Privacy Policy

• Website means www.lightnet.ie, operated by Lighthouse Networks Limited T/A Lightnet.
• Servicesmeans the telecommunications transmission services, such as internet access, voice services, e-mail, or related value added services noted in our Terms and Conditions or as changed from time to time in accordance with those Terms and Conditions, whether provided directly by Lighthouse Networks Limited or under licence by third party suppliers.
• Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Usage data means data collected automatically either generated by the use of the Services or from the Website infrastructure (for example, the duration of a page visit).
• Cookies are small pieces of data stored on your device (computer or mobile device). You can learn more about cookies here or view our cookie policy here.
• Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and how any personal information are or are to be, processed. For the purposes of this Policy, we are a Data Controller of your Personal Data.
• Data Processors (or Service Providers) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers to process your data more effectively.
• Data Subject (or User), for the purposes of this Policy, means any living individual who avails of the Services, whose personal data is shared with us in relation to the Services, and/or visits the Website.  
• Data Protection Law means EU Regulation 679/2016 General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other applicable laws and guidance relating to data protection.

While signing up for and using our Services and when you use our Website, we may ask you to provide us with certain Personal Data.

When relating to the Services, this may include:

• Name
• Address (including Eircode)
• Contact details (including telephone number and email address)
• Household data (including demographics, in-home devices, etc.)
• Data held by routers or other equipment provided by us, including location
• Call traffic data
• Diagnostic & usage data
• Financial data/payment information (including bank account and/or credit card details)

When you use our Website, the Personal Data we may collect includes:

• IP traffic data
• Device data
• Cookies and website usage data

This section sets out how we obtain or collect Personal Data from third parties.

Occasionally, we may receive information about you from third parties. The third parties from which we are likely to receive information about you will generally include:

• Other members of your household or neighbourhood
• Our service providers and sub-contractors
• Third party partners such as OpenEir, the Department of Education, Comreg, local authorities and housing agencies, telecoms service providers
• Social media, in the event that you contact us through your social media profile
• Your financial institution or legal representative
• Employers and landlords
• Persons taking over your connection

It is also possible that some of these third parties with whom we have had no prior contact may provide us with information about you. The types of Personal Data those third parties may provide to us includes:

• Location information
• Device information as supplied by our provided hardware for support and account usage data
• Service information

Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.

We do not store any Personal Data outside the EEA. However, Personal Data controlled by us may be transferred and stored outside the EEA in certain circumstances. This may occur when sharing data with third parties – for example, if we use servers or third-party mail server provider’s servers based outside the EEA.

We may also transfer your information outside the EEA or to an international organisation to comply with legal obligations should they arise (compliance with a court order, for example).

If it is necessary to transfer any transfer of your Personal Data outside of the EEA, we will ensure that appropriate and valid legal safeguards and protections in accordance with Data Protection Law are in place.

We may collect Usage Data from our Website. This Website Usage data may include information such as your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Usage Data may be collected through the use of Cookies and other tracking technologies. You can learn more about cookies here or view our cookie policy here.

We collect and use several different types of information for the purpose of providing you with our Services in accordance with our contract with you and to manage your relationship with us.  We also use it for the purposes of providing and improving our services and Website. We may also use it for legitimate business reasons or to comply with a legal or regulatory obligation.

We will also contact you with service announcements that may affect your account – these service announcements may contain information about new services that are available to you and may improve the quality of broadband service we provide to you.

We may also use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these marketing or promotional materials communications from us by following the unsubscribe instructions or instructions provided in any email we send.

Lighthouse Networks Limited T/A Lightnet uses the collected data for various purposes:

• To provide and maintain our Services.
• To maintain our relationship with you as our customer.
• To notify you about changes to our Services.
• To notify you via service announcements of upgrades and alternative services available to you.
• To allow you to participate in interactive features of our Website when you choose to do so.
• To calculate billing and to process payments.
• To provide customer and technical support.
• To carry our repair and site visits at customer premises.
• To retrieve our property.
• To deliver goods.
• To gather analysis or valuable information so that we can improve our Website and Services.
• To monitor the usage of our Website and Services.
• To detect, prevent and address technical issues.
• To resolve disputes.
• For legitimate business reasons or to comply with a legal, contractual, or regulatory obligation.
• To provide you with news, special offers, promotional, and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

Our legal basis for collecting and using the personal information described in this Policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process your Personal Data because:

• We need to perform a contract with you (in particular, our contract with you to provide the Services)
• You have given us your consent to do so
• The processing is in our legitimate interests, and those interests are not overridden by your interests, rights or fundamental freedoms
• To comply with a legal obligation

The period for which we retain Personal Data varies according to the use of that information. In some cases, there are legal requirements to keep Personal Data for a minimum period of time. Unless specific legal requirements dictate otherwise, we will only retain your Personal Data only for as long as it is necessary for the purposes set out in this Policy.

We may disclose your Personal Data only when it is necessary as part of our contract with you, for the conduct of business or when there is a legal or statutory obligation to do so. Whenever we disclose your Personal Data to third parties, we will only disclose that amount of your Personal Data necessary to meet such business need or legal requirement. Third parties that receive your Personal Data from us must satisfy us as to the measures taken to protect the Personal Data such parties receive, in accordance with Data Protection Law and as stated in this Notice. These third parties have access to your information only to perform legitimate business tasks on our behalf and are obligated not to disclose or use it for any other purpose.

We may employ third party companies and individuals to facilitate our Services or to communicate to you, to provide the Services on our behalf, to provide information to perform Service-related services or to assist us in analysing how our Service is used. These categories of third parties include:

• Service wholesalers and their subcontractors
• Industry regulators
• Financial institutions
• Our service providers, including professional services advisors, communications facilitators, billing service providers, couriers, etc.
• Customer personal contacts as necessary, including next of kin, landlords/tenants, employers/employees, etc.

We may also provide your Personal Data when required to do so by law, for example under a court order, and may transfer data to legal counsel where same is necessary for the defence of legal claims.

We provide paid products and/or services within the Service. We use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. We also process direct debit payments. This information is provided directly to our third-party payment processors whose use of your personal information is governed by their own privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

Lightnet may also share Personal Data internally, i.e within the Group’s various entities, where necessary as part of our business and in order to fulfil our contract with you. We may also transfer your Personal Data to another company (including another member of the Group) in the event of a merger or potential merger or the acquisition or potential acquisition of all or some of our assets or the shares in us. We will advise you if such a change of ownership or change of corporate structure takes place and we will update this Policy accordingly.

We may provide your Personal Data when obliged to do so under Data Protection Law and in response to properly made requests, for example, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. We may also provide your Personal Data for the purpose of safeguarding national security. In the case of any such disclosure, we will do so only in accordance with the relevant Data Protection Law.

We may use third-party Service Providers to monitor and analyse the use of our website and Services. Website data, including Usage Data, may be processed on our behalf by the following. We include links to their privacy policies (available at the time of writing) for convenience:

• Google Analytics: Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

The security of your Personal Data is important to us but no method of transmission over the internet, or method of electronic storage is 100% secure and may be outside our control. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. We aim to protect your information against unauthorised access. We take all appropriate security measures, protocols and processes to secure and protect the confidentiality and availability of your information, including Personal Data.

We shall vindicate all rights under European Data Protection Law. In certain circumstances, you have the following data protection rights:

• The right to access the Personal Data we hold on you. You may request that we provide you with information as to whether we process your Personal Data and details relating to our processing, and that we provide you with a copy of your Personal Data.
• The right of erasure. Under certain circumstances, you may request that we erase your personal data without undue delay.
• The right of rectification. You have the right to have your Personal Data rectified or updated if that Personal Data is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. Under certain circumstances, you have the right to request that we restrict the processing of your Personal Data.
• The right to data portability. You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Lighthouse Networks Limited T/A Lightnet relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. Vindication of these rights shall not affect any rights which we may have under Data Protection Law.

Note that you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

You have the right to complain to the appropriate supervisory authority (in Ireland, the Office of the Data Protection Commission) about our collection and use of your Personal Data.

Our Website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Our Service does not address anyone under the age of 18 (“Children“).

We do not knowingly collect Personal Data from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

We may update this Policy from time to time. We will notify you of any changes by posting the new Policy on this page.
We will let you know via email and/or a prominent notice on our Service, before the change becoming effective and update the “effective date” at the top of this Policy.
We encourage you to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.

If you have any questions about this Policy or if wish you to request access to your information, please contact us:

• By email: dataprotection@lightnet.ie
• By visiting our website: www.lightnet.ie
• By phone number: +353 (091) 395 804
• By mail: Lightnet, Eastpoint Business Park, Loughrea, Galway, H62 YE28