CBPM Real Estate - Privacy Notice

Contents

1. Introduction
2. Who we are
3. Companies and websites within scope
4. Collection of personal data
5. Lawful basis for the processing of personal data
6. Storage of personal data
7. Security measures
8. Your rights as a data subject
9. Contact us
10. Complaints

  1. Introduction

We appreciate the trust you place in us when sharing your personal data. The security of that data is very important to us. In this document, we will explain how we collect, use and protect your personal data.

We will also explain what rights you have with regards to your personal data and how you can exercise those rights.

  1. Who we are

CBPM Real Estate is a wholly owned Irish organisation based in Portlaoise, Co Laois.

Caroline Bergin as the data controller determines what data is collected by CBPM Real Estate, how this data is going to be used and how this data is protected.

Our registered office address is:

CBPM Real Estate, 13/14 Kilminchy Court, Portlaoise, Co laois.

If you have questions about how we process personal data, or would like to exercise your data subject rights, please email us at caroline@cbpm.ie.

  1. Companies and websites within scope

CBPM Real Estate

www.cbpm.ie 

  1. Collection of personal data

We collect personal data from you for one or more of the following purposes:

  • 1. To provide you with information that you have requested or which we think may be relevant to a subject in which you have demonstrated an interest;
  • 2. To initiate and complete commercial transactions with you, or the entity that you represent, relating to the rent or sale of property and for the payment of outstanding accounts relating to property maintenance expenses.
  • 3. To fulfil a contract or tenancy agreement that we have entered into with you or with the entity that you represent. 
  • 4. To ensure the security and safe operation of our websites and underlying business infrastructure, and
  • 5. To manage any communication between you and us.
 

The table in Section 5 below provides more detail about the data that we collect for each of these purposes, the lawful basis for doing so, and the period for which we will retain each type of data.

Technical information

In addition, and in order to ensure that each visitor to any of our websites can use and navigate the site effectively, we collect the following:

  • Technical information, including the Internet Protocol (IP) address used to connect your device to the Internet;
  • Your login information, browser type and version, time zone setting, browser plug-in types and versions;
  • Operating system and platform;
  • Information about your visit, including the Uniform Resource Locators (URL) clickstream to, through, and from our site.

Our cookies policy (below) describes how we use cookies.

In Section 8 below, we identify your rights in respect of the personal data that we collect and describe how you can exercise those rights.

  1. Lawful basis for the processing of personal data

The table below describes the various forms of personal data we collect and the lawful basis for processing this data. Our business architecture, accounting and systems infrastructure and compliance organisation means that all personal data is processed on common, office-wide platforms. We have processes in place to make sure that only those people in our organisation who need to access your data can do so. A number of data elements are collected for multiple purposes, as the table below shows. Some data may be shared with third parties and, where this happens, this is also identified below.

Data Collected

Name, Address, Telephone No, Email Address, Geographical Location.

Means Of Collection

Phone, Email, Website Forms, Adobe E-sign forms, Paper Forms, Daft.ie, Myhome.ie, Office, Meetings at valuations and viewings or other venues.

Lawful Basis & Purposes Of Collection 

  • Contractual Fulfillment –  To provide appropriate online or email information about products and services that you have requested.
  • Legitimate Interest – To provide further, related, online or email information and ongoing news updates in relation to the identified area of interest. Follow-up to ensure requested information meets you needs and identify further requirements.
  • Consent – To provide information via email to those  who sign up to our newsletter. 

Data Shared With:

Data collected for the purpose of providing information is only shared Internally.

Retention Period

Maximum 8 years from the date the information is collected.

Where the lawful basis for collecting information is ‘consent’  we will hold your information for 12 months if a marketing email is left unopened.

 

Data Collected

Name, physical address, email address, telephone number, bank account details (IBAN & BIC for Tenant, Landlord & Vendor accounts), debit and credit card details.

Means Of Collection

Phone, email, recorded in office.

Lawful Basis & Purposes Of Collection 

  • Contractual Performance – To process financial transactions for products and services with Vendors, Landlords and Tenants, and to ensure any transaction issues can be dealt with. 
  • Statutory Obligation – For accounting and taxation purposes. 
  • Legitimate Interest – Documentation should any contractual legal claim arise.

Data Shared With:

Data is shared with AIB via online banking. Data is shared with professional advisers.

Retention Period

We will not hold your data for longer than is necessary. We will retain your personal data for the duration of your engagement with us and for such a period, after your contract ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise relating to your contract.

Where you do not enter into a contract with us, we will only retain your information for so long as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise relating to our interactions with you.

 

Data Collected

Name, physical address, email address, telephone number, PPSN. Where necessary information relating to your financial means, such as documentary proof of funds or payslips in the case of tenants. We may also request and hold information which we are required to collect to carry out anti-money laundering and identity checks and to comply with our legal obligations. 

Means Of Collection

Phone, email, recorded in office, mail.

Lawful Basis & Purposes Of Collection 

  • Contractual Performance – To carry out our contractual duties based on the services which we are providing to you or the estate agency activities which we are carrying out.  

Data Shared With:

Tenant and landlord details (including PPS no’s) are shared with the Residential Tenancies Board. Tenant and Landlord contact details may be shared with various maintenance personnel as deemed neccessary by us. Tenant contact details may be shared with utility providers such as gas and electricity suppliers.

Retention Period

We will not hold your data for longer than is necessary. We will retain your personal data for the duration of your engagement with us and for such a period, after your contract ends as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise relating to your contract.

Where you do not enter into a contract with us, we will only retain your information for so long as is necessary to comply with our obligations under applicable law and, if relevant, to deal with any claim or dispute that might arise relating to our interactions with you.

Data Collected

Technical information, as described above, plus any other information that may be required for this purpose.

Means Of Collection

Via our website – www.cbpm.ie

Lawful Basis & Purposes Of Collection 

  • Legitimate Interest –  To protect our websites and infrastructure from cyber attack or other threats and to report and deal with any illegal acts. 

Data Shared With:

Forensic and other organisations with whom we might contract for this purpose.

Retention Period

Relevant statutes of limitation.

Data Collected

Names, contact details, identification details

Means Of Collection

Phone, Email, Website Forms, Adobe E-sign forms, Paper Forms, Daft.ie, Myhome.ie, Office, Meetings at valuations and viewings or other venues.

Lawful Basis & Purposes Of Collection 

  • Legitimate Interest –   To communicate with you about any issue that you raise with us or which follows from an interaction between us

Data Shared With:

Internally and, as necessary, with professional advisers

Retention Period

Relevant statutes of limitation

  1. Storage of personal data

CBPM is an Irish-domiciled organisation whose primary offices are in Ireland.

  • Our websites and web applications are hosted in the EU and are accessed only by our EU-based staff.
  • Our customer relationship management, marketing and accounting systems for our businesses are EU-based.
  • We operate a data retention policy in respect of all data. Data required to fulfil contractual requirements will be held for up to 10 years after the contract is fulfilled. Data held for marketing and/or legitimate interest purposes will be retained for up to one year in the event of an unopened marketing email. All marketing emails will afford you the opportunity to unsubscribe from our mailing list.

 

  1. Security measures

All data is held on our internal computers and backed up to the cloud. Our systems are password protected. Paper forms and documents are scanned, stored and destroyed where appropriate. Retained documents are secured under lock and key.

We have what we believe are appropriate security controls in place to protect personal data. We do not, however, have any control over what happens between your device and the boundary of our information infrastructure. You should be aware of the many information security risks that exist and take appropriate steps to safeguard your own information. We accept no liability in respect of breaches that occur beyond our sphere of control.

  1. Your rights as a data subject

As a data subject whose personal information we hold, you have certain rights. If you wish to exercise any of these rights, please email caroline@cbpm.ie. In order to process your request, we will ask you to provide two valid forms of identification for verification purposes. Your rights are as follows:

  • The right to be informed
    As a data controller, we are obliged to provide clear and transparent information about our data processing activities. This is provided by this privacy policy and any related communications we may send you.
  • The right of access
    You may request a copy of the personal data we hold about you free of charge. Once we have verified your identity and, if relevant, the authority of any third-party requestor, we will provide access to the personal data we hold about you as well as the following information:
  • a) The purposes of the processing
    b) The categories of personal data concerned
    c) The recipients to whom the personal data has been disclosed
    d) The retention period or envisioned retention period for that personal data
    e) When personal data has been collected from a third party, the source of the personal data
  • The right to rectification
    When you believe we hold inaccurate or incomplete personal information about you, you may exercise your right to correct or complete this data. This may be used with the right to restrict processing to make sure that incorrect/incomplete information is not processed until it is corrected.
  • The right to erasure (the ‘right to be forgotten’)
    Where no overriding legal basis or legitimate reason continues to exist for processing personal data, you may request that we delete the personal data. This includes personal data that may have been unlawfully processed. We will take all reasonable steps to ensure erasure.
  • The right to restrict processing
    You may ask us to stop processing your personal data. We will still hold the data, but will not process it any further. This right is an alternative to the right to erasure. If one of the following conditions applies you may exercise the right to restrict processing:

      a) The accuracy of the personal data is contested
      b) Processing of the personal data is unlawful
      c) We no longer need the personal data for processing but the personal data is required for part of a legal process
      d) The right to object has been exercised and processing is restricted pending a decision on the status of the processing

  • The right to data portability
    You may request your set of personal data be transferred to another controller or processor, provided in a commonly used and machine-readable format. This right is only available if the original processing was on the basis of consent, the processing is by automated means and if the processing is based on the fulfilment of a contractual obligation.
  • The right to object
    You have the right to object to our processing of your data where
    • Processing is based on legitimate interest;
    • Processing is for the purpose of direct marketing.

 

  1. Contact us

Any comments, questions or suggestions about this privacy policy or our handling of your personal data should be emailed to caroline@cbpm.ie

Alternatively, you can contact us at our offices using the following postal address or telephone numbers:

CBPM Real Estate, 13/14 Kilminchy Court, Portlaoise, Co Laois.

Telephone: +353 (0)57 8635824

Our telephone switchboard is open 9:30 am – 5:30 pm GMT, Monday to Friday.

  1. Complaints

Should you wish to discuss a complaint, please feel free to contact us using the details provided above. All complaints will be treated in a confidential manner.

Should you feel unsatisfied with our handling of your data, or about any complaint that you have made to us about our handling of your data, you are entitled to escalate your complaint to a supervisory authority within the European Union. In Ireland this is the through the the Data Protection Commission https://dataprotection.ie

CBPM Real Estate - Cookie Policy

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

CBPM Real Estate uses cookies on our website (www.cbpm.ie) for the purposes of monitoring, administering and improving business performance; improving the content of the website, providing increased levels of customer service and making other products and services available to our customer base and other interested parties.

Necessary Cookies

__cfduid (Cloudflare) – Used by the content network, Cloud flare, to identify trusted web traffic.
PHPSESSID (cbpm.ie) Preserves user session state across page requests.

Statistical Cookies

_ga (cbpm.ie) – Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

_ga (vr-360-tour.com) – Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

_gat (cbpm.ie) – Used by Google Analytics to throttle request rate.

_gat (vr-360-tour.com) – Used by Google Analytics to throttle request rate.

_gid (cbpm.ie) – Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

_gid (vr-360-tour.com) – Registers a unique ID that is used to generate statistical data on how the visitor uses the website.

Marketing Cookies

 NID (google.com) – Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads.

r/collect (doubleclick.net) – collects data to measure efficiency of viewed or clicked ads and shows targeted ads.

3rd Party Cookies

Google Re-Captha 

We use Googles Re-captcha service to authenticate form submissions. Google Re-captcha uses cookies placed on your computer to confirm that you are a human and not a bot.  

Youtube

We use YouTube  widgets and iframes to host and display videos on our website. YouTube may use cookies to track and monitor users who view videos on our website. You can read You-tubes Privacy policy below (operated by Google): 

Google Analytics

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of cbpm.ie, to prepare reports on its activities and share them with other Google services. You can view the Google Privacy Policy here: www.google.com/policies/privacy/
 

Livechat

The live chat feature on our website uses cookies to monitor and record chats and allow you to converse with us in real time. You can view Livechats privacy policy here: https://www.livechatinc.com/privacy-policy/