Direct Marketing & Communications Policy

1. PURPOSE

This Direct Marketing & Communications Policy explains how Career Ireland Seirbhísí Limited, trading as CareerIreland ("CareerIreland", "we", "us" or "our"), manages customer and prospective-customer communications.

It applies to communications relating to:

• consultation services;
• immigration-related services;
• Website services;
• promotional communications;
• service updates;
• appointment communications;
• customer support; and
• other communications sent by CareerIreland.

This Policy supplements the Privacy Policy and does not replace it.

2. COMPANY DETAILS

Career Ireland Seirbhísí Limited
Trading as CareerIreland

Registered Office:
109 Windmill Park,
Crumlin,
Dublin, Dublin 12,
D12 Y0YX, Ireland

Office:
3 Crumlin Village,
Crumlin, Dublin 12,
D12 X8N5, Ireland

Telephone: +353 89 971 8143

Email: contact@irelandimmigrationcheck.com

Website: irelandimmigrationcheck.com

3. WHAT IS DIRECT MARKETING?

Direct marketing generally involves communications targeted to an individual for the purpose of promoting a product or service or encouraging the individual to request additional information or services.

Depending on the circumstances, direct marketing may include:

• email;
• SMS;
• telephone calls;
• messaging services;
• postal communications; and
• other targeted communications.

The Data Protection Commission distinguishes direct marketing from purely administrative or service communications.

4. SERVICE COMMUNICATIONS

Not every communication sent to a customer is direct marketing.

CareerIreland may send communications necessary to provide or administer a service, including:

• consultation confirmations;
• appointment reminders;
• appointment changes;
• payment confirmations;
• booking information;
• service-related instructions;
• responses to customer enquiries;
• account or security notifications; and
• information necessary to administer a customer's request.

These communications may be sent where necessary to provide the requested service or fulfil the relevant contractual or legal obligations.

5. MARKETING COMMUNICATIONS

Marketing communications may include information intended to:

• promote CareerIreland services;
• promote consultations;
• introduce additional services;
• encourage enquiries;
• provide promotional information; or
• communicate other commercial offers.

Where a communication constitutes electronic direct marketing, CareerIreland will apply the applicable ePrivacy and data-protection requirements.

6. CONSENT FOR ELECTRONIC DIRECT MARKETING

The general rule in Ireland is that electronic direct marketing requires the recipient's clear and affirmative consent, subject to limited exceptions under the ePrivacy Regulations.

Where consent is required, CareerIreland will seek it through an appropriate opt-in mechanism.

Consent for marketing should be separate from acceptance of:

• Terms & Conditions;
• Privacy Policy;
• consultation booking terms; or
• other unrelated Website terms.

7. MARKETING OPT-IN

Where marketing consent is requested, the user should be able to actively indicate whether they wish to receive marketing communications.

For example:

□ Yes, I would like to receive updates and offers from CareerIreland.

The wording should clearly identify that the user is agreeing to receive marketing communications.

8. NO PRE-SELECTED MARKETING CONSENT

Marketing consent should not be obtained through:

• pre-ticked boxes;
• default-on switches;
• silence;
• inactivity;
• continued Website browsing; or
• acceptance of unrelated terms.

The DPC has emphasised that marketing consent should be clearly distinguishable and not bundled with other consent requests.

9. EXISTING-CUSTOMER MARKETING

Irish ePrivacy rules provide a limited exception for certain electronic marketing to existing customers.

The exception may apply only where the applicable statutory conditions are satisfied, including circumstances involving:

• lawful collection of the customer's electronic contact details in connection with a sale;
• marketing of CareerIreland's own similar products or services;
• a clear opportunity to object when the contact details are collected; and
• a clear opportunity to object in each subsequent marketing communication.

The DPC confirms that this exception does not generally apply to prospective customers who have not completed a purchase.

CareerIreland will not assume that every existing contact automatically qualifies for this exception.

10. PROSPECTIVE CUSTOMERS

A person who merely:

• visits the Website;
• completes part of an assessment;
• submits an enquiry;
• starts but does not complete a booking; or
• otherwise interacts with the Website

should not automatically be treated as having consented to electronic direct marketing.

Where marketing consent is required, the appropriate opt-in should be obtained.

11. ABANDONED BOOKINGS

CareerIreland may send an operational communication where reasonably necessary to assist with an incomplete booking or customer request.

However, an abandoned booking does not automatically constitute marketing consent.

Any promotional content included in such communication must be assessed against the applicable direct-marketing rules.

12. CONSULTATION REMINDERS

Consultation reminders and appointment-related communications may be sent where necessary to administer a booked consultation.

Examples include:

• appointment confirmation;
• appointment reminder;
• change of appointment time;
• cancellation notice;
• joining instructions; and
• technical information required for the consultation.

These communications are administrative/service communications rather than marketing where they do not contain promotional content.

13. MIXED COMMUNICATIONS

Where a communication contains both service information and promotional content, CareerIreland will assess whether the communication constitutes direct marketing.

The fact that a message also contains useful administrative information does not automatically prevent the communication from being considered marketing.

The DPC has noted that communications that are otherwise informational can become direct marketing where promotional content is included.

14. EMAIL MARKETING

Where email marketing is sent, CareerIreland will:

• use an appropriate lawful basis;
• comply with applicable ePrivacy requirements;
• identify CareerIreland appropriately;
• provide a functioning unsubscribe mechanism where required; and
• process opt-out requests promptly.

15. SMS MARKETING

Where SMS marketing is used, CareerIreland will apply the applicable electronic direct-marketing requirements.

Marketing SMS messages should not be sent without the required consent or another applicable legal basis permitted under the ePrivacy Regulations.

Where applicable, each marketing message should provide an effective method of opting out.

16. TELEPHONE MARKETING

Where CareerIreland makes marketing calls, applicable Irish rules concerning direct-marketing telephone calls will apply.

CareerIreland will consider:

• the type of telephone number;
• the individual's marketing preference;
• applicable consent requirements;
• relevant opt-out mechanisms; and
• any applicable directory preferences.

17. WHATSAPP OR OTHER MESSAGING SERVICES

Where CareerIreland uses WhatsApp or another messaging service for customer communications, the nature of the communication will determine the applicable requirements.

Operational communications relating to a requested service may be treated differently from promotional communications.

Marketing through electronic messaging channels will be subject to applicable consent and direct-marketing requirements.

18. SOCIAL-MEDIA COMMUNICATIONS

CareerIreland may operate social-media accounts for business and marketing purposes.

Users who voluntarily interact with CareerIreland through social-media platforms should be aware that the relevant platform may independently process personal information under its own terms and privacy policies.

CareerIreland will not treat a social-media interaction by itself as automatic consent to unrelated electronic direct marketing.

19. MARKETING THROUGH THIRD-PARTY PLATFORMS

CareerIreland may use third-party platforms for:

• email delivery;
• CRM;
• advertising;
• customer communications;
• audience management; or
• campaign administration.

Where third-party providers process personal information on CareerIreland's behalf, the relevant contractual and data-protection arrangements will apply.

Where a third party acts independently as a controller, its own privacy terms may also apply.

20. META AND ADVERTISING AUDIENCES

Where CareerIreland uses Meta or other advertising platforms for audience management or advertising, the relevant technology and consent requirements will apply.

Advertising cookies or pixels requiring consent should not be activated before the relevant consent is obtained.

The Cookie Policy and Cookie Consent Notice & Preference Centre provide further information concerning tracking technologies.

21. MARKETING PREFERENCES

CareerIreland may maintain a record of marketing preferences, including:

• opted in;
• opted out;
• consent withdrawn;
• communication channel preferences; or
• suppression status.

These records may be retained where reasonably necessary to respect the user's preferences and demonstrate compliance.

22. WITHDRAWING MARKETING CONSENT

A recipient may withdraw marketing consent at any time.

Withdrawal should be straightforward and free of unnecessary barriers.

Where marketing is sent by email, the communication should provide an appropriate unsubscribe mechanism where required.

23. UNSUBSCRIBE MECHANISM

Marketing emails should contain a clear and functioning method of unsubscribing.

For example:

Unsubscribe from marketing

or

Manage communication preferences

The unsubscribe mechanism should not require the recipient to provide unnecessary information.

24. OPT-OUT PROCESSING

When a valid marketing opt-out is received, CareerIreland will process the request promptly.

The person should generally be removed from the relevant marketing list.

A limited suppression record may be retained where necessary to ensure that the person is not inadvertently added back to the marketing list.

25. OPT-OUT FROM ONE CHANNEL

Where technically possible, CareerIreland may allow users to manage communication preferences by channel.

For example, a person may be able to:

• stop marketing emails;
• continue receiving consultation reminders; or
• stop promotional SMS while continuing to receive service communications.

Stopping marketing does not necessarily stop essential service communications.

26. SERVICE COMMUNICATIONS AFTER MARKETING OPT-OUT

A marketing opt-out does not necessarily prevent CareerIreland from sending communications necessary to:

• provide a purchased service;
• administer a booking;
• process a payment;
• address a customer enquiry;
• handle a complaint;
• communicate a security issue; or
• fulfil a legal obligation.

27. DIRECT MARKETING OBJECTION

Individuals have a strong right to object to processing of their personal information for direct marketing purposes.

The DPC states that a person may object to direct marketing at any time and that the relevant processing must stop following a valid objection.

28. MARKETING PROFILE AND TARGETING

Where CareerIreland uses personal information to create or use a marketing profile, the relevant data-protection requirements will apply.

Individuals may have the right to object to profiling for direct marketing purposes.

29. MARKETING DATA SOURCES

CareerIreland should use marketing contact information only where it has been obtained lawfully and may be used for the intended marketing purpose.

CareerIreland will not knowingly purchase or use contact databases where the relevant data has not been lawfully obtained or where the required permissions are absent.

30. THIRD-PARTY CONTACT LISTS

CareerIreland should not upload or use third-party contact lists for marketing unless the relevant use is lawful and appropriate consent or another permitted basis exists.

A person's contact details being publicly available does not automatically mean that the person has consented to electronic direct marketing.

31. REFERRALS AND "TELL A FRIEND"

CareerIreland will not knowingly send unsolicited marketing communications to a person merely because another customer provides that person's contact details.

Where referral functionality is offered, it should be designed so that the communication is sent in a manner consistent with applicable law.

32. MARKETING CONTENT AND IMMIGRATION INFORMATION

Marketing communications may contain information concerning:

• consultation services;
• eligibility assessments;
• immigration routes;
• application-related services;
• Website services; or
• other CareerIreland offerings.

Marketing content should not be presented as an official Irish Government communication.

33. NO MISLEADING GOVERNMENT ASSOCIATION

CareerIreland's marketing communications must not imply that CareerIreland is:

• an Irish Government department;
• Immigration Service Delivery;
• the Department of Justice;
• an embassy;
• a consulate; or
• another official immigration authority.

Marketing should clearly identify CareerIreland as the service provider where appropriate.

34. MARKETING CLAIMS

Marketing communications should not make misleading claims concerning:

• visa approval;
• immigration eligibility;
• employment permits;
• citizenship;
• naturalisation;
• guaranteed outcomes;
• Government endorsement; or
• processing times.

Claims should be capable of being reasonably substantiated.

35. CUSTOMER REVIEWS AND TESTIMONIALS

Where CareerIreland uses customer reviews or testimonials in marketing, it should not knowingly present fabricated or materially misleading testimonials.

Where applicable, testimonials should accurately represent the customer's experience.

A customer's positive experience with a consultation should not be presented as proof of a guaranteed immigration outcome.

36. MARKETING AUTOMATION

CareerIreland may use CRM or marketing-automation technology to manage permitted communications.

Automated campaigns must respect:

• marketing consent;
• opt-outs;
• suppression lists;
• communication preferences; and
• applicable legal restrictions.

Automation does not remove CareerIreland's responsibility to comply with applicable marketing rules.

37. AI-GENERATED MARKETING

Where AI or automated tools assist with marketing content, CareerIreland remains responsible for reviewing the resulting communication.

AI-generated content must not knowingly contain:

• false Government claims;
• fabricated approvals;
• misleading guarantees;
• inaccurate service descriptions; or
• other materially misleading statements.

38. DATA PROTECTION

Personal information used for marketing is processed in accordance with the Privacy Policy.

The Privacy Policy explains relevant matters including:

• categories of information;
• purposes of processing;
• legal bases;
• recipients;
• retention;
• international transfers; and
• data-subject rights.

39. RETENTION OF MARKETING SUPPRESSION RECORDS

Where a person opts out of marketing, CareerIreland may retain a limited suppression record.

The purpose is to ensure that the person is not inadvertently contacted for the same marketing purpose again.

This record will not be used for unrelated marketing.

40. MONITORING COMPLIANCE

CareerIreland may periodically review its marketing processes to ensure that:

• consent records are maintained where required;
• unsubscribe mechanisms function correctly;
• opt-outs are actioned;
• marketing lists are appropriately maintained;
• automated campaigns respect preferences; and
• third-party marketing providers operate within the applicable arrangements.

The DPC's 2025 Annual Report highlights the importance of functioning opt-out mechanisms and testing them regularly.

41. COMPLAINTS ABOUT MARKETING

If you believe you have received marketing in error, you may contact CareerIreland and request that your marketing preference be reviewed.

You may also exercise your right to object to direct marketing.

Complaints may additionally be raised under the Complaints & Customer Support Policy.

42. REGULATORY RIGHTS

Nothing in this Policy limits any right available under:

• GDPR;
• the Data Protection Act 2018;
• the ePrivacy Regulations;
• applicable consumer law; or
• other applicable legislation.

43. CONTACT

For marketing preferences, unsubscribe requests or communication concerns:

Career Ireland Seirbhísí Limited
Trading as CareerIreland

Registered Office:
109 Windmill Park,
Crumlin,
Dublin, Dublin 12,
D12 Y0YX, Ireland

Office:
3 Crumlin Village,
Crumlin, Dublin 12,
D12 X8N5, Ireland

Telephone: +353 89 971 8143

Email: contact@irelandimmigrationcheck.com

Website: irelandimmigrationcheck.com

44. RELATED DOCUMENTS

This Policy should be read together with:

• Privacy Policy;
• Data Subject Rights & Privacy Request Procedure;
• Data Retention & Deletion Policy;
• Cookie Policy;
• Cookie Consent Notice & Preference Centre;
• Website Terms & Conditions; and
• Complaints & Customer Support Policy.

45. CHANGES TO THIS POLICY

CareerIreland may update this Policy to reflect:

• changes in marketing channels;
• changes to CRM or communication systems;
• changes in third-party providers;
• changes in applicable law;
• regulatory guidance; or
• changes to internal marketing procedures.

The latest version will be published on the Website.

Last Updated: 11 August 2026