Data privacy is taken very seriously at Property Properly. It is important that you know exactly what we do with the personal information you and others provide to us, why we gather it and what it means to you. This document outlines our approach to Data Privacy to fulfil our obligations under the General Data Protection Regulation (2018). We also welcome it as an opportunity to reassure you of the importance we place on keeping your personal data secure, and of the strict guidelines we apply to its use. We want you to be clear on:
- Who we are
- The information we collect about you
- When and how we collect information about you
- How we use your information.
- Who we share your information with.
- How long we hold your information.
- The legal basis for using your information.
- How to exercise your information rights (including the right to object).
- How to contact us and/or our Data Protection Officer.
- Changes to this notice.
- Who we are:
Throughout this document, “we”, “us”, “our” and “ours” refer to Tony Brown T/A Property Properly.
Property Properly means Tony Brown.
Registered Office: 36 Main Street, Portlaoise, Co. Laois.
Licence Number: 001464.
- The information we collect about you:
There are numerous reasons for gathering information about you. For instance, we need to know how to get in touch with you, we need to be certain of your identity, and we need to understand your personal circumstances to provide the best possible customer experience. The information we collect falls into various categories.
- Identity & contact information:
Name, date of birth, copies of ID, contact details, PPS number (or foreign equivalent), security details to protect identity, nationality, home status and address, email address, work and personal phone numbers, marital status, family details, tax residency and tax related information, marital status and family status.
- Financial details/circumstances:
Bank account details, income details, personal guarantees provided, application processing and administration records, your employment status and employment details of your partner, occupation and partners occupation, contact details for employers, etc.
- Information you provide us about others or others provide us about you:
If you give us information about someone else (for example, information about a spouse or financial associate provided during the course of a joint application with that person), or someone gives us information about you, we may add it to any personal information we already hold and we will use it in the ways described in this Data Privacy Notice. Before you disclose information to us about another person, you should be sure that you have their agreement to do so. You should also show them this Data Privacy Notice. You need to ensure they confirm that they know you are sharing their personal information with us for the purposes described in this Data Privacy Notice.
- Sensitive categories of data:
We may hold information about you which includes sensitive personal data, such as health or criminal conviction information. We will only hold this data when we need to for the purposes of the product or services we provide to you or where we have a legal obligation to do so. Examples of when we use this type of data include:
- Medical information, for example, where you apply for life insurance, income protection, mortgage protection or investment.
- Information about you provided by others:
If you give us information about someone else, or someone gives us information about you, (for example, where another person provides your information to us during the course of a joint application), we may add it to any personal information we already hold and use it in the ways described in this Data Privacy Notice.
- Information which you have consented to us using:
Your agreement to allow us contact you through certain channels to offer you relevant products and services.
- Information from online activities.
- We collect information about your internet browser settings or otherwise Internet Protocol (IP) and other relevant information to help us identify your geographic location when providing you with our services.
- Other personal information
CCTV images at our main office (but only for security reasons and to help prevent fraud or crime). • Information in relation to data access, correction, restriction, deletion and complaints.
- Sometimes we may collect and use your information even though you are not a customer of ours:
For example, you may be an investor, potential tenant, a representative of one of our customer or be in the process of making an application/offer or one of our properties. If so, we will apply the principles outlined in this Data Privacy Notice when dealing with your information.
- When and how we collect information about you:
As you use our services, apply for products, make enquiries and engage with us, information is gathered about you. We may also collect information about you from other people and other parties, for example, when you are named in additional third party documentation, sources where you have chosen to make your information publicly available, such as social media sites.
When we collect information about you:
- When you apply/enquire about various products and services that we operate.
- When you use our website
- When you visit out main office
- When you or others give us information verbally or in writing. This information may be on application forms, in records of your transactions with us or if you make a complaint
- When you use our products or services, including making transactions on your account, how much the payments are for and when the payments are made.
- From your online activities with third parties where you have given us your consent (for example, by consenting to our use of certain cookies or other location tracking technologies).
- From public agencies such as property registration authorities, the Companies Registration Office or your local district councils.
- How we use your information
Whether we’re using it to confirm your identity, to help in the processing of an application for a product or service or to improve your experiences with us, your information is always handled with care and the principles outlined in this Data Privacy Notice are always applied.
We use your information:
- Establish your eligibility for our products and services.
- Manage and administer your accounts, for example if you are a current customer.
- Process payments that are paid to you or by you.
- Process your applications for rental and auctioneering services.
- Contact you by post, phone, text message, email, fax, or other means, but not in a way contrary to your instructions to us or contrary to law.
- Recover debts you may owe us.
- Manage and respond to a complaint or appeal.
To manage our business we may use your information to:
Provide service information, to improve our service quality and for training purposes:
We may use information from your interactions with us to help improve our customer service and provide a better service to all our customers
Conduct marketing activities:
For example, direct marketing (provided that you have not objected to us using your details in this way), and research, including customer surveys, analytics and related activities.
To run our business on a day to day basis including to:
- Carry out strategic planning and business portfolio management.
- Compile and process your information for statistical or research purposes (including, in some instances, making your data anonymous) in order to help us understand trends in our customer behaviour and to understand our risks better, including for providing management information, operational management.
- Protect our business, reputation, resources and equipment, manage network and information security (for example, developing, testing and auditing our websites and other systems, dealing with accidental events or unlawful or malicious actions that compromise the availability, authenticity, integrity and confidentiality of stored or transmitted personal data, and the security of the related services) and prevent and detect fraud, dishonesty and other crimes (for example, to prevent someone trying to steal your identity), including using CCTV at our premises.
- Manage and administer our legal and compliance affairs, including complying with our obligations to regulatory guidance and voluntary codes of practice to which we have committed.
We need to use your information to comply with legal and regulatory obligations including:
- Complying with your information rights.
- Providing you with statutory and regulatory information and statements.
- Establishing your identity, residence and tax status in order to comply with law and regulation concerning taxation and the prevention of money laundering, fraud and terrorist financing.
- Preparing returns to regulators and relevant authorities including preparing income tax, capital gains tax, capital acquisition tax and other revenue returns.
- Complying with binding requests from regulatory bodies, including the PSRA (Property Service regulatory Authority).
- Complying with binding production orders or search warrants, and orders relating to requests for mutual legal assistance in criminal matters received from foreign law enforcement agencies/prosecutors.
- For other reasons where a statutory reason exists we do so, including use of your Personal Public Service (PPS) number (or foreign equivalent).
- Complying with court orders arising in civil or criminal proceedings.
- Performing a task carried out in the public interest.
Where you have given us permission (which you can withdraw at any time) we may:
- Send electronic messages to you about product and service offers from our Group and/or our selected and trusted partners.
- Share your data with third parties so that they may send you electronic messaging about their products and offers.
- Use special categories of data, or sensitive data.
- Use your location data to send you information regarding special offers from us or our partners close to your location.
- Use information you have made public and combine with this with the activities outlined above.
When we ask for your consent, we will provide you with more information on how we will use your data in reliance on that consent, including in relation to third parties we would like your consent to share your data with.
- Who we share your information with:
We only share your information with a select number of individuals and companies, and only as necessary. Sharing can occur in the following circumstances and/or with the following persons:
- Companies that provide support services for the purposes of protecting our legitimate interests.
- Your personal information remains protected when our service providers use it. We only permit service providers to use your information in accordance with our instructions, and we ensure that they have appropriate measures in place to protect your information.
Our service providers include our contractors (plumbers, electrical etc), debt collection agency, administrative services, software development contractors, document storage and destruction companies, IT and telecommunication service providers, electrical service providers, accountants, receivers, legal advisors, trade associations and professional bodies, insurers.
- Statutory and regulatory bodies (including central and local government) and law enforcement authorities.
These include the courts and those appointed by the courts, government departments, statutory and regulatory bodies in all jurisdictions where Property Properly operates including: the Data Protection Commission, Financial Services Ombudsman, An Garda Síochána/police authorities/enforcement agencies, Revenue Commissioners, Criminal Assets Bureau, US, EU and other designated authorities in connection with combating financial and other serious crime, police forces and security organisations, ombudsmen and regulatory authorities, as well as fraud prevention agencies.
- Third parties in connection with a sale or purchase of assets by a member of our Group.
Those who are interested in or participating in buying or selling assets.
- How long we hold your information:
The length of time we hold your data depends on a number of factors, such as regulatory rules and the type of financial product we have provided to you. Those factors include:
- The regulatory rules contained in laws and regulations or set by authorities like the Central Bank of Ireland, for example, in the Consumer Protection Code.
- The type of financial product we have provided to you. For example, we may keep data relating to a mortgage product for a longer period compared to data regarding a single payment transaction.
- Whether you and us are in a legal or some other type of dispute with another person or each other.
- The type of data we hold about you.
- Whether you or a regulatory authority asks us to keep it for a valid reason.
- Whether we use your data for long-term statistical modelling, provided that such modelling does not affect any decision we make about you.
As a general rule, we keep your information for a specified period after the date on which a transaction has completed or you cease to be a customer. In most cases this period is seven (7) years.
- Implications of not providing information:
Sharing information with us is in both your interest and ours. We need your information in order to:
- Provide our products and services to you and fulfil our contract with you.
- Manage our business for our legitimate interests.
- Comply with our legal obligations.
Of course, you can choose not to share information, but doing so may limit the services we are able to provide to you.
- We may not be able to provide you with certain products and services that you request. We may not be able to continue to provide you with or renew existing products and services.
- How to exercise your information rights (including the right to object):
Providing and holding personal information comes with significant rights on your part and significant obligations on ours. You have several rights in relation to how we use your information. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise:
- Find out if we use your information, to access your information and to receive copies of the information we have about you.
- Request that inaccurate information is corrected and incomplete information updated.
- Object to particular uses of your personal data where the legal basis for our use of your data is our legitimate business interests (for example, profiling we carry out for our legitimate business interests) or the performance of a task in the public interest. However, doing so may have an impact on the services and products we can / are willing to provide.
- Object to use of your personal data for direct marketing purposes. If you object to this use, we will stop using your data for direct marketing purposes.
- Have your data deleted or its use restricted – you have a right to this under certain circumstances. For example, where you withdraw consent you gave us previously and there is no other legal basis for us to retain it, or where you object to our use of your personal information for particular legitimate business interests.
- Obtain a transferable copy of certain data to which can be transferred to another provider, known as “the right to data portability”.
- This right applies where personal information is being processed based on consent or for performance of a contract and the processing is carried out by automated means. You are not able to obtain through the data portability right all of the personal information that you can obtain through the right of access. The right also permits the transfer of data directly to another provider where technically feasible. Therefore, depending on the technology involved, we may not be able to receive personal data transferred to us and we will not be responsible for the accuracy of same.
- Withdraw consent at any time, where any processing is based on consent. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.
You have the right to complain to the Data Protection Commission or another supervisory authority. You can contact the Office of the Data Protection Commissioner at:
Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231 Fax: +353 57 868 4757
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois
- How to contact us and/or our Data Protection Officer:
If you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact our Data Protection Officer at:
Postal Address: Property Properly, 36 Main Street, Portlaoise, Co. Laois.
- Changes to this notice:
We will update this Data Privacy Notice from time to time. Any changes will be communicated to you and made available on this www.propertyproperly.com and, where appropriate, notified to you by SMS, e-mail or via phone call.
We do not collect personal information about you when you visit the web site unless you choose to provide it to us to take advantage of a specific service, for example completing an online form. Any information which you provide in this way is not made available to any third parties and is used by Property Properly only in line with the purpose for which you provided it.
If you choose to send us personal information, for example via the Contact Us email form, we will use that information to respond to your enquiry and will only pass your details to another agency if it is required by law or that agency is relevant to your enquiry. We do not collect personal information for commercial purposes.
Material on this site is protected by copyright. The copyright owner is Property Properly. You may not make alterations or additions to the material on this site. Appropriate acknowledgement of the copyright owner is required if material is re-published in any format.
All information on these pages is provided by Property Properly and is believed to be correct as at the time of issue. Property Properly accept no liability for any inaccuracies or any loss or damage arising from the use or reliance on information obtained from the website.
The Property Properly website links you to many other websites. We are not responsible for the content or availability of these sites.