ROBERT LOWRY PROPERTIES GDPR STATEMENT
The purpose of this Data Privacy Statement is to explain how we at Robert Lowry Properties, (hereinafter referred to as “RLP”, “we” or “us”) collect and use personal information in connection with our business. RLP is the data controller for all personal data collected from the www.robertlowryproperties.ie website. RLP respect your right to privacy and comply with our obligations in accordance with GDPR Regulation 2016/679.
By visiting, and continuing to use our website, you are accepting the terms of this Data Privacy Statement. Any external links to other websites are clearly identifiable as such, and we are not responsible for the content or the privacy statements of these other websites.
2. Information Collected by RLP
We may gather statistical and other analytical information collected on an aggregate basis of all visitors to our website. This Non-Personal Data comprises information that cannot be used to identify or contact you, such as demographic information regarding, for example, user IP addresses (where they have been clipped or anonymised), browser types and other anonymous statistical data involving the use of our website.
This is data that identifies you or can be used to identify or contact you and may include information such as your name, address, email address, birth date, marital status, occupation and salary range. While information such as name and email address is required by RLP (we need it to provide you with our services), other personal data is only collected from you if you voluntarily submit it to us.
3. How we collect your personal data
Information You Supply to Us
You provide most of such information when you search, buy, post, participate in a contest or questionnaire or communicate with customer services. For example, you provide information when you search for a property through RLP or one of our third-party partners, communicate with us by phone, e-mail or otherwise, complete a questionnaire or a contest entry form, employ other personal notification services such as RLP Property Alerts. As a result of those actions, you might supply us with such information as your name, address and phone number etc.
Information Automatically Collected by Us
Examples of the information we collect and analyse include the Internet protocol (IP) address used to connect your computer to the Internet, login, e-mail address, computer and connection information such as browser type and version, your operating system and platform, purchase history, which we sometimes aggregate with similar information from other customers to create features the full Uniform Resource Locators (URL), through and from our website (including date and time), cookie number and products/services you viewed or searched for.
4. Purposes for which we process your Information
We use Non-Personal Data gathered from visitors to our website in an aggregate form to get a better understanding of where our visitors come from and to help us better design and organise our website.
We will process Personal Data that you provide to us for the following purposes:
contact you in relation to property sales and rentals;
provide you with information regarding property sales and rentals;
respond to any queries which you submit to us;
where you have consented to the sharing of your information with third parties, we will do so in accordance with Section 6 below;
Seek your views on our site and our services;
Provide you with information on ancillary services offered by us or our business partners.
Send you newsletters or other forms of communication in relation to site services and products;
Send you messages or data to your mobile phone where you have provided us with mobile phone details and requested such information.
This website uses “cookie” technology. A cookie is a small text file stored by the browser on your computer, at the request of our server. This website uses session and persistent cookies. Session cookies are deleted when you close your web browser.
You are always free to decline our cookies, if your browser permits, or to ask your browser to indicate when a cookie is being sent. You can also delete cookie files from your computer at your discretion.
Note: if you decline our cookies or ask for notification each time a cookie is being sent, this may affect your ease of use and the functionality of this website.
4. Data Retention
The length of time we will retain your personal data will depend on the purpose for which we are processing it. The following criteria will be applied:
We will retain personal data for the minimum period required for the purpose(s) of processing.
Personal data will be retained for a period of time subject to our data retention policy and/ or legal requirements
When personal data is no longer required to be retained, it will be anonymized, to remove all personal identifiable information, or deleted in a secure manner in accordance with our technical and organisational procedures.
5. Disclosure of Information to Third Parties
We may provide Non-Personal Data to third parties, where such information is combined with similar information of other users of our website. For example, we might inform third parties regarding the number of unique users who visit our website, the demographic breakdown of our community users of our website, or the activities that visitors to our website engage in while on our website. The third parties to whom we may provide this information may include potential or actual advertisers, providers of advertising services (including website tracking services), commercial partners, sponsors, licensees, researchers and other similar parties.
We will not disclose your Personal Data to third parties unless you have consented to this disclosure or unless the third party is required to fulfil a service you have requested (in such circumstances, the third party is bound by similar data protection requirements). Any third party we disclose your personal information to will use it for the purposes of delivering the service in question unless you have agreed otherwise.
We will disclose your Personal Data if we believe in good faith that we are required to disclose it in order to comply with any applicable law, a summons, a search warrant, a court or regulatory order, or other statutory requirement.
6. Sale of Business
We reserve the right to transfer information (including your Personal Data) to a third party in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of the Website Privacy Statement and provided that the third party only uses your Personal Data for the purposes that you provided it to us. You will be notified in the event of any such transfer and you will be afforded an opportunity to opt-out.
Your Personal Data is held on secure servers hosted by our Internet Service Provider. The nature of the Internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the Internet. No data transmission over the Internet can be guaranteed to be 100% secure. However, we will take all reasonable steps (including appropriate technical and organisational measures) to protect your Personal Data.
8. Transferring information to countries outside of the European Economic Area
We may transfer your Information to a country outside the European Economic Area ("EEA"), on the basis that the country to which personal data is transferred ensures an adequate level of protection for your rights and freedoms. Where personal data is transferred outside the EEA, RLP will ensure that the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately. If this country does not offer the same level of data protection as the European and local data protection legislation, RLP will take adequate measures to ensure that the collected personal data is processed in accordance with the applicable legislation relating to data protection.
9. Updating, Verifying and Deleting Personal Data
Your Personal Data Rights
Right to access personal information we hold about you.
Right to rectification of personal information that you consider to be inaccurate.
Right to update personal information that you consider to be incomplete.
Right to request that we delete personal information we hold about you.
Right to request us to restrict the processing of your personal information
Right to data portability.
Right to object to the processing of your personal information.
Right to object to direct marketing.
Right to withdraw your consent, where processing is based upon consent.
Right to lodge a complaint with the Office of the Data Protection Commissioner.
If you wish to exercise any of these rights, or if you have any queries about how we use your personal information, please contact us at the details set out below.
Updating your personal Information
You can add or update certain information on the registration page. When you update information, we usually keep a copy of the previous version for our records. You may inform us of any changes in your Personal Data, and in accordance with our obligations under GDPR 2016/679, we will update or delete your Personal Data accordingly. To find out what Personal Data we hold on you or to have your Personal Data updated, amended or removed from our database, please email firstname.lastname@example.org.
Please note that to help protect your privacy, we take steps to verify your identity before granting access to personal data.
If you do not want to receive e-mail or other correspondence from us, please send an email to email@example.com.
This notice is governed by the laws of Ireland. If you have any concerns about data privacy at RLP, please send a thorough description to a firstname.lastname@example.org and we will endeavour to resolve it to the best of our ability.
If you are not satisfied with the outcome of the response you received from RLP in relation to a Personal Data request, you have the right to make a complaint to the Data Protection Commission who may investigate the matter on your behalf.
Data Protection Commission’s contact details:
Phone: 1890 252 231
Data Protection Commission,
Canal House, Station Road,
Portarlington, Co. Laois.
11. Policy Updates
Our business changes constantly and our Privacy Notice may change from time to time to reflect such changes. We may e-mail you periodic reminders of our notices and conditions, unless you have instructed us not to, but we recommend that you check our website frequently for updates or changes. Unless stated otherwise, our current Privacy Notice applies to all personal information that we have about you, including your account. This privacy statement was last updated on the 1st November 2018.
12. Contact Details
For all correspondence in relation to data privacy please contact:
Robert Lowry Properties
T: 01-8260847 / 086-0236685
PSRA Licence Number: 001682
ROBERT LOWRY PROPERTIES ANTI-MONEY LAUNDERING (AML) POLICY AND PROCEDURES
We Robert Lowry Properties have the following Anti-Money Laundering procedures in place.
Customer Due Diligence (CDD)
• As a provider of property services, Customer Due Diligence is compulsory. The following documents are required for each transaction, where the client is a:
o Individual - Photo ID (Passport, Full Drivers Licence, National Identity Card, Social Welfare Card with photo, National Age card….) - Non – Photo Verification (Revenue Commissioners Letter with PPSN, Dept of Social Protection letter with PPSN, Utility Bill, Medical Card….)
o Corporate Clients – This also covers Receivers - Memorandum and Articles of Association - List of Directors names - Verify identity of one director and one signatory (as for individual) - Beneficial Owners identity can be verified via clients’ solicitor
o Trusts - Copy of Trust Deed - Full name of Trust - Nature and purpose of Trust - Country of establishment - Names of all Trustees and name and address of any protector/settler - Verify the identity of one Trustee and one signatory as for individual.
o Partnerships - Obtain a copy of Partnership agreement - Verify the identity of one Partner and one signatory as for individual
• Where a client refuses or cannot comply with the requirements of Customer Due Diligence, we will cease the provision of the property services.
• Records are maintained on file, regarding CDD of all clients for each transaction for 5 years.
• Suspicions relating to ownership of property to be confirmed with the Property Registration Authority (www.prai.ie).
• As a good practice measure, CDD for the purchaser/Lessee may also be undertaken.
Suspicious Transaction Reports (STRs):
• The threshold for the amount of cash which can be accepted, without making a Suspicious Transaction Report (STR), is €3,000.
• Any cash received, unless where Robert Lowry Properties is absolutely satisfied as to its bona fides, or where Robert Lowry Properties has cause for concern relating to the client or purchaser, must be considered as suspicious and a Suspicious Transaction Report (STR) completed and forwarded to the Gardaí and Revenue.
• AML training to be undertaken annually as part of the PSRA CPD programme.