PRIVACY POLICY

1. Introduction

This Privacy Policy (“Policy”) refers to the website www.mdfosb.com (the “Website”) and relates to the products and services provided by the following companies:

Smartply Europe DAC, with an address of Belview, Slieverue, Waterford, Ireland, X91 PX75; and
Medite Europe DAC, with an address of Redmondstown, Clonmel, County Tipperary, Ireland, E91 V584. (collectively as "we", “our” or “MEDITE SMARTPLY”).
Coillte Panel Products (UK) Limited, with an address of Medite Smartly UK Ltd
Cotton Lake House, Anchor Boulevard, Crossways Business Park, Dartford, Kent, DA2 6QH, United Kingdom, trading as MEDITE SMARTPLY;

The Policy explains how we process personal data, including special category of data and the basis on which persona data is obtained from you or collected about you from third parties. In this Policy, the term “personal data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).

We will handle your personal data in accordance with Data Protection Legislation. “Data Protection Legislation” means the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Data Protection Act 2018 (“UK DPA”) and the GDPR (as retained by section 3(10) (as supplemented by section 205(4)) of the UK DPA) (“UK GDPR”), the Data Protection Acts 1988 and 2018, and any other applicable law or regulation relating to the processing of personal data and to privacy including the Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011.

2. Information we gather from you

We fully respect your right to privacy in relation to your interactions with the Website and our services and endeavour to be to be transparent in our dealings with you as to what information we collect about you.

We may collect personal data from you in the course of our dealings with you, including through your use of our service, when you contact or request information from us, when you register with us, when you do business with us, when you enter into a contract with us or where we are legally entitled to do so. We gather information about you when you provide it to us directly. We may also collect or receive information about you from other sources other than you. We will only collect information that is adequate, relevant and limited to what is necessary in relation to the purposes identified within this Policy.

The table below outlines the categories and types of data we collect. The types of data we collect may change over time; the following table is an indicative list to help you understand the types of data we collect.

Data Category	Data Type
Identity & Individual Data	Name, postal address, delivery address, email address, phone number, photograph, official identification documents and numbers including PPSN/National Insurance Number/BSN, social security number, driver number, license number, company name, VAT number and passport number, date of birth, or your relationship to a person.
Financial Data	Your financial information: bank details, credit limits and rating, payment card details, invoices, payment history, tax details.
Recruitment Data	Name, date of birth, postal address, email address, CV, Work history including the company you work for, your title or position, qualifications, education details, and referee details, work permits.
Special Category Data – Health Data	Information about your health such as psychometrics test results, dietary restrictions, and accessibility requirements where necessary.
Criminal Convictions Data	Details of Garda vetting where necessary.
Technical Data	IP address, login info, browser details, device IDs, page URL, visitrelated technical logs.
Usage Data	Statistical data about your browsing actions and patterns from your interaction with the Website, timestamps of visits, session length, chatbot responses.
CCTV	CCTV footage

We endeavour to keep all personal data that you provide to us accurate and up-to-date. As such, you must tell us about any changes to such information as soon as possible.

If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal data to us.

3. How will we use the information we gather?

The main purposes for which we use your data is to provide you the product or service you requested, manage and administer our relationship with you, communicate with you about updates or relevant information, carry out marketing, and comply with our legal obligations. The following section provides more detail on the purposes for which we process your personal data and the legal basis by which we do this.

Reason for processing	Legal basis for processing
To assess your suitability for a role, manage the recruitment process, and communicate with you during the application process.	Performance of a contract Necessary for our legitimate Interest (to evaluate candidates and manage recruitment)
To provide and enhance our services and products.	Performance of a contract
To issue invoices, manage payments to/from suppliers and customers, and maintain related records.	Performance of a contract
To respond to your queries, provide you with the information or download you request from us in relation to our services and goods, and manage your complaints.	Consent Performance of a contract Necessary for our legitimate interests (to provide efficient customer support and respond to your enquiries/complaints and grow our business)
To manage our relationship with you, including notifying you about changes to our services, or our Privacy Policy.	Performance of a contract Necessary for our legitimate interests (to keep our records updated and to analyse how customers use our products and services).
To provide you with marketing communications and send you updates, publications and details of events.	Consent
To identify, evaluate, and engage third-party service providers and manage procurement contracts.	Necessary to comply with a legal obligation
To manage accident reporting.	Necessary to comply with a legal obligation
To monitor our technology tools and services, including the Website and email communications.	Necessary for our legitimate interest (to monitor security and performance).
To invite you to participate in surveys about our service and products.	Necessary for our legitimate interest (to evaluate and improve the quality of our services)
To manage the CCTV on the exterior of the building and within premises where necessary.	Necessary for our legitimate interest interests (to ensure security.)
To provide access to the MEDITE community platform, deliver exclusive content, and share updates, and support professional networking.	Consent
To manage room booking requests, communicate with customers, and provide the meeting facilities and related support.	Performance of contract
To administer competitions, including verifying eligibility, managing entries, selecting winners and delivering prizes,	Consent Performance of contract
To operate the chatbot, understand and respond to your messages, improve service functionality, ensure platform security, and provide followup information when you voluntarily supply contact details.	Consent (when you voluntarily provide contact information such as your email, phone number, or company name so we can follow up) Legitimate interest (to provide and improve the chatbot service, maintain security, and analyse usage)

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (see ‘How to contact us’ below). Where we wish to use your data for an unrelated purpose, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of your data for purposes other than those for which it was originally collected. Please note that we may process your personal data without your knowledge or consent, in compliance with this Policy, where this is required or permitted by law.

While you are not required to provide your personal data, this may impact you. If you choose not to give us this personal data, it could delay or prevent us from entering the contract with you, delivering our service or products to you or fulfilling our legal obligations as required.

We wish to remind you that this Policy extends to personal data that we collect/process through your use of our service or the Website. It does not apply to any links to third-parties’ websites and/or services, such as third-party applications, that you may encounter when you use the Website. You acknowledge that we may provide, may enable or assist you to access the website content of, correspond with, and purchase products and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your personal data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Website. We encourage you to carefully familiarise yourself with terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

4. Are there cases where we may use your information to contact you?

We may contact you:

for administration reasons related to the service to which you have signed up (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us);
to provide you with information about our services, activities or online content.
to follow up with you when you voluntarily supply contact details through our chatbot;
to invite you to participate in surveys about our services and products (participation is always voluntary).

You may unsubscribe from emails and other updates by selecting the Unsubscribe button at the foot of every communication or by contacting us using the contact details in our ‘How to Contact Us’ section of this Policy.

5. AI-Powered Chatbot

Our website uses an AI-powered chatbot service provided by SiteGPT (operated by SiteGPT, United States) to help answer your questions about our products and services. The chatbot uses large language model technology provided by OpenAI to generate responses to your inquiries.

Please note that you are interacting with an artificial intelligence system, not a human representative. If you would prefer to speak with a person, please contact us at info@mdfosb.com.

While we strive to ensure accuracy, AI-generated responses are informational only and do not constitute binding commitments, professional advice, or automated decisions that produce legal effects. For definitive product specifications, pricing, or contractual matters, please contact our team directly.

You have the right to access, rectify, or request deletion of your chatbot conversation data. To exercise these rights, contact us at info@mdfosb.com with details of your request. We will coordinate with our chatbot service provider to fulfil your request within one month. Please note that while we can delete your data from our systems and instruct our processors to do the same, data already processed through OpenAI's API for response generation cannot be retroactively retrieved, though OpenAI automatically deletes API data within 30 days. For more information on your data subject rights please see Section 6 of this Policy.

Your chatbot conversations are not used to train AI models.

6. What Rights Do You Have?

As a data subject, you have the following rights under the Data Protection Legislation:

the right of access to personal data relating to you;
the right to correct any mistakes in your personal data;
the right to object to processing of your personal data;
rights in relation to automated decision making including profiling;
the right to restrict your personal data being processed;
the right to have your personal data transferred to another data controller;
the right to erasure; and
the right to withdraw consent; and
the right to complain to the Data Protection Commission (“DPC”) or your local supervisory authority if you believe we have not handled your personal data in accordance with Data Protection Legislation.

These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your personal data, please contact us (see ‘How to contact us’ below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.

6.1 Right to access

You may ask to see what personal data we hold about you and be provided with:

a summary of such personal data and the categories of personal data held;
details of the purpose for which it is being or is to be processed;
details of the recipients or categories of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers;
details of the period for which it is held or the criteria we use to determine how long it is held;
details of your rights, including the rights to rectification, erasure, restriction or objection to the processing;
details of your right to lodge a complaint with the supervisory authority;
any information available about the source of that data;
whether we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling (please note that we do not currently carry out any profiling – we will notify you if this changes); and
where your personal data are transferred out of the EEA/UK, what safeguards are in place.

Requests for your personal data must be made to us (see ‘How to contact us’ below) specifying what personal data you need access to, and a copy of such request may be retained by us. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. We may need to verify your identity and request more information or clarifications from you if needed to help us locate and provide you with the personal data requested. There is usually no charge applied to access your personal data.

If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.

There are certain types of data which we are not obliged to disclose to you, which include personal data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations.

We are entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the personal date requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.

6.2 Right to rectification

You have the right to have MEDITE SMARTPLY correct any inaccurate personal data which we hold free of charge. You also have the right to have incomplete personal data completed; you may provide us with supplementary information to do so. If you would like to do this, please:

email or write to us (see ‘How to contact us’ below);
let us have enough information to identify you (e.g. name, registration details); and
let us know the information that is incorrect/incomplete and what it should be replaced with.

If we are required to update your personal data, we will inform recipients to whom that personal data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.

It is your responsibility that all of the personal data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to contact us’ below).

6.3 Right to object

You have the right to object to the processing of your personal data at any time:

For direct marketing purposes.
For profiling to the extent, it relates to direct marketing.
Where we process your personal data for the purposes of legitimate interests pursued by us, except where we can demonstrate compelling legitimate grounds for this processing which would override your interests, rights and freedoms or in connection with the enforcement or defence of a legal claim.

Should this occur, we will no longer process your personal data for these purposes unless doing so is justified by a compelling legitimate ground as described above.

If you would like to object to the processing of your personal data for direct marketing purposes, please:

email or write to us (see ‘How to contact us’ below). You can also click on the ‘unsubscribe’ button at the bottom of the electronic communication. It may take up to 15 days for this to take place; and
let us know what method of contact you are not happy with if you are unhappy with certain ways of contacting you only (for example, you may be happy for us to contact you by email but not by telephone).

We will provide you with information on action taken on a request to stop direct marketing. This may be in the form of a response email confirming that you have ‘unsubscribed’.

6.4 Rights in relation to automated decision making including profiling (if applicable)

You may ask us to ensure that, if we are evaluating you, we do not base any decisions solely on an automated process and have any decision reviewed by a member of staff. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.

6.5 Right to restrict processing

You have the right to have MEDITE SMARTPLY restrict the processing of your personal data where one of the following applies:

you do not think that your personal data is accurate (but we will start processing again once we have checked and confirmed that it is accurate);
the processing is unlawful but you do not want us to erase your personal data;
we no longer need the personal data for our processing; or
you have objected to processing because you believe that your interests should override the basis upon which we process your personal data.

If you exercise your right to restrict us from processing your personal data, we will continue to store your personal data but will only continue to process the personal data if:

you consent to such processing;
the processing is necessary for the exercise or defence of legal claims;
the processing is necessary for the protection of the rights of other individuals or legal persons;
the processing is necessary for public interest reasons.

6.6 Right to data portability

You have the right to receive personal data concerning you which you have provided to us in a structured, commonly used and machine-readable format. You also have the right to have MEDITE SMARTPLY transmit this data directly to another controller on behalf of you. This right only applies to personal data that you have provided to us – it does not extend to data generated by us.

The right to data portability also only applies where:

the processing is based on your consent or for the performance of a contract; and
the processing is carried out by automated means.

6.7 Right to erasure

You have the right to have MEDITE SMARTPLY erase the personal data we have collected about you where:

your personal data is no longer necessary in relation to the purpose for which it was collected or processed;
if you had given us consent to process your personal data, you withdraw that consent and we cannot otherwise legally process your personal data;
you object to our processing and we do not have any legal basis for continuing to process your personal data;
you object to our processing and your personal data are being processed for direct marketing purposes;
your data has been processed unlawfully or have not been erased when it should have been; or
the personal data have to be erased to comply with a legal obligation.

We may continue to process your personal data in certain circumstances in accordance with Data Protection Legislation.

Where you have requested the erasure of your personal data, we will inform recipients to whom that personal data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.

6.8 Right to withdraw consent

Where we are processing your personal data on the legal basis of consent, you are entitled to withdraw your consent at any time.

6.9 Right to complain to the supervisory authority

If you do not think that we have processed your personal data in accordance with this Policy, please contact us in the first instance. If you are not satisfied with our use of your personal data or our response to any request by you to exercise any of your rights, you can complain to the Data Protection Commission (DPC). Please see below for contact details of the DPC.

Data Protection Commission,
6 Pembroke Row
Dublin 2
D02 X963
Ireland
Telephone: +353 1 765 0100 / 1800 437 737 Email: info@dataprotection.ie.

Similarly, you can complain to the UK Information Commissioner’s Office (“ICO”). Information about how to do this is available at https://ico.org.uk/global/contact-us/ or you can contact them by phone at +44 303 123 1113.

7. Offensive Content

If you post or send content which may reasonably be deemed to be offensive, inappropriate or objectionable anywhere on the Website or otherwise engage in any disruptive behaviour on any MEDITE SMARTPLY service, we may remove such content.

Where we reasonably believe that you are or may be in breach of any applicable laws, for example on hate speech, we may disclose your personal information to relevant third parties, including to law enforcement agencies or your internet provider. We would only do so in circumstances where such disclosure is permitted under applicable laws, including Data Protection Legislation.

8. Do we protect your personal information?

We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to personal data to employees, contractors and agents who need to know such personal data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, the website contains hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of your personal data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any data submitted or accessed from unsecure user systems or passing over intermediate systems on the public internet. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over unsecure communications networks and facilities, including the public internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the website may be subject to limitations, delays and other problems inherent in the use of such communications facilities. Users are therefore solely responsible for maintaining the security of systems or devices used to access our websites and encouraged to pay particular attention to any security warnings issued by their device, browser, or network when accessing or using the website and to ensure that their own systems are adequately protected. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses.

9. Breach Reporting

We will notify serious data breaches to the supervisory authority without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the supervisory authority where the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A personal data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your personal data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:

we have implemented appropriate technical and organisational measures that render the personal data unintelligible to anyone not authorised to access it, such as encryption; or
we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
it would involve disproportionate effort, in which case we may make a public communication instead.

10. Who we share data with

We may disclose your personal information to any business unit, company or other corporate entity under the control and direction of MEDITE SMARTPLY.

We may also disclose your personal information to the other business entities of the Coillte Group comprising of Coillte CGA, a company incorporated in Ireland with registration number 138108 and an address of Dublin Road, Newtownmountkennedy, Co. Wicklow; Smartply Europe DAC, a company incorporated in Ireland with registration number 205747 with an address of Belview, Slieverue, Waterford; and Medite Europe DAC, a company incorporated in Ireland with registration number 80984 and an address of Redmondstown, Clonmel, Co. Tipperary.

Additionally, we may share your personal data with outside organisations or recipients with whom we have a relationship to provide services on our behalf. Any third parties who access your data in this way on our behalf are subject to strict contractual restrictions to ensure that your data is protected in compliance with Data Protection Legislation. We will only provide to those third parties the information that is necessary for them to performance the agreed services.

Below is a list of categories of recipients we share your personal data with:

Our service providers that help us provide our services or run the Website, including those in relation to marketing communications or the chatbot service. i.e., your chatbot interaction data is processed by our chatbot service provider, SiteGPT (United States), and transmitted to OpenAI (United States), which provides the artificial intelligence technology that generates chatbot responses. These providers act as data processors and are contractually restricted from using your data for their own purposes and subject to strict contractual restrictions to ensure that your data is protected, in compliance with Data Protection Legislation.
Selected third-parties to provide you with information about our goods and services which may be of interest to you.
Government, statutory and regulatory bodies such as the DPC or ICO, the Revenue Commissioners, the Central Bank of Ireland, Law Enforcement Agencies such as An Garda Síochána.

11. International Transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) or the UK, including jurisdictions in which and through which transactions occur, jurisdictions linked to your engagement with us, jurisdictions from which you regularly receive or transmit information, and jurisdictions where our third parties conduct their activities. It may also be processed by staff operating outside the EEA/UK who work for us or for one of our service providers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. If we transfer personal data to a third party outside the EEA/the UK, we, as the data controller, will ensure the recipient has the necessary protections in place, such as an adequacy decision, Standard Contractual Clauses, or International Data Transfer Agreement (IDTA) or UK International Data Transfer Addendum (UK Addendum) where applicable.

Your chatbot interaction data is transferred to and processed in the United States by our service providers SiteGPT and OpenAI, along with their infrastructure sub-processors. These transfers are protected by Standard Contractual Clauses, supplemented by additional technical and organisational measures including encryption in transit and at rest.

You may request a copy of the relevant safeguards by contacting us at info@mdfosb.com.

12. Cookies

For further details on our use of cookies, please refer to our Cookie Policy which you can view by visiting www.mdfosb.com/en/cookies-policy

13. Retention of personal data

Any information that you provide to us will be kept and stored for such period of time as we deem necessary taking into account the purpose for which it was collected in the first instance, any legal and regulatory requirements we have, and our obligations under Data Protection Legislation.

We will only keep your personal data for as long as is necessary. We have specific retention periods for different types of data processing. You can request information on the specific retention periods using the details set out in the ‘How to contact us’ section below.

We have set out specific retention periods where possible as follows:

Enquiry: when you contact us with an enquiry, we retain that information on our CRM system for 7 years.
Mailing list: when you consent to being added to our mailing list, we retain that information on an on-going basis or until you wish to unsubscribe.
Chatbot conversation logs are retained for 12 months from the date of the interaction, after which they are automatically deleted. Where you have provided contact details through the chatbot, these are retained in accordance with the retention periods stated above for enquiry information. OpenAI retains data processed through its API for up to 30 days for security monitoring purposes.

14. Changes to the Policy

This Policy may be updated from time to time, so you may wish to check it each time you submit personal information to the Website. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use this Website to submit personal information. If material changes are made to the Policy, we will notify you by placing a prominent notice on the Website. We will not process your personal data in a manner not contemplated by this Policy without your consent.

15. How to contact us

We are the data controller (as defined in Data Protection Legislation) for the Website and services provided through the Website or covered in this Policy.

If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be sent by email info@mdfosb.com. Written requests may also be sent to the relevant company at the applicable address below:

Medite Smartly UK Ltd
Cotton Lake House, Anchor Boulevard,
Crossways Business Park,
Dartford, Kent, DA2 6QH,
United Kingdom
Smartply Europe DAC
Belview,
Slieverue,
Waterford,
Ireland

X91 PX75

Medite Europe DAC
Redmondstown,
Clonmel,
County Tipperary,
Ireland

E91 V584

Effective date of this policy: 24 April 2026