Privacy Policy

Privacy Policy – Clare Connolly Estate Agent

Introduction

This is the Privacy Policy of Clare Connolly Estate Agent of 6 Main Street, Dundrum, Dublin 16.

The purpose of this Privacy Policy is to ensure individuals understand how we process their information.

Clare Connolly Estate Agent endeavours to comply with the General Data Protection Regulation, Data Protection Act 2018 and data protection best practices. This Policy informs individuals how of Clare Connolly Estate Agent processes personal data in accordance with the principles of data protection identified in data protection legislation.

We process personal information provided to us by individuals, whether it be provided through our website (www.clareconnolly.ie), in person, by any form, correspondence, telephone, email or by any other means, or otherwise processed by us in relation to you, in the manner set out in this policy.

By submitting your information to us and or by using the Website you consent to the use of your personal information as set out by this Privacy Policy. If you do not agree with the terms of this Privacy Policy please do not use the Website or volunteer or provide us with any personal information.

Information collected by us

The information about you that we may collect, use and store (process) includes:

• Information necessary in order to facilitate, process, invoice or collect monies related to any agreed business transaction with Clare Connolly Estate Agent (of which such data may include name, address, contact details, billing details, etc.).
• Information you provide to us by filling out any forms on the website or by way of emailing us or by any other form of written communication.
• Records of correspondences whether by email, telephone, through any form on our website or by any other means,
• Information you provide to us in person.
• Details of any business, commercial or trade transactions you carry out with us, whether through email, the website, telephone, or by any other means.
• Information provided by a landlord about a tenant and or a tenant about a landlord that is necessary for the management and or upkeep of a property and or for complying with a letting agreement or property management agreement.
• Details of your visits to our website including traffic data, location data, weblogs and other communication data in accordance with our Cookie Policy that may identify personal information (e.g. cookies) and non-personal information (e.g. information of an anonymised or technical nature).

How we use your personal information

We may use your personal information for the purposes of:

1. Processing any enquiry requested by you;
2. Entering into and or completing any sales commercial or business related requests or transactions requested by you;
3. Complying with any contractual obligations relating to a letting agreement and or property management agreement that you enter into;
4. Setting up, operating and managing any account or line of credit, if applicable;
5. Setting up, operating and managing any marketing and or advertising services subject to your explicit consent (please see Marketing & Advertising below);
6. Complying with our legal duties and responsibilities;
7. Debt collection and the collection of outstanding monies;
8. Providing, monitoring, reviewing and supporting our online presence via our website and social media (please see our Cookie Policy 
9. Monitoring any billing or credit transactions for the purpose of preventing fraud;
10. Provision of security to, and ensuring the health and safety of employees, customers and visitors to our premises.

We normally obtain consent to process personal data by way of notification on our website that requires an explicit acceptance of this Privacy Policy and associated Cookie Policy to use the website. Consent for data processing purposes can also be obtained by way of a physical application form, credit form or other Clare Connolly Estate Agent paperwork that refers to our data protection policy on this website and acceptance of same.

All data processed will be held as confidential, secure, will be used only for the purposes for which it was collected and will be destroyed or deleted once is it no longer necessary (in accordance with our data retention policy).

Clare Connolly Estate Agent does not engage in any automated decision-making processes nor do we use any personal data as a basis for any such automated decisions.

Clare Connolly Estate Agent does not transfer personal data outside the jurisdiction of, or application of, the General Data Protection Regulation. However, Clare Connolly Estate Agent may outsource some commercial activities and or and or engage with some service providers based within the EU that may share data within other EU member states (e.g. back up, storage facilities, etc.) and such suppliers are subject to the One Stop Shop Mechanism as identified by the Irish Data Protection Commission.

We may also outsource some commercial actives to third parties that are based outside the EU but GDPR still applies to any data processed as a result, in accordance with GDPR, the Data Protection Act 2018 and practice directives issued by the Irish Data Protection Commission. For example, we may use Mailchimp for processing marketing emails but Mailchimp has a EU-US Privacy Shield Framework in place to ensure GDPR compliance.

For more information about the One Stop Shop Mechanism, Privacy Shield Framework or mechanisms applicable to data being processed outside of Ireland and or the EU, please visit the Data Protection Commission website at www.dataprotection.ie.

Marketing & Advertising

Clare Connolly Estate Agent provides estate agent services such as facilitating the selling, letting and management of properties.

As part our marketing and advertising practices, we may use promotional emails, text messages and or phone calls to people who have consented to being contacted for marketing and advertising purposes.

In terms of data processing, subject to your explicit consent, we may use your personal information for the purpose of:

1. Marketing and Sales promotions;
2. Providing you with information about promotional offers on our products and services;
3. Carrying out any service user, membership or customer research, survey and analysis;
4. Commercial activities, including brand or event awareness, participation and product or service launches;

At some interactions with Clare Connolly Estate Agent you may be asked to consent to your data being used for marketing purposes. In such cases, consent will require positive action on your part. For example, on an enquiry form you would have to tick a box stating that you consent to your data being processed for marketing purposes in according with this privacy policy in order to receive personalised targeted marketing emails, text messages and or phone calls.

Clare Connolly Estate Agent uses Mailchimp for our email marketing who are GDPR compliant by way of an EU-US Privacy Shield. Please note that if you do not consent to your email being used for marketing purposes then we do not contact you by email for marketing or advertising purposes and the privacy shield stated here is not applicable.  For more information on Privacy Shield please see the Data Protection Commission’s website www.dataprotection.ie  and Mailchimp at https://mailchimp.com/help/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr/

Clare Connolly Estate Agent is committed to privacy by design and privacy by default. As such, you will never have to ‘opt-out’ of our marketing processes; you will only ever have the option of ‘opting in’ if you’d like to be included. We do not engage in ‘pre-ticked’ boxes on consent forms nor do we ever assume you would consent to your data being processed. You are free to withdraw consent for any marketing matters at any time you want.

Social media

Clare Connolly Estate Agent engages in a number of social media services and we strive to uphold privacy rights online. However, sometimes members of the public may post something objectionable and beyond our control to our social media pages/forums. In such cases, we will act to rectify any difficulties as soon as we are notified or become aware of the problem. We do not provide a continuous monitoring of social media sites/forums so there may be a slight delay from the initial post to when become aware of a problem.

Clare Connolly Estate Agent may hold marketing events in which customers, visitors or employees may be present. Sometimes we may wish to take a photograph at such events to promote our brand or event on social media. In such cases, it is our policy for our photographer/social media handler to announce their presence and provide additional instructions and assistance. However, we do not have any control over private individuals or their personal social media accounts, as such we cannot stop or prevent private individuals from posting materials to their own personal social media accounts that others may find objectionable.

For information relating to social media usages, cookies or widgets, please see our Cookie Policy

Information Storage

We will take reasonable steps to ensure that your information is kept secure and protected, including but not limited to electronic data being protected using appropriate software, relevant networks safety and security checks, and, where applicable, any physical data records will be kept in an appropriately secure environment.

We have a general data retention policy that relates to the retention of relevant data for seven years. Personal data that is no longer required will be destroyed and or deleted in secure manner.

We do not record or process personal data that is not required or not necessary for any of our stated purposes.

Disclosure of data

We may outsource certain commercial functions to external third parties, e.g. debt collection, accounting auditors, etc. and in such cases where personal data is required for the purposes of completing those functions then an appropriate data processing agreement, with relevant safeguards, will be in place to ensure our ongoing obligations under the Data Protection Act 2018 are upheld.

We may also have to disclose certain personal data in accordance with any legal obligation imposed on us. Any such disclosure would be in accordance with the law, e.g. disclosed on foot of a court order, Child First Act, etc.

Requesting your data

Any person has the right to find out whether an organisation has any personal data about them, what they use the personal data for and ask for copies of personal information held by that organisation.

If you wish to make a data access request in order to get a copy of any personal data we may process, please write a letter stating that you wish to make a data access request and address it to:

Data Protection

Clare Connolly Estate Agent

6 Main Street

Dundrum

Dublin 16

Or email info@clareconnolly.ie.

In order to process your request, we may request that you send us a copy of your identification (passport, driver’s licence, etc.). The reason we ask for personal identification is to ensure that you are the correct person making the request for your personal data.

Unfortunately, verbal access requests cannot be entertained.

In response to any data access request, you have the right to refer the matter to the Data Protection Commission if you are unhappy with the outcome, however, we ask that you notify us first of any issue so that we may help resolve it as quickly as possible.

Rectifying mistakes

You have the right to rectify any incorrect or inaccurate personal data at no cost to you.

If you believe that we are incorrectly processing any of your personal data, please inform us by writing to the above address or email info@clareconnolly.ie.

Queries or complaints

If you have any queries or complaints regarding our Privacy Policy or any data protection matter, please let us know by writing to the above address or email info@clareconnolly.ie.

Individuals have the right to refer any matter to the Data Protection Commission by contacting them at www.dataprotection.ie or by writing to:

Data Protection Commission

Office of the Data Protection Commission

21 Fitzwilliam Square South

Dublin 2

D02 RD28

Ireland

If you are, for whatever reason, considering contacting the Data Protection Commission about us we would ask that you inform us of your difficulty first so that we can try to resolve it to your satisfaction.

Changes to our Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on our website.

Any changes will become effective upon posting the revised Privacy Policy on our website. If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavours to inform you by email, notice on the Website or any other agreed communications channels.

Privacy Policy last reviewed: March 2019