1. Introduction

Inis Offshore Wind Limited (“Inis”, “we”, “our” and “us”) is committed to protecting the privacy and security of the Personal Data that we hold. 

This notice is intended to explain how we collect, use, and protect your Personal Data.

2. Who we are

Inis is owned by the Temporis Aurora LP, an Irish limited partnership, which is categorised under the Alternative Investment Fund Managers Directive (“AIFMD”) as an Alternative Investment Fund.   

Inis is committed to handling Personal Data fairly and lawfully and takes its data protection obligations very seriously. Inis ensures that it processes Personal Data in compliance with applicable data protection laws, including without limitation, the General Data Protection Regulation 2016/679 (“GDPR”).

3.Type of data & purpose

• Personal data will be processed to control and manage requests of contact, consultation, information, and claims, as well as to manage commercial and/or pre-contractual relationships.
• Likewise, personal data will be processed for sending, including through electronic means, communications, and information about the activity of Inis.

4. How is personal data collected?

We use different methods to collect Personal Data including the following:
• personal details provided directly by employees, clients, contractors, other business contacts and persons consulted about or interested in our activities; and
• information from third parties and publicly available sources e.g. Companies Registration Office Ireland, Registrars and Background Check Providers. It should be noted that our website does not capture or record any Personal Data relating to website users/visitors.

5. How do we use personal data?

The Personal Data we obtain, and hold is used to enable us to:

• fulfil our contractual and other obligations to employees, suppliers, contractors and other business partners;
• engage with persons consulted about or interest in our activities;
• meet our legal and regulatory obligations.

Under the GDPR a firm must have a legal basis / justification for processing data. In the vast majority of instances, Inis will have one of the following justifications:

• Performance of a contract;
• Compliance with legal obligations; and
• Legitimate business interests – in this instance the processing must be “necessary” and must balance the interests of the controller with the rights of the individual. We may combine the Personal Data that we collect from Data Subjects with information obtained from other sources to the extent permitted by law. It is important that the Personal Data we hold is accurate and therefore the Data Subject should advise us as soon as possible in the event of any changes.

6. To whom do we disclose personal data?

We will only use a Data Subject’s Personal Data for our internal business purposes. This includes the provision of marketing related correspondence to the Data Subject on our products and services.
We do not sell any Personal Data to third parties and we do not share Personal Data with third parties for the third parties’ marketing purposes.
However, we may need to disclose Data strictly on a need to know basis to our service providers, contractors, suppliers and other parties such as banks, brokers, registrars, lawyers, accountants, actuaries, regulators and Revenue Commissioners.

7. What do we do to keep personal data secure?

We have put in place appropriate physical and technical measures to safeguard the Personal Data we collect in connection with our services. In addition, we limit access to Personal Data to those employees, agents, contractors and other third parties who have a business need to
know. They will only process Personal Data on our instructions and are subject to a duty of confidentiality.
However, please note that although we take appropriate steps to protect Personal Data no device, computer system, transmission of data or wireless connection is completely secure and therefore we cannot guarantee the absolute security of Personal Data.

8. International transfer of data

The Personal Data that we collect may be stored and processed in the European Economic Area (“EEA”) or transferred to, stored at, or otherwise processed outside the EEA. Where Personal Data is transferred outside the EEA, we will take all steps reasonably necessary to ensure that the Data is kept secure and treated in accordance with this Privacy Notice and the requirements of applicable law wherever the data is located. Appropriate transfer agreements and mechanisms (such as the EU Model Clauses) will be put in place to help ensure that our third-party service providers provide an adequate level of protection for Personal Data. We will only transfer Personal Data outside the EEA in accordance with applicable laws or where the Data Subject has given us consent to do so.

9. Data retention – how long is personal data stored / kept?

Inis retains Personal Data for as long as necessary to fulfil the purposes for which the Data has been collected as outlined in this Privacy Notice unless a longer retention period is required by law. Data is kept under regular review to ensure that it is not held longer than is strictly necessary, whilst taking account of Inis’ other regulatory obligations such as the requirement to retain evidence of anti-money laundering checks. When Personal Data is no longer required for the purpose, it was collected or as required by applicable law, it will be deleted or in certain circumstances returned to the Data Subject in
accordance with applicable law.

10. Accessing personal data and other rights that a data subject has

Inis will collect, store and process Personal Data in accordance with the Data Subject’s rights under the GDPR. Under certain circumstances the Data Subject has the following rights in relation to their Personal Data:

• the right to request details of their Personal Data held by Inis and to request copies of such information;
  
• where Inis use of Personal Data is based upon their consent, the right to
  withdraw such consent at any time;
  
• the right in certain circumstances to request Inis to port (i.e. transmit) their Personal Data direct to another organisation;
  
• the right to request Inis to rectify or update any Personal Data that is incorrect or complete;
  
• the right to have Personal Data erased in certain specified circumstances;
  
• the right to request Inis to stop processing their Personal Data and to only store such Data;
  
• the right to object to specific types of processing of Personal Data, for example where it is being used for the purpose of direct marketing; and
  
• the right in certain circumstances not to be subject to decisions being taken solely on the basis of automated processing (e.g. profiling).

11. How can a data subject enforce their rights?

In the event of a Data Subject wishing to enforce any of their rights under the GDPR then please use the contact details at section 14. A response to the request will be made without undue delay and no later than one month from receipt of such a request. We will not charge a fee for processing such a request. If a Data Subject is concerned that we have not complied with their legal rights under applicable Data Protection Laws, they may contact the Information Commissioner’s Office (https://www.oic.ie/) which is the data protection regulator in Ireland. 

12. Cookies

A ‘cookie’ is a packet of information placed on a user’s computer by a website for record keeping purposes. Cookies may be used on our site to:

• manage visitors – cookies are sometimes used to collect anonymous information about the page you visit and the type of software you are using.
• monitor traffic – we may use anonymous information to track how people are using the Inis site. This may include time of visit, pages visited and some system information about the type of computer you are using.
• monitor your use of our website – if we have identified you as a result of you accessing our website from a personalised communication or providing us with personal information, we may use cookies to collect personal information about you.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. (Each browser is different, so check the Help menu of your browser to learn how to change your cookie preferences).

If you disable the use of cookies on your web browser or remove or reject specific cookies from our websites or linked sites, then you may not be able to gain access to all of the content and facilities on those websites.

13. Changes to this privacy notice

We will update this Privacy Notice from time to time and hence it is important to check the “Date Notice Last Updated” legend at the bottom of this Notice. Any changes will become effective upon posting the revised Privacy Notice on our website.
We will provide notice to Data Subjects where any of the changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by e-mail or by posting notice of the changes on our website.

14. Contact us / further information

If you have any questions concerning the content of this Privacy Notice, including any requests to exercise your legal rights, the relevant contact details are set out below.

Contact details

Name of Contact: Linda O’Riordan
Position: Risk & Compliance Officer
Email address:   Linda.ORiordan@temporis.ie
Postal address: Temporis Investment Management Limited, Unit 74, Penrose Wharf, Penrose Quay, Cork, T23 HF51

Date Notice Last Updated – 6th October 2021