Legal

The following sets out our terms and conditions of use and our privacy policy (together the “Terms”) for our website, our Android and iOS applications, internal Abtran sites and any mobile friendly version of our websites (together “Our Site”). Your use of Our Site requires the acceptance of these Terms without change and by using Our Site you acknowledge that you have read and understood and agree to be bound by the Terms. If you do not wish to be bound by the Terms you may not use Our Site.

ABTRAN PRIVACY NOTICE

Introduction

Abtran Unlimited Company (“We”, “Us”, “Abtran”) are committed to protecting and respecting your privacy.

This notice (together with any other documents) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. Our Commitment

Abtran is committed to ensuring that your privacy is protected. The General Data Protection Regulation and Data Protection Acts 1988-2018, when enacted (together “Data Protection Law”) apply to the processing of personal data. Under Data Protection Law, personal data is information that identifies you as an individual or is capable of doing so.

We comply with Data Protection Law and this notice applies to the personal data collected, processed and stored by us during and after your employment with us (“Your Data”).

For the purposes of Data Protection Law, we are the data controller of Your Data. You will find our contact details in the “Contact us” section below.

2. How we gather Your Data

You may give us information about you by filling in forms on our website www.Abtran.com (“Our Site”) or by corresponding with us by phone, e-mail, or otherwise. This includes information you provide when you register to use Our Site, subscribe to our services, search for a product or service, participate in discussion boards or other social media functions on Our Site, enter a competition, promotion or survey, and when you report a problem with Our Site.

We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, recruiters etc.) and may receive information about you from them.

We gather Your Data from when you apply for employment with us whether directly through our website or otherwise or through a recruitment partner.

3. Categories of Personal Data

Your Data may include

(a) your name,

(b) your address,

(c) your e-mail address,

(d) your telephone number,

(e) your personal or professional description

(f) your photograph;

(g) information regarding your professional or educational background; or

(h) any other information about yourself that you may voluntarily provide to us.

You are not obliged to provide us Your Data but if you do not we may not be able to carry out the service you have requested of us.

4. Why we process Your Data and legal basis for processing

We collect and process Your Data for the following purposes:

(a) to provide you with any service you may have requested or to take steps at your request prior to performing any service you have requested of us;

(b) to market our services or keep you informed of our business; and

(c) to inform you of changes to our services.

We rely on the following legal bases under Data Protection Law in processing Your Data:

(a) Performance of a contract: For example, if you or your company requests Abtran to provide services we may process Your Data in connection with the performance of those services.

(b) Consent: Where you have subscribed to our newsletter, for example, or opted in to receive information from Abtran.

(c) Compliance with legal obligations: For example, we may need to disclose Your Data in order to comply with a legal obligation to which were are subject including an order of any court or request from a regulatory or governmental body to whose jurisdiction we are subject.

(d) Legitimate interests: We may, for example, disclose Your Data in in connection with the establishment, exercise or defence of any legal claims in which we are involved to the extent that such disclosure is reasonably required.

5. Person with whom we may share Your Data

We may disclose your data with the following categories of recipients:

(a) our group companies for the administration and management of our business and compliance with applicable laws rules and regulations, and internal policies and procedures across the Abtran group (including statutory reporting and disclosures to regulatory authorities);

(b) third party agents, service providers and contractors for the purposes of providing services to us (for example, professional advisors, Abtran’s IT systems providers and communications providers) who are subject to confidentiality obligations and will be required to observe security and privacy obligations in respect of Your Data;

(c) to a governmental or regulatory body (including tax authorities, law enforcement agencies and financial regulators) in order to comply with a legal obligation;

(d) to any person pursuant to an order of a court or tribunal; or

(e) to a purchaser (or potential purchaser) and its advisors in connection with the sale or merger of Abtran or any of its assets.

Whenever we disclose Your Data to third parties, we will only disclose that amount of Your Data necessary to meet such business need or legal requirement.

6. Security

Abtran will take all reasonable steps to ensure that appropriate security measures are in place to protect the confidentiality of Your Data. Security measures will be reviewed from time to time, having regard to the technology available, the cost and the risk of unauthorised access.

7. Retention of data

The time period for which we retain information varies according to the use of Your Data and will be determined by reference to the following criteria:

(a) the purpose for which Abtran is using your data – we will need to retain Your Data for so long as is necessary for the purpose for which it was originally obtained;

(b) in some cases there may we may have legal obligation to keep Your Data for a minimum period of time or may need to keep your Data for the duration of statute of limitation that be applicable depending the nature of your engagement with us (for example seven years in the case of a contract).

In the case of job applications, our general retention period in respect of personal data of unsuccessful applicants is 12 months.

8. Where we store Your Data

We might store Your Data in different places. Physical files are stored in our office and our archives. Electronic files are stored on our secure servers and in the cloud. We may transfer Your Data to, and store it at, a destination outside of the European Economic Area (the “EEA”). Whenever we transfer Your Data in such a way, we will ensure appropriate safeguards are in place. Your data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the processing of your details. Any transfer of Your Data outside of the EEA would only be made through transfer mechanisms approved or allowed for under Data Protection Law and we shall take all necessary steps to ensure that there is adequate protection, as required by Data Protection Law.

9. Your rights in respect of Your Data

You have the following rights in respect of Your Data under Data Protection Law: • the right to request from us access to Your Data and to have any incorrect personal data rectified;

• where we rely on your consent in order to process Your Data, the right to withdraw that consent at any time; • in some circumstances, the right to receive some of Your Data in a structured, commonly used and machine-readable format and/or request that Abtran transmit that data to a third party where this is technically feasible but please note that this right only applies to personal data which you have provided to us;

• the right to the restriction of processing concerning you or to object to processing but please note that there may be circumstances in which we are legally entitled to retain Your Data notwithstanding any objection by you to, or request from you to restrict, our processing of Your Data;

• the right to have Your Data erased in circumstances but please note that we may be legally entitled to refuse that request and retain Your Data; • the right to make a complaint with a supervisory authority (including the Data Protection Commission of Ireland) if you fell any of your rights have been infringed;

We shall employ reasonable means to keep Your Data accurate, complete and up to date in accordance with the purposes for which it was collected.

10. How you can exercise your rights

You may exercise any of your rights by contacting us. Our contact details are set out in section 12 of this notice.

We will confirm your request within 21 days of receipt, and process your request within 30 days of receipt.

You may also make a complaint to the Data Protection Commission (www.dataprotection.ie)

11. Changes to this notice

This notice will be reviewed from time to time to take into account changes in the law, the experience of the notice in practice or changes to the extent to which we process Your Data. Any such changes will published on Our Site or otherwise notified to you in such manner as we deem appropriate. We encourage you to periodically review this notice to stay informed about how we collect, use, and disclose personal information.

12. Contact Information

Questions, comments and requests regarding this notice are welcomed and should be addressed to:

Name: The Data Privacy Coordinator,

Address: Abtran

Blackrock Business Park

Bessboro Road

Mahon

Co Cork

E-mail: dataprivacycoordinator@abtran.com