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Privacy Policy

Privacy Policy - Origin Systems


Effective Date: 1 March 2026

Last Updated: 17 March 2026


Introduction


Origin Systems respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, process, and protect your personal data when you interact with our website and Services. It also outlines your rights under applicable law.

This policy applies when you visit our website, submit forms, make enquiries, purchase Services, subscribe to communications, or otherwise engage with Origin Systems.

This Privacy Policy is governed by the laws of the Republic of Ireland and complies with:

- General Data Protection Regulation (EU) 2016/679 ("GDPR")

- Data Protection Act 2018 (Ireland)

- ePrivacy Regulations (Ireland)

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1. Important Information and Who We Are

1.1 Purpose of This Policy

This Privacy Policy applies to personal data collected when you:

- Visit this website

- Submit enquiries or forms

- Purchase or engage with Services

- Subscribe to communications

This policy should be read alongside any additional privacy notices provided at the point of data collection.

1.2 Controller

Origin Systems is the data controller responsible for your personal data.

Contact: support@originsystems.ie

Where Origin Systems operates through a registered legal entity, company details may be provided separately on this website or upon request.

1.3 Right to Complain

You have the right to lodge a complaint with the Data Protection Commission (Ireland) if you believe your personal data has been processed unlawfully or mishandled.

Data Protection Commission

21 Fitzwilliam Square South

Dublin 2, D02 RD28

Ireland

We request that you contact us first so we can address your concerns directly before you approach the Commission.

1.4 Accuracy of Data

You are responsible for ensuring that the personal data you provide is accurate and kept up to date.

1.5 Third-Party Links

This website may contain links to third-party websites.

We are not responsible for their privacy practices. You should review their privacy policies separately.

1.6 Age Restriction

This website is not intended for individuals under the age of 18.

We do not knowingly collect personal data from minors.

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2. The Data We Collect About You

Personal data means any information capable of identifying you directly or indirectly.

We may collect, use, store, and transfer the following categories of personal data:

2.1 Identity Data

- First name

- Last name

- Username

- Title

2.2 Contact Data

- Email address

- Phone number

- Billing address

- Postal address

2.3 Financial Data

- Payment details processed through secure third-party payment providers

2.4 Transaction Data

- Details of payments

- Purchase history

- Services purchased

- Payment records

2.5 Technical Data

- IP address

- Browser type

- Browser version

- Device information

- Operating system

- Time zone settings

2.6 Profile Data

- Preferences

- Feedback

- Interactions

- Account details

2.7 Usage Data

- How you use our website

- How you use our content

- How you engage with our Services

2.8 Marketing and Communications Data

- Marketing preferences

- Communication preferences

- Consent records

2.9 Aggregated Data

We may use anonymised and aggregated data for analytics, performance monitoring, business intelligence, reporting, and improvement purposes.

Aggregated data does not identify you.

2.10 Sensitive Data

We do not intentionally collect sensitive personal data.

If such data is voluntarily provided, it will only be processed with your explicit consent where required and in accordance with GDPR.

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3. How Your Data Is Collected

We collect data through the following methods.

3.1 Direct Interactions

You may provide personal data when you:

- Fill in forms

- Submit enquiries

- Contact us

- Purchase Services

- Subscribe to communications

- Participate in surveys or feedback activities

3.2 Automated Technologies

We collect Technical Data and Usage Data through:

- Cookies

- Analytics tools

- Website tracking technologies

- Server logs and website security monitoring tools

Non-essential cookies and tracking technologies are only used with your consent.

3.3 Third Parties

We may receive data from:

- Payment processors

- Analytics providers

- Technology providers

- Service delivery platforms

- Communication providers

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4. How We Use Your Personal Data

We will only use your personal data where legally permitted.

4.1 Legal Bases for Processing

Purpose| Type of Data| Legal Basis

Account creation and enquiries| Identity, Contact| Contract

Service delivery| Identity, Contact, Transaction| Contract

Payment processing| Financial, Transaction| Contract / Legal Obligation

Business operations and improvement| Technical, Usage| Legitimate Interest

Marketing communications| Contact, Marketing Preferences| Consent / Legitimate Interest

Website analytics| Technical, Usage| Consent

Fraud prevention and security| Technical, Transaction| Legitimate Interest

Where we rely on legitimate interests, we ensure those interests do not override your fundamental rights and freedoms.

4.2 Purposes of Use

We use your personal data to:

- Register you as a client

- Process payments

- Deliver Services

- Manage our relationship with you

- Respond to enquiries

- Improve website functionality and user experience

- Analyse website performance

- Protect against fraud, misuse, or security threats

- Send communications where consent has been provided or where otherwise permitted by law

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5. Marketing Communications

You will only receive marketing communications where:

- You have provided consent; or

- It falls within legitimate interest under applicable law.

You may withdraw consent at any time by:

- Clicking the unsubscribe link contained within communications

- Contacting us directly

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

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6. Disclosure of Your Data

We may share your data with trusted third parties, including:

- Payment service providers

- Email and communication platforms

- Website hosting providers

- Analytics providers

- Technology providers

- Scheduling platforms

- Cloud storage providers

- Professional advisers

- Regulatory authorities where required by law

Examples of service providers may include website hosting providers, payment processors, email communication providers, scheduling platforms, analytics providers, cloud storage providers, and professional advisers.

A current list of significant third-party processors is available upon request.

All third parties are required to process your data securely, confidentially, and lawfully.

We do not sell personal data.

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7. Use of AI-Enabled Tools

Origin Systems may utilise AI-enabled technologies to assist with administrative functions, drafting, analysis, note-taking, summarisation, operational efficiency, and service support.

Personal data will only be processed through such technologies where there is an appropriate lawful basis and suitable safeguards are in place.

We do not use AI systems to make solely automated decisions that produce legal effects or similarly significant effects.

Where AI-enabled service providers process personal data on our behalf, we seek to ensure appropriate contractual, technical, and organisational safeguards are maintained.

Where possible, we configure AI-enabled services to apply available privacy and data protection controls.

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8. International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), we ensure appropriate safeguards are implemented in accordance with GDPR.

These safeguards may include:

- Adequacy Decisions

- Standard Contractual Clauses

- Other GDPR-compliant transfer mechanisms

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9. Data Security

We implement appropriate technical and organisational measures to protect your personal data from:

- Unauthorised access

- Loss or misuse

- Alteration

- Disclosure

- Destruction

Security measures may include:

- Access controls

- Password protection

- Encryption where appropriate

- Secure payment processing

- Confidentiality obligations

- Restricted access to personal data

- Security monitoring

- Procedures for responding to suspected data breaches

While we take reasonable steps to protect personal data, no method of transmission or storage can be guaranteed to be completely secure.

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10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected and to satisfy legal, regulatory, accounting, tax, or reporting obligations.

Typical retention periods include:

- Financial and tax records: up to 6 years

- Client records: for the duration of the contractual relationship and thereafter as required by law

- Enquiry records not resulting in a client relationship: generally up to 24 months

- Marketing records: until consent is withdrawn or an individual opts out of communications

Where retention is no longer necessary, personal data will be securely deleted or anonymised.

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11. Your Legal Rights

Under GDPR and Irish law, you have the right to:

- Access your personal data

- Correct inaccurate personal data

- Request erasure of your personal data

- Restrict processing

- Object to processing

- Request data portability

- Withdraw consent at any time

To exercise your rights, contact:

support@originsystems.ie

We aim to respond to all legitimate requests within one month.

Where requests are particularly complex or numerous, we may extend this period by up to a further two months in accordance with applicable law.

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12. Cookies

We use cookies and similar technologies to:

- Improve functionality

- Improve website performance

- Analyse usage

- Enhance user experience

- Support website security

Non-essential cookies require your prior consent.

You can manage cookie preferences through:

- Your browser settings

- Our cookie consent banner

- Any cookie preference tools made available through the website

Further information regarding cookies and similar technologies may be provided through a separate Cookie Notice.

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13. Automated Decision-Making

We do not engage in automated decision-making or profiling that produces legal effects or similarly significant effects on individuals.

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14. Data Breach Procedures

In the event of a personal data breach:

- We will investigate and take appropriate remedial action.

- We will notify the Data Protection Commission where required by law.

- We will notify affected individuals where there is a high risk to rights and freedoms.

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15. Changes to This Policy

We may update this Privacy Policy from time to time.

The latest version will always be available on this website.

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16. Contact

For all privacy-related enquiries:

Email: support@originsystems.ie

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17. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Ireland.

Your continued use of this website constitutes acknowledgement of this Privacy Policy. Where consent is required under applicable law, such consent will be obtained separately.

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