- What information we will collect about you
- How we collect your personal information
- How we use your personal information
- Disclosures of your personal information
- Data retention
- Your data protection rights
- Third party links
“Narosa” is the trading name of Narosa Limited which is an Ireland registered company.
First of all, we’d like to assure you that we are committed to protecting the privacy of all our users. We will endeavour to ensure that the information you provide us with is kept secure and managed within the General Data Protection Regulations.
If you are not happy with any aspect of how we collect and use your data, please let us know so we can try and resolve it for you. Should this not be resolved, you have the right to complain to the Office of Information Commissioner (OIC), the Irish supervisory authority for data protection issues (https://www.oic.ie/).
It is important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes by emailing us at firstname.lastname@example.org or by editing your information in the ‘my account’ section of our website (https://narosalife.com/my-account/).
1 What information we will collect about you
We collect information about you when you register with us or place an order for products or services. We also collect information when you complete surveys, provide feedback or supply us with information during the course of our relationship. Website usage information is collected using cookies.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, last name, username, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
2 How we collect your personal information
We collect data about you through a variety of different methods including:
- Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- order our products or services;
- create an account on our site;
- request resources or marketing be sent to you;
- enter a competition, prize draw, promotion or survey; or
- give us feedback.
- Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- our booking service Eola;
- advertising networks such as Facebook based outside the EU; and
- search information providers such as Google and BING based outside the EU
- Email newsletters and mailing lists are administered using a third party service provider, Mailchimp.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and PayPal, based inside and outside the EU
3 How we use your personal information
We collect your data so that we can:
- Process your order, manage your account.
- Email you with special offers on other products and services we think you might like.
- Manage your lesson/course/event bookings & notify you about dates, times and schedule changes.
- Manage your accommodation booking and notify you about checkin details and further information regarding your stay.
When Our Company processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.
4 Disclosures of your personal information
We may have to share your personal data with the parties set out below for the purposes set out in part 3 of this document (see above):
- Third parties who provide fulfilment, marketing and customer support services, such as logistics companies, review platforms, email marketing services, marketing automation platforms, social media platforms and Google Ad services (for example, for display advertising and retargeting), and our booking system Eola.
- Surf instructors and course leaders.
- Accommodation managers.
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- Revenue – Irish Tax & Customs, regulators and other authorities based in Ireland and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We will not share your details with any other third parties unless we have your explicit consent.
However, if we reasonably believe that we are required by law to disclose your personal information to a third party, whether in compliance with any applicable law or regulation or by court order or in connection with legal proceedings, we may do so. We may also use aggregate anonymised data and share it with third parties.
5 Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
6 Your data protection rights
We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
- The right to access – You have the right to request us for copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
- The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to Narosa’s processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us via email to email@example.com.
7.1 What are cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
7.2 Purpose & types of cookies
- Keeping you signed in
- Understanding how you use our website
- Avoiding multiple popups & notifications during the same session
There are a number of different types of cookies, however, our website uses:
- Functionality – Narosa uses these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what what items you looked at previously. A mix of first-party and third-party cookies are used.
- Advertising – Narosa uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address.
7.3 How to manage cookies
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
8 Third party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We reserve the right to change this policy at any time. However, we will not change the way we use your personal information without telling you in advance and giving you the chance to opt out of or prevent the new use of your information.
Last updated: April 2020