**Last updated: [4/9/2026]** --- ## 1. Who we are This notice explains how Michael Kelly, trading as Nemetan ("Nemetan", "we", "us"), collects and uses personal data. We are the data controller for the personal data described in this notice. 93 George's St. Upper Dun Laoghaire, Dublin Ireland - **Contact for privacy matters:** info@nemetan.com We have not appointed a Data Protection Officer, as we are not required to. --- ## 2. What personal data we collect ### When you visit nemetan.com Our website is hosted on Wix. Wix and our analytics tools automatically record technical information including your IP address, browser type and version, device type, operating system, the pages you view, and the site or advertisement that referred you. We also run the **LinkedIn Insight Tag** on our website. This is a piece of code from LinkedIn that records visits to our pages and allows us to measure the performance of our advertising and to show ads to people who have visited the site. LinkedIn may be able to identify you from this if you are a LinkedIn member. [CONFIRM WHICH ANALYTICS YOU ACTUALLY RUN: Wix Analytics, Google Analytics, both, or something else. List them here.] ### When you use our free assessment tools We provide free online tools, including the **Transition Gap Check** and the **Sustainability Opportunity Maturity Matrix**. When you use one, we collect the answers you give and the score the tool produces. Where the tool asks for an email address and your role before it will run, we collect those too. ### When you download a research resource We publish research including *The Stunted O* white paper and its Executive Brief. When you request a copy, we collect your **name and email address**. If you request a copy through an advertisement on LinkedIn, you will complete a **LinkedIn Lead Generation Form**. LinkedIn pre-fills that form from your LinkedIn profile and passes the details you submit to us. LinkedIn also processes that data for its own purposes as a separate controller; see LinkedIn's own privacy policy for how it does so. ### When you buy a course or engage our services We collect your name, email address, billing details, the organisation you work for, and records of what you purchased and when. Payments are processed by [PAYMENT PROVIDER], and we do not receive or store your full card details. ### When you contact us If you email us, book a call, or connect with us on LinkedIn, we keep the content of that correspondence and your contact details. --- ## 3. Why we use your data, and our legal basis | What we do | Why | Legal basis | |---|---|---| | Run and secure the website | To provide the site and keep it working | Legitimate interests: operating our business | | Analytics and advertising measurement, including the LinkedIn Insight Tag | To understand how the site is used and whether our advertising works | Consent, given through our cookie banner | | Provide a free assessment tool and its result | To give you the thing you asked for | Legitimate interests: responding to your request | | Send you a research resource you requested | To deliver the download | Legitimate interests: responding to your request | | **Send you further emails about Nemetan research, courses and services** | **To market our services** | **[SEE NOTE BELOW — THIS ONE NEEDS A DECISION]** | | Deliver a course or consulting engagement | To perform our contract with you | Performance of a contract | | Keep financial and tax records | Because we are legally required to | Legal obligation | | Answer your enquiry | To respond to you | Legitimate interests: dealing with enquiries | > **[DECISION NEEDED — MARKETING.]** You have chosen not to include a marketing consent checkbox on the LinkedIn form. That means people who download the white paper have asked for a document, and have not agreed to receive anything else. If you later want to email them about courses or services, you will need a lawful basis for it. In Ireland the relevant rules are the ePrivacy Regulations (S.I. 336/2011) alongside the GDPR, and the "soft opt-in" that lets you market to existing customers does not apply to someone who has only downloaded a free resource. **The safe position is: do not add downloaders to any marketing sequence unless and until they opt in separately.** Confirm this with a lawyer before you send anything, and delete or rewrite this row to match what you decide. --- ## 4. Cookies and similar technologies We use cookies and similar technologies to run the site, to understand how it is used, and to measure advertising. - **Strictly necessary** cookies make the site work. These do not require your consent. - **Analytics and advertising** cookies, including those set by the LinkedIn Insight Tag, are only set if you agree to them. You can change your choices at any time through [LINK TO YOUR COOKIE SETTINGS], and through your browser settings. [CONFIRM YOU HAVE A COOKIE BANNER THAT ACTUALLY BLOCKS NON-ESSENTIAL COOKIES UNTIL CONSENT IS GIVEN. A banner that only announces cookies is not sufficient under EU law, and the Insight Tag is exactly the kind of tag that has to wait for consent.] --- ## 5. Who we share your data with We do not sell your personal data. We share it with service providers who process it on our behalf: - **Wix** — website hosting, forms, and [EMAIL/CRM, IF YOU USE WIX FOR THAT] - **LinkedIn** — advertising, Lead Generation Forms, and the Insight Tag - **[EMAIL PROVIDER]** — sending email - **[PAYMENT PROVIDER]** — processing payments - **[ANALYTICS PROVIDER]** — website analytics - Our accountants and professional advisers, where necessary We may also disclose personal data where we are required to by law. --- ## 6. Transfers outside the EEA Some of our providers, including Wix and LinkedIn, may process personal data outside the European Economic Area, including in the United States. Where that happens, the transfer is covered by an adequacy decision of the European Commission or by Standard Contractual Clauses together with any additional safeguards required. You can ask us for more detail about the safeguards that apply by emailing info@nemetan.com. --- ## 7. How long we keep your data | Data | Retention | |---|---| | Website analytics | [e.g. 14 months] | | Assessment tool responses and scores | [e.g. 24 months from your last interaction] | | Resource download records, name and email | [e.g. 24 months from your last interaction] | | Leads held inside LinkedIn Campaign Manager | LinkedIn deletes these automatically after 90 days. We download them before then and hold them as above. | | Customer and financial records | [Six years, or as your accountant advises, to meet tax law] | | Correspondence | [e.g. 24 months] | [THESE ARE PLACEHOLDERS, NOT RECOMMENDATIONS. SET PERIODS YOU WILL ACTUALLY HONOUR, BECAUSE A POLICY THAT PROMISES DELETION YOU DO NOT CARRY OUT IS WORSE THAN NO PROMISE.] --- ## 8. Your rights Under the GDPR you have the right to: - **access** the personal data we hold about you - ask us to **correct** it if it is wrong - ask us to **erase** it in certain circumstances - ask us to **restrict** how we use it - **object** to processing we carry out on the basis of legitimate interests, including any direct marketing, which you can object to at any time and without giving a reason - receive your data in a portable format - **withdraw consent** at any time, where we rely on consent, without affecting anything we did before you withdrew it To exercise any of these, email **info@nemetan.com**. We will respond within one month. We may ask you to confirm your identity first. --- ## 9. Complaints If you are unhappy with how we have handled your personal data, please tell us first at info@nemetan.com so we can try to put it right. You also have the right to complain to a supervisory authority. In Ireland this is the **Data Protection Commission**, 6 Pembroke Row, Dublin 2, D02 X963 (www.dataprotection.ie). If you live or work in another EU country, you may complain to your own national authority instead. [CONFIRM YOUR LEAD SUPERVISORY AUTHORITY. THIS ASSUMES THE ENTITY IS ESTABLISHED IN IRELAND. IF IT IS NOT, THIS SECTION IS WRONG AND MUST CHANGE.] --- ## 10. Changes to this notice We may update this notice from time to time. The current version is always at [URL OF THIS PAGE], and the date at the top tells you when it last changed. --- ## 11. Contact **[FULL REGISTERED LEGAL ENTITY NAME]** [REGISTERED ADDRESS] info@nemetan.com --- ## What you need to fill in before this goes live 1. Full registered legal entity name, company number, registered address, and country of establishment 2. Which analytics tools you actually run 3. Your email provider and payment provider 4. Whether you have a cookie banner that blocks non-essential cookies before consent 5. The URL of your cookie settings page 6. Retention periods you will genuinely apply 7. The marketing decision in section 3, which is the one to take to a lawyer first 8. The URL this page will live at