Postmobile (“Postmobile”, “we” or “us”) is a division of An Post. Postmobile will collect and process your Personal Data and other information relating to your interactions and dealings with Postmobile. This Privacy Statement explains how we will manage your Personal Data, how and why we use it, and how you may contact us if you have a query about Personal Data that we hold about you. Where you use other An Post websites or obtain other specific An Post products and services, separate privacy statements may apply.
Personal Data means any information which Postmobile has or obtains or which you provide to us, such as your name, address, email address, telephone number(s) and date of birth, from which you can be directly or indirectly personally identified, and may include information such as identification, account numbers, International Mobile Equipment Identity Number, top-up history, IP addresses, cookie identifiers or online identifiers, depending on the services which we provide to you and the manner in which we interact. This may include mobile traffic data such as calls, texts and data usage including details of the date, time, duration and location of use. This data is processed in accordance with the Communications (Retention of Data) Act, 2011.
How we collect your Personal Data
We will obtain some of your Personal Data directly from you, such as when you join the Postmobile network in one of our Post Offices or on-line via our web shop.
We may also obtain some of your information indirectly such as from a family member purchasing a SIM card and/or a phone on your behalf or as a gift in one of our Post Offices or on-line via our web shop.
Why we use and hold your Personal Data
We will use your Personal Data, but only to the extent necessary:
a) for the purposes of performing a contract you have entered into with Postmobile, such as:
(i) to facilitate you in accessing your Account(s) online in a secure manner when you register at www.mypostmobile.ie;
(ii) to contact you if required in connection with, or to deal with queries, complaints, service messages or suggestions in relation to, the services we provide to you; and
(iii) to aid customer verification when you contact us or our customer care team in relation to any query you may have.
b) where you have consented to our use for a particular purpose, such as for marketing (please see “Marketing Preferences”) . If you do give your consent for us to use your Personal Data for a particular purpose, you have the right at any time to withdraw your consent to our future use of your Personal Data for some or all of those purposes by writing to us at the address set out under “Contact Us ” below.
c) for compliance with our legal obligations, including:
(i) where we are ordered to disclose information by a court with appropriate jurisdiction;
(ii) where we are required under criminal law to keep records of telephone calls and electronic communications; and
(iii) compliance with regulatory reporting obligations.
d) where our use is for a legitimate purpose of Postmobile, including:
(i) for day to day operational and business purposes, including board and group reporting and management purposes;
(ii) for the purposes of managing our contracts and relationships with our customers, suppliers, service providers, vendors and other commercial partners;
(iii) taking advice from our external legal and other advisors;
(iv) to help us improve our services and systems, and to improve your experience on our website and online services;
(v) to undertake market research, statistical and product development analyses; and
(vi) to provide you with information in relation to An Post Group products and services, as well as those of certain selected third parties, where we are permitted to do so (please see “Marketing Preferences”) .
e) where necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings; and
f) for such other purposes as were notified to you at the time you provide the information to us.
When we disclose your Personal Data
We will not disclose your Personal Data except as outlined above and / or as follows:
a) where the disclosure is necessary to enable us to carry out our obligations under any agreement we have with you;
b) to anyone providing a service to us or acting as our agents, which may include either other companies within the An Post Group or third party service providers, on the understanding that they will keep the Personal Data confidential;
c) where we need to share your Personal Data within the An Post Group or with our auditors, actuaries and our legal and other advisors; and
d) if the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of our regulators.
We will not otherwise share your Personal Data with any third party unless we receive your prior written consent to do so.
Where we process your Personal Data for other people
In certain circumstances, we may act as a data processor for other organisations. It will be made clear to you at the time your Personal Data is collected whether we are acting on our own behalf, or on behalf of a different entity.
In cases where we are acting on behalf of a different data controller, we will act only on their instructions in relation to processing your Personal Data. In these cases, it is that third party which is responsible to you for complying with your rights in relation to your Personal Data. If you send any request to us to exercise your rights, we will send it on to the data controller as soon as possible.
Other Recipients of your Personal Data
In any case where we are acting on our own behalf and we share your Personal Data with a third party data controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
International Transfers of Personal Data
Personal Data may be transferred outside of Ireland where necessary to provide our services to you, where you have explicitly consented, and / or as otherwise required or permitted by law.
Many of the countries will be within the EEA, or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in Ireland.
However, some transfers may be to countries which do not have equivalent protections, and in that case Postmobile shall use reasonable efforts to implement contractual protections for your Personal Data. While this will not always be possible where we are required to transfer your Personal Data in order to comply with and perform our agreement(s) with you or where we have a legal obligation to do so, any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.
Third Party Information
Where you provide us with Personal Data relating to other people, such as your spouse, children, mail recipients (if you use the postal service or for the administration of postal services), partners, directors, officers, employees, advisors or other related persons, you represent and warrant that you will only do so in accordance with applicable data protection laws. You will ensure that before doing so, the individuals in question are made aware of the fact that we will hold information relating to them and that we may use it for any of the purposes set out in this Privacy Statement and the relevant terms and conditions, and where necessary you will obtain their consent to our use of their information. We may, where required under applicable law, notify those individuals that you have provided their details to us.
Retention of Personal Data
Where you register your contact details with Postmobile, we retain those details for the duration of your use of the Postmobile network in order to provide customer care services to you. Subject to our legal obligations, we endeavour to delete customer registration details within 6 months of Postmobile becoming aware that you no longer use the Postmobile network.
Where you exercise your right of erasure to request deletion of your Personal Data, we will delete your details subject to applicable exceptions set out in data protection laws.
We are obliged to retain certain customer information to ensure accuracy, to help maintain quality of service and for legal, regulatory, fraud prevention and legitimate business purposes. In particular, under the Communications (Retention of Data) Act, 2011 we have a legal obligation to retain certain call and text information (eg, date, time, duration) for 2 years and certain internet data usage records (eg, date and time of log-in and log-off of the Internet access service) for one year. Where internet data usage records and telephony data records are combined, we will hold both for two years, unless we are legally obliged to hold those records for a longer period.
We hold recordings of calls to our customer care line, emails to and web chat conversations with our customer care team for a period of 6 months, unless we are legally obliged to hold it for a longer period.
Other information will be retained for no longer than is necessary for the purpose for which it was obtained by us or as required or permitted for legal, regulatory, fraud prevention and legitimate business purposes.
A cookie is a small piece of information which is transferred to your computer’s hard disk from a website. Cookies can store information about your preferences and other information which you need when you visit a website.
Your rights in relation to your Personal Data
Updating and correcting your Personal Data
If we hold incorrect Personal Data about you, you have the right to have the data amended. While we will use reasonable efforts to keep your Personal Data up to date, you will need to notify us without delay in the event of any change in your personal circumstances, so that we can keep your Personal Data up to date.
When you register at www.mypostmobile.ie, you can view and amend your Personal Data by logging onto your account at www.mypostmobile.ie.
Alternatively, Postmobile customers can contact Postmobile Customer Care on 1850 789 789 to amend any details.
You can also update your Personal Data by writing to the Data Privacy Office, An Post, GPO, O’Connell Street Lower, Dublin 1, D01 F5P2 or email@example.com together with:
1. Your name and address; and
2. A description of the specific Personal Data you wish to have rectified.
Right of erasure
You have the right in some circumstances to have your Personal Data, which we hold, erased by writing to the Data Privacy Office, An Post, GPO, O’Connell Street Lower, Dublin 1, D01 F5P2 or firstname.lastname@example.org together with:
1. Your name and address; and
2. A description of the specific Personal Data you wish to have erased.
If you request an erasure of your Personal Data, all your data will be erased subject to the following important notice.
We will not be required to erase your data where to do so would prevent us from meeting our respective contractual obligations, or where we are required to process (including retaining) your Personal Data in order to comply with a legal obligation, or if the Personal Data is necessary to establish, exercise or defend our legal rights or for the purpose of legal proceedings.
Right of Access
You have a right to be given a copy of your Personal Data on request, subject to certain exceptions. Please note that we have the right to require that you identify yourself before we will respond to any access request.
For more information, see our Data Access Policy .
Your Other Rights
You also have the right, in certain circumstances, to request restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. Further information on these rights, and the circumstances in which they may arise in connection with our processing of your Personal Data can be obtained by writing to us at the address set out under “Contact Us ” below.
In any case where we rely on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to us at the address set out under “Contact Us ” below.
Where we rely on a legitimate purpose of ours or of a third party recipient of the Personal Data, in order to use and disclose your Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do so, we will cease to use and process your Personal Data for that purpose, unless we can show there are compelling legitimate reasons for us to continue or we need to use the Personal Data for the purposes of legal claims.
In limited circumstances, you may also have the right to data portability in respect of certain of your Personal Data, which means you can request that we provide it to you in a structured, commonly used and machine-readable format, or transmit it to your third party nominee where this is technically feasible.
You have the right to lodge a complaint about our processing of your Personal Data with the Data Protection Commission at email@example.com.
Where you have agreed to receive marketing material, we will use this information to contact you with news and special offers from the An Post Group of companies and selected third parties.
We may use your Personal Data as part of general market, statistical and product development analyses in relation to our business generally.
Your Personal Data will not be given to any third parties for marketing purposes. Where you have opted to receive marketing information, you will always be contacted by Postmobile.
You can change your marketing preferences at any time by contacting us:
By phone – Postmobile Customer Care 1850 789 789
By e-mail – firstname.lastname@example.org
By Post – Manager, Postmobile, 3D, GPO, Dublin 1, D01 F5P2
Each time we send you marketing information, we will give you the option to change your mind about receipt of marketing (eg SMS: text STOP).
Any queries or complaints regarding our use of your Personal Data and / or the exercise of your individual rights should be addressed to the Data Privacy Office, An Post, GPO, O’Connell Street Lower, Dublin 1, D01 F5P2 or email@example.com.
Last updated on 2nd July 2018.