LAST UPDATE: 22nd March 2022
1 WHO WE ARE
1.1 Hali Operations Limited, the Data Controller, pursuant to Articles 4 (7) and 24 of the GDPR, and CWTC Multi Family ICAV, the Joint Data Controller, pursuant to Article 26 of the GDPR, and our affiliates, respect the privacy rights of prospective tenants, tenants and visitors of its Site ("you") and is committed to handling personal data responsibly and in accordance with applicable law.
Hali is the property manager appointed to manage the property on behalf of the owner and we also operate this Site. We collect and process your personal data in connection with your tenancy and/or your use of the Site.
2 THE DATA WE COLLECT ABOUT YOU
2.1 We may collect personal data about you when you: visit our Site, enquire about a potential tenancy; submit a tenancy application; sign up to a lease with the landlord; participate in any tenant amenities offered at the property; contact or request information from us; engage our services; or as a result of your relationship with the property(together, the "Services").
2.2 You have the option of not providing us with certain data, although this may affect our ability to provide you with the Services or assess your tenancy eligibility.
2.3 We may collect and process certain personal data from you, including the following:
If you are a tenant:
- 2.3.1 Contact information: such as title, first name, middle name, last name, date of birth, postal address, email address and phone or mobile number(s);
- 2.3.2 Tenancy information: such as tenant information, key holder details, reasons for moving, emergency details, household pet details, car ownership, registration details, enquires you make regarding your tenancy, defects you notify to us regarding your property, incident reports or descriptions, requests for replacement keys, fobs or car park cards; smart home device information; legal confirmation information;
- 2.3.3 Identification information: such as national identification, passport or driver's licence, nationality, immigration or visa status, social security number, PPS number, national insurance number; vehicle details; user access credentials;
- 2.3.4 Financial information: salary or income details, bank account details, rental amounts owing, paid or in arrears, tenancy deposits, services charges; payment card information; cardholder information; sensitive authentication information; credit information; insurance information; utility information; call information;
- 2.3.5 Employment information: employment status, employer, work address, job title, employment duration, employer's email address or phone number, previous employers; student education information;
- 2.3.6 Background check information: character or employer reference, prior residential addresses, prior leasing history, financial history, household pet ownership, dependents/children staying at the property; guarantor information; family and relationship information;
- 2.3.7 Marketing information: content you provide through the free text box in any general contact us form, details about how you engage with any direct marketing we send you and, if you unsubscribe from any direct marketing, a record of this so we ensure your preferences are respected;
If you are user of our website:
- 2.3.8 Technical information: operating system, IP address, time zone setting and location, device model, browser brand and version, browser plug-ins, analytics information, other technology you use to access the Site; and
- 2.3.9 Additional information you may provide us with: notification and package delivery preferences or instructions and survey responses.
If you are a prospective employee:
- 2.3.10 Contact information: such as title, first name, middle name, last name, date of birth, postal address, email address and phone or mobile number(s).
- 2.3.11 Employment history and professional qualifications: such as employment status, previous employment duration, previous employers, job titles, education information and any other information provided through the CV.
3 HOW WE OBTAIN YOUR PERSONAL DATA
3.1 If you are a tenant:
Submitting tenancy enquiry or application forms, signing up to a lease, interacting with us in person, email or telephone or through applications relating to the property
3.2 If you are our website user:
Data you give us voluntarily by visiting the Site
If you are a prospective employee:
Submission of application forms or provided to us by HR and recruitment service providers or by someone who referred you to us
4 WHY WE USE YOUR PERSONAL DATA
We use personal data we hold about you in different ways, as described below:
4.1 If you are our website user:
- 4.1.1 If you are a prospective tenant, but at the time of your enquiry we do not have a property available that meets your needs, we may contact you if such a property becomes available within 12 months of your enquiry.
- 4.1.1 If you are a prospective tenant,
but at the time of your enquiry we do not have a property available
that meets your needs, we may contact you if such a property
becomes available within 12 months of your enquiry.
These communications to you are on the basis of our legitimate interest to market potentially suitable properties to you. You can opt out of receiving such communications from us at any time.
4.2 If you are a tenant:
- 4.2.2 To communicate with utility companies, suppliers and other contractors to arrange access to the property for repairs and/or maintenance and in order to facilitate background checks or payments due, for example with credit or reference providers or debt collection companies. We do this on our legitimate interest to maintain the property and seek outstanding rental payments and other charges and in the legitimate interest of third parties who supply services to you (e.g. utility companies).
- 4.2.3 For our legitimate business interests such as to provide you with Services as part of your tenancy such as ongoing works at the property, building access or window cleaning; provide you with access to resources which provide services such as deliveries, bookings, enquiries, social clubs or forums, events, announcements, concierge services and various amenities in relation to your tenancy; communicate with you about any changes to our properties or Services, or new Service offerings; to enhance and improve our overall Service offering.
4.3 If you are a prospective employee:
- 4.3.1 To evaluate your interest in employment and contacting you regarding possible employment with us where you have indicated that you are intereste in this. We may also use the information in other ways for which we provide specific notice at the time of collection.
4.4 For all above options:
- 4.4.1 To provide information, that you request, or which we think may be of interest to you in order to support and enhance our relationship. We will use this data in accordance with any preferences you have selected, either on the basis of consent (where appropriate) or of legitimate interests where you have not objected to receiving such information.
- 4.4.2 To fulfil our legal and regulatory obligations, including establishing, exercising or defending legal claims or providing information as required by a court order. To protect the safety and security of our Services, staff, systems, property or any person, including to investigate, prevent and minimise the effects of fraud and otherwise to protect our vital interests or the vital interests of the tenant or of others.
5 LEGAL BASIS FOR PROCESSING PERSONAL DATA
5.1 In order to collect, process and share personal data for the purposes described in this Privacy Notice, we rely on a number of separate and overlapping legal bases, including where:
- 5.1.2 consistent with obtained consent, for example, where you have opted-in to receive our marketing information, we may use your information to send you news and newsletters, special offers, and promotions, or information we think may interest you;
- 5.1.3 necessary for the legitimate interests of us or of a third party, provided those interests are not overridden by your interests or rights;
- 5.1.4 necessary to comply with our legal obligations, including as a registered property service provider;
- 5.1.5 necessary to protect the vital interests of tenants or of others.
5.2 We may process personal data on more than one lawful ground depending on the specific purpose for which we are using that data. We only use personal data for the purposes for which we collected it, unless we believe that we need to use that personal data for another reason that is compatible with the original purpose or as applicable law permits.
6 HOW WE SHARE YOUR PERSONAL DATA
6.1 We may disclose your personal data to:
- 6.1.1 our subsidiaries, related companies and affiliates, including CWTC Multi Family ICAV, the owner and landlord of applicable properties;
- 6.1.2 our third party services providers, suppliers and partners that assist in providing our Services, including IT systems providers, utility providers, parcel couriers and other services provided to you;
- 6.1.3 credit or reference providers or debt collection companies;
- 6.1.4 our professional advisors, including lawyers, consultants, accountants, auditors and insurers;
- 6.1.5 possible acquirers or investors (and our and their advisors) in the context of facilitating or implementing a business reconfiguration or reorganisation or a transfer or sale of all or part of our assets or business, including, but not limited to a divestiture, acquisition or business reconfiguration. Alternatively, we may seek to acquire other businesses or merge with them;
- 6.1.6 providers of HR and recruitment services (when we are looking for a new employee) and other goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them);
- 6.1.7 intermediaries, brokers, and other individuals and entities that partner with us;
- 6.1.8 competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal, where we are required to do so by applicable law or regulation at their request);
- 6.1.9 any central or local government department and other statutory or public bodies;
- 6.1.10 any other person or entity with your consent.
6.2 We will only provide these third parties with the personal data that is necessary. Where these third parties are processors, they are contractually required to only use the personal data in accordance with our instructions to provide their service to us.
7 TRANSFER OF YOUR INFORMATION
As we operate internationally, your personal data may also be disclosed and transferred to a person or company that is located in a country outside the European Economic Area ("EEA") for any of the purposes set out in this notice. Some of these countries may not have the same levels of data protection or similar rules in relation to processing your personal data as are present. We will typically transfer and disclose your data in compliance with the Standard Contractual Clauses approved by the European Commission. If you would like to get more information about the measures we put in place to protect your information when it is transferred outside of the EEA (including a copy of the Standard Contractual Clauses), please contact us using the details in section 13 below.
8 PROTECTING YOUR PERSONAL DATA
We maintain appropriate technical and organisational measures to protect a tenantÕs personal data, such as up-to-date antivirus protection, internal IT security measures, and disclosing personal data both internally and to our trusted third party service providers only on a 'need-to-know' basis.
9 HOW LONG WE RETAIN YOUR PERSONAL DATA
9.1 We will keep your personal data for as long we have an ongoing legitimate business need to do so (for example, to provide you with your tenancy or a service you have requested or to comply with applicable legal, tax or accounting requirements).
9.2 When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
9.3 Examples of the retention periods of the types of data which we collect, in accordance with our data retention policy, are summarised below. If you would like additional information regarding our retention policies or have any additional queries, please contact us by e-mailing email@example.com:
- Type of Data
- Tenancy information
- Background check
- Retention Period
- 7 years post tenancy or 12 months
if no active tenancy
- 12 months if there is no tenancy
and 7 years post tenancy
If you are a prospective employee:
- Type of Data
- Contact Information
- Retention Period
- 12 months
10 YOUR LEGAL RIGHTS
The joint controller relationship with CWTC Multi Family ICAV
established that Hali acts as a point of contact for data subject
to exercise their rights, as indicated below. In spite of this,
data subject may exercise their rights before any of the data
The list below sets out the rights which you have to address any concerns or queries with us about our processing of your personal data. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law.
10.1 As a data subject, you have the following rights under data protection law:
- 10.1.1 the right to know what personal data we process about you and how we use this personal data;
- 10.1.2 the right to obtain a copy of the personal data we hold about you;
- 10.1.3 the right to have any inaccurate personal data which we hold about you updated or corrected;
- 10.1.4 the right to port your personal information in certain cases;
- 10.1.5 the right to stop us from using your personal data in certain cases, including if you believe that the personal date we hold about you is inaccurate or our use of your information is unlawful;
- 10.1.6 and in certain circumstances you may request that we delete the personal data which we hold about you.
- 10.1.7 where we rely on our legitimate interest to use your personal data, you have a right to object to this use
- 10.1.8 Wewill desist from processing your personal data unless we can demonstrate overriding legitimate grounds for the continued processing of your personal data;
- 10.1.9 where we rely on consent, the right to withdraw your consent at any time (though this does not impact on the lawfulness of what we did up based upon your consent until that point);
- 10.1.10 You can unsubscribe from direct marketing at any time by following the instructions we send in any SMS marketing message or clicking on the unsubscribe link in our marketing emails or by emailing firstname.lastname@example.org
You may exercise any of your rights, or ask questions about our use of your personal information, by e-mailing or writing to us as provided in section 14 (HowTo Contact Us) below.
11 RIGHT TO COMPLAIN TO THE DATA PROTECTION COMMISSION
If you do not think that we have processed your personal data in
accordance with this Notice, please contact us in the first
instance. If you are not satisfied, you can complain to the Data
Protection Commission ('DPC') or exercise any of your other rights
pursuant to data protection law.
Information about how to do this is available on the DPC website at www.dataprotection.ie.
For more information about the cookies we use, please see our cookies policy.
13 CHANGES TO THIS NOTICE
We may update our Privacy Notice from time to time. The latest version of this Privacy Notice is always accessible on our Site. If material changes are made to the Notice, a copy will be made available on request.
14 HOW TO CONTACT US
If we are the controller of your personal data, and you have any questions about this privacy notice or our data protection practices please contact us. You can send an email to email@example.com or write to us at Data Protection Queries, 48 Mount Street Upper, Dublin 2, Dublin, Ireland.