
• Mediate Travel is an IRL/EU based Limited Company. As such, we may transfer your personal information to any other partner with responsibility for the promotion/execution of any part of your event/activity/tour on the island of Ireland or destination of your choice and the partner offices worldwide. When processing that information for the purposes described in this privacy policy we may also transfer your personal information to our third party service providers, who may be located in a different country to you.
• Whenever we share personal information originating in the European Economic Area (EEA) with a business partner/entity or office outside the EEA, we will do so by its approved binding corporate data processing agreement (DPA) which establishes adequate protection of such personal information and are legally binding on our partners.
• Where our DPA does not apply, we will instead rely on other lawful measures to transfer your personal information outside the EEA and Switzerland, such as the EU standard contractual clauses.
• In agreeing to our privacy policy the data subject gives his/her explicit consent in respect of potential data transfers outside the EEA for the purposes mentioned.
Third parties;
• We wish to remind you that this policy applies to personal data that we collect/process through your use of the websites. It does not apply to any links to third-parties’ websites and/or services, such as third-party applications, that you may encounter when you use the websites. You acknowledge that the service that we provide may enable or assist you in accessing the website content of, correspond with, and purchase products and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your data.

We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the websites. We encourage you to carefully familiarise yourself with terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

6. How you can manage your personal data

We endeavour to keep all personal data that you provide to us accurate and up to date. As such, you must tell us about any changes to such information as soon as possible. If you are a registered user of any of the Mediate Travel web entities you can update your personal information held on the Mediate Travel Website at any time, and change your stated interests and whether or not you wish to receive correspondence from us. You may unsubscribe from newsletters and other updates by selecting the Unsubscribe button at the foot of every communication.

7. Security – How we protect your personal information

The Mediate Travel services are designed to provide reasonable and appropriate organisational, technical, and administrative measures to protect personal information within our organisation against unauthorised or unlawful access, alteration, disclosure, or destruction. Users of our services must also do their part in protecting the data, systems, networks, and service they are utilising. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to any Mediate Travel account has been compromised), please immediately notify us by contacting us using the “Contact Us” section below.

For your protection, we will only implement requests concerning personal information about you (not anyone else), and we may need to verify your identity before performing your request. We will comply with your request as soon as reasonably practicable and by applicable law. We may need to retain certain information for record keeping purposes, as required under applicable legal obligations, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g. when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion). Some of your information may remain within our systems and other records, in compliance with applicable law.

8. How long do we keep your data for?

To meet our legal and regulatory obligations, any information that you provide to us will be kept and stored for such period as we deem necessary taking into account the purpose for which it was collected in the first instance, and our obligations under data protection legislation.

In general, your data will be retained by us for 30 months from the last date of contact or transaction.

9. What rights do you have?

As a data subject, you have the following rights under data protection legislation:
• The right of access to personal data relating to you.
• The right to correct any mistakes in your data.
• The right to ask us to stop contacting you with direct marketing.
• Rights about automated decision making.
• The right to restrict or prevent your data from being processed.
• The right to have your data ported to another data controller.
• The right to be forgotten/deleted.
• The right to complain to the Data Protection Commissioner if you believe we have not handled your data by the data protection legislation.
These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your data, please contact us (see ‘How to contact us’ below).

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it takes longer than one month for us to answer).

Where a response is required from us within a particular period according to data protection legislation, we will respond within that period.

Right to access to personal data relating to you

You may ask to see what personal data we hold about you and be provided with:
• A summary of such personal data and the categories of personal data held.
• Details of the purpose for which it is being or is to be processed.
• Details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers.
• Details of the period for which it is held (or the criteria we use to determine how long it is held).
• Details of your rights, including the rights to rectification, erasure, restriction or objection to the processing.
• Any information is available about the source of that data.
• Whether we carry out automated decision-making or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling.
• Where your data are transferred out of the EEA, what safeguards are in place.
Requests for your data must be made to us (see ‘How to contact us’ below) specifying what personal data you need access to, and a copy will be retained on your particular file. To help us find the information quickly, please give us as much information as possible about the type of information you would like to see.

If to comply with your request, we would have to disclose information relating to or identifying another person; we may need to obtain the consent of that person, if possible. If we cannot get permission, we may need to withhold that information or edit the data to remove the identity of that person, if possible.

There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions concerning any negotiations with you where disclosure would be likely to prejudice those negotiations.

We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to data protection legislation.

Right to update your data or correct any mistakes in your data

You can require us to correct any errors in your data, which we hold free of charge. If you would like to do this, please:
• Email, call or write to us (see ‘How can you contact us’ below).
• Let us have enough information to identify you (e.g. name, registration details).
• Let us know the information that is incorrect and what it should be replaced with.
If we are required to update your data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.

It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).

Right to ask us to stop contacting you with direct marketing

You can ask us to stop communicating with you for direct marketing purposes. If you would like to do this, please:
• Email, call or write to us (see ‘How can you contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to five days for this to take place.
• Let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be pleased for us to contact you by email but not by telephone).
We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’.

Rights concerning automated decision taking (if applicable)

You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff.

Profiling may occur with your data for targeted travel experiences and de-targeting you from specified advertising. This allows us to tailor our marketing to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising.

These rights will not apply in all circumstances, for example, where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (iii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.

Right to restrict or prevent processing of personal data

By data processing legislation, you may request that we stop processing your data temporarily if:
• You do not think that your information is accurate (but we will start preparing again once we have checked and confirmed that it is correct).
• The processing is unlawful, but you do not want us to erase your data.
• We no longer need the personal data for our processing, but you need the data to establish, exercise or defend legal claims.
• You have objected to processing because you believe that your interests should override the basis upon which we process your data.
If you exercise your right to restrict us from processing your data, we will continue to process the data if:
• You consent to such processing.
• The processing is necessary for the exercise or defence of legal claims.
• The processing is required for the protection of the rights of other individuals or legal persons.
• The processing is needed for public interest reasons.

Right to data portability

By data protection legislation, you may ask for an electronic copy of the data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.

The right to data portability also only applies where:
• the processing is based on your consent or for the performance of a contract
• the processing is carried out by automated means
• Right to erasure
• By data protection legislation, you can ask us to erase your data where:
• You do not believe that we need your data to process it for the purposes set out in this policy.
• If you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data.
• You object to our processing and we do not have any legal basis for continuing to process your data.
• Your data has been processed unlawfully or have not been erased when it should have been.
• The personal data have to be deleted to comply with the law.
We may continue to process your data in certain circumstances by data protection legislation.

Where you have requested the erasure of your data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves a disproportionate effort. We will also notify you about those recipients if you request it.

Right to complain to the Data Protection Commissioner (DPC)

If you do not think that we have processed your data by this policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights under data protection legislation. Information about how to do this is available on the DPC website at www.dataprotection.ie.

Offensive content

If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the website or otherwise engage in any disruptive behaviour on any of our services, we may remove such content.

Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including data protection legislation.

10. Updates to this privacy policy

We may change this privacy policy. The “Last Updated” section at the top of this page stated when this privacy policy was last revised. Any changes to this privacy policy will become effective when we post the revised privacy policy on the Mediate Travel websites. Your use of our services following these changes means that you accept the revised privacy policy.

If any change may materially and negatively affect the privacy of your personal information, we will use reasonable efforts to notify you in advance and give you a reasonable period to object to any changes.

We encourage you to periodically review this privacy policy to stay informed about how we collect, use, and share personal information.

11. How to contact us

The data controller (as defined in data protection legislation) for the website and services provided through the website is Mediate Travel and its Entities, located at Enfield Co Meath – Ireland.

Unsubscribing from electronic communications can be achieved by pressing the ‘unsubscribe’ or similar button on any electronic communication received. However, if you need to contact us concerning any of your rights as set out in this policy, all such requests should be made in writing by:
1. Using the online form at https://www.kilura.com/connect
2. Emailing: harald@kilura.com
3. Or writing to:
Harald Huebner
Mediate Travel
Enfield
Co Meath A83V027
Ireland