Last Updated: March 2021
Full name of legal entity: Sherborough Enterprises Limited (CRO number: 286010)
Email address: email@example.com
Postal address: Hospitality House, Cumberland Street South, Dublin 2. D02 Y097
1. Personal information we collect and why we collect it
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, marital status, title, date of birth, nationality and gender.
- Contact Data includes address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Property Information includes your contact details, move in and move out date, utility meter serial number and meter readings. References relating to you, or information required to prepare a reference for you.
- Financial Data includes bank account and payment card details.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Your PPSN for registration with the Residential Tenancies Board Ireland.
- Your proof of funds, to confirm your financial ability to perform this monthly transaction.
- Your previous landlord reference and current work reference in order to protect the Landlord’s own financial or property interests.
- CCTV footage in the public areas of our residential properties for security, crime prevention and safety.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2. How We Use Your Personal Information
2.1. Our legal basis for processing
Under applicable data protection legislation, we are only permitted to use your personal information if we have a lawful basis for doing so. We rely on the following lawful basis to use your information:
- Where we need information to perform the contract we have entered into with you.
- Where we need to comply with a legal obligation.
- Where the processing is necessary for us to carry out activities for which it is in Só Living’s legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
- Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns. This will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
- Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively. This will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialise in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.
2.2. Our use of your personal information
Specific information on how your personal information will be used for the particular services you have requested from us is provided below.
- We use your personal information for the purposes arranging viewings, obtaining feedback, and arranging a lease for you.
- We will use your personal information to conduct due diligence in accordance with other legal or regulatory obligations
- If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.
- We will share personal information with our regulators, governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
- Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors, accountants, and solicitors and tradesmen appointed by us to carry our maintenance or repair work on our properties.
- We may share your personal information with any person working within Só Living on a need to know basis to ensure we are able to perform our obligations to you.
- We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by Só Living to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.
We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.
If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.
2.4. How long we keep your personal information
The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.
3. Your rights in relation to your personal information
You have the following rights*, in certain circumstances and subject to certain restrictions, in relation to your personal data:
- the right to access your personal data;
- the right to request the rectification and/or erasure of your personal data;
- the right to restrict the use of your personal data;
- the right to object to the processing of your personal data;
- the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.
*Please note that these rights can be subject to certain restrictions, we are legally obliged to retain records of all viewings and offers made on a property for a minimum of 6 years after the transaction so a request to delete cannot be actioned until that legal timeframe has passed.
To exercise any of the rights set out above, you can contact us at Hospitality House, Cumberland Street South, Dublin 2
Tel: +353 (1 535 8885) or by emailing us at firstname.lastname@example.org
If you are not happy with the way we have used your information or addressed your rights, you have the right to make a complaint to the Data Protection Commission by emailing email@example.com.
4. Other Important Privacy Information
4.1. Security of personal information
The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:
- Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.
- Hard copy documentation is stored in secure offices, locked cabinets and/or off-site long term storage.
We ensure access to personal information is restricted to Só Living employees and workers or other persons working within the Só Living Group on a need to know basis. Training is provided to any of those Só Living employees and workers who need access to personal information.
4.2. Overseas transfers of your personal information
We may transfer, store, or process your personal information in locations outside the Republic of Ireland and the European Economic Area (EEA). Where the countries to which your personal information is transferred do not offer an equivalent level of protection for personal information to the laws of Ireland, we will ensure that appropriate safeguards are put in place.
We’ll use one of these safeguards:
- Transfer it to a non-EEA country that has received an adequacy decision from the European Commission. This means that country has privacy laws that give the same protection as within the EEA.
- Put in place the EU Commission’s standard contractual clauses with the recipient. This means that they must protect it to the same standards as organisations within the EEA.
- Transfer it to organisations that have implemented binding corporate rules, which have been approved by an EU supervisory authority.
5. The Use of Website Cookies by Só Living
5.1. What is a cookie?
A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user’s computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.
5.2. What cookies do Só Living use?
When browsing our website, cookies that are strictly necessary for the performance and function of the website are automatically utilised. We will only utilise non-essential cookies if you have provided us with consent to do so by selecting ‘Allow all cookies’ in the cookies banner.
5.3. How do I restrict or delete cookies?
Certain cookies we use are essential for parts of the website to operate and have already been set. You may delete and block all cookies from this website, but please be aware that restricting or deleting cookies may impact on the functionality of the website.
Your web browser may allow you to restrict or delete cookies set by this website. The Help function within your browser should tell you how. Alternatively, you can visit www.allaboutcookies.org, which provides general information about cookies and how you can manage cookies on your computer.
To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.