Privacy Policy

At Circol ELT Limited, we are committed to ensuring that your privacy and Personal Data are protected.  Our use of your Personal Data is governed by this Privacy Policy.

This Privacy Policy explains how we use your personal data and your rights in relation to that data, such rights being set out in the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018, together referred to herein as the “DPA”)

In this statement we use the terms “Circol ELT”, “we”, “our” and “us” to refer to Circol ELT CLG, which is a registered company (Companies Registration Office number 565567) and our registered office is at Red Cow Interchange Estate, 1 Ballymount Road, Clondalkin, Dublin 22.

Circol ELT is the data controller responsible for the personal data it collects, uses and stores about you. A data controller is someone who alone or jointly with others, determines the purposes and means of the processing of personal data.

We have appointed a Data Compliance Manager (DCM) who is responsible for overseeing the implementation and questions in relation to this Privacy Policy.  If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DCM using the details set out in section 10 below.



Personal data is any information relating to an identified or identifiable individual that allows us to identify you.  This could include information such as your name, postal address, telephone number, email address or date of birth.



Direct interactions.  You may give us your personal data by filling in forms or by corresponding with us by post, phone, and email or otherwise.  This includes personal data you provide when you:

  • Apply for membership to Circol ELT;
  • Create an account on our website;
  • Subscribe to our service or publications;
  • Request information to be sent to you or signing up to a mail list;
  • Enter a competition, promotion or survey;
  • Give us feedback or contact us;
  • Apply to work with us; or

Reply to a request for the provision of goods or services or solicitation of same.

Automated technologies or interactions.  As you interact with our website, we will automatically collect information about your equipment, browsing actions and patterns.  We collect this personal data by using cookies and other similar technologies.  Please see our cookie policy ( for further details.

Publically available sources such as social media and the Companies Registration Office.

Our website may include links to third-party websites, plug-ins and applications.  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for how they use your personal data or their privacy statements.  When you leave our website, we encourage you to read the privacy policy of every website you visit.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into  with you (for example, to provide you with services).  In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.



Under data protection law we are only permitted to use your personal data if we have a legal basis for doing so.  We rely on the following legal bases to use your personal data:

1.a)     To enter into and perform a contract with you

We may use your personal data in order to enter into a contract with you or to provide you with a service that you have requested from us.


1.b)      To comply with a legal obligation

We are required to use your personal data to comply with certain legal and regulatory obligations to which we are subject.


1.c)      For our legitimate interests

We may use your personal data for the purposes of carrying out activities that are in our legitimate interests (or those of a third party).  When we use your personal data in this way, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.

In more limited circumstances we may also rely on the following legal bases:

  • Where we need to protect your vital interests (or someone else’s vital interests); or
  • Where your personal data is needed in the public interest or for official purposes.


1.d)     With your consent

We may send you information by post, text, email and/or phone from time to time about waste reducing activities, campaigns and initiatives where you have consented to us contacting you in this way.  You can withdraw this consent at any time free of charge by following the opt-out links on any such communications sent to you.


1.e)      To recruit staff



We have set out below, in table format, a description of the ways we use your personal data, and which of the legal bases we rely on to do so.

Purpose/activity for which it is used


Lawful basis for processing


To register your business as a member and administer such membership


Performance of a contract with you


To process and administer your membership application including:

(a)   Managing payments, fees and charges

(b)   Collecting and recovering money owed to us

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)


To manage our relationship with you which will include asking you to leave a review or take a survey



Performance of a contract with you

Necessary for our legitimate interest (to keep our records updated; to assess how users engage with our services)


To enable you to partake in a campaign, prize draw, competition or complete a survey



Necessary for our legitimate interests (to assess how users engage with our services; to raise awareness and generate interest in our waste-reducing activities, campaigns and initiatives)


To administer, secure  and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)



Necessary for our legitimate interest (for the running of our business; provision of administration and IT services and network security; to prevent fraud)

Necessary to comply with a legal obligation


To deliver relevant website content to you, measure or understand the effectiveness of the content we serve and to allow you to participate in interactive features of our website when you choose to do so

Necessary for our legitimate interests (to assess how users engage with our services; to develop our services; to grow our business and to inform our marketing strategy)


To use data analytics to improve our website, services, marketing, member relationships and experiences


Necessary for our legitimate interests (to keep our website updated and relevant; to develop our business; to inform our marketing strategy)


To respond to any queries or other communications you submit to us


Necessary for our legitimate interest.


To create a candidate profile for you if you are a prospective employee


Necessary for our legitimate interest.


We do not collect special categories of personal data about you. Special categories of personal data include details about your and health, race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation and political opinions.