Safety on Site App Privacy Policy

Global Sensing Solutions Technology Limited ("we", "us" or "our"), a private limited company incorporated in Ireland with company registration number 724311, is committed to protecting and respecting your privacy and data protection rights. This privacy policy (the "Policy") sets out how we, as a data controller, collect and process personal data about you when you use our Safety On Site mobile application (the "App"), a platform that enables site visitor registration and other safety and compliance capability for construction sites, in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), the Irish Data Protection Acts 1988 to 2018, the EU Privacy and Electronic Communications Directive 2002/58/EC (the "e-Privacy Directive"), and any national implementing laws, as amended or updated from time to time.

By publishing this Policy, we intend to ensure that you understand how and why we collect, process and use your personal data, your rights regarding your personal data, and how you can exercise those rights.

Scope And Related Policies

This Policy applies to you as an individual that has been invited to or given access to use the App by the contractor who is engaging you to work on a given construction project (the "Organisation") ("you" or "your"). It applies to all personal data collected, maintained, transmitted, stored, retained, or otherwise used by us regardless of the media or device on which that personal data is stored.

This Policy does not apply to any third-party websites or other services, including those of the Organisation, which may provide information or otherwise be made available through the App.

Personal Data We May Collect About You

When you download the App, create an account with the App, and become a user of the App we will collect personal data from you in order for you to use the App and the Organisation to make use of the dashboard functionality.

"Personal data" is defined as any data relating to a living individual who can be identified directly from that data or indirectly in conjunction with other information.

The categories of personal data that we collect include the following:

General Categories of Personal Data

Identifying/Contact Data	email address, employee ID.
Account Data	your password.
Profile Data	your role/skill (e.g. bricklayer, carpenter, electrician) and seniority/experience.
Geolocation	information related to your presence and activity on the project site you are working at (including in particular in terms of your allocation at certain areas of the site). Location information is collected through your mobile device when you step into a geo-fenced work site as configured by the Organisation (a "geo-fence" is a virtual perimeter around a geographic area). The App uses the GPS location tracking features on your mobile device to generate and present data and insights on the allocation of your team generally and of workers with your role/skill and seniority/experience, collectively, for the Organisation.
Technical Data	information about your device, including your hardware model, operating system and version, unique device identifier, mobile network information and information regarding your interaction with the App, including your access time and date, browser type and language, and Internet Protocol (IP) address.

How Your Personal Data Is Collected

We collect personal data from and about you in the following ways:

Direct interactions: personal data you provide to us directly through your use of the App, and which you provide us when providing feedback to us or when you communicate with us via other means, such as by email or post.
Automated/technological means: personal data we collect when you interact with the App (e.g. when you sign up and use the App). For example, we will automatically collect Technical Data about your device to provide you with functionality of the App.
Third Parties: personal data that has been provided to us by the Organisation and by other third-party sources (e.g. from our third party service providers). These third-party service providers include:
- Google (in relation to its Google Play Store and Google Firebase platform). Click here to view the Google Privacy Policy;
- the Organisation and/or the contractor you are engaged by in relation to a given construction project, in relation to your Profile Data;
- MSite, who operate and maintain access gates on-site, provide us with your Identifying/Contact Data; and
- providers of the technical infrastructure underpinning the App.

How And Why We Process Your Personal Data

We will process your personal data for the following purposes and according to the following legal bases:

Categories of Personal Data Processed	Purpose(s) for Processing	Legal Basis for Processing
Identifying / Contact Data	To send you a communication linking you to the App. To provide our App to you and to enable you to use it. To match you as an App user against the database of workers on a given construction project.	This processing is necessary in pursuit of our legitimate interests in managing our business and making the App available, and those of the Organisation in providing you and the Organisation with the features and functionality of our App.
Identifying / Contact Data Account Data	To identify you as a user of our App. To enable you to access and use the App. To enable us to send a notification to you via the App should it become necessary to do so.	This processing is necessary in pursuit of our legitimate interests in managing our business and making the App available, and those of the Organisation in providing you and the Organisation with the features and functionality of our App.
Identifying / Contact Data Profile Data	To identify your role and seniority on a given project To facilitate appropriate communications from us to you. To deliver insights to the Organisation on the allocation of workers with your role/skill and seniority/experience on-site, and whether work is being appropriately supervised.	This processing is necessary in pursuit of our legitimate interests in managing our business and making the App available, and those of the Organisation in providing you and the Organisation with the features and functionality of our App.
Geolocation Data Profile Data	To deliver insights to the Organisation on the presence and activity of your team, and workers with your role/skill and seniority, on-site. To deliver insights to the Organisation on the presence and allocation of team members on-site at a given time. To facilitate time-sensitive communications to you by the Organisation in relation to activity or incidents on-site, especially in emergency circumstances.	This processing is performed on the basis of your consent.
Technical Data	To enable and facilitate your use of our App. To identify and address issues and scope for improvement of the App. To optimise the performance of the App. To understand how you use the App	This processing is necessary in pursuit of our legitimate interests in managing our business and making the App available, and making improvements.
We may also process your personal data for the purposes of establishing, exercising or defending legal proceedings.

Please note that you have a right to object to processing of your personal data where that processing is carried out on the basis of our pursuit of legitimate interests. Where we rely on our legitimate interests as a legal basis for processing your personal data, we have considered whether those interests are overridden by the impact on your rights and freedoms and have concluded that they are not.

If you fail to provide certain personal data, we may not be able to provide the App or certain features and functionality of the App.

Change Of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and update this Policy, which will explain the legal basis which allows us to do so.

How We Share Your Personal Data With Others

It will be necessary from time to time for us to disclose your personal data to third parties, including the following:

The Organisation, who we provide with an overview of certain personal data collected via the App;
Third parties to assist in the administration, processing and management of certain activities pertaining to the provision of the App;
Third parties to whom you have expressly consented we may share your personal data with;
Third parties such as emergency services where it is necessary to protect your vital interests or the vital interests of another individual;
Regulatory bodies to whom we are obliged or required to disclose information including Courts and Court-appointed persons for compliance with our legal obligations, and/or to establish, exercise or defend legal claims;
Insurance or assurance companies and health insurance providers;
Legal and medical practitioners;
Relevant Government departments and agencies;
Other users of our services with whom you interact through your own use of the App; and
Other support service providers necessary to assist us with the above.

We take all reasonable steps, as required by law, to ensure the safety, privacy and integrity of such data and information and, where appropriate, enter into contracts with such third parties to protect the privacy and integrity of such data and any information supplied.

Links To Other Sites

The App may from time to time contain links to and from other websites/apps. If you follow a link to any of those websites/apps, please note that those websites/apps have their own privacy policies and we do not accept any responsibility or liability for those policies. Please review those policies before you submit any personal data.

International Data Transfers

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA), for the purposes described above. In some cases these transfers are to countries which the European Commission has determined provide an adequate level of protection of personal data (such as the United Kingdom); otherwise we ensure that appropriate safeguards are in place to protect your personal data in the context of such transfers (such as in relation to transfers to our third party service providers in the US).

Data Retention

We will store your personal data only for as long as necessary in relation to the purposes for which we collected your personal data. Generally, this will only be until your Organisation has completed its engagement on the construction project you are working on, but we may retain your personal data for a longer period of time where necessary to comply with our legal obligations, where we are required to do so by law or regulatory guidance to which we are subject, to establish, exercise or defend legal claims, and to protect your vital interests or the vital interests of another person. Our retention periods are reviewed and updated from time to time in line with legal requirements and best practice.

For further information, please refer to the Contact Us section below.

Security

We are committed to protecting the security of your personal data.

We have implemented appropriate physical, organisational and technical security measures to protect your personal data from accidental loss, unauthorised access, use, alteration or disclosure.

As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply or we have received from third parties will not be intercepted while being transmitted to us over the internet.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach as appropriate and in accordance with our legal obligations.

Automated Decision-Making

Automated decision-making takes place when an electronic system uses personal data to make a decision about you which has legal or similarly consequential effects, without human intervention. We do not process your personal data to perform any automated decision-making, however we will notify you in writing if this position changes.

Your Rights In Relation To Your Personal Data

You have the right to request access to, rectification of, or erasure of your personal data, restriction of the processing of your personal data, and to object to the processing of your personal data, as well as the right to data portability. The following is a summary of what these rights involve:

The right of access enables you to receive a copy of your personal data.
The right to rectification enables you to ask us to correct any inaccurate or incomplete personal data we hold about you.
The right to erasure enables you to ask us to delete your personal data in certain circumstances, for example where it is no longer necessary for us to process it.
The right to restrict processing enables you to ask us to halt the processing of your personal data in certain circumstances, for example if you want us to verify its accuracy or our legitimate interests in processing it.
The right to object enables you to object to your personal data being processed on the basis of our legitimate interests (or those of a third party), including processing for direct marketing purposes. We will cease processing your personal data unless the processing is based on compelling legitimate grounds or is needed for the exercise or defence of legal claims.
The right to data portability enables you to ask us to transmit the personal data, that you provided to us, to a third party without hindrance, or to give you a copy of it so that you can transmit it to a third party, where technically feasible.

Please note that these rights are not absolute and are subject to restrictions, limitations and exceptions as provided for in law.

Where we process your personal data for a specific purpose on the basis of your consent, you have the right to withdraw your consent at any time. Your withdrawal of your consent will not affect the lawfulness of our processing based on consent before its withdrawal. If you wish to exercise this right, please see the Contact Us section below.

If you wish to exercise any of these rights, please see the Contact Us section below. We will respond to your request within one month. That period may be extended by two further months where necessary, taking into account the complexity and number of requests. We will inform you of any such extension within one month of receipt of your request. We may request proof of identification to verify your request. We have the right to refuse all or part of your request where there is a legal basis to do so, or if it is manifestly unfounded or excessive, or to the extent necessary for important objectives of public interest.

Making A Complaint

If you believe your privacy rights have been breached or you have a complaint about how we handle your personal data we ask that you please contact us in the first instance using the details below in the Contact Us section.

You also have the right to lodge a complaint with the Office of the Data Protection Commission (DPC) at any time. Click here for contact details of the DPC.

Contact Us

If you have any questions or concerns regarding this Policy, or if you want to exercise any of your rights, please contact us in writing:

by email: info@gsst.io; or
by post: Global Sensing Solutions Technology, 36 Fitzwilliam Square, Dublin 2, Ireland.

All questions and requests will be dealt with as promptly and efficiently as possible.

Changes to this Privacy Policy

We reserve the right to change this Policy from time to time at our sole discretion. Changes to this Policy are effective immediately. If we make any changes, we will post those changes here and update the "Last Updated" date at the bottom of this Policy. However, if we make material changes to our Policy we will notify you by sending you a communication via the App, by email, and/or by means of a prominent notice presented to you when next open the App.

Last Updated: 8th November 2023