Data Protection Policy

At Origina, the protection of personal data is a particularly high priority for us. This policy aims to inform you about whether and how personal data is collected and processed in connection with the use of our Internet presence and about your rights in relation to your personal data. Origina has implemented numerous technical and organizational measures designed to protect personal data processed through this website as fully as possible. Nevertheless, data transfers over the Internet may fundamentally have security loopholes, and thus total protection cannot be guaranteed.

I. Name and address of the organization responsible for processing personal data

With regard to the use of our website www.origina.com and its subpages, as well as the linked websites and social media presences of Origina, the organization responsible for processing personal data under applicable privacy, data protection and electronic communications laws and regulations, including where applicable the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), the UK GDPR, the Data Protection Act 2018, and any other equivalent or successor laws that apply to our processing activities, is Origina Ltd.

Our contact details are:

Address: Origina Ltd, Termini Building, 2nd Floor, 3 Arkle Road, Sandyford Business Park, Dublin 18, D18 T6T7
Phone: +353 1 294 2300
Email: dataprotection(at)origina.com
Webform: Privacy rights request form

If you have concerns about the way we handle your personal data, you may raise them with your relevant data protection authority. However, we would welcome the opportunity to resolve your concern first, so please contact us using the details above.

II. Collection and storage of personal data in connection with visits to our website; nature and purpose of its use

1. Security

If personal data is transmitted to us over our website, we use numerous secure technologies, in particular the Transport Layer Security (TSL) and Secure Socket Layer (SSL) transfer protocols. All information and data transferred using these secure methods is encrypted before being sent to us. The IP address of the system used to access the website is transmitted to us so that you and Origina are protected against misuse and attack. We process this data where necessary to protect the security, integrity and availability of our website and IT systems. Where the GDPR or UK GDPR applies, we rely on our legitimate interests under Article 6(1)(f). Where other privacy or data protection laws apply, we rely on the equivalent lawful basis available under those laws.

2. Recording of general data and information

Whenever it is called, our website records a number of items of general data and information that are stored in the server’s log files. The following may be recorded:

The types of browser used and their versions
The operating system used by the system accessing our website
The website from which a system accesses our website (referrer)
The subpages accessed by a system on our website
The date and time our website was accessed
The Internet Protocol (IP) address of the system calling our website
The Internet service provider of the system accessing our website
Other similar data and information that helps repel threats in the event that our IT systems are attacked.

We do not use this log data and general information to identify you. This information is required instead (1) to deliver our website’s content correctly, (2) to optimize our website’s content and advertising for it, (3) to ensure that our IT systems and our website’s technology keep running properly, and (4) to provide law-enforcement authorities with the information required to prosecute any cyberattacks that occur. This data and information, which is collected anonymously, is therefore analyzed statistically, with the objective of increasing data protection and data security at our company and thus ultimately ensuring an ideal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from personal data you provide directly to us. We process this log data and general technical information where necessary to operate, secure and improve our website, prevent misuse, investigate security incidents, and protect our IT systems. Where the GDPR or UK GDPR applies, we rely on our legitimate interests under Article 6(1)(f). Where other privacy or data protection laws apply, we rely on the equivalent lawful basis available under those laws.

3. Cookies

Our website uses cookies, which are small text files that are placed and stored by a web browser on a computer system. Many websites and servers use cookies. Many cookies contain a cookie ID that uniquely identifies the cookie. It consists of a character string that permits websites and servers to be linked to the specific web browser in which the cookie was stored. As a result, the websites visited and servers can distinguish your browser from other web browsers containing other cookies. A particular web browser can be recognized and identified by the unique cookie ID. Cookies help improve user-friendliness and site functionality. We use cookies to provide certain core functionalities (for example, to remember your preferences) and to analyze how our website is used. We categorize cookies as follows: (a) Necessary cookies, which are required for technical functionality or security and do not require consent, and (b) Analytics/Marketing cookies, which help us improve our website and measure the effectiveness of our marketing – these are used only with your prior consent. We present a cookie consent banner when you first visit our site, where you can accept or reject non-essential cookies. You can also adjust your browser settings to block all or some cookies; however, blocking certain cookies may impact your experience (for instance, some interactive features might not work). You can prevent cookies from being placed by our website at any time by changing the relevant settings in your browser. You can also delete cookies that have already been placed by using your browser or other software programs. This is possible in all common web browsers. If you disable cookies in your browser, you may not be able to use all the functions of our website in full.

4. Registration on our website

You can register on our website, for example to download content or sign up to a newsletter. Registration involves the collection of personal data through the relevant input screen. The personal data required is identified in that input screen, such as name, contact details and other registration information. Once provided, we collect and store that personal data only for the purpose stated at the point of registration. We may share it with processors, service providers or equivalent third parties under applicable law where this is necessary to provide the relevant content or service. When you register on our website, we also store the IP address assigned by your internet service provider, together with the date and time of registration. This information helps us prevent misuse of our services, maintain the security of our systems and investigate unlawful activity where necessary. Where the GDPR or UK GDPR applies, this processing is based on our legitimate interests in maintaining the security and integrity of our services. Where other privacy or data protection laws apply, we rely on the equivalent lawful basis or permitted processing ground available under those laws. By registering and voluntarily providing your personal data, you enable us to provide content or services that are only available to registered users. Where the GDPR or UK GDPR applies, we process this data where necessary to perform a contract with you or to take pre-contractual steps at your request under Article 6(1)(b). Where other privacy or data protection laws apply, we rely on the equivalent lawful basis or permitted processing ground available under those laws.

5. Subscription to a newsletter

You can subscribe to newsletters on our website. The personal data sent to us when a newsletter is ordered is as defined in the input screen used for subscribing (typically name and email address). Origina regularly informs its customers and prospects about what the company has to offer, and updates to these offerings, by means of a newsletter. If you register for the newsletter, we also store the IP address assigned by your internet service provider to the system you used at the time of registration, as well as the date and time of registration. We collect this information to help confirm that the subscription was requested, prevent misuse of email addresses, and maintain evidence of the subscription request. The personal data collected during registration for the newsletter is used solely for sending out the newsletter. In addition, newsletter subscribers can be notified by email if this is necessary for the operation of the newsletter service or if registration is required, such as may be the case if there are changes in the newsletter offer or technical circumstances. The personal data collected as part of the newsletter service is not transmitted to third parties, with the exception of our email provider and the persons responsible for the newsletter’s contents at Origina. You can unsubscribe from the newsletter at any time. You can withdraw your consent to the storage and use of personal data for newsletter distribution at any time. Every newsletter contains a link that can be used to withdraw consent. You can also cancel your newsletter subscription directly on our website or by contacting us using another available method. The legal basis for processing personal data in connection with the newsletter is that explicit consent has been given and may be withdrawn at any time, as we honour requests to unsubscribe immediately.

6. Tracking

Origina’s newsletters contain tracking pixels. A tracking pixel is a miniature graphic that is embedded in emails sent in HTML format to enable recording and analysis of log files. This permits statistical evaluation of the success or lack of success of online marketing campaigns. The embedded tracking pixel allows Origina to understand whether and when a subscriber has opened an email and which links in the email were clicked. We store and analyze the personal data collected by tracking pixels contained in newsletters (open rate, click-through data, and similar personal data associated with the newsletter email) in order to optimize newsletter distribution and tailor future newsletter content to subscriber interests. Importantly, newsletter tracking is used only for subscribers who have consented to receive the newsletter, and it operates under the same consent. We consider the act of subscribing and confirming via double opt-in as consent to this tracking in newsletter emails, but subscribers can opt out at any time. When a subscription to the newsletter is canceled, Origina automatically interprets that as a withdrawal of such consent. The legal basis for processing personal data for newsletter tracking purposes is that explicit consent has been given and may be withdrawn at any time. Our website uses the tracking pixel technology of Hubspot¹ to analyse user behaviour. Data is collected, processed and stored and used to create use profiles under a pseudonym. These use profiles are anonymized completely where possible and sensible. This analysis may require the use of cookies as described above. We use this information to understand aggregate user engagement and to improve our website and marketing efforts. Depending on the nature of the tracking, the legal basis for data processing is either your consent via our cookie banner (for any tracking that is not strictly necessary) or our legitimate interest in improving our website (for aggregated, non-identifiable data which is necessarily processed).

7. Contacting us via the website

In compliance with statutory requirements, our website contains information that enables you to contact Origina quickly by electronic means. That information likewise comprises a general email address. If you contact us by email or through a contact form, the personal data you send, such as your name, email address and message information, is automatically stored. Personal data provided voluntarily in this way is stored so that your request can be handled or we can contact you. We do not share this information outside Origina except where necessary to fulfil your request.

8. Use of Google analytics (with anonymization function)

The component Google Analytics (with an anonymization function) is integrated in our website. Google Analytics is a web analytics service. Web analytics is the collection, gathering and analysis of data on the behaviour of visitors on websites. Among other things, a web analytics service records data on the website from which a visitor accesses a website, which subpages are accessed, and how often and for how long a subpage was viewed. Web analytics is mainly used to optimize a website and to conduct a cost-benefit assessment of Internet advertising. The operator of the Google Analytics component is the company Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA. The purpose of the Google Analytics component is to analyze visitor flows on our website. Among other things, Google uses the data and information it gathers for evaluating the use of our website, compiling online reports on activities on our web pages for us, and providing services related to the use of our website. Google Analytics places a cookie, as described above, on the visitor’s device. Placement of the cookie enables Google to analyse the use of our website. Whenever a visitor accesses a page of our website on which Google Analytics is integrated, the visitor’s web browser is automatically prompted by Google Analytics to transmit data to Google for online analysis. As part of that technical process, Google may receive personal data, such as the IP address of the visitor’s device. This helps Google trace the origin of visitors and clicks and thus, for example, enable commission to be charged. The cookie is used to store information such as the time and location from which our website was accessed and how often the visitor used it. Whenever our web pages are visited, this personal data, including the IP address of the visitor’s device, may be transferred to Google in the United States of America and stored by Google there. Google may transmit the personal data collected by this technical method to third parties. As described above, you can prevent cookies from being placed by our website at any time by changing the relevant settings in your browser. Such a browser setting would also prevent Google from placing a cookie on your device. In addition, a cookie that has already been placed by Google Analytics can be deleted at any time in the web browser or by using other software programs. You can also prevent Google Analytics from recording data generated by your use of this website and from processing that data. To do that, you can download and install Google’s browser add-on at tools.google.com/dlpage/gaoptout. This browser add-on notifies Google Analytics by means of JavaScript that no data and information on visits to websites may be transmitted to Google Analytics. Installation of the browser add-on is interpreted by Google as an objection to the recording of data. If your device is deleted, formatted or reinstalled later, the browser add-on must be installed again in order to disable Google Analytics. If the browser add-on is uninstalled or disabled by you or another person using the same device, the browser add-on can be reinstalled or reactivated. More information and Google’s Privacy Policy can be found at https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en. More detailed explanations on Google Analytics can be found at https://www.google.com/analytics

9. Links to third-party websites

Origina’s website contains links to other websites. By clicking these links, you leave the Origina website. The presence of these links on Origina’s website does not mean that Origina supports, promotes or claims ownership of the sites to which we provide links. These linked sites are beyond the control of Origina and Origina accepts no responsibility for these linked websites, in particular for their content, their data protection and privacy policies or any possible transmission of data by them. You can view the privacy policies of the social media channels linked from our website below:

10. Third-party service providers

Our partners and service providers may process personal information about you on our behalf as described below: Digital Marketing Service Providers. We periodically appoint digital marketing agents to conduct marketing activity on our behalf. This activity may involve the compliant processing of personal information. Our appointed service providers include:

Demandbase – used for account-based marketing, advertising, campaign targeting, website personalisation and related analytics. Demandbase’s privacy notice is available at https://www.demandbase.com/privacy/.
ZoomInfo – used for business-to-business contact intelligence, prospecting, sales and marketing enrichment activities. ZoomInfo’s privacy policy is available at https://www.zoominfo.com/legal/privacy-policy.
Lusha – used for business-to-business contact validation, data enrichment, prospecting and marketing support activities. Lusha’s privacy notice is available at https://www.lusha.com/legal/privacy-notice/.
Google – used for advertising, analytics, Customer Match lists and enhanced conversion measurement. Where customer match lists or enhanced conversion data are used, personal data is encrypted or hashed before being shared with Google for matching and measurement purposes. Google’s privacy policy is available at https://policies.google.com/privacy

III. Collection and processing of personal data for job applications and in the application process

We collect and process personal data from job applicants for the purpose of processing job applications for open positions at Origina from the point at which we receive an applicant’s application documents. We will need to maintain and process data about you for the purposes of reaching and communicating a recruitment decision and making of an offer of employment if appropriate. The data collected includes your application details, employment history and interview notes where relevant. If we conclude an employment contract with an applicant, the data provided and any further information which will be gathered at the relevant time, will be subsequently used for the administration of your employment in accordance with statutory provisions. If we do not conclude an employment contract with an applicant, such data is retained for a period of twelve months following the recruitment process in the event that a suitable role becomes available. After the expiry of this period such data is destroyed or erased. Origina will provide a privacy notice for job applicants to individuals who submit a job application.

IV. Collection and processing of personal data as part of commissions

Personal data may be collected and processed as part of customer commissions, service engagements or similar arrangements, based on the requirements of the relevant engagement. In this context, Origina Ltd. may act as a processor, service provider or equivalent role under applicable privacy and data protection laws, and will process personal data in accordance with the relevant customer instructions and contractual terms.

V. Legal basis for processing personal data

We process personal data only where we have a valid legal basis under applicable privacy and data protection laws. Where the GDPR or UK GDPR applies, the relevant legal bases may include the following:

Consent — where we ask for and obtain consent for a specific purpose, the legal basis is consent under Article 6(1)(a) GDPR/UK GDPR. Consent will be requested clearly and separately for distinct purposes and will not be required where it is not necessary.
Contractual necessity or pre-contractual steps — where processing is necessary to perform a contract with the individual, or to take steps at their request before entering into a contract, the legal basis is Article 6(1)(b) GDPR/UK GDPR.
Legal obligation — where processing is necessary for us to comply with a legal obligation, such as tax, accounting, employment, corporate or regulatory obligations, the legal basis is Article 6(1)(c) GDPR/UK GDPR.
Legitimate interests — where processing is necessary for our legitimate interests, or those of a third party, and those interests are not overridden by the individual’s rights and freedoms, the legal basis is Article 6(1)(f) GDPR/UK GDPR. This may include operating, securing and improving our website, protecting our IT systems, preventing misuse, responding to enquiries, supporting direct marketing to business contacts, and conducting our business effectively.

Where other privacy or data protection laws apply, we rely on the equivalent lawful basis or permitted processing ground available under those laws. Where we rely on legitimate interests, we consider whether the processing is something the individual would reasonably expect, whether it has a limited privacy impact, and whether appropriate safeguards are in place. Individuals may object to processing based on legitimate interests where that right is available under applicable law, including under Article 21 GDPR/UK GDPR where relevant.

VI. Transmission of personal data

Personal data is transmitted to third parties only if that is authorized under data protection law, for example on the grounds specified under the Legal grounds for processing Section of this Policy, and to external service providers for processing on behalf of the controller and subject to its instructions. In general, data is not processed outside the EU or EEA. If data needs to be transmitted to a country outside the EU or EEA in an individual case, this is done solely on the basis of the EU standard contractual clauses or to countries for which an adequacy decision has been adopted by the EU and under a contract on processing on behalf of the controller. We will not sell your personal data to third parties or otherwise market it. Data transfers to the United States (for example, to some of our service providers like Google) are safeguarded by SCCs and other measures, We continuously monitor regulatory developments and guidance (including EDPB recommendations) regarding international data transfers, and we will adjust our measures accordingly.

VII. Length of time for which personal data is stored

The criterion for storing personal data is the respective statutory retention period. When this period ends, the data in question is routinely deleted, if and to the degree that it is no longer required to perform a contract or steps prior to a contract. However, data may continue to be stored where permitted by law, including where Origina has a legitimate business or legal need to retain it, such as to defend legal claims, maintain insurance cover, enforce rights, resolve disputes, or comply with limitation periods. If there is no such legitimate interest, this data is also routinely erased. Origina maintains records of relevant personal data processing activities and periodically reviews the data we hold. We have implemented policies to delete data that is no longer required. This means personal data will not be kept indefinitely – we regularly cleanse our databases, for example by removing inactive leads, ensuring opt-outs are respected, and purging outdated information.

VIII. Rights of individuals

Individuals may have certain rights in relation to their personal data under applicable privacy and data protection laws. These rights may vary depending on the law that applies, the individual’s location, the nature of the personal data, and the reason we process it. Where applicable, these rights may include the right to:

Access personal data — request confirmation of whether we process their personal data and receive information about that processing, including the purposes of processing, categories of personal data, recipients or categories of recipients, retention periods, the source of the data where it was not collected directly, and whether automated decision-making is used. To help us respond securely, the individual must sufficiently identify themselves and we may request additional information before fulfilling the request.
Receive a copy of personal data — request a copy of the personal data we process about them, where this right is available under applicable law.
Correct personal data — request correction of inaccurate personal data and completion of incomplete personal data.
Delete personal data — request deletion of personal data in certain circumstances, where there is no longer a valid reason for us to continue processing it. This right is not absolute and may be subject to legal, regulatory, contractual, legitimate business or other permitted grounds for retention.
Restrict or limit processing — request that we restrict, limit or suspend how we process their personal data in certain circumstances. Where this right applies, we may still be permitted to store the personal data and process it for limited purposes, including where required or permitted by law. This right may also be subject to exemptions under applicable law.
Object to processing — object to processing based on legitimate interests, direct marketing, targeted advertising, or other grounds where that right is available under applicable law.
Withdraw consent or opt out — withdraw consent at any time where we rely on consent as the legal basis for processing, or opt out of certain processing where an opt-out right is available under applicable law. Withdrawal of consent does not affect processing carried out before consent was withdrawn.
Data portability — request to receive personal data they provided to us in a structured, commonly used and machine-readable format, or request that we transmit it to another controller, where this right is available under applicable law.
Appeal or challenge a decision — where applicable, appeal or challenge a decision we make in response to a privacy rights request.
Automated decision-making — where granted by applicable law, not be subject to solely automated decisions, including profiling, that produce legal or similarly significant effects, and to request human review or contest the decision where permitted.
Lodge a complaint — make a complaint to a relevant data protection authority, privacy regulator or other authority responsible for handling privacy complaints.

We will respond to privacy rights requests in accordance with applicable legal timeframes. We may need to verify the identity of the requester before processing a request and may refuse or limit a request where permitted by law, including where the request is excessive, unfounded, affects the rights of others, or conflicts with legal obligations. Where the GDPR or UK GDPR applies, the rights described above include the rights set out in Articles 15 to 22 and Article 77 GDPR/UK GDPR. Where other privacy or data protection laws apply, we will honour the equivalent rights available under those laws.

IX. Privacy contact/Data Protection Officer

For privacy enquiries, rights requests or questions about how we process personal data, you can contact our privacy contact / Data Protection Officer using the details below:

Name: Diana Sirila
Address: Origina Ltd, Termini Building, 2nd Floor, 3 Arkle Road, Sandyford Business Park, Dublin 18, D18 T6T7, Ireland
Phone: +353 1 294 2300
Email: [email protected]
Webform: Privacy rights request form

X. Updates to this Privacy and Data Protection Policy

This Privacy and Data Protection Policy may need to be amended if our website and offerings are developed further or pursuant to changes in the law or official requirements, changes to our business or marketing practices or changes to the operation of our website.

Privacy and Data Protection Policy.