This Policy This policy explains how we may process your personal data.

This policy may be amended or updated from time to time, so please check it regularly for updates.

This policy is issued by Ray of Sunshine, its subsidiaries and its affiliates and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our web sites, users of our Apps, and other users of our services. For the purposes of this policy, Ray of Sunshine is the Data Controller. This policy covers the information practices relating to our company web sites and services offered now or in the future. This policy may be amended or updated from time to time to reflect changes in our practices with respect to the processing of personal data, or changes in Irish or European Union law. We encourage you to read this policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this policy.

Collection of Personal Data We may collect personal data about you from the following sources: –

• Data you provide: We may obtain your personal data when you provide it to us e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card.

• Relationship data: We may collect or obtain your personal data in the ordinary course of our relationship with you e.g., if you purchase a service from us.

• Data you make public: We may collect or obtain your personal data that you manifestly choose to make public, including via social media e.g., we may collect information from your social media profile(s), if you make a public post about us.

• App data: We may collect or obtain your personal data when you download or use any of our Apps.

Web site data: We may collect or obtain your personal data when you visit our web sites or use any features or resources available on or through a web site.

• Registration details: We may collect or obtain your personal data when you use, or register to use, any of our web sites, Apps, or services.

• Content and advertising information: If you choose to interact with any third-party content or advertising on a web site or in an App, we may receive personal data about you from the relevant third-party.

• Third party information: We may collect or obtain your personal data from third-parties who provide it to us e.g., credit reference agencies; law enforcement authorities; etc. Creation of Personal Data We may also create personal data about you, such as records of your interactions with us, and details of your purchase history for internal administration purposes and analysis. Categories of Personal Data we may Process We may process the following categories of personal data about you: –

Personal details

  • given name(s)

Demographic information

  • salutation
  • gender
  • date of birth or age
  • nationality
  • job title
  • industry
  • language preferences

Contact details

  • correspondence address
  • telephone number(s)
  • email address
  • details of your public social media profile(s)

Consent records

  • records of any consents you may have given o the date and time
  • the means by which we obtained your consent

Purchase details

  • records of purchases
  • prices paid

Payment details

  • invoice records
  • payment records
  • billing address
  • payment method
  • bank account number
  • credit card number
  • cardholder or account holder name
  • card or account security details
  • card ‘valid from’ date
  • card expiry date
  • BACS details
  • IBAN details
  • SWIFT details
  • payment amount
  • payment date
  • records of cheques

Data relating to our web sites and Apps

  • device type used
  • operating system
  • browser type
  • browser settings
  • IP address
  • language settings
  • dates and times of connecting to a web site
  • App usage statistics
  • App settings; dates and times of connecting to an App o location and other technical communications

Legitimate interests:

We may process your personal data where we have a legitimate interest in carrying out the processing for managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms. Sensitive Personal Data We do not seek to collect or otherwise process your sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on one of the following legal bases:

Compliance with applicable law:

• We may process your sensitive personal data where the processing is required or permitted by applicable law e.g. to comply with our diversity reporting obligations Detection and prevention of crime:

• We may process your sensitive personal data where the processing is necessary for the detection or prevention of crime, including the prevention of fraud. Establishment, exercise or defence of legal rights:

• We may process your sensitive personal data where the processing is necessary for the establishment, exercise or defence of legal rights. Consent:

• We may process your sensitive personal data where we have, in accordance with applicable law, obtained your prior, express consent prior to processing your sensitive personal data. This legal basis is only used in relation to a process that is entirely voluntary – it is not used for data processing that is necessary, legal or obligatory in any way. Purposes for which we may Process your Personal Data The purposes for which we may process personal data, subject to applicable law, include:

• Provision of services to you: – o providing our web sites, Apps and services to you o communicating with you in relation to those services and providing you with promotional items at your request or in connection with those services or similar services.

• Our web sites and Apps: –

  • operating and managing our web sites and our Apps
  • providing content to yo
  • displaying advertising and other information to you
  • communicating and interacting with you via our web sites and our Apps o identifying issues with our web sites and Apps and planning improvements to or creating new web sites and Apps
  • notifying you of changes to any of our web sites, our Apps, or our services.

• Communications:

  • communicating with you via any means (including via email, telephone, text message, social media, post or in person) for news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law o maintaining and updating your contact information where appropriate
  • obtaining your prior ‘Opt-In’ consent where required.

Communications and IT operations:

    • management of our communications systems
    • operation of IT security systems
    • IT security audits.

Health and safety:

  • health and safety assessments
  • record keeping
  • compliance with related legal obligations

• Financial management

  • sales; finance
  • corporate audit
  • vendor management

• Surveys: –

  • engaging with you for the purposes of obtaining your views on our services

• Security: –

  • physical security of our premises
  • records of visits to our premises
  • CCTV recordings
  • electronic security: – including login records & access details

Investigations: – detecting, investigating and preventing breaches of policy, criminal offences in accordance with applicable law

Legal proceedings: – establishing, exercising and defending legal rights

Legal compliance: – compliance with our legal and regulatory obligations under applicable law

Improving our web sites, Apps, services: – identifying issues with our web sites, our Apps, or our services o planning improvements to our web sites, our Apps, or our services o creating new web sites, Apps, or services

Disclosure of Personal Data to third parties

We may disclose your personal data to other entities within the company group, for legitimate business purposes, including operating our web sites and our Apps, and providing services to you, in accordance with applicable law. In addition, we may disclose your personal data to legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation • outside professional advisors, accountants, auditors, or lawyers, subject to binding contractual obligations of confidentiality • third party processors, e.g. payment services providers, data centres; etc., located anywhere in the world, subject to the requirements noted below. • any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights • any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security • any relevant third-party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets, including in the event of a reorganisation, dissolution or liquidation. • any relevant third-party provider, where our web sites and our Apps use third-party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your personal data may be shared with the relevant third-party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content. If we engage a third-party processor to process your personal data, the processor will be subject to binding contractual obligations to: a) only process the personal data in accordance with our prior written instructions; b) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law. International transfer of Personal Data Because of the international nature of our business, we may need to transfer your personal data within the company or group, and to third-parties as noted in the ‘Disclosures’ section above, in connection with the purposes set out in this policy. For this reason, we may transfer your personal data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located. Where we transfer your personal data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so based on standard contractual clauses. You may request a copy of our standard contractual clauses using the contact details provided. Please note that when you transfer any personal data directly to a company entity established outside the EEA, we are not responsible for that transfer of your personal data.

We will nevertheless process your personal data, from the point at which we receive the data, in accordance with the provisions of this Privacy Policy. Data security We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable Irish and European Union law. As the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any personal data that you send to us are sent securely. Data accuracy We take every reasonable step to ensure that: – • your personal data that we process is accurate and kept up to date • any of your personal data that we process which you inform us is inaccurate will be erased or rectified as per your instruction Data minimisation We take every reasonable step to ensure that your personal data which we process is limited to the personal data reasonably necessary in connection with the purposes set out in this policy or as required to provide you services or access to our web sites and/or Apps. Data retention We take every reasonable step to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this policy. The criteria for determining the duration for which we will keep your personal data are as follows: We will retain copies of your personal data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this policy unless applicable law requires a longer retention period. We may retain your personal data for the duration of any period necessary to establish, exercise or defend any legal rights. Your legal rights Subject to applicable law, you may have several rights regarding the processing of your relevant personal data, including: • the right not to provide your personal data to us. However, please note that we may be unable to provide you with the full benefit of our web sites, Apps or services. • if you do not provide us with your personal data, we may not be able to process your orders without the necessary details the right to request access to, or copies of, your relevant personal data, together with information regarding the nature, processing and disclosure of those relevant personal data • the right to request rectification of any inaccuracies in your relevant personal data • the right to request, on legitimate grounds: – o the erasure of your relevant personal data o restriction of processing of your relevant personal data • the right to object, on legitimate grounds, to the processing of your relevant personal data by us or on our behalf • the right to have certain relevant personal data transferred to another Data Controller, in a structured, commonly used and machine-readable format, to the extent applicable • where we process your relevant personal data based on your consent, the right to withdraw that consent, noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your personal data in reliance upon any other available legal bases. • the right to lodge complaints with the Data Protection Commissioner regarding the processing of your relevant personal data by us or on our behalf. This does not affect your statutory rights. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this policy, or about our processing of your personal data, please use the contact details provided below. Please note that: – • we may require proof of your identity before we can give effect to these rights • where your request requires the establishment of additional facts, e.g., a determination of whether any Processing is non-compliant with applicable law, we will investigate your request reasonably promptly, before deciding on what action to take. Cookies and similar technologies When you visit a web site or use an App, Cookies may be placed onto your device, or Cookies already on your device may be read. This should always be subject to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may process your personal data through Cookies and similar technologies, in accordance with our Cookie Policy: http://bit.ly/ROSKidscookiepolicy Terms of Use All use of our Web sites, our Apps, and/or services is subject to our Terms and Conditions. We recommend that you review our Terms and Conditions regularly, to review any changes, we might make from time to time. 10 © C Me Online all rights reserved 2018 SOP 5 – Privacy Statement Direct marketing We may process your personal data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law. You may unsubscribe from our promotional email list at any time by following the unsubscribe instructions included in every promotional email we send.

We will not send you promotional emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any services you have requested or from additional lists you have signed up under.

Contact details

You may contact us about your direct marketing preference by emailing: [email protected] If you wish to be taken off our contact list for direct marketing, or if you have any comments, questions or concerns about any of the information in this Policy, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact:

Email: [email protected]

Address: Unit 39, The Village Mill Enterprise Park, Rathnew, Co. Wicklow, A67 VE22

Phone: 087 272 4881

Contact: Amanda Spiteri

Definitions • App means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means). • Adequate Jurisdiction a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data. • Cookie means a small file that is placed on your device when you visit a website (including our Web sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs. • Controller means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws. • Data Protection Authority means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws. • EEA means the European Economic Area. • Personal Data means information that is about any individual, or from which any individual is directly or indirectly identifiable, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. • Process, Processing or Processed means anything that is done with any Personal Data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. • Data Processor means any person or entity that processes personal data on behalf of the Data Controller (other than employees of the Data Controller). • Relevant Personal Data means personal data in respect of which we are the Data Controller. It expressly does not include personal data of which we are not the Data Controller. • Sensitive Personal Data means personal data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law. • Standard Contractual Clauses means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission. • Site means any website operated, or maintained, by us or on our behalf.