Privacy Policy

1. Introduction

1.1 The Wicklow Heather Gift Cards & eGift Cards website (the “Website“) is operated by Exclusives Gift Card System (“our“, “we” and “us”), with our main office at Unit 69, Cookstown Rd, Cookstown Industrial Estate, Dublin, D24 N702. We operate the Website on behalf of The Wicklow Heather Restaurant Limited, trading as Wicklow Heather, with their registered office at Oyster Point, Temple Road, Blackrock, Co Dublin, A94 E3P9. At Exclusive Gift Card System and Wicklow Heather, we respect your right to privacy and this Privacy Policy (the “Policy“) sets out the basis on which we use, process, store or disclose any personal data detailed below (“Personal Data“) that we collect from you or that you provide to us through the Website. The information provided by you will be held by us as a controller.

1.2 This Policy, together with our Terms & Conditions and our Cookie Policy applies to your use of the Website.

2. Overview of this Policy

2.1 We collect and process your Personal Data when you use our websites (including to purchase our products) and when you engage us. Our processing operations are mainly necessary to enter into and perform our contract with you, necessary for the purposes of our legitimate interests, or based on you having given us consent. We store your Personal Data on servers located within the European Economic Area (the “EEA”). We share your Personal Data within Wicklow Heather (as defined in Section 5 below) and with third parties. We may also share your Personal Data with law enforcement agencies or other bodies if we are required by law to do so.

3. The personal data we process

3.1 We will collect and process the following Personal Data when you use the Website:

Device Information

When using the Website and availing of services through the Website, Personal Data will be collected from you through the use of cookies and by Wicklow Heather Gift Cards & eGift Cards. This includes information about: your device type, operating system, browser, IP address and other information derived from cookies used on the Website. Please see our Cookie Policy for further information; and details of your visits to the Website such as traffic data, location data and the resources advertisements and Linked Websites that you access through the Website.

3.2 You can choose to provide us with the following Personal Data:

Purchase Information

If you make a purchase using the Website, we will process your email address, your name, telephone number, company name (if you choose to provide it), your address (both for shipping and billing), your order information.
Please note that we do not process or store any card or payment information on our own servers as we engage with third parties for this. For more on card and payment information, please see Security, Storing and Transfers of Your Personal Data in Section 6.

Customer Account Registration Information

If you choose to register a Customer Account with us you will have to provide us with information including your email address, a password of your choosing, your name, your phone number and your address. You may also choose to provide us with the name of your company.
Where you choose to register a Customer Account with us, we will process your transactional information and purchase history.

Subscription Information

If you choose to subscribe to our marketing material, we will process your email address and phone number in order to send this to you, but also information about how you interact with the emails and SMS messages you receive from us, such as whether or not you open the communication, the links you click on, whether you purchase anything or whether you opt out of the communications.

Query Information

You may choose to give us information such as your name, email address, address, telephone number and other details when contacting us by submitting enquiries through the Website contact form or by emailing
If you choose to provide us with this information, we will keep a record of this correspondence for as long as is necessary to deal with this query (for further information please see our section on How Long We Keep Your Personal Data For in Section 8).

4. How and why we use your personal data

4.1 The following table details the legal basis for (“Legal Basis“) and the reasons why (“Purposes“) we process your Personal Data:

Legal Basis	Purpose(s)	Personal Data Processed
Contract It is necessary to process Personal Data to enter into and perform our contract with you in relation to: Your use of the Website as set out in the Terms & Conditions; The provision of goods and services which you purchase through the website; To provide you with a customer account; and The benefits of our Loyalty Programme. If you do not wish to provide us with your Personal Data for these purposes, we will not be able to enter into or perform our contract(s) with you and you will need to leave the Website instead.	Access to the Website To provide you with access to the Website and to allow you to use the Website. Fulfilling your Orders and Requests To provide you with information and items that you request from us and to fulfil orders placed through the Website shop. To process your purchases. To process your payments, through our third party payment providers. To prevent the fraudulent use of gift vouchers. Customer Account To create your online customer account for you to use on the Website. To process your purchases through this account. To otherwise manage and administer your customer account.	Device Information Purchase Information Customer Account Registration Information
Legitimate Interests It is in our legitimate interests to collect and process your Personal Data for the purposes of improving and monitoring website efficiency, enhancing your use of the Website. It is also necessary for the purposes of our legitimate interests to process your Personal Data to respond to any queries or requests submitted by you to us. When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not process your Personal Data for activities where our interests are overridden by the impact on you.	Improving Website Functionality and Efficiency To provide, improve, test and monitor the effectiveness of the Website. To monitor metrics such as total number of visitors, traffic data and demographic patterns. To ensure the content on the Website is presented in the most effective manner for you and your device. Responding to Queries To process and respond to any enquiries or requests you submit to us by emailing us at To seek your views on the Website and our services.	Device Information Query Information Third Party Information
Consent We process your Personal Data for these purposes where we have your consent to do so. Should you wish to withdraw your consent to our processing of your Personal Data for these purposes you may do so by contacting You will also be given an option to opt-out on each communication you receive. However, please note that any processing carried out before you withdraw your consent will remain valid.	Promotional and Marketing Materials To send you the rewards, exclusives and promotional material that you subscribe for or that you consent to receiving in the course of setting up your customer account.	Subscription Information
Compliance with a Legal Obligation We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject to.	Legal Obligations To comply with our obligations under consumer, tax and other Irish and European laws.	Device Information Purchase Information Customer Account Registration Information Subscription Information Query Information Third Party Information
To Defend, Establish or be a Party to Legal Claims We may process your Personal Data as necessary in order for us to establish, investigate, exercise or defend a legal claim to which you are a party.	Legal Proceedings To file legal proceedings. To investigate, establish, exercise or defend a legal claim. To settle legal claims.	Device Information Purchase Information Customer Account Registration Information Subscription Information Query Information Third Party Information

Legal Basis

Purpose(s)

Personal Data Processed

Contract

It is necessary to process Personal Data to enter into and perform our contract with you in relation to:

Your use of the Website as set out in the Terms & Conditions;
The provision of goods and services which you purchase through the website;
To provide you with a customer account; and
The benefits of our Loyalty Programme.

If you do not wish to provide us with your Personal Data for these purposes, we will not be able to enter into or perform our contract(s) with you and you will need to leave the Website instead.

Access to the Website

To provide you with access to the Website and to allow you to use the Website.

Fulfilling your Orders and Requests

To provide you with information and items that you request from us and to fulfil orders placed through the Website shop.
To process your purchases.
To process your payments, through our third party payment providers.
To prevent the fraudulent use of gift vouchers.

Customer Account

To create your online customer account for you to use on the Website.
To process your purchases through this account.
To otherwise manage and administer your customer account.

Device Information
Purchase Information
Customer Account Registration Information

Legitimate Interests

It is in our legitimate interests to collect and process your Personal Data for the purposes of improving and monitoring website efficiency, enhancing your use of the Website.

It is also necessary for the purposes of our legitimate interests to process your Personal Data to respond to any queries or requests submitted by you to us.

When we process your Personal Data based on our legitimate interests, we make sure to consider and balance any potential impact on you and your data protection rights. We will not process your Personal Data for activities where our interests are overridden by the impact on you.

Improving Website Functionality and Efficiency

To provide, improve, test and monitor the effectiveness of the Website.
To monitor metrics such as total number of visitors, traffic data and demographic patterns.
To ensure the content on the Website is presented in the most effective manner for you and your device.

Responding to Queries

To process and respond to any enquiries or requests you submit to us by emailing us at
To seek your views on the Website and our services.

Device Information
Query Information
Third Party Information

Consent

We process your Personal Data for these purposes where we have your consent to do so.

Should you wish to withdraw your consent to our processing of your Personal Data for these purposes you may do so by contacting You will also be given an option to opt-out on each communication you receive. However, please note that any processing carried out before you withdraw your consent will remain valid.

Promotional and Marketing Materials

To send you the rewards, exclusives and promotional material that you subscribe for or that you consent to receiving in the course of setting up your customer account.

Subscription Information

Compliance with a Legal Obligation

We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject to.

Legal Obligations

To comply with our obligations under consumer, tax and other Irish and European laws.

Device Information
Purchase Information
Customer Account Registration Information
Subscription Information
Query Information
Third Party Information

To Defend, Establish or be a Party to Legal Claims

We may process your Personal Data as necessary in order for us to establish, investigate, exercise or defend a legal claim to which you are a party.

Legal Proceedings

To file legal proceedings.
To investigate, establish, exercise or defend a legal claim.
To settle legal claims.

Device Information
Purchase Information
Customer Account Registration Information
Subscription Information
Query Information
Third Party Information

5. Who we share your personal data with

5.1 We may disclose your Personal Data to other members of our (“Wicklow Heather“) group which means our subsidiaries, our ultimate holding company and its subsidiaries, if applicable.

5.2 We will disclose your personal information to third parties outside Wicklow Heather including in the following circumstances:

Recipient
Third Party Service Providers To couriers and other parties who deliver our goods to you when you make an order. To send you postal, email and SMS messages via third party communications or delivery service providers. To process your credit card payments. For logistical and IT service purposes. To provide our customer service infrastructure including our helpdesk features.
Regulatory Authorities, Law Enforcement Agencies, Public Bodies and Other Third-Party Companies To comply with any applicable legal obligation, court order, summons, search warrants, or any other legal or regulatory obligation or request to which Wicklow Heather Gift Cards & eGift Cards is or may become subject; and To protect the rights, property or safety of Wicklow Heather Gift Cards & eGift Cards, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Recipient

Third Party Service Providers

To couriers and other parties who deliver our goods to you when you make an order.
To send you postal, email and SMS messages via third party communications or delivery service providers.
To process your credit card payments.
For logistical and IT service purposes.
To provide our customer service infrastructure including our helpdesk features.

Regulatory Authorities, Law Enforcement Agencies, Public Bodies and Other Third-Party Companies

To comply with any applicable legal obligation, court order, summons, search warrants, or any other legal or regulatory obligation or request to which Wicklow Heather Gift Cards & eGift Cards is or may become subject; and
To protect the rights, property or safety of Wicklow Heather Gift Cards & eGift Cards, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6. Security, storing and transfers of your personal data

6.1 We store and process your Personal Data on servers located within the European Economic Area (the “EEA“). However, we may transfer your Personal Data outside the EEA where we engage with third party services providers. We only transfer your personal data outside the EEA where the European Commission has decided that the third country in question ensures an adequate level of protection in line with EEA data protection standards or there are appropriate safeguards in place to protect your Personal Data. If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact us at

6.2 Information you provide to us through the Website is protected by encryption. Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your Personal Data, we cannot guarantee the security of any information you transmit to us. Any transmission is at your own risk. Once we have received your information, we use strictly maintained physical, electronic and procedural safeguards to prevent unauthorised access.

6.3 Wicklow Heather Gift Cards & eGift Cards does not store or process any of your card or payment information. All payment information is processed by third party service providers engaged by us for this purpose, including Stripe who are Level 1 PCI DSS v3.2 certified.

7. Links

7.1 The Website contains links to other websites (“Linked Websites“). Wicklow Heather is not responsible for the privacy policies, statements or practices on the Linked Websites. This Policy governs only information collected on the Website. When accessing Linked Websites, you should read the privacy policy or statement published on the relevant Linked Website. The terms of our Policy do not apply to Linked Websites. Please check these policies or statements before you submit any Personal Data to Linked Websites.

7.2 The Website contains links to other websites and resources provided by third parties for your convenience and information only. We accept no liability in connection with any Linked Website, or any contract entered into on or through a Linked Website. We have no control over the contents of those websites or resources, and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.

8. How long we keep your personal data for

8.1 We will keep your Personal Data no longer than is necessary for the purposes for which the data was provided.

8.2 Please note that in certain circumstances, we may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.

9. Your rights and how to exercise them

9.1 The table below sets out the rights which you have to address any concerns or queries with us about our processing of your personal data:

Right	Further Information
Right to be Informed	You have the right to know whether your Personal Data is being processed by us, how we use your Personal Data and your rights in relation to your Personal Data.
Right of Access	You have the right to request a copy of the Personal Data held by us about you and to access the following information in relation to the processing of your Personal Data: The purposes of processing; The categories of Personal Data concerned; The recipients of your Personal Data; The period for which your Personal Data will be stored; The existence of your right to lodge a complaint with the Office of the Data Protection Commissioner; and The source of your Personal Data; We will only charge you for making such an access request where we feel your request is unjustified or excessive.
Right to Rectification	You have the right to request that we amend any inaccurate Personal Data that we have about you.
Right to Erasure	You have the right to ask us to erase your Personal Data where: It is no longer necessary to perform the contract; You withdraw your consent and there is no other legal basis permitting us to process your Personal Data; You object to the processing and we have no overriding legitimate grounds; Your Personal Data have been unlawfully processed; or It must be erased to comply with a legal obligation. Please note that some of your Personal Data may be required in order for the Website to function properly.
Right to Restriction of Processing	You have the right to ask us to restrict processing your Personal Data in the following situations: Where you contest the accuracy of your Personal Data; Where the processing is unlawful and you do not want us to delete your Personal Data; Where we no longer need your Personal Data for the purposes of processing but you require the data in relation to a legal claim; or Where you have objected to us processing your Personal Data pending verification as to whether or not our legitimate interests override your interests or in connection with legal proceedings. When you exercise this right, we may only store your Personal Data. We may not further process the data unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest. Please note that it be may necessary for us to process some of your Personal Data in order to provide the Website services and in certain instances where you ask us not to process your Personal Data you may not be able to use the Website. We will inform you before the processing restriction is lifted.
Right to Data Portability	You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where we process your Personal Data on the legal bases of your consent or where it is necessary to perform our contract with you.
Right to Object	You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

9.2 You can exercise any of these rights by submitting a request to

9.3 We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within one month of receiving your request. We may extend this up to 2 months if necessary however we will inform you if this arises.

9.4 You have the right to lodge a complaint with a data protection supervisory authority with regards to us processing your Personal Data.

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

We use cookies in the following ways:

to track how you use our website
to record whether you have seen specific messages we display on our website
to keep you signed in to our website
to record your answers to surveys and questionnaires on our site while you complete them
to record the conversation thread during a live chat with our support team
Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

11. Changes to this Privacy Policy

11.1 If we amend this Policy, in whole or part, any changes will be posted on this page and, where appropriate, notified to you by email or when you use the Website. The new Policy may be displayed on-screen and you may be required to read and accept it to continue your use of the Website.

11.2 If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Policy, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail, and you will have a choice as to whether or not we use your Personal Data in the new manner.

12. Who to contact with queries

12.1 Questions, comments and requests regarding this Privacy Policy are welcomed and should be sent to