We value your privacy Website Privacy Notice Glenveagh Properties Plc, (“Glenveagh”, “us” or “we”), operates Glenveagh.ie, and has created this Privacy Notice to demonstrate our firm commitment to privacy. The purpose of our website is to advertise and provide you with information on our current developments. We also use our website 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, we may therefore collect some of your personal data. 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 here If you are a shareholder, please see our Shareholders 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 personal data from you when you access our website and use the platforms on the website. 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. 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 Cookies Statement. 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 provide you with a way or platform through which you can register your interest in a development. 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. Legal Basis Your consent – which you can withdraw at any time. Purposes for Processing To administer our website and for internal operations, including troubleshooting, data analysis, testing, 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. Legal Basis To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights. 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. 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. 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. 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; Data retention periods We will keep your personal data for as long as it is necessary to enable you to use our services, to provide our services to you, unless a longer retention period is required. This is to comply with applicable laws, 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 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); 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. Right to Complain and what this means. ou 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 Commissioner Phone: +353 (0)761 104 800. Canal House E-Mail: info@dataprotection.ie Station Road Website: www.dataprotection.ie Portarlington County Laois R32 AP23 COVID-19 We may collect and process your personal data in response to the recent outbreak of coronavirus (COVID-19), in order to ensure your safety and wellbeing together with the safety of our employees. Such information will be limited to what is proportionate and necessary, taking into account local laws and the latest guidance issued by Government with public health requirements to manage and contain the virus. Before entering a Glenveagh premises, we may collect the following information about you: name, phone number, email address, and whether you have had COVID-19 like symptoms, been in contact with a person who is a confirmed or suspected case of COVID-19, or been asked or advised to self-quarantine by health officials. Our processors (Agents) may collect this data on our behalf but that they act in accordance with the data protection legislation and act under a contract with us. The information we collect about you will only be used for contact tracing purposes. We will not share your information with anyone else except the public health authorities, who request the information for contact tracing purposes if necessary. We rely on our legitimate interests as legal bases to collect and process your personal data. We have carried out balancing tests on the processing activities, to ensure your rights are protected and data protection principles are followed. Where health related personal data are collected and processed with regards to COVID-19 like symptoms, we rely on processing in the interest of public health as the legal basis so that we can protect against serious cross-border threats to health. We will retain your information for one month after your visit to our premises, unless a longer period is required by law. We will securely delete and destroy your personal data once the retention period is reached. Details of this policy Data protection compliance is reviewed and updated by the Group Audit Committee and may be changed from time to time to comply with amended regulation, legislation or Applicable Laws. This statement is dated 20 August 2019. 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