Glenveagh Homes Limited, (“Glenveagh”), operates Glenveagh.ie. Knight Frank and Dillon Marshall New Homes are the appointed Sales Agents (“the Sales Agents”) for Glenveagh in respect of the sale of the units within Semple Woods (“the Development”). Throughout this Joint Controller Privacy Notice, when we refer to “us” or “we”, we mean Glenveagh and the Sales Agents together.
There are a number of different ways in which you can register your interest in the Development with us which include:
- Using the “register your interest” platform on Glenveagh.ie,
- Using the “register your interest” platform on Semple Woods,
- Using the “register your interest” platform, the contact platform and/or the enquiries platform on http://www.knightfrank.ie/ or https://dmpc.ie/new-homes/,
- By telephoning us,
- By attending in person at the premises of the Sales Agents, and
- By sending written correspondence (including by email) to us.
In essence, 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 the Development in any of the ways listed above. 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.
Who is the Data Controller?
For the purpose of the General Data Protection Regulation (“GDPR”), Glenveagh and the Sales Agents are Joint Data Controllers. Glenveagh’s registered office is located at Block B, Maynooth Business Campus, Maynooth, County Kildare and its company number is 368093. Knight Frank registered office is located at 20-21 Upper Pembroke Street, Dublin 2 and its company number is 499911. Dillon Marshall registered office is located at 212 Harolds Cross Road, Harolds Cross, Dublin 6W and its company number is 512601.
How to Contact the Data Controller
If you have any questions or queries about how your data is processed, please contact Glenveagh at firstname.lastname@example.org or Knight Frank at email@example.com or Dillon Marshall at firstname.lastname@example.org or at the above registered office address.
What Information is Collected About You?
We collect personal data from you when you register your interest in the Development in any of the ways listed in the Introduction paragraph above. We obtain from you your name, email address, telephone number, buyer type, financial status (e.g. mortgage approved) and/or age group.
When you use 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.
The Purpose for Obtaining and Processing Your Personal Data
We obtain, use and process your personal data when you register your interest in the Development for the following purposes:
- to provide you with marketing communications/further information on the Development;
- to answer any queries which you may have about the Development;
- to arrange for viewings of units within the Development or show houses;
- to liaise with you throughout the bidding/sale process of a unit or units within the Development if you are a party involved in that bidding/sale process;
- to receive from you and process a booking deposit on the purchase of a unit or units within the Development;
- 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;
- for the Appointed Solicitor, as a Data Processor, to draft Contracts for Sale on receipt of the Sales Advice Notice from the Sales Agents,
- to facilitate the completion of the sale of a unit or units within the development purchased by you, for example arranging for you to collect the keys,
- to make suggestions about other developments that may interest you,
- 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;
- 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;
- where you register your interest through the website, as part of our efforts to keep our website safe and secure;
- 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;
The Legal Basis for Obtaining Your Data
We process your personal data once we have obtained your consent to do so in order to send you marketing communications/further information on the Development. By registering your interest in the Development through any of the ways listed in the Introduction paragraph, this affirmative action will constitute your consent to us sending you our marketing communications/further information on the Development.
Please note that if you register your interest through our website, we will also ask you to tick the appropriate box to confirm your consent to received such marketing communications/further information on the Development and you will be provided with a link to view or download a copy of this Notice. If you register your interest at the Sales Agents’ premises, by telephone or by written correspondence, then you will be provided with a copy of this Notice by hand, by email or by post. 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.
B. Legitimate Interests
In most cases, it is in our legitimate interest to process your personal data for the following reasons:
- To advertise and promote the Development;
- To enable us to communicate with you about the 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).
C. 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, we will need to process your personal data in order for the Contracts for Sale to be drafted. An example of this would be 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 the 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 keep your Personal Data for no longer than is necessary pursuant to the GDPR and also in accordance with any statutory or professional retention periods. Please see our Retention Schedule for further information.
Disclosure of your personal information
When you register your interest in the Development by any of the ways listed in the Introduction paragraph, the recipients of your personal data include, our Appointed Solicitor and IT providers. We may also disclose your personal data to any member of our 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.
Disclosure of your personal information
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
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 Glenveagh 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.
Our website may, from time to time, contain links to and from other websites and web platforms. In addition, third parties’ websites may also provide links to our website. If you follow a link to any of those websites or web platforms, please note that those websites and web platforms have their own privacy policies and that we do not accept responsibility or liability for those policies. Please check those policies before you submit any person data to those websites.
We do not accept, and we disclaim, any responsibility for the privacy statements and information protections practices of any third-party website (whether or not such website is linked on or to our website). These links are provided to you for convenience purposes only, and you access them at your own risk. It is your responsibility to check the third-party website’s privacy statements before you submit any personal data to their websites.
Changes to our Joint Controller Privacy Notice
This Joint Controller Privacy Notice has been updated on the 12 June 2018. We reserve the right to change this Notice at any time at our sole discretion. If we make changes, we will post these changes here so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our website after we post any such changes, you accept and agree to this Joint Controller Privacy Notice as modified.
Questions, comments and requests to exercise any of your rights set out in this Joint Controller Privacy Notice and the information we hold are welcome and should be addressed to email@example.com or our registered address of Block B, Maynooth Business Campus, Maynooth, County Kildare