This Privacy Policy applies to all personal information you provide or obtained from you, when you browse and otherwise generally use this website (hali.ie) including all related information, tools, technology, mobile applications, content, and services available from that website (the “Site”). 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).
1 WHO WE ARE
1.1 Hali Operations Limited, and our affiliates, including CWTC Multi Family ICAV (“Hali”, “we”, “us” or “our”) 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.
1.2 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:
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;
2.3.8 Technical information: operating system, IP address, time zone setting and location, device model, browser brand and version,
Privacy policy
LAST UPDATE: 12TH OCTOBER 2021
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.
3 HOW WE OBTAIN YOUR PERSONAL DATA
3.1 Data you give us voluntarily by visiting the Site, 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.
4 WHY WE USE YOUR PERSONAL DATA
4.1 We use personal data we hold about you in different ways, as described below:
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.
4.1.2 To administer and manage our relationship with you, including the performance of a contract with you (such as your lease or tenancy agreement) and enforcing our Terms of Use or other legal rights.
4.1.3 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).
4.1.4 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.
4.1.5 To fulfil our legal and regulatory obligations, including establishing, exercising or defending legal claims or providing information as required by a court order.
4.1.6 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.
4.1.7 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.
4.1.8 To evaluate your interest in employment and contacting you regarding possible employment with us where you have indicated that you are interested in this.
4.1.9 We may also use the information in other ways for which we provide specific notice at the time of collection.
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:
5.1.1 necessary to perform a contract, for example under your tenancy agreement or lease, or under our Terms of Use;
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 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 tenant’s personal data, such as up-todate
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 protected]:
Type of Data Retention Period
Tenancy information 7 years post tenancy or 12 months
Contact information if no active tenancy
Financial information
Background check 12 months if there is no tenancy
information and 7 years post tenancy
Employer information
10 YOUR LEGAL RIGHTS
10.1 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.
10.2 As a data subject, you have the following rights under
data protection law:
10.2.1 the right to know what personal data we process
about you and how we use this personal data;
10.2.2 the right to obtain a copy of the personal data
we hold about you;
10.2.3 the right to have any inaccurate personal data
which we hold about you updated or corrected;
10.2.4 where we rely on our legitimate interest to use
your personal data, you have a right to object
to this use. We will desist from processing your
personal data unless we can demonstrate an
overriding legitimate grounds for the continued
processing of your personal data;
10.2.5 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);
10.2.6 the right to port your personal information in
certain cases;
10.2.7 the right to stop us from using your personal
data in certain cases, including if you believe
that the personal data we hold about you is
inaccurate or our use of your information is
unlawful; and
10.2.8 in certain circumstances you may request that
we delete the personal data which we hold
about you.
10.3 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 [email protected].
10.4 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
(How To 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.
12 COOKIES
We use cookies and related technology on the Site.
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 protected] or write to us at Data Protection Queries, 48
Mount Street Upper, Dublin 2, Dublin, Ireland.