Privacy Statement
ReGEN(“we” or “us”) will collect and process your Personal Data and other information in relation to your dealings with us, including through your use of the ReGEN website, ReGEN.aero (the “Website”). This Privacy Statement explains how ReGEN will manage your Personal Data, why we use it, and how you may contact ReGEN in relation to the use of your Personal Data.
Types of Information We Collect
We collect information, which includes Personal Data, about directors, officers, employees, agents, guarantors and / or authorised signatories of ReGEN’s customers, suppliers, service providers, vendors and other commercial partners, and media contacts (“Individuals”) for the purposes of and in connection with ReGEN’s dealings with those relevant commercial and other entities. You may be such an Individual.
Personal Data means any information which ReGEN has or obtains, or which you provide to ReGEN, and includes your name, address, email address, phone number(s), title or position and any other information from which you can be directly or indirectly personally identified.
We may also collect certain statistical and other analytical information collected on an aggregate basis relating to all visitors to the Website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding browser types, mobile device equipment, mobile network and other anonymous statistical data involving the use of the Website.
We collect this information to help us monitor traffic and enhance your experience of the Website. Please see further detail on this in our Cookie Policy.
How We Obtain Your Information
We will obtain some of your Personal Data directly from you where we interact directly with you in the course of our business. We may also obtain Personal Data directly from you through the Website, such as (i) when you sign up to our mailing list, (ii) when you sign up to receive financial results, or (iii) when you apply for a position with ReGEN.
This information may be collected indirectly from a variety of sources, such as the commercial entity which you represent, publicly available sources including media reports and social media, such as LinkedIn, and from any of the companies within ReGEN with which you interact.
Use of Personal Data and Basis of Processing
ReGEN will use the Personal Data where necessary:
- (a) for the purposes of “know your customer” (“KYC”) and sanctions screening due diligence checks which we undertake relating to our customers, service providers trading counterparties, consignment partners and their guarantors (where applicable) among others, as may be applicable;
(b) for the purposes of managing its contracts and relationships with its customers, suppliers, service providers, vendors and other commercial partners;
(c) for day to day operational and business purposes, including recruitment purposes;
(d) board reporting and management purposes;
(e) in the event of a merger, reorganisation or disposal of, or a proposed merger, reorganisation or disposal of (all or part of) ReGEN; and/or
(f) to take advice from ReGEN’s external legal and other advisors; - for compliance with ReGEN’s legal obligations, including:
(a) compliance with applicable tax and regulatory reporting obligations; and/or
(b) where ReGEN is ordered to disclose information by a court with appropriate jurisdiction; - where necessary to establish, exercise or defend its legal rights or for the purpose of legal proceedings; and/or
- where you have consented to the use of your Personal Data for a particular purpose. If you give consent for ReGEN to use your Personal Data for a particular purpose (e.g., when signing up to ReGENmailing list) you have the right at any time to withdraw consent to the future use of your Personal Data for some or all of those purposes by writing to the address specified below.
Know Your Customer
We may collect certain documentation (which contains Personal Data) from you for KYC purposes. This documentation includes proof of identity (e.g. copy passport / driving licence) and proof of address (e.g. copy utility bill). We are not under a legal obligation to collect this documentation. However, we consider it a legitimate business interest of ReGEN to verify the identity of our customers, service providers trading counterparties, consignment partners and their guarantors (where applicable) among others as may be applicable for anti-money laundering and counter-terrorist financing and for sanctions screening purposes.
Applicants for jobs
Where you, or a third-party recruitment agent acting for you, provides us with your CV and other Personal Data, we will use that information solely for the purposes of considering your application for a position with ReGEN, including to check your references. However, we will only hold Personal Data of applicants for positions for a period of 12 months from our final interaction with a candidate during the recruitment process. If you are a successful candidate, some of the Personal Data we obtain during the recruitment process will be held on your personnel file, which will be subject to our separate Employee Privacy Statement.
Sharing Personal Data
ReGEN may disclose your personal data to parties as outlined above and / or as follows:
(a) to enable ReGEN to carry out the obligations under and enforce its contracts with its customers, suppliers, service providers, vendors and other commercial partners;
(b) to anyone providing a service to ReGEN or acting as ReGEN’s agent, including data processors, for the purposes of providing services to ReGEN;
(c) where ReGEN needs to share Personal Data with its auditors, and legal and other advisors;
(d) in the event of a merger or proposed merger, any (or any proposed) transferee of, or successor in title to, the whole or any part of ReGEN’s business, and their respective officers, employees, agents and advisers, to the extent necessary to give effect to such transaction; and
(e) the disclosure is required by law or regulation, or court or administrative order having force of law, or is required to be made to any of ReGEN’s regulators.
You should note that where you interact with one member of ReGEN’s group of companies, your Personal Data may be shared with the other members of ReGEN’s group of companies for the purposes and in the circumstances outlined above.
International transfers
Personal Data may be transferred outside the country in which you or the ReGEN entity with which you initially interact in connection with the uses described above are located. This will occur where you have explicitly consented to the transfer, and / or as otherwise required or permitted by law.
Many of the countries to which Personal Data is transferred will be within the European Economic Area (the “EEA”), or will be ones which the European Commission has approved, and will have data protection laws which are the same as or broadly equivalent to those in the European Union. However, some transfers may be to countries which do not have equivalent protections, and in that case ReGEN shall ensure that any transfers will be done in accordance with applicable data protection laws, including through the implementation of appropriate or suitable safeguards in accordance with such applicable data protection laws.
For the avoidance of doubt, safeguards in the form of EU Commission approved standard contractual clauses will be implemented where personal data is transferred for processing to any ReGEN member or a service provider outside the EEA. Further information in relation to international transfers can be obtained by writing to us at the address specified below.
Third Party Providers of Information
ReGEN may obtain Personal Data relating to Individuals from someone other than that Individual, such as his / her employer. The person providing the information will be asked to warrant that it will only do so in accordance with applicable data protection laws, and that it will ensure that before doing so, the Individuals in question are made aware of the fact that ReGEN will hold information relating to them and that it may use it for any of the purposes set out in this Privacy Statement, and where necessary that it will obtain consent to ReGEN’s use of the information.
Recipients of the Personal Data
In any case where ReGEN shares Personal Data with a third-party data controller, the use by that third party of the Personal Data will be subject to the third party’s own privacy policies.
Updates to Personal Data
ReGEN will use reasonable efforts to keep Personal Data up to date. However, you will need to notify ReGEN without delay in the event of any change in your personal circumstances, or those of the others mentioned above, so that ReGEN can keep the Personal Data up to date.
Retention of Personal Data
ReGEN will not hold your personal data for longer than is necessary. We retain your personal data for as long as we need it for the purposes described in this privacy statement, or to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise between you and us.
Your Rights in relation to Personal Data
You may at any time request a copy of your Personal Data from ReGEN. This right can be exercised by writing to ReGEN at the address specified below.
You also have the right to correct any inaccuracies in, and in certain circumstances, to request erasure, or restriction on the use, of your Personal Data, and to object to certain uses of your Personal Data, in each case subject to the restrictions set out in applicable data protection laws. In some circumstances you are also entitled to receive a copy of your personal data in a structured, commonly used, electronic form, or to request us to transfer your data in this form to a third party. Further information on these rights, and the circumstances in which they may arise in connection with ReGEN’s processing of Personal Data, can be obtained by writing to ReGEN at the address specified below.
In any case where ReGEN is relying on your consent to process your Personal Data, you have the right to change your mind and withdraw consent by writing to the address specified below.
Where ReGEN is relying on a legitimate interest of ReGEN or a third party recipient of the Personal Data, in order to use and disclose Personal Data, you are entitled to object to such use or disclosure of your Personal Data, and if you do so, ReGEN will cease to use and process the Personal Data for that purpose unless ReGEN can show there are compelling legitimate reasons for it to continue or it needs to use the Personal Data for the purposes of legal claims.
You also have the right to lodge a complaint about the processing of your Personal Data by ReGEN with the Data Protection Commission, or your local supervisory authority. You can contact the Data Protection Commission at the following address:
Data Protection Commissioner
21 Fitzwilliam South
Dublin 2
D02 RD28
Ireland
Contacting ReGEN
Any queries or complaints regarding the use of employee-related Personal Data by ReGEN and / or the exercise of your rights should be addressed to ReGEN at legal@genesis.aero or by writing to:
ReGEN
Attn: Legal Department
7th Floor, Block I, Central Park
Leopardstown, Dublin 18, D18 HCP5
Ireland
Any queries or complaints regarding the use of all other Personal Data by ReGEN and / or the exercise of your rights should be addressed to ReGEN at legal@genesis.aero or by writing to:
ReGEN
Attn: Legal Department
7th Floor, Block I, Central Park
Leopardstown, Dublin 18, D18 HCP5
Ireland