Introduction

PXS provides the communications industry with user friendly and accessible numbering management and data processing services. Managing and maintaining the National Directory Database (NDD) for Ireland is an example of the services provided by PXS.

PXS designs and implements secure and reliable solutions for an international customer base, customised to and compliant with current and evolving national regulations and policies. As such, PXS is committed to the protection of the data and privacy of their customers and end users.

Applicability

This privacy statement applies to the processing of personal data by PXS as directed by the  Commission for Communications Regulation (ComReg) under ComReg Decision D16/18 . PXS respects your privacy and ensures that your personal data are processed in accordance with applicable laws and regulations. 

The purpose of this privacy statement is to inform you about which personal data are collected by PXS, for which purpose they are collected and on the basis of which principles they are collected. We also inform you about how your personal data are processed, which rights you have when your personal data are processed and who you can contact if you have questions concerning your privacy.

What are personal data?

Personal data are data that relate to an identified or identifiable natural person.

Type of data being processed

PXS receives your personal data from your telecommunications provider. Based on the data provided by your telecommunications provider, PXS may process the following personal data:

1. Surname or Company/Business Name
2. First Name/Rest of Name
3. Address Premises
4. House Number
5. City/Town
6. Post Code
7. County
8. Phone number
9. Type of Telephone listing

Processing purposes

PXS only processes personal data for the specified, explicit, and legitimate purposes. Your personal data will not be processed for any purpose that does not comply with this principle without your consent.

To manage and maintain the NDD, PXS processes personal data for two purposes. The first purpose is to facilitate the listing preferences of all subscribers of public telephony services in Ireland, including those with fixed, personal and mobile numbers, as to whether they wish to be listed for telephone directories and directory enquiry services purposes. The subscriber preferences for listing their telephone numbers are:

• Listed: Details (name, address, telephone number) are listed in the telephone directory and with Directory Enquiries;
• Unlisted : Listed with Directory Enquiries only, i.e. not in the phonebook;
• Ex-Directory: Details not listed in the phone book or with Directory Enquiries.

The second purpose is to facilitate the “opt-out” register for direct marketing purposes, by which subscribers opt out to be contacted by direct marketing companies.

Processing principles

PXS only processes your personal data if and in so far as at least one of the conditions below is met:

1. you have consented to your personal data being processed;
2. compliance with legal obligations;
3. processing of personal data is required for the performance of a contract to which you are a party.

Data retention period

Personal data will only be stored for the purposes stated in this privacy statement and will remain stored in the NDD until the subscriber requests its telecommunications provider to delete the personal data from the NDD, upon which the personal data will be deleted following an automated request by the telecommunications provider.

Sharing personal data

PXS may share personal data with a third party if this is required for the provision of services or upon request of an authority based on laws and regulations. When PXS provides personal data to a third party, PXS implements contractual and organisational measures to ensure that personal data is processed exclusively for the purposes defined above. The personal data will be deleted as soon as it is no longer needed for the specified purposes. In the event data is shared with a third party from outside the European Union, PXS ensures that such third party is bound by obligations (organisational and technical measures) no less onerous as a third party from the European Union.

Automated decision-making

PXS does not apply automated decision-making processes, such as decisions made by computer programs or systems, without an employee of PXS being involved regarding matters that can have (significant) consequences for data subjects.

Personal data security

PXS has taken appropriate technical and organisational measures to secure your personal data against loss or any form of illegal processing. Measures that are applied in this context include, amongst other things, encryption and anonymisation of personal data, as well as encrypted communication and confidential treatment of personal data.

PXS employees and any third parties who may have access to personal data recorded by PXS are obliged to keep this information confidential. Only authorised personnel are allowed to view and edit data and are only allowed to the extent necessary for the proper execution of the services. As such, PXS ensures that personal data is handled with care. PXS continuously invests in employee knowledge and awareness regarding the privacy regulations. PXS actively screens employees upon enlistment.

Your rights

PXS respects your rights pursuant to data protection laws and regulations. Below you will find more information about these rights and on how you can invoke them.

Right of access

You have the right to verify which of your personal data are being processed by PXS.

Right to rectification and erasure

In specific circumstances, you are entitled to have your personal data rectified or erased if the data are not – or are no longer – correct or if the processing is – or is no longer – legitimate.

Right to object

When PXS processes your personal data because of a legitimate interest or a task carried out in the public interest, you have the right to object to that processing activity.

If you object to any form of processing with respect to your personal data, PXS will verify if your objection can be granted. If your objection outweighs the obligation of PXS to process your personal data – and in continuing to do so, PXS will stop processing such data. If PXS is of the opinion that their legitimate interest to continue processing your personal data outweighs yours, PXS will explain their position.

Right to restriction of processing

In specific circumstances, you also have the right to restrict the processing of your personal data. This means that PXS temporarily “freezes” the processing of your data. You can invoke this right while waiting for the assessment of a request for rectification, if the data should have to be erased because the processing is unlawful but you should request restriction of processing instead of erasure, if PXS no longer needs the data whereas you still need these data for legal proceedings – or the preparation of legal proceedings – or pending the assessment of an objection.

Right to data portability

If PXS processes your personal data based on your consent or an agreement entered into, you have the right, with respect to such data, to receive (in return) the data you provided to PXS digitally, in a commonly used format. You are then free to transmit the data to any other party.

Withdrawal of consent

If PXS processes your personal data on the basis of your consent, you usually have the right to withdraw your consent. PXS will immediately stop the processing of your data. Withdrawal of consent has no retro-active effect. Any processing that has taken place up to that moment will, therefore, remain lawful.

As the data in the NDD is provided to PXS by your telecommunications provider, PXS will contact the respective telecommunications provider to assist in the execution of any right invoked.

Questions or comments

This privacy statement is intended to provide insights in how PXS processes personal data. If you have any questions or comments, please contact PXS’ Data Protection Officer at dataprivacy@pxs.com.

PXS will assist in case of complaints about the processing of personal data. Nevertheless, if you have a complaint about the use of your data by PXS, you also have the right (under the privacy legislation) to file a complaint with the data privacy authority, the Irish Data Protection Commission.

PXS reserves the right to make changes to this privacy statement, for example due to adjustments to (changed) laws and regulations.