Privacy Policy
Last Updated: 2 April 2023
Welcome to Tirlán’s Privacy Policy.
Tirlán Limited respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after the personal data we collect from you or that you provide to Tirlán Limited in regard to your use of the MyMilkman service and the MyMilkman Website and tells you about your privacy rights and how the law protects you.
Mymilkman.ie is a website hosted by Tirlán Limited (“MyMilkman Website” or “the website”) on behalf of franchised milk distributors (“Milk Distributors”). Please read the following carefully to understand Tirlán’s views and practices regarding your personal information and how we will treat it.
The MyMilkman service referred to in this Privacy Policy is the supply of dairy and other grocery products by the Milk Distributors to you and other customers.
Tirlán may amend this policy from time to time and you should check this page over time to ensure that you are happy with any changes to this policy made by Tirlán.
1. Important information and who we are
Controller
Tirlán Limited is the controller and responsible for your personal data (referred to as “Tirlán”, “we”, “us” or “our” in this Privacy Policy).
Please note, in certain instances, we may process your personal data as a processor acting for and on behalf of your Milk Distributor.
Purpose of this Privacy Policy
This Privacy Policy (together with our terms of use) and any other documents referred in the Privacy Policy set out how we give you information on how we collect and process the personal information that you provide to us when:
- you use the MyMilkman Website; and/or
- you receive the MyMilkman Service through one of the following methods:
- you sign up to the service through the MyMilkman Website, and the Milk Distributors receive your personal data through the MyMilkman online platform;
- you provide personal data to Milk Distributor directly in order to sign up to the service, and this information is shared by the Milk Distributors with Tirlán;
- you sign up to the service through the MyMilkman Website and Tirlán shares your details with the Milk Distributors for the purposes of ensuring you receive the MyMilkman service; or
- you sign up to the service through canvassers acting on behalf of Tirlán and Tirlán shares your details with the Milk Distributors.
Contact details
If you have any questions about this Privacy Policy, please contact us in the following ways:
Full name of legal entity: Tirlán Limited
Email address: dataprotection@tirlan.ie
Postal address: Abbey Quarter, Kilkenny, R95DXR1, Ireland
Telephone number: +353 567796300
You have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
Changes to the Privacy Policy and your duty to inform us of changes
We keep our Privacy Policy under regular review. This version was last updated on the date referenced above.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name and social media username.
- Contact Data includes address, email address, telephone numbers and Eircode.
- Profile Data includes your username and password, purchases or orders made by you, your contact preferences and delivery preferences and instructions.
- Transaction Data including details about payments from you and details of products and services you have purchased from the MyMilkman service.
- Competition Data includes the response to the competition/promotion question, where this is an original answer and not multiple choice and any photos submitted as part of your entry.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Communication and Usage Data includes when you contact us by phone, letter, email, live chat or through our website about the MyMilkman service or your MyMilkman profile.
- Marketing and Communications Data includes your name, contact details, your order history and preferences in receiving marketing from us and our third parties and your communication preferences.
Please note that in certain circumstances we may also process your Identity Data, Contact Data, Profile Data, Transaction Data, and Communication and Usage Data as a processor for and on behalf of your Milk Distributor as controller.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact, Profile, Transaction or Competition Data when you order services through the website, enter a competition or promotion on the website or by corresponding with us or contacting us by post, phone, email or otherwise.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy for further details.
- Third parties or publicly available sources. We may receive personal data about you from the third parties as set out below:
- Technical Data from analytics providers such as Google Analytics.
- Experian Ireland Limited
- Milk Distributors.
4. How we use your personal data
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
| Purpose/Activity | Type of Data | Lawful basis for processing including basis of legitimate interest |
| To carry out our obligations under the Terms and Conditions or any other contracts entered into between you and us. | Identity Data Contact Data | Performance of the Terms and Conditions contract with you. |
| For internal record keeping purposes to support the delivery of the MyMilkman service, where the personal data is provided by you through the website. | Identity Data Contact Data Profile Data Marketing and Communications Data | Legitimate Interests (to run our website and to facilitate the MyMilkman service) |
| For internal record keeping purposes to support the delivery of MyMilkman service, where your personal data is provided by the Milk Distributors to Tirlán. | Identity Data Contact Data Marketing and Communications Data | Legitimate Interests (to run our website and to facilitate the MyMilkman service) |
| To notify you about changes to our products or services that relate to your subscribed services. | Identity Data Contact Data | Necessary for our legitimate interests (to run our website and to facilitate the MyMilkman service) |
| To process and respond to any queries you submit to us. | Identity Data Contact Data Communication and Usage Data | Performance of the Terms and Conditions contract with you Necessary for our legitimate interests (to facilitate the MyMilkman service and to run our website) |
| To enable you to participate in a promotion or competition run through the website. | Identity Data Contact Data | Performance of a the promotion or competition contract with you |
| To administer the promotion/ competition. | Identity Data Contact Data Competition Data Marketing and Communications Data | Performance of a contract with you Necessary for our legitimate interests (to run the promotion or competition) |
| To publish the names of the winners on social media | Identity Data | Necessary for our legitimate interests (to comply with the requirements of the ASAI Code) |
| To provide you with information and promotional material about products, special offers or other information which you request from us or we think you may find interesting | Identity Data Contact Data Technical Data Marketing and Communications Data | Necessary for our legitimate interests (to develop our products/services and grow our business) Specific Consent to the processing has been provided. |
| To improve products and services directly related to the website / supported services. | Technical Data | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Data Contact Data Technical Data | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation. |
| To enable us to contact you if a milkman becomes available in your area when initially there was no service available at the time. | Contact Data | Specific Consent to the processing has been provided. |
Marketing
We may use your Identity, Contact, Technical, Usage and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will obtain your consent before sending direct marketing communications to you via email or text message. You will receive these marketing communications from us if you have opted in to receiving these communications as part of the sign up process, promotion / competition or through the website.
We will also get your express opt-in consent before we share your personal data with any third party for marketing purposes. There is an unsubscribe button at the end of all of our marketing communications and an unsubscribe link under the MyAccount function on the website, both of which enable you to ask us or third parties to stop sending you marketing communications at any time by following the opt out link.
Cookies
A cookie is a small file which asks permission to be placed on the web browser of your PC, telephone, tablet or other Internet-connected device (each a “Device“). Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.We use traffic log cookies to identify which pages are being used. This helps us analyse information about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the information is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does not in any way give us access to your computer or any information about you, other than the information you choose to share with us.
Our website uses strictly necessary cookies and optional cookies such as performance and targeting cookies. We require your consent to set optional cookies on your Device. On your first visit to our Website, you will see our cookies banner and you will be asked to select your consent preferences. You can update your consent preferences at any time by selecting “Cookie Settings” in the bottom right-hand corner of any webpage of the website.
For more information about our use of cookies, please consult our {cookies policy}.
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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table above.
External Third Parties
We may share information with the following external third parties:
- Milk Distributors for the purposes of providing the MyMilkman services where you have signed up for this service through the website or provided your personal data to us directly for this purpose.
- Professional advisers including lawyers, bankers, financial service providers, auditors and insurers who provide banking, financial, legal, insurance and accounting services to us.
- IT and Technical Service providers which provide IT and technical services.
- Third party service providers such as accounting, administration, payment and customer relationship management service providers.
- Canvassing service providers and canvassing software service providers that provide the canvassing services and canvassing software.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
- The competition/promotion supplier for the purposes of administering the competition/promotion.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
To deliver the services set out in this Privacy Policy to you, it is sometimes necessary for us to share your personal data with service providers who are located outside the EEA. We may transfer your personal data to another country outside the EEA if we are satisfied that the transfer complies with data protection law, appropriate safeguards are in place and enforceable rights and effective legal remedies are available for data subjects.
The safeguard we use to facilitate these transfers is the European Commission’s Standard Contractual Clauses (“SCCs”), which we will either enter into directly with service providers, or we will require our service providers to have the SCCs in place with any non-EEA based sub-processors of such service providers who receive your information.
6. 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 or 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We are committed to maintaining the highest levels of Information Security across our business functions and electronic business channels.
We implement the following Information Security safeguards:
- We apply digital certificates to our official corporate web sites to secure communications and also provide assurance that you are connected to approved resources
- We will treat all your queries in relation to potentially fraudulent activity with the highest urgency
- We maintain in-house and external Information Security services to provide website security analysis and identify areas of website security improvement
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. 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.
Links to other websites
Our website may from time to time contain links to enable you to visit other websites of interest easily. However, once you follow a link to any of these websites, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by our Privacy Policy. Please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. You should exercise caution and check these policies before you submit any personal information to these websites.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your legal rights
You have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in certain scenarios.
Request the transfer of your personal data (as provided by you) to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You also have the right to make a complaint at any time to the Data Protection Commission (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance.
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.
9. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to run the best promotion/competition/service and to give you the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.