Privacy Notice

NR3 Ireland LTD is committed to protecting your personal information by processing it responsibly and safeguarding it using appropriate technical, administrative and physical security measures. This privacy notice explains what information we gather about you, what we use that information for and to whom we give the information. It also sets out your rights and who you can contact for more information or queries.

Who this privacy notice applies to and what it covers
1. This privacy notice applies to NR3 Ireland LTD and the entities we own or control (“NR3”, “we”, “us” or “our”) with offices at:
  - Churchtown, Dublin 16 Ireland
  - Sao Domingo de Rana, Lisbon, Portugal
2. We are committed to protecting your personal data and processing your information in an open and transparent manner in accordance with Data Protection Legislation (EU General Data Protection Regulation 2016/679 together with all other applicable legislation relating to privacy or data protection).
3. This privacy notice sets out how we will collect, process, store and protect information about you when:
  1. providing services to you or our clients;
  2. you use "our Website"; or
  3. performing any other activities that form part of the operation of our business
4. When we refer to "our Website" or "this Website" in this privacy notice we mean the specific webpages of nrthree.com.
5. This privacy notice also contains information about when we share your personal data with other members of the NR3 Network and other third parties (for example, our service providers).
6. In this privacy notice, your information is sometimes called "personal data". We may also sometimes collectively refer to processing, collecting, protecting and storing your personal data as "processing" such personal data.
What information we collect
1. In the course of providing services to you or our client and performing due diligence checks in connection with our services (or communicating with you regarding possible services we might provide), we may collect or obtain personal data about you in physical and electronic form. We may also collect personal data from you when you use our Website.
2. We may collect or obtain such data because you give it to us (for example in a form on our Website), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.
3. We may also collect personal information if you contact us via other networking channels such as LinkedIN. The information we collect may depend on the privacy settings you have with the social network site, so please review the privacy statement or policy of the applicable social network site. When you access the Website through your social network account, you are authorising us to collect and use your information in accordance with this privacy statement.
4. We do not use cookies to collect personal information.
5. The personal data that we may collect or obtain may include:
  1. your name, gender, age and date of birth;
  2. your contact information, such as your address and contact details (including your email and mobile telephone number);
  3. country of residence;
  4. family circumstances (for example, your marital status and dependents);
  5. employment and education details (for example, the organisation you work for, your job title and your education details);
  6. Government identifiers (for example your personal public service number, passport number, driver's licence).
6. We do not collect and process personal data relating to ethnic or racial origin.
Information provided by or about third parties
1. Where we are provided with personal data about you by our client or another third party, we take steps to ensure that the client or other third party has complied with the data protection laws and regulations relevant to that information; this may include, for example, that the client or other third party has provided you with notice of the collection (and other matters) and has obtained any necessary consent for us to process that information as described in this privacy notice.
2. If any information which you provide to us relates to any third party (such as a spouse, people who depend on you financially, or a joint account holder or beneficiary), by providing us with such personal data you confirm that you have obtained any necessary permissions from such persons to the reasonable use of their information in accordance with the above provisions, or are otherwise permitted to give us this information. You should share a copy of this privacy notice with those other individuals before disclosing any personal information about them to us.
How we use information about you
1. We will use your personal data to provide you or our clients or other third parties with services. As part of this, we may use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, other third parties, other members of the NR3 Network, our service providers, or competent authorities.
2. We may also use your personal data to conduct due diligence checks relating to the services.
3. Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data:
  1. about a client's employees to help those employees manage their tax affairs when working overseas;
  2. about a client's employees and customers in the course of conducting an audit (or similar activity) for a client; or
  3. about a client to help him/her complete a tax return.
4. We may also use your personal data for the purposes of, or in connection with:
  1. applicable legal, regulatory, or professional requirements;
  2. financial accounting, invoicing, and risk analysis purposes; or
  3. protecting our rights and those of our client.
5. We may use your personal data for recruitment and business development purposes (for example, testimonials from a client's employees may be used as part of our recruitment and business development materials with that employee's permission).
6. In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:
  1. to manage and improve our Website;
  2. to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information about our products and services that may be of interest to you; or
  3. to manage and respond to any request you submit through our Website.
The legal grounds we use for processing personal data

In respect of the use of personal data in connection with providing services to our clients and activities relating to our business (as set out above) we rely on one or more of the following lawful grounds:
1. the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
2. the processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency; or
3. the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
  - to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;
  - to prevent fraud;
  - to protect our business interests;
  - to ensure that complaints are investigated;
In respect of use of personal data for marketing and business development purposes and personal data collected via our Website (as set above), we rely on legitimate interest:
- to develop our business and maintain business relationships with clients and business contacts;
- to evaluate, develop or improve our services or products; or
- to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.
To the extent that we process any special categories of data relating to you for any of the purposes outlined above, we will do so because either:
- you have given us your explicit consent to process that data;
- we are required by law to process;
- the processing is necessary to carry out our obligations under employment, social security, or social protection law;
- the processing is necessary for the establishment, exercise or defence of legal claims; or
- you have made the data manifestly public.
Please note that in certain circumstances it may still be lawful for us to continue processing your information even where you have withdrawn your consent if one of the other legal bases described above is applicable.

Sharing your personal data
1. In connection with one or more of the purposes outlined in the "How we use information about you" section above, we may disclose details about you to the following recipients or categories of recipients:
  1. other members of the NR3 Network; third parties that provide services to us and/or the NR3 Network;
  2. competent authorities (including courts and authorities regulating us or another member of the NR3 Network);
  3. your employer and/or their advisers; your advisers;
Transferring your personal data outside Ireland
1. Information about you in our possession may be transferred to other countries but is limited to Ireland, UK, and Portugal.
2. You understand and accept that these countries may have differing (and potentially less stringent) laws relating to the degree of confidentiality afforded to the information it holds and that such information can become subject to the laws and disclosure requirements of such countries, including disclosure to governmental bodies, regulatory agencies, and private persons, as a result of applicable governmental or regulatory inquiry, court order, or other similar process. In addition, a number of countries have agreements with other countries providing for the exchange of information for law enforcement, tax, and other purposes.
3. We do not share non-personal, de-identified, and aggregated information with third parties.
Protection of your personal data
1. We use a range of physical, electronic, and managerial measures to ensure that we keep your personal data secure, accurate, and up to date. These measures include:
  1. education and training to relevant staff to ensure they are aware of our data protection obligations when processing personal data;
  2. administrative and technical controls to restrict access to personal data on a 'need to know' basis;
  3. technological security measures, including firewalls, encryption, and anti-virus software; and
  4. physical security measures, such as staff security passes to access our premises.
2. Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.
How long we keep your information for
1. We will hold your personal data on our systems for the longest of the following periods:
  - as long as is necessary for the relevant activity or services;
  - any retention period that is required by law; or
  - the end of the period in which litigation or investigations might arise in respect of the services.
Your rights
1. You have various rights in relation to your personal data. In particular, you have a right to:
  1. obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
  2. be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from where it was obtained);
  3. ask that we update the personal data we hold about you or correct such personal data that you think is incorrect or incomplete;
  4. ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
  5. receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
  6. ask us to stop sending you marketing messages at any time by following the unsubscribe instructions in our communications or contacting us in the way set out in paragraph 12;
  7. object to our processing of your personal data.
2. Any request for access to or a copy of your personal data must be in writing and we will endeavor to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
3. We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change using the contact details set out in paragraph 12.1.
4. You may also use the contact details in paragraph 12.1 if you wish to make a complaint to us relating to your privacy.
Sending you marketing information
1. If a member of NR3 staff believes you are a client or business contact who may be interested in our thought leadership or marketing campaigns, we may use your information from time to time to inform you by letter, telephone, email, and other electronic methods, about similar products and services (including those of third parties) which may be of interest to you.
2. You may, at any time, request a change to your marketing preferences by following the instructions in communications from us or contacting us in the way described in paragraph 12.1 below.
Right to complain
1. If you wish to exercise any of the rights relating to your information set out above, or if you have any questions or comments about privacy issues, or you wish to raise a complaint about how we are using your information you can contact us in the following ways:
  1. write to Data Protection Officer, NR3, D&T House, Earlsfort Terrace, Dublin 2;
  2. send an email to privacy@nrthree.com
2. If you have any concerns about our use of your information, you also have the right to make a complaint to the Office of the Data Protection Commissioner (www.dataprotection.ie) or if the query or concern relates to our office in Northern Ireland, you have the right to contact the Information Commissioner’s Office (https://ico.org.uk).
Changes to this privacy notice
1. We may modify or amend this privacy notice from time to time.
2. To let you know when we make changes to this privacy notice, we will amend the revision date at the top of this page. The new modified or amended privacy notice will apply from that revision date. Therefore, we encourage you to periodically review this notice to be informed about how we are protecting your information.