Privacy Policy

1. Who we are

Sroware is a trading name of Nutrapi Ltd (“Sroware”, “we”, “us” or “our”), a software and hardware development company. We are the data controller responsible for the personal data described in this policy. We provide technology services only — we do not sell, supply, prescribe or dispense medications, and we do not provide healthcare or medical services directly to patients.

Our data controller and contact details are:

Nutrapi Ltd, trading as Sroware
Data Controller: Kieran Walkin
80 Patrick St, Dun Laoghaire, Co. Dublin, Ireland
Email: kieran@sroware.com
Phone: +353 86 782 7399
Company Registration Number (CRO): [TO CONFIRM]

2. Scope of this policy

This policy explains how we handle personal data when you visit our website, contact us, or engage our services. It covers data for which Sroware is the controller — primarily our own website and business contacts.

When we build and operate software or devices for clients, we typically act as a data processor, processing data only on the documented instructions of our client, who remains the controller. That processing is governed by a separate Data Processing Agreement with the relevant client, and the client’s own privacy notice applies to their users.

3. The information we collect

Information you give us

When you complete our contact form or email us, we collect the information you provide — typically your name, email address and the contents of your message. Our contact form is processed on our behalf by Web3Forms, which delivers your submission to us by email.

Information collected automatically

Our hosting provider keeps standard server logs that may include your IP address, browser type, the pages you request and the date and time of access. These are used for security and to keep the website running reliably. Our website uses only strictly necessary cookies required for it to function.

We do not currently operate advertising or analytics tracking on this website. If we add tools such as analytics or advertising pixels in future, we will update this policy and request your consent where required.

Information processed for clients

In the course of building and running software or devices, we may process personal data belonging to our clients’ users. We process this data only as a processor, under our client’s instructions, and do not use it for our own purposes.

4. How we use your data and our legal bases

We use personal data for the following purposes, relying on the lawful bases set out in Article 6 GDPR:

• To respond to enquiries you send us — on the basis of our legitimate interest in answering and following up with people who contact us, or to take steps at your request before entering a contract.
• To provide and manage our services to clients — on the basis of performance of a contract.
• To operate and secure our website — on the basis of our legitimate interest in maintaining a safe, functional website.
• To comply with legal obligations — for example accounting, tax and record-keeping requirements.

5. Who we share data with

We do not sell your personal data. We share it only with trusted service providers who help us run our business, and only as far as necessary:

• Hosting — our website is hosted by Hostinger, which stores the website and server logs.
• Contact form processing — Web3Forms processes contact-form submissions and forwards them to us.
• Infrastructure and tooling providers — where we build or run client solutions, data may be processed by cloud, communications, telephony or email providers engaged for that project.
• Professional advisers and authorities — where required by law or to establish, exercise or defend legal claims.

Each provider is bound to protect personal data and to use it only for the agreed purposes.

6. International transfers

Some of our service providers may process data outside the European Economic Area (EEA). Where that happens, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses or an adequacy decision, so that your data continues to receive an equivalent level of protection.

7. How long we keep data

We keep personal data only for as long as necessary for the purposes described above. Enquiry and contact data is kept for as long as needed to deal with your request and for a reasonable period afterwards; client project data is retained for the duration of the engagement and any period required by our contract or by law, after which it is deleted or returned.

8. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you;
• have inaccurate data corrected;
• have your data erased in certain circumstances;
• restrict or object to our processing of your data;
• data portability; and
• withdraw consent at any time, where we rely on consent.

To exercise any of these rights, or to request deletion of your data, contact us at kieran@sroware.com. We will respond within one month. If your data is processed by us on behalf of a client, we will direct your request to that client as the controller.

9. Complaints

If you have a concern about how we handle your data, please contact us first so we can try to resolve it. You also have the right to lodge a complaint with the Irish supervisory authority:

Data Protection Commission
21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland
www.dataprotection.ie

10. Security

We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss or disclosure. No method of transmission or storage is completely secure, but we work to keep our systems and our providers’ systems protected.

11. Children

Our website and services are intended for businesses and are not directed at children. We do not knowingly collect personal data from children.

12. Changes to this policy

We may update this policy from time to time. The current version is always available on this page, with the “last updated” date shown above.

13. Contact us

For any question about this policy or your personal data, contact kieran@sroware.com or write to us at 80 Patrick St, Dun Laoghaire, Co. Dublin, Ireland.