Glenveagh Properties Plc (“Glenveagh” or “us”/“we”/“our”) comply with the Data Protection Acts 1988-2018, the General Data Protection Regulation (2016/679) and the ePrivacy Regulations where amended (the “Applicable Law”). This Privacy Notice demonstrates our firm commitment to privacy and it sets out how we collect and share your personal data.
We are the Data Controllers for the personal data we process since we determine the essential means and purposes of the processing of this personal data.
This personal data is initially collected when you register your interest in a development. You may do this either on the Glenveagh.ie website or on one of our Sales’ Agents websites. The categories of personal data we collect, either directly or indirectly, are set in the section “What Personal Data is Collected About You?”.
We do not share or disclose any of your personal data where we do not have a legal basis to do so. Our legal bases for processing are set out in the section “Our Legal Bases for Processing your Personal Data”.
We will only share or disclose your personal data for the purposes specified in this Privacy Notice. Where we intend to do so for other purposes, we will ensure that we have a legal basis (such as by asking your consent or to satisfy a legal obligation). Our purposes for processing your personal data are set out in the section “The Purposes for Processing Your Personal Data”.
Who is the Data Controller?
We, Glenveagh (and our affiliate companies, such as Glenveagh Homes Limited) are the Data Controller. Our registered office is located at Block B, Maynooth Business Campus, Maynooth, County Kildare, W23 W5X7.
How do I Contact the Data Controller?
If you have any questions or queries about how your data is processed, please contact us:
• by post at The Company Secretary, Glenveagh Properties Plc, 15 Merrion Square, Dublin 2, or;
• by email at firstname.lastname@example.org. We ask that you insert “Website Data Protection Notice” into the subject line when contacting us by email to ensure we get to it on time.
Who processes your personal data on our behalf?
We appoint Sales Agents for the sale of units within our developments. Sales Agents collect your personal data from their website after you’ve registered your interest and process the data through our CRM system. Alternatively if you have provided Glenveagh with your data, we may pass it to our Sales Agents so that they may assist you.
The Sales Agents referenced above act as Data Processors on our behalf and process your data in line with the instructions provided to them by Glenveagh under the relevant contract as mandated by the GDPR.
What other parties do we may share your personal data with?
We may share your personal data with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- Appointed Solicitors for the purposes outlined in section “The Purposes for Processing Your Personal Data”;
- Analytics and search engine providers that assist us in the improvement and Optimisation of our website; and
- Mortgage brokers and/or financial institutions.
- Should you wish to contact any of our Sales Agent in relation to a specific development, please contact Glenveagh using the details outlined in the ‘Contact Us’ section of this website and we can provide you with the necessary information
We may also disclose your personal data 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 Processors (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 personal data with other companies and organisations for the purposes of fraud protection and credit risk reduction.
What Personal Data is Collected about You?
When you register your interest in a development, we collect your:
• Full name
• Email address
• Phone number
• Estimated age profile
• Buyer status (whether you are an investor, a first time buyer or whether you have a house to sell)
• Financial status
• Mortgage status (whether you are seeking a mortgage, are a cash buyer or have a mortgage approved)
• Lending institution’s name (if applicable)
• Whether you are hoping to avail of the Help to Buy Scheme
• Whether you would like to be contacted by our mortgage partner
• Whether you would like to you to receive marketing communications about any Glenveagh developments.
The Purposes for Processing Your Personal Data
We 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 Agents or to the solicitor directly (Glenveagh, Solicitor and Sales Agent);
- 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 and Solicitor);
- 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 Glenveagh developments which 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, IT Provider, Analytics Provider, Search Engine Provider 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, IT Provider, Search Engine Provider and Sales Agents);
- where you register your interest through the website, as part of our efforts to keep our website safe and secure (Glenveagh, IT Provider 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).
Our Legal Bases for Processing your Personal Data
We have selected the following legal bases for the processing of your personal data:
• Your Consent
We process your personal data once we have obtained your freely given and unambiguous consent in order to send you marketing communications/further information on our developments. You have a right to withdraw your consent, as is set out in the section “What are Your Rights?”.
• Our Legitimate Interests
In most cases, it is in our legitimate interest to process your personal data for the following reasons:
1. To advertise and promote our developments;
2. 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 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).
• 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 by our solicitor directly, we 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 an 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.
• To Comply with a Legal Obligation We are Subject to
Where we have certain legal obligations to process personal data, we may do so based on the acts of the regulatory authorities.
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 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. Your rights are set out in the section “What are Your Rights?”.
How Long Do We Keep Personal Data?
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 personal data 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 systems. It is our policy to retain documents in hardcopy and electronic form in accordance with any retention period required by law or until the end of the period in which litigation might arise from our engagement. The data will then be destroyed without further notice or liability.
Where Do We Store your Personal Data?
The transmission of personal data 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 personal data, we will use strict procedures and security features to try to prevent unauthorised access.
Is My Personal Data Transferred Outside the EEA?
The personal data that we collect from you may be transferred to and stored at any member of Glenveagh’s group, our subsidiaries, our ultimate holding company or its subsidiaries who process personal data outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. This transfer is subject to strict contractual obligations to protect your personal data.
What are Your Rights?
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 Privacy Notice.
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 Data Sharing Privacy Notice).
Right of Rectification
You have the right to correct any inaccuracies we may have regarding the data we hold about you.
Right of Erasure
This is also known as the ‘right to be forgotten’ and, in simple terms, it 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 an absolute right of erasure; there are exceptions.
Right to Restrict Processing
You have rights to ‘block’ or suppress further use of your personal data for a certain period. 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.
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 personal data easily between our IT systems and theirs safely and securely, without affecting its usability.
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.
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 Commission.
Right to Withdraw Consent
If you have provided us with your consent, you can withdraw this consent at any time. To withdraw your consent, please use the contact details provided in the “How to Contact the Data Controller” section above. Do note, however, that any processing done before you withdraw your consent will this be lawful.
Changes to this Data Sharing Privacy Notice
This Data Sharing Privacy Notice has been updated on the 15th of June 2020. We reserve the right to change this Privacy 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.