Joint Controller Privacy Notice
Glenveagh Properties Plc, (“Glenveagh”), comply with the Data Protection Act 2018 and General Data Protection Regulation and e-Privacy Regulations where amended (the ‘Applicable law’). Glenveagh appointed two Sales Agent, Flynn & Associates and REA Grimes (“the Sales Agents”) in respect of the sale of the units for this development. Throughout this Joint Controller Privacy Notice, when we refer to “us”, “our” or “we”, we mean Glenveagh and the Sales Agent together.
We have determined that we are Joint Controllers where we jointly determine the purpose and the means of processing your personal data when it is collected on the “register your interest” forums below.
You can register your interest in this development in either of the following ways: –
- Using the “register your interest” platform on Glenveagh.ie; or
- Using the “register your interest” platform on the Sales Agents’ website.
This Joint Controller Privacy Notice demonstrates our firm commitment to privacy and it also outlines our information gathering and sharing practices concerning your personal data that is obtained by us from you when you register your interest in this development. We set out below what type of personal data we are likely to obtain from you, how we will use that personal data and the legal basis that we rely on in processing your personal data. The Joint Data Controllers have entered into a written arrangement setting out the responsibilities of each Joint Data Controller, which is available on request to either Joint Controller at their details below.
Who is the Data Controller?
Glenveagh (and its affiliate companies including Glenveagh Homes Limited) and the Sales Agent are Joint Data Controllers. Glenveagh’s registered office is located at Block B, Maynooth Business Campus, Maynooth, County Kildare. Flynn & Associates’s registered office is located at Castlecourt, Castleknock, Dublin 15. REA Grimes registered office is located at Main Street, Ashbourne, Co. Meath.
How to Contact the Data Controller
If you have any questions or queries about how your data is processed, please contact Glenveagh at:
The Company Secretary
Glenveagh Properties Plc
15 Merrion Square
Glenveagh may also be contacted by email at email@example.com. We ask that you insert “Website Data Protection Notice” into the subject line when contacting Glenveagh by email to ensure prioritised attention.
Flynn Associates may be contacted at 58 Main Street, Swords, Co Dublin, and by email at firstname.lastname@example.org.
REA Grimes may be contacted at Main Street, Ashbourne, Co. Meath and by email at email@example.com.
What Information is Collected About You?
We collect personal data from you when you register your interest in this development. We obtain from you your name, email address, telephone number, buyer type, financial status, estimated age profile and the name of your lending institution (if applicable).
The Purpose for Obtaining and Processing Your Personal Data
The Joint Data Controllers will only process your personal data when you register your interest in this development for the following purposes:
- to provide you with marketing communications/further information on this development (Glenveagh and Sales Agents);
- to answer any queries which you may have about this development (Glenveagh and Sales Agents);
- to arrange for viewings of units within this development or show houses (Sales Agents);
- to liaise with you throughout the bidding/sale process of a unit or units within this development if you are a party involved in that bidding/sale process (Glenveagh and Sales Agents);
- to receive from you and process a booking deposit on the purchase of a unit or units within this development which is passed to Glenveagh’s solicitors either through the Sales Agent or to the solicitor directly;
- when an offer on a unit or units made by you has been accepted by Glenveagh, to draft and send a Sales Advice Notice to the Appointed Solicitor (Glenveagh);
- for the Appointed Solicitor, as a Data Processor, to draft Contracts for Sale on receipt of the Sales Advice Notice from the Sales Agent/Glenveagh (Glenveagh and Sales Agents);
- to facilitate the completion of the sale of a unit or units within this development purchased by you, for example arranging for you to collect the keys (Glenveagh and Sales Agents);
- to make suggestions about other developments that may interest you (Glenveagh and Sales Agents);
- where you register your details through the website, to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes (Glenveagh and Sales Agents);
- where you register your interest through the website, to improve our website to ensure that content is presented in the most effective manner for you and for your computer (Glenveagh and Sales Agents);
- where you register your interest through the website, as part of our efforts to keep our website safe and secure (Glenveagh and Sales Agents);
- where you register your interest through the website, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you (Glenveagh and Sales Agents);
The Legal Basis for Obtaining Your Data
We process your personal data once we have obtained your affirmative consent to do so in order to send you marketing communications/further information on this development. If you have provided us with your consent, you can withdraw this consent at any time, however it will not affect the lawfulness of processing based on consent before its withdrawal. To withdraw your consent, please use the contact details provided in the “How to Contact the Data Controller” paragraph above.
- Legitimate Interests
In most cases, it is in our legitimate interest to process your personal data for the following reasons:
- To advertise and promote this development;
- To enable us to communicate with you about this development and the sale process if you make an offer/bid;
When we rely on legitimate interests as a legal justification for processing your personal data, we must consider whether those legitimate interests are overridden by your interests, fundamental rights and freedoms. We have considered these matters and we believe that our legitimate interests are not overridden by your interests, fundamental rights and freedoms. If this were to change and if we think that there is a risk that one or more of your interests, fundamental rights and freedoms may be affected, then we will not use your personal data unless there is another legal basis for us to do so (for example by obtaining your consent).
- For the Performance of a Contract to Which You are a Party or in Order to Take Steps at Your Request to Enter into a Contract
If a booking deposit is accepted from you by the Sales Agents or the Glenveagh’s solicitor directly, Glenveagh will need to process your personal data in order for the Contracts for Sale to be drafted. An example of this would be the Sales Agents sending a Sales Advice Notice which contains your personal data to the Appointed Solicitor who will draft the Contracts for Sale. We will also have to process your personal data in order to assist in the completion of the sale for example arranging for you to collect keys upon completion of the sale from the Sales Agents.
What Happens if You Do Not Want to Provide us with Your Personal Data
If you do not want us to process your personal data or if you request (see your rights) that we stop processing your personal data, then we cannot provide you with further marketing information about this development, communicate with you about viewings or any offers/bids that you wish to make, accept a booking deposit, issue a Sales Advice Notice and/or assist in the completion of the sales process.
Data Retention/How Long We Keep Your Personal Data For
We only retain your personal data for as long as necessary to fulfil the purpose for which it was collected, including for the purposes of satisfying any legal, accounting or reporting requirements. Depending on the nature of the information we hold and the purposes for which it is processed, this will determine the number of years we need to retain your personal data in our system. It is our policy to retain documents in hardcopy and electronic form in accordance with any retention period required by law or to the end of the period in which litigation might arise from our engagement. The data will then be destroyed without further notice or liability.
Disclosure of your personal information
When you register your interest in this, the recipients of your personal data include, our Appointed Solicitor and IT providers. Glenveagh may also disclose your personal data to any member of its group, within and outside of the European Economic Area (“EEA”) which means our subsidiaries, our ultimate holding company and its subsidiaries to provide services for us, subject to strict contractual obligations to protect your personal information and process it on our behalf and under our control only.
We may also share your information with selected third parties including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our website; and
- mortgage brokers and/or financial institutions where you have provided your consent.
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if the Joint Controllers (or either of them) (or substantially all of its assets) are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms and conditions and other agreements; or to protect the rights, property, or safety of Glenveagh, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Where we store your personal data
The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your Rights What does this mean?
The right to be informed You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we’re providing you with the information in this notice.
The right of access You have the right to obtain access to your personal data (if we’re processing it), and certain other information (similar to that provided in this Joint Controller Privacy Notice).
The right of rectification This is so you’re aware and can check that we’re using your personal data in accordance with data protection law.
The right to erasure This is also known as the ‘right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing You have rights to ‘block’ or suppress further use of your personal data. When processing is restricted, we can still store your personal data, but may not use it further. We keep lists of people who have asked for further use of their personal data to be ‘blocked’ to make sure the restriction is respected in the future.
The right to data portability You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
The right to object to processing You have the right to object to processing for direct marketing (which we do only with your consent) and also to processing which is carried out for the purposes of our legitimate interests.
The right to lodge a complaint You have the right to lodge a complaint about the way we handle or process your personal data with the Data Protection Commissioner.
The right to withdraw consent If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
Changes to our Joint Controller Privacy Notice
This Joint Controller Privacy Notice has been updated on the 31st of July 2019. We reserve the right to change this Notice at any time at our sole discretion. If we make changes, we will inform you by placing an updated copy on our website or otherwise informing you by email or other means of communication.