Data Privacy Policy




    Privacy Policy.


    How to contact us.

    Terminology used.

    Personal data and basis for collection.

    If you fail to provide personal data.

    How is your personal data collected?.

    How Cirrutech Software Ltd uses your personal data.

    How your personal data may be shared.

    How Cirrutech Software Ltd stores personal data.

    Data security.

    Personal data retention.

    Your rights.



    External websites.

    Use of cookies by us.

    Remember the risks whenever you use the Internet

    Changes to this Privacy Policy and your duty to inform us of changes.



    Privacy Policy

    Cirrutech Software Ltd Software Limited, (T/A ECCEsoft) is a company registered in Ireland whose registered address is Kingsfurze House, Old Lucan Road, Dublin, D20 KR60. (“Cirrutech Software Ltd” “We”).


    This Privacy Policy sets out how Cirrutech Software Ltd uses and protects any personal data that you provide to Cirrutech Software Ltd (including personal data provided through the website  (“Website”). Cirrutech Software Ltd provides services to its business clients, including access to software and technology for clients to use in their business operations (“Services”).

     Cirrutech Software Ltd is firmly committed to respecting and protecting the privacy of all personal data received or collected, in strict adherence to Data Protection Legislation (defined below) and best business practice. Cirrutech Software Ltd has established this Policy so that you can understand the care with which we intend to treat personal data, as a standard. Although legal requirements may vary from country to country, Cirrutech Software Ltd intends to adhere to the principles set out in this Privacy Policy even if, in connection with the above, we transfer your personal information from your country to countries outside of the EEA that may not require a high level of protection for your personal information (as detailed further below).

    How to contact us

    If you have any questions regarding your personal data and how we may use it, including any queries relating to this Policy, please contact us at (with the subject heading “Data Protection”), or writing to the “Data Protection Officer” at the office address noted above.

    It is important that the personal data we hold about you is accurate and current. Please keep us (or our clients, where appropriate) informed if your personal data changes.

    Terminology used

    Cirrutech Software Ltd’s data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the Ireland and UK and then (ii) any successor legislation to the GDPR or the country specific Data Protection Acts (“Data Protection Legislation”).

    For the purpose of Data Protection Legislation:

    1. Where personal data is provided directly to Cirrutech Software Ltd through use of the Website, email, or other means where Cirrutech Software Ltd is determining the way in which that personal data is processed for its own use, then Cirrutech Software Ltd will be a data controller of such information.
    2. Where Cirrutech Software Ltd is provided personal data in its capacity of providing Services to its clients, then Cirrutech Software Ltd will only process that personal data in accordance with the instructions of its clients and Cirrutech Software Ltd will therefore act as a data processor in respect of such personal data; Cirrutech Software Ltd’s client will be the data controller of that personal data for that purpose and will be responsible to data subjects for the way in which their personal data is processed as the data controller.
    3. Where Cirrutech Software Ltd acts as a data processor on behalf of its clients, Cirrutech Software Ltd will process that personal data on the instructions of its clients, who would have collected that personal data in accordance with that client’s own privacy policy. Individuals who have contracts with our clients should therefore check that client’s own privacy policy, to ensure they understand how their personal data may be processed.


    Personal data and basis for collection

    Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

    Where Cirrutech Software Ltd is acting as a data controller, Cirrutech Software Ltd may collect, use, store and transfer different kinds of personal data about you which Cirrutech Software Ltd has grouped together as follows

    • Identity Data includes first name, last name, username or similar identifier, title, job title and date.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Usage Data includes information about how you use Cirrutech Software Ltd’s Services or submit an enquiry or query through the Website.

    Subject to where Cirrutech Software Ltd needs to verify your identity and you provide your express consent for Cirrutech Software Ltd to process such information, Cirrutech Software Ltd does not process any Special Category personal data (as defined by Data Protection Legislation) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor does Cirrutech Software Ltd collect any information about criminal convictions and offences. As mentioned above, Cirrutech Software Ltd may process Special Category personal data about individuals on behalf of its clients, in which case our client’s own privacy policy will explain the Special Category data being processed and the purposes for which it will be processed.

    If you fail to provide personal data

    Where Cirrutech Software Ltd needs to collect personal data by law, or under the terms of a contract Cirrutech Software Ltd has with you (or our client whom Cirrutech Software Ltd acts for) and you fail to provide that data when requested, Cirrutech Software Ltd may not be able to perform the contract it has or is trying to enter. In this case, Cirrutech Software Ltd may have to cancel the Services but it will notify you (or where appropriate, its client) if this is the case at the time.

    How is your personal data collected?

    Cirrutech Software Ltd uses different methods to collect personal data from and about you including through: 

    • Direct interactions.You may give us your contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when Cirrutech Software Ltd provides its Services;
    • We may meet you at events and you may provide us with your contact details in order for us to contact you about our Services; or
    • Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources such as:
      • Contact data from providers.
      • Internet / Websites / IP lookups / databases
      • Our Partners with whom you have already shared data.

    How Cirrutech Software Ltd uses your personal data

    Cirrutech Software Ltd will only use your personal data when the law allows us to, i.e., if we have a legal basis for doing so, as outlined in this Policy or as notified to you at the time we collect your personal data, and for the purposes for which it was collected for, 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 we will explain the legal basis which allows us to do this. Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.

    Where we act as the data controller for client contact information, we have set out below in the table a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact Cirrutech Software Ltd if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

    Where we act as a data processor of personal data on behalf of our clients, we will process personal data in accordance with our clients’ instructions, or in order to comply with all legal or regulatory obligations.

    How your personal data may be shared

    Where we act as the data controller for client contact information, or where permitted by Cirrutech Software Ltd’s data controller clients, personal data processed by Cirrutech Software Ltd may be shared as follows:

    • with any member of the Cirrutech Software Ltd Group, which means Cirrutech Software Ltd’s subsidiaries, Cirrutech Software Ltd’s  ultimate holding company and its subsidiaries, as defined in Companies Act 2006;
    • with permitted third party contractors of Cirrutech Software Ltd for the purposes of performing its Services, help us to deliver our products and information (“Data Processors” or “Sub-Processors”);
    • where Cirrutech Software Ltd is under a duty to disclose your personal data to comply with any legal obligation, or to enforce or apply Cirrutech Software Ltd’s terms and conditions and other agreements;
    • to protect the rights, property, or safety of Cirrutech Software Ltd, Cirrutech Software Ltd’s client, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws; or
    • with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

    Where we provide your personal data to Data Processors or Sub-Processors we will have in place a written agreement with each third party confirming on what basis the third party will handle your personal data and will ensure that there are sufficient safeguards and processes in place to protect your personal data. We require all third parties to respect the security of your personal data and to treat it in accordance with the law and only process that personal data in accordance with our (or our client’s) instructions. The third parties that we may send your personal data to are either within the European Economic Area (“EEA”) or to third parties under suitable protection mechanisms as laid out in applicable Data Protection Legislation.

    How Cirrutech Software Ltd stores personal data

    From time to time we may transfer your personal data from within the EEA to other countries where we have put in place adequate security measures to ensure your personal data will be handled in a way that matches applicable Data Protection Legislation, so that where your personal data is being transferred it will be processed in line with our EEA-based service, regardless of which country (even if outside of the EEA).

    Separate to the above, we may also transfer your personal data to countries outside of the EEA to other people or companies for one of the legal bases for processing your personal data as indicated above, or at the request of our data controller clients. Where we do so, we will take all steps to ensure that any country to which the personal data has been transferred has suitable protection mechanisms in place to protect personal data, including (if applicable) use of EU Model Clauses in any contract with that third party for steps to be taken to keep personal data secure.


    Data security

    We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed and have various information security policies in place to which we adhere to. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

    Personal data retention

    We will only retain personal data in accordance with our retention policy, which includes:

    1. where we act as a data controller in connection with client contact information, for as long as necessary to fulfil the purposes we collected it for;
    2. where we act as a data processor on behalf of its clients, for the period notified to Cirrutech Software Ltd by the data controller client;
    3. in either case, for the period required for the purposes of satisfying any legal, accounting, regulatory or reporting requirements.

    Your rights

    Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

    • The right to be informed – this is information on for what purpose we are processing it and what personal data we are processing.
    • The right of access – you have the right to be provided with copies of the personal data of you that we are processing as well as confirmation of the processing we are doing. You can do this by sending a “subject access request” to the contact details
      noted above for our consideration.
    • The right to rectification – if you think the personal data that we hold on you is wrong you can tell us and we will fix it.
    • The right to erasure (also known as the right to be forgotten) – if you want us to permanently delete the personal data we hold for you then you can ask us to do so. Our ability to delete such personal data is subject to exceptions in accordance with data protection laws.
    • The right to restrict processing – if you do not like how we are using your personal data then you can let us know and we will stop processing it in that way.
    • The right to data portability – if you want us to pass on your personal data to someone else then please let us know. This transfer should not affect the integrity or otherwise damage your personal data.
    • The right to withdraw your consent – you can withdraw your consent for us to process your personal data (if we have relied on your consent to process your personal data) at any time by contacting us. If we have relied only on your consent as the basis to process your personal data then we will stop processing your personal data at the point you withdraw your consent. Please note that if we can also rely on other bases to process your personal data aside from consent then we may do so even if you have withdrawn your consent.
    • Rights in relation to automated decision making and profiling – if we use either automated decision making or profiling then you have a right to know. Also, we need your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.

    To exercise any of the above rights please email your request to: with the subject heading “Data Processing Request”. Alternatively write to the “Data Protection Officer” at the office address noted above.


    Where you exercise your right to erasure (and we do not have another legal basis to hold on to that personal data) or where information is deleted in accordance with Cirrutech Software Ltd retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period Cirrutech Software Ltd retains the data.

    Where you exercise your right to request access to the information Cirrutech Software Ltd processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Cirrutech Software Ltd will try to respond to all legitimate access requests within one month.



    The Website is not intended for children and Cirrutech Software Ltd will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.


    If you would like to make a complaint in relation to how Cirrutech Software Ltd may have stored, used or processed your personal data, you have the right to make a complaint at any time to the Data Protection Commissioner. Cirrutech Software Ltd would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commissioner, so please contact us in the first instance.

    External websites

    The Website may, from time to time, contain links to and from the websites of Cirrutech Software Ltd partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Cirrutech Software Ltd is not responsible for the content of external internet sites and you are advised to read the privacy policy of external sites before disclosing any personal data.

    Use of cookies by us

    We would like to place cookies on your computer to help us make your use of our Website better. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Just so you know, the main cookies on our Website are from Google Analytics tracking and there’s also a session cookie generated that is essential to the running of the Website but holds no personal data.

    Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re-enter your details to gain access to certain parts of the website.

    We may also use third party IP lookup software which identifies and tracks visitors or organisations to our Website, which may create a link to an identifiable individual. Tracking technologies may record information such as internet domain and host names, internet protocol addresses, browser software and operating system types, clickstream patterns and dates and times that our website is accessed. We may also analyse information that does not contain personal data for trends and statistics.


    Remember the risks whenever you use the Internet

    Cirrutech Software Ltd is committed to ensuring that your information is secure and has in place reasonable and proportionate safeguards and procedures to protect your personal data. While Cirrutech Software Ltd does its best to protect your personal data, Cirrutech Software Ltd cannot guarantee the security of any information that you transmit to Cirrutech Software Ltd and you are solely responsible for maintaining the secrecy of any passwords or other account information.

    Changes to this Privacy Policy and your duty to inform us of changes

    As and when necessary, changes to this Privacy Policy will be posted here. Where changes are significant, we may also email all our registered users with the new details, and where required by law, we will obtain your consent to these changes.