At Harbowe LTD (“Harbowe”, “we”, “us”, “our”) we want you to feel comfortable on our website 
and not have to worry about the security of your data. That is why data protection is an important part 
of our philosophy. 

In this Privacy Policy you will find all the information about which personal data we collect and 
process and for what purpose. You will also find out what rights you have and how you can assert 
them.

The Data Controller
Responsible for the collection and processing of your personal data is

Harbowe LTD
Unit 2, Canal Walk, Parkwest industrial estate
Dublin, Ireland

Web: www.harbowe.ie
E-Mail: harbowe@icould.com 
Phone: 087 1670266

The Supervisory Authority
The Data Protection Commissioner (DPC) is the relevant authority in Ireland. The DPC is located at 
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland and their website can be found at 
www.dataprotection.ie. 

What is personal data?
According to Ireland’s Data Protection Act (“DPA”)and the EU`s General Data Protection Regulation 
(“GDPR”), personal data are "any information relating to an identified or identifiable natural person.
This is, for example, name or address data, telephone number, mobile number, bank details or 
insurance number.

General information on data processing
All personal data that we obtain from you via the website will be processed for the purposes described 
in more detail below. This is done within the framework of the DPA and GDPR or with your consent. 
And of course, only when data processing is permitted and if:

  • you have given your consent,

  • the data is necessary for the fulfilment of a contract / pre-contractual measures,

  • the data is necessary for the fulfilment of a legal obligation or

  • the data is necessary to protect the legitimate interests of our company, provided that your 
    interests are not overridden. 

We process and store your personal data only for the period of time required to achieve the respective 
processing purpose or for as long as a legal retention period (in particular commercial and tax law) 
exists. Once the purpose has been achieved or the retention period has expired, the corresponding data 
is routinely deleted.

What data does Harbowe process?
Harbowe offers you a wide range of services and in the process, various data are always collected. 
Most of the data we process is provided by you when you use our services or contact us. 
Further, we also automatically collect technical device and access data that occur during your 
interaction with our website. And we collect further data through website analyses in order, for 
example, to optimise our offers for you personally (e.g., to optimise our offers for you).

a) Log files, Cookies and Analytical data

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Even if you do not log in or register on our website, but simply browse our website, data is collected 
and stored and processed by us. Specifically, this requires the IP address of your computer, Date and 
time of access, Name and URL of the accessed file, Browser used, amount of bytes transferred, Status 
of the page retrieval, Session ID, Referrer URL.

You can find more information in our Cookie Policy. The legal bases for processing are contract and 
our legitimate interest. The collection and processing of this data is necessary from a technical point 
of view so that you can use our website.

b) Contacting us 
You can easily contact us via our contact form, e-mail, social media or phone. In this case, we store 
and process the following data from you: Name, e-mail address, telephone number as well as other 
personal data that you provide when contacting us.

This data is collected and processed exclusively for the purpose of contacting you and processing 
your request and then deleted, provided there is no legal obligation to retain it. The legal bases for 
processing are contract and our legitimate interest.

c) Processing of Personal Data when using our services
Personal Data will be collected, processed, or used in connection with the services offered. This is 
always done in compliance with the provisions of the DPA and GDPR. Insofar as we use your 
Personal Data for a purpose that requires your consent according to the legal provisions, we will 
always ask for your express consent.

d) Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our operations, 
financial accounting, payment, and compliance with legal obligations, such as archiving. In this 
regard, we process the same data that we process in the course of providing our contractual services 
(see sections b, and c above). 

The processing bases are contract and our legitimate interest and in individual cases your consent. The 
purpose and our interest in the processing lies in the administration, financial accounting, office 
organisation, archiving of data, i.e., tasks that serve the maintenance of our business activities, 
performance of our tasks and provision of our services. The deletion of data with regard to contractual 
services and contractual communication corresponds to the data mentioned in these processing 
activities mentioned above. 

Integration of third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in 
order to integrate their content and services (hereinafter uniformly referred to as "content"). 
This always requires that the third-party providers of this content are aware of the IP address of the 
user, as without the IP address they would not be able to send the content to their browser. The IP 
address is therefore necessary for the display of this content. 

Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web 
beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information 
such as visitor traffic on the pages of our website. The pseudonymous information may also be stored 
in cookies on the user's device and may contain, among other things, technical information about the 
browser and operating system, referring websites, time of visit and other information about the use of 
our website, as well as being linked to such information from other sources.

The following provides an overview of third-party providers and their content, together with links to 
their privacy policies, which contain further information on the processing of data and so-called optout measures, if any:

  • Content Delivery Network, Content Management System: Wix.com, Inc

  • Mapping: Google Maps by Google LLC

  • Web Hosting Provider: by Google LLC

The legal basis for the data processing is your consent and our legitimate interest.

Transfer of Personal data 
We will not disclose or otherwise distribute your Personal data to third parties unless this is necessary 
for the performance of our services, you have consented to the disclosure, or the disclosure of data is 
permitted by relevant legal provisions. 

However, we are entitled to outsource the processing of your Personal data in whole or in part to 
external service providers acting as processors for us within the framework of the DPA and the 
GDPR. External service providers support us, for example, in the technical operation and support of 
the website, data management, the provision and performance of services as indicated above, as well 
as the implementation and fulfilment of reporting obligations. 

The service providers commissioned by us process your data exclusively in accordance with our 
instructions. We remain responsible for the protection of your data, which is ensured by strict 
contractual regulations, technical and organisational measures, and additional controls by us.
Personal data may also be disclosed to third parties if we are legally obliged to do so e.g., by court 
order or if this is necessary to support criminal or legal investigations or other legal investigations or 
proceedings at home or abroad or to fulfil our legitimate interests.

​

How is my data protected?

We want you to feel and be safe on our website. Therefore, we take various measures to meet both the 
legal requirements and our own very high standards of data protection and data security. 

Harbowe takes the protection of your personal data seriously. All data is handled and processed in 
accordance with the DPA and GDPR, which ensures the highest standards of data protection. 

Our data processing is subject to the principle that we only process the personal data that is necessary 
for the sensible and economic use of our offer. In doing so, we take great care to ensure that your 
privacy and the confidentiality of all personal data are always guaranteed.

All transmitted data is protected by TLS encryption. Transport Layer Security (TLS) is a protocol 
used to ensure secure data transmission on the Internet. The public-private key procedure is used here. 
This means that data encrypted with a publicly accessible key can only be decrypted again with a 
separate private key.

Harbowe uses technical and organisational security measures (TOMs) throughout the company to 
protect the data we manage from you against accidental or intentional manipulation, loss, destruction 
or against access by unauthorised persons. For example, we regularly train all employees on current 
IT security topics.

Duration of data storage
We store personal data on our secure server and only for as long as it is necessary for the purposes for 
which it is processed or for as long as any consent you have given us has been revoked by you. 
Insofar as statutory retention obligations must be observed, the storage period for certain data may be 
up to 6 years, irrespective of the processing purposes.

Marketing
Insofar as you have also given us your separate consent to process your data for marketing and 
advertising purposes, we are entitled to contact you for these purposes via the communication 
channels you have given your consent to.

​

You may give us your consent in a number of ways including by selecting a box on a form where we 
seek your permission to send you marketing information, or sometimes your consent is implied from 
your interactions or contractual relationship with us. Where your consent is implied, it is on the basis 
that you would have a reasonable expectation of receiving a marketing communication based on your 
interactions or contractual relationship with us.

Direct Marketing generally takes the form of e-mail but may also include other less traditional or 
emerging channels. These forms of contact will be managed by us, or by our contracted service 
providers. Every directly addressed marketing sent or made by us or on our behalf will include a 
means by which you may unsubscribe or opt out. 

Your data subject rights
These rights are standardised in the DPA and GDPR. These include: 

   • the right to information,

   • the right to rectification,

   • the right to erasure,

   • the right to restriction of data processing,

   • the right to data portability,

   • the right to object to data processing,

   • the right to revoke any consent you have given, and

   • the right to lodge a complaint with the competent supervisory authority.

Please contact us at any time with questions and suggestions regarding data protection and to enforce 
your rights as a data subject. 

We encourage you to contact us if you have any information requests, requests for information or 
objections about data processing or concerns. However, you also have the right to file a complaint 
with your local supervisory authority. However, we would appreciate it if you would contact us with 
your concern before turning to a supervisory authority.

Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to 
use it and want to request its rectification, deletion, or object to its processing, please do so by 
contacting us. For your protection and the protection of all of our users, we may ask you to provide 
proof of identity before we can answer the above requests.

Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it 
may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not 
be able to accommodate certain requests to object to the processing of Personal Data, notably where 
such requests would not allow us to provide our service to you anymore.

Withdraw your consent
You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for 
any or all of the Purposes by submitting your request to us. Should you withdraw your consent to the 
collection, use or disclosure of your Personal Data, it may impact our ability to proceed with your 
transactions, agreements, or interactions with us. Prior to you exercising your choice to withdraw your 
consent, we will inform you of the consequences of the withdrawal of your consent. Please note that 
your withdrawal of consent will not prevent us from exercising our legal rights (including any 
remedies) or undertaking any steps as we may be entitled to at law.

Personal Data and children 
Our services are aimed at people aged 18 and over. We will not knowingly collect, use or disclose 
Personal Data from minors under the age of 18 without first obtaining consent from a legal guardian 
through direct offline contact. 

​

Changes to this Privacy Policy
We are constantly developing and improving our website - and as a result, some of the information in 
this Privacy Policy is likely to change. We therefore recommend that you read this Privacy Policy 
again from time to time so that you are informed about the current status. This Privacy Policy was last 
updated on Thursday, 24 November 2022.

Do you have any questions?
Please contact us if you have any comments or questions about this policy and/or our use of your 
Personal Data