We value your privacy

Website Privacy Notice

Glenveagh Properties plc and its subsidiaries, (together “Glenveagh”, “the Group”, “us”, “we” or “our”), is the Data Controller, operate Glenveagh websites, and has created this privacy notice to demonstrate our firm commitment to privacy and it sets out how we collect and use personal data on our websites.

The purposes of our websites are to advertise and provide you with information on our current developments, job opportunities and investor information. We also use our websites in order to provide you with a platform or way of registering your interest in a particular development and to enable you to contact us with any queries that you may have.

By using our website and/or registering your interest, you agree to the terms of this policy and we may collect and process your personal data in accordance with the Data Protection Act 2018 and the General Data Protection Regulation 2016/679 (GDPR) and the e-Privacy Regulations where amended (the “Applicable Law”). We have explained 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. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. If you have any queries in relation to this data protection notice, or if you have any concerns as to how your data is processed, please contact us at the contact information.

If you are a shareholder, please see our Shareholders Privacy Notice.

If you are an employment candidate, please see our Employment Candidate Privacy Notice.

What Information is Collected About You?

“Personal data” means any information about an individual from which that person can be identified.

We collect different categories of personal data about you depending on the nature of our relationship with you and the purposes for which such information is necessary in the context of our relationship. For example, we collect personal data from you when you access our websites and use any of our website platforms for any purpose, including to register your interest in one of our developments, participate in a survey or register to attend one of our events. The categories of personal data we collect from you in each of these instances are set out below.

Like most websites, when you access our website, your device’s browser provides us with information such as your IP address, browser type, access times and referring URL which is collected and used to compile statistical data. This information may be used to help us to improve our website and the services we offer.

Most of the other personal data that we obtain from you, for example your name, email address, telephone number, buyer type, financial status (e.g. mortgage approved) or age group is obtained when you sign up for email alerts or register your interest in a particular development through our website.

When you register your interest in a development

When you register your interest in a Glenveagh development, we collect personal data from you or from third-party estate agents or services, depending on the channel through which you submitted your registration request. The information we obtain includes your name, e-mail address, telephone number, (types of) properties you are interested in, buyer type (e.g. first-time buyer), mortgage status (e.g. mortgage approved), price range, current location (county and townland), funding scheme status and type, and your marketing preferences. Where you choose to create an optional customer account on our website, we may collect your e-mail and password to provide you with a secure means to access your account.

When you are getting ready to buy a property

Registrations of interest are classified based on a tiered approach using commercial criteria including affordability, buyer type, and mortgage status. Depending on your initial readiness to buy, we may collect additional information including funding scheme details (e.g., access code, application number, and/or claim amount), home sale status (cash buyers only), mortgage approval letter, and your home selection preferences.

If you register your interest in one of our developments and/or are getting ready to buy a property, we use the information you supply to:

• respond to your enquiry.
• understand the type of home you are interested in, your requirements and circumstances.
• send you further information about that development, like brochures, viewing opportunities, digital news articles about the development, and the completion of new phases.
• send you marketing information on similar Glenveagh developments that may interest you.
• provide you with direct links to contact points for Irish mortgage providers and/or help to purchase schemes (should you wish to contact them directly).
• improve our offering and optimise your experience with our website's customer journey.

When you choose to participate in a Glenveagh survey

When you choose to participate in a survey, such as our social value/community impact survey, we collect your feedback on the Glenveagh development in which you reside ("Survey data"). Survey data may include the development where you reside, length of your residency, renting status, satisfaction ratings in relation to your development, wider community, developer awareness and development selection criteria. We may also collect health information (optional) subject to your explicit consent as it relates to the impact of the development on residents' health and wellbeing. If you choose to participate in our social value/community impact survey, we use Survey data to assess the impact of, and effectively channel our investment in our developments and local communities for the benefit of residents.

We also conduct optional satisfaction surveys following your contact with our customer care teams. The information we collect when you participate in our survey is limited to a positive or negative rating of your experience. Survey results may be reused for reporting and, in some circumstances, we may contact you to understand how we may improve our service. If you do not wish to participate and/or to be contacted, you can choose not to complete the survey and/or request to opt-out of further contact (see Your Data Rights and Contact sections).

When you register to attend a Glenveagh event

We organise free community events annually across our developments for the benefit of Glenveagh home residents, including know-your-neighbours, planting days, barbecues, and face painting events. When you choose to register and attend a community event, we may collect Event data that is necessary for the organisation, delivery and overall management of our events. Event data may include name, e-mail and home address. Subject to your consent, including parental consent in the event that you choose to bring your children along to an event, we may also collect photo and video images for social media publication for brand awareness purposes.

When you contact our customer care teams

We provide dedicated support to our customers who can raise requests with our customer care teams through our contact web form or by phone. Whenever you contact our customer care teams, we may collect Customer Service data. This Information may including your name, e-mail and home address, details of your query, request, or complaint, and any notes taken by our customer care agents in the process of handling your submission. When you choose to contact our customer care teams by phone, we may record calls for training and monitoring purposes. Where the nature of your customer care matter requires a home visit to deliver a service, we may also collect appointment details.

When you visit one of our physical locations

We use construction cameras and drone technology to track the progress of development projects across our construction sites. Whenever you visit one of our construction sites, this equipment may incidentally capture personal information such as facial images and vehicle plates, including in photo and video format.

When you engage with our web platforms

We provide a range of platforms and/or resources through our websites, including our North Portal which parents can leverage to enhance their children's experience of Christmas festivities. The portal can be used by parents to generate a personalised certificate addressed to their children from Santa announcing his visit to houses with no chimneys, such as Glenveagh new build homes. Children's names and city locations may be collected from parents, subject to their parental consent, to generate the certificate. Parents' e-mail address (optional) may also be collected for certificate generation and annual reengagement purposes.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them please see our Cookie Policy.

In providing our services, we may also receive personal data indirectly. Categories of such personal data include names, addresses, contact information and other information that is relevant to the provision of our services.

If you do not provide the requested information, we may not be able to provide you with our services or respond to any questions or requests you submit to us via our website. We will tell you when we ask for personal data whether it is a contractual requirement or needed to comply with our legal obligations.

Purpose and legal basis for processing your data

We collect and process your personal data in accordance with the Data Protection Acts 1988-2018 and the General Data Protection Regulation 2016/679 (GDPR).

Purposes for Processing

• For the prevention and detection of fraud, money laundering or other crimes or for the purpose of responding to a binding request from a public authority or court.

Legal Basis

• To comply with legal and regulatory obligations.

Purposes for Processing

• To market and advertise our new and current developments to you through the website.
• To provide you with email alerts once you have registered your details to receive those email alerts, including similar developments of interest and contact information for mortgage providers in your market.
• For customer relationship management and services, to improve our developments and communities for the benefit of Glenveagh home residents (sensitive data only).
• To promote brand awareness, including through the social media publication of Glenveagh event images and the launch of festive campaigns for parents and children (e.g. North Portal).

By registering your interest you consent to your data being processed for the purposes set out in this privacy notice.

Legal Basis

• Your consent – which you can withdraw at any time.
• Parental consent – We do not offer services directly to children and generally do not process children's data. However, as children do reside in Glenveagh homes, we may exceptionally process limited data concerning children forming part of our communities (e.g. North Portal campaign, community events). Where this is the case, processing only takes place subject to parental/ legal guardians' consent and attestation of their authority to act as the same, which can be withdrawn at any time.

Where personal data processing relies on consent, we may also collect and retain associated consent preference records to enable us to effectively observe and respect your choice as they concern your or your children’s data.

Purposes for Processing

• To administer our website and for internal operations, including troubleshooting, data analysis, testing (including the testing of live data), research, statistical and survey purposes.
• To improve our website to ensure that content is presented in the most effective manner for you and for your computer.
• As part of our efforts to keep our website safe and secure.
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
• For customer relationship management, to improve our customer care services, our developments, communities, and resident experience for the benefit of Glenveagh home residents (non-sensitive data).
• For brand awareness purposes and to enhance the user experience with Glenveagh resident campaigns.
• To derive commercial insights regarding our business lead generation and sales processes.
• For tracking the progress of our construction projects.

Legal Basis

• To support our legitimate interests, provided such interests are not overridden by your interests and rights. The nature of such legitimate interests includes:
  • Managing our business;
  • Honouring our commitments to Corporate Social Responsibility through effective community Investment;
  • Promoting the Glenveagh brand through community initiatives - which do not involve direct marketing;
  • Monitoring and improving the quality of our customer care services and providing associated staff training;
  • Improving the sales lifecycle and overall performance of our business.
  • Tracking the progress of construction projects to target timelines.

When we rely on legitimate interests as a legal basis 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 or to satisfy a legal obligation).

We do not intend to process your personal data for a purpose other than for which data was collected. Where there is a need to process your data for a purpose other than outlined to you, we will inform you of this.

Your right to object – Please note that you have a right to object to the processing of your personal data where that processing is carried out for our legitimate interests (see Your Data Rights section).

Where there is a need to process your data for a purpose other than those set out in this section or otherwise outlined to you.

Purposes for Processing

• To provide you with a way or platform through which you can register your interest in a development and progress through the associated property acquisition process.
• To address customer care requirements, such as queries, requests, and to arrange associated service appointments.

Legal Basis

• To perform a contract to which you are a party or to take steps at your request prior to entering into a contract with you.

Sharing personal data

We may disclose your personal data to other third parties or agents, including the following:

• Sales Agents or Estate Agents who act as data processors on our behalf;
• Regulatory bodies to whom we are obliged or required to disclose information;
• Relevant Government departments and agencies;
• Potential acquirers of our assets;
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• A prospective seller or buyer of business or assets in the event that we sell or buy any business or assets;
• A third party in a situation where Glenveagh or substantially all of its assets are acquired by that third party, in which case personal data held by it about its customers will be one of the transferred assets; and
• Other third parties where 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. These third parties include other companies and organisations for the purposes of fraud protection and credit risk reduction.

International data transfers

In some instances, we may need to transfer your personal data from the originating country (i.e. Ireland) to third parties located outside the European Union, including the United Kingdom, the United States, and Algeria. Third party recipients include organisations with whom we engage to deliver our products and services to you (see Sharing personal data). In transferring personal data to the United Kingdom, we rely on the European Commission's decision on the adequate protection of personal data by the United Kingdom under the General Data Protection Regulation. The Decision, which can be publicly accessed here helps us to ensure that personal data transferred remains adequately protected, as required by applicable law. In transferring personal data to the United States and Algeria, we rely on the European Commission's standard contractual clauses for International transfers which can be publicly accessed here.

Data retention periods

We will only keep your personal data for as long as it is strictly necessary for the purpose for which such data was collected, such as to enable you to use our services, platforms, events, and to provide our services to you (see Purpose and legal basis for processing your data section), unless a longer retention period is required. This is to comply with Applicable Law, resolve disputes with any parties and otherwise as necessary to allow us to conduct our business, including to detect and prevent fraud or other illegal activities.

Your Data Rights

Right to Withdraw Consent and what this means

If we are processing your personal data on the legal basis of consent, you are entitled to withdraw your consent at any time (see Contact Us below). However, the withdrawal of your consent will not invalidate any processing we carried out prior to your withdrawal and based on your consent.

Right to Information and what this means

You have the right to be informed about our collection and use of personal data through the privacy notice set forth.

Right of Access and what this means

You can request a copy of the personal data we hold about you.

Right to Rectification and what this means

You have the right to request that we correct any inaccuracies in the personal data we hold about you and complete any personal data where this is incomplete.

Right to Erasure (‘Right to be Forgotten’) and what this means

You have the right to request that your personal data be deleted in certain circumstances including:

• The personal data are no longer needed for the purpose for which they were collected;
• You withdraw your consent (where the processing was based on consent);
• You object to the processing and there are no overriding legitimate grounds justifying us processing the personal data (see Right to Object below); and
• The personal data have been unlawfully processed; or to comply with a legal obligation.

However, this right does not apply where, for example, the processing is necessary:

• To comply with a legal obligation; or
• For the establishment, exercise or defence of legal claims.

Right to Restriction of Processing and what this means

You can ask that we restrict your personal data (i.e., keep but not use) where:

• The accuracy of the personal data is contested;
• The processing is unlawful, but you do not want it erased;
• We no longer need the personal data, but you require it for the establishment, exercise or defence of legal claims; or
• You have objected to the processing and verification as to our overriding legitimate grounds is pending.

We can continue to use your personal data:

• Where we have your consent to do so;
• For the establishment, exercise or defence of legal claims;
• To protect the rights of another; or
• For reasons of important public interest.

Right to Data Portability and what this means

Where you have provided personal data to us, you have a right to receive such personal data back in a structured, commonly-used and machine-readable format, and to have those data transmitted to a third-party data controller without hindrance but in each case only where:

• The processing is carried out by automated means; and
• The processing is based on your consent or on the performance of a contract with you.

Right to Object and what this means

You have a right to object to the processing of your personal data in those cases where we are processing your personal data in reliance on our legitimate interests, for the performance of a task carried out in the public interest or in the exercise of our official authority. In such a case we will stop processing your personal data unless we can demonstrate compelling legitimate grounds which override your interests, and you have a right to request information on the balancing test we have carried out. You also have the right to object where we are processing your personal data for direct marketing purposes.

Automated Decision-Making Rights and what this means

You have the right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects or significantly effects. You also have the right to obtain human intervention in any such decision-making process, to express your point of view and to contest such decisions.

We do not engage in processing involving automated decision-making through our websites. Should this change at any time in future, we will inform you of the same and provide you with information about the logic underpinning the automated decision-making process, and any consequences of such decisions on you.

Right to Complain and what this means

You have the right to lodge a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

The contact details for the Irish Data Protection Authority:

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland

Phone: 01 7650 100 / 1800437 737
E-Mail: info@dataprotection.ie
Website: www.dataprotection.ie

Contact Us

If you have any queries in relation to this data protection notice, or if you have any concerns as to how your data is processed, we welcome the opportunity to address these by submitting them to our Company Secretary at the address listed below.

The Company Secretary

Glenveagh Properties plc

Block C, Maynooth Business Campus

Straffan Road

Maynooth

Co. Kildare

We may also be contacted by email at dataprivacy@glenveagh.ie. We ask that you insert ‘Website Privacy Notice’ into the subject line to ensure prioritised attention and we will respond free of charge within 30 days.

Details of this policy

Data protection compliance is reviewed and updated by the GDPR Committee and may be changed from time to time to comply with amended regulation, legislation or Applicable Law.

Disclaimer

Glenveagh reserves the right to change this Privacy Notice at any time and without advance notice, therefore, we encourage you to review this Privacy Notice from time to time to review any changes.

This statement is dated 22 November 2024.