Privacy Statement ISE Direct Website

PURPOSE AND SCOPE OF STATEMENT

This Statement explains how personal data relating to you will be handled by The Irish Stock Exchange Public Limited Company, trading as Euronext Dublin, of 28 Anglesea Street, Dublin 2, D02 XT25, Ireland ("Euronext Dublin, "we" or "us") and sets out how and why your personal data will be collected and processed by Euronext Dublin and/or on its behalf by its third party service providers.

For the purpose of this Statement, the controller of your personal data is the Irish Stock Exchange Public Limited Company trading as Euronext Dublin of 28 Anglesea Street, Dublin 2, D02 XT25, Ireland

APPLICATION OF THIS STATEMENT

This Statement applies to the way we collect and process your personal data. Personal data will be collected and processed by Euronext Dublin when you or a company with which you are connected engage with us and/or avail of our services, whether through www.ise.ie and www.isedirect.ie(our "Websites") or otherwise.

We will collect personal data:

  • from you: for example through our Websites, when you avail of our products and services, when you attend one of our events or an event hosted at our premises and when you correspond with us; and                         
  • from third party sources: including the Central Bank of Ireland, Euronext Dublin-quoted companies or companies applying for listing which with which you are connected and/or from publicly available resources (e.g. company filings).

 THE PERSONAL DATA WE PROCESS

The personal data we may process, which we may collect either directly from you or a company with which you are connected or from a third party, may include some or all of the following depending on the nature of the processing activity:

Device information

We collect information about your computer/device browser including your IP address and other information derived from cookies used on our Websites.  Please see our Cookie Policy for further information. 

Contact and company information

This may include general personal data about who you are such as your name, your contact details and your job title and position in a company.

AML information

This may include your position as a director, officer or beneficial owner of a company, copy documentation confirming your identity (such as your passport or driving licence) and copy documentation showing proof of your address (such as a utility bill).

Publicly available information

This may include information available: (i) on the websites or promotional material of companies or organisations with which you are connected; (ii) in news articles; or (iii) from registries such as the Companies Registration Office.

Other information

We may also process any personal data which you or the company with which you are connected choose to provide us.

 HOW AND WHY WE PROCESS YOUR PERSONAL DATA

The following table details the legal bases ("Legal Basis") according to which and the reasons why ("Purposes") we collect, obtain and process your personal data. 

Legal Basis

Purpose(s)

Contract

It is necessary to process your personal data to enter into and perform our contracts with you or your organisation for the provision of our services.

 

If you do not wish to provide us with your personal data for these purposes, we will not be able to enter into or perform our contract(s) with you or your organisation.

 

We obtain, collect and process your personal data:

 

  • To process applications for financial products including Legal Entity Identifiers (LEI) and International Securities Identification Numbers (ISIN), Net Asset Valuations (NAVs);
  • to manage, administer and maintain the ISEdirect system;
  • review and publish announcements
  • for invoicing and billing purposes.

Legitimate Interests

We process certain of your personal data on the basis of our legitimate interests, such as in pursuit of our business or security interests.

 

Where we process your personal data in pursuit of our legitimate interests we determine if such processing is necessary and we carefully consider the impact of our processing activities on your fundamental rights and freedoms. We will not process your personal data where our legitimate interests are outweighed by the impact on your rights and freedoms (unless otherwise required or permitted by law).

 

You have the right to object to us processing your personal data on the basis of our legitimate interests.  For more on this and other rights please see section on "your rights and how to exercise them". 

 

We obtain, collect and process your personal data in order to:

 

  • provide you with access to our Websites and to enable you to use them;
  • test and improve the effectiveness of our Websites and to monitor metrics such as numbers of visitors, traffic data and demographic patterns;
  • provide you with information about our products and services;
  • respond to your enquiries; and
  • circulate reports, statements and other material which you sign up to receive. 

Compliance with a Legal Obligation

We process your personal data where it is necessary to comply with legal obligations to which we are subject.

 

Where necessary and/or applicable, we obtain, collect and process your personal data in order to comply with our legal and regulatory obligations, including under anti-money laundering and terrorist financing legislation, the Markets in Financial Instruments Directive Regulations 2017 and other applicable law.


DISCLOSURE OF PERSONAL DATA

We may disclose your personal data to other members of the Euronext Group of companies.

We will also disclose your personal information to other third parties including:

  • the Central Bank of Ireland;
  • regulatory authorities and law enforcement agencies;
  • other people in your company or organisation;
  • third parties involved in hosting or organising events or courses;
  • professional advisors such as tax or legal advisors, consultants and accountants; and
  • any prospective buyers of Euronext Dublin or the business of Euronext Dublin.

TRANSFERS OF YOUR PERSONAL DATA

We store and process your personal data on servers located within the European Economic Area (the "EEA"). We only transfer your personal data outside the EEA where the European Commission has decided that the third country in question ensures an adequate level of protection in line with EEA data protection standards or there are appropriate safeguards in place to protect your personal data.

If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your personal data you can contact us at gdpr-dublin@euronext.com 

Although we will always do our best to protect your personal data, we cannot guarantee the security of any information you transmit to us. Any transmission is at your own risk. Once we have received your information, we use strictly maintained physical, electronic and procedural safeguards to prevent unauthorised access.

RETENTION OF YOUR PERSONAL DATA

Generally we shall retain your personal data for a period of seven years after the later of: (i) the conclusion of your relationship with Euronext Dublin; or (ii) the conclusion of the relationship between Euronext Dublin  and the company with which you are connected.

YOUR RIGHTS AND HOW TO EXERCISE THEM

The table below sets out the rights which you have to address any concerns or queries with us about our processing of your personal data. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law.

Right

Further Information

Right to be informed

You have the right to know your personal data is being processed by us, how we use your personal data and your rights in relation to your personal data. 

Right of access

You have the right to ascertain what type of personal data Euronext Dublin  holds about you and to a copy of this personal data.

Right to rectification

You have the right to have any inaccurate personal data which we hold about you updated or corrected.

Right to erasure

In certain circumstances you may request that we delete the personal data that we hold on you.

Right to restriction of processing

You have the right to request that we stop using your personal data in certain circumstances including if you believe that the personal data we hold about you is inaccurate or that our use of your personal data is unlawful. If you validly exercise this right, we will store your personal data and will not carry out any other processing until the issue is resolved.

Right to object

Where we rely on our legitimate interests to process your personal data, you have a right to object to this use. We will desist from processing your personal information unless we can demonstrate an overriding legitimate interest in the continued processing.

Right to data portability

You may request us to provide you with certain personal data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another controller where this is technically feasible.

You can exercise any of these rights by submitting a request to us at gdpr-dublin@euronext.com.

 We may request that you provide proof of your identity for security reasons and in order to prevent the unauthorised disclosure or misuse of personal data.  We will only charge you for requests to access your personal data where they are unreasonable, unfounded or excessive.   If, after contacting us, you are still not satisfied with our response, you have the right to lodge a complaint with the Data Protection Commission.  Please see www.dataprotection.ie for further information.

CHANGES TO THIS STATEMENT

We may occasionally update this Statement to reflect changes in our business or to comply with applicable law and regulations.  If there are material changes to this Statement concerning how we use your personal data, we will notify you by either prominently posting a statement of such changes on the relevant Website before they take effect.

CONTACT

If you have any concerns about the way your personal data are being used or processed by Euronext Dublin, please contact us at gdpr-dublin@euronext.com