Guide to how we manage and protect your personal data

Data Privacy Policy

This is your guide to how personal data is managed by Property Button. Please read it carefully.

Data privacy is taken very seriously at Property Button. 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:

1. Who we are
2. The information we collect about you
3. When and how we collect information about you
4. How we use your information
5. How we use automated processing or “analytics”
6. Who we share your information with 
7. How long we hold your information 
8. Implications of not providing information
9. The legal basis for using your information
10. Processing your information outside the EEA
11. How to exercise your information rights (including the right to object) 
12. How to contact us and/or our Data Protection Officer 
13. Changes to this notice

 

1. Who we are

Throughout this document, “we”, “us”, “our” and “ours” refer to Property Button. “Property Button” means: Residential Utility Management LTD, trading as Property Button.

Registered Office

Residential Utility Management LTD
First Floor
The Boulevard Centre
Quinsborough Road
Bray
A98 R6D7
Registered in Ireland. Company Number 512213.

2. The information we collect about you 

There are a number of 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, we need to be able to direct you to appropriate services, and we need to be able to process service requests on your behalf. The information we collect falls into various categories.

Identity & contact information

Name, date of birth, copies of ID, contact details, online user identities, security details to protect identity, nationality, home status and address, email address, work and personal phone numbers, marital status and family details.

Financial capacity

Employment status, salary details, welfare details, pension details, maintenance payment details, savings, guarantors and any other information that demonstrates your ability to afford a given property. 

Information you provide us about others or others provide us about you

If you give us information about someone else (for example, a prospective co-tenant), 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 do not invite the submission of information about you which includes sensitive personal data, such as health or criminal conviction information.

Information about you provided by others

If you give us information about someone else, or someone gives us information about you, (for example, an existing landlord), 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 to contact you through certain channels to offer you relevant products and services.

We collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy, which is available on our website.

We may 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 data we collect

Information in relation to data access, correction, restriction, deletion, porting requests and complaints.

Sometimes we may collect and use your information even though you are not using Property Button for your own benefit

For example, you may be a previous landlord, guarantor, co-tenant or a representative of one of our customers. If we do collect it, we will apply the principles outlined in this Data Privacy Notice when dealing with your information.

3. 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, such as a letting or estate agent, and from sources where you have chosen to make your information publicly available, such as social media sites.

When we collect information about you:

• When you ask us to provide you with certain products and services. For example, subscription to utility or broadband products may require us to collect bank account details from you.
• When you use our website and online services provided by us.  
• 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.

Please note: If you apply for a property or sign up for a service in joint names, you should only give personal information about someone else (for example, a joint applicant, a guarantor or a former landlord) with their permission.

4. 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.

To provide our products and services to you and perform our contract with you, we use your information to:

• Establish your suitability for a property or a service.
• Manage and administer your account on Property Button or other products and services that our partners or we may provide you with.
• Contact you by post, phone, text message, email, social media, fax, using our online website or other means, but not in a way contrary to your instructions to us or contrary to law.
• Monitor and record our conversations when we speak on the telephone (for example, to check your instructions to us, to analyse, to assess and improve customer service and for training and quality purposes).
• 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. 
• Conduct marketing activities and research, including customer surveys, analytics and related activities.
• To run our business on a day to day basis including to:
• Compile and process your information for audit, 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 and data risk 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).
• Manage and administer our legal and compliance affairs, including compliance with regulatory guidance and voluntary codes of practice to which we have committed.
• Enable us to share or access your information for internal administrative purposes, for audit and for statistical or research purposes (including making your data anonymous) to help us understand trends in customer behaviour and for the purposes set out in this Data Privacy Notice (but not for the purposes of direct marketing where you have objected to this). 
• To buy and/or sell assets our assets: 
• Property Button may in the future wish to sell, transfer or merge part or all of its business or assets or to buy a new business or the assets of another business or enter into a merger with another business. If so, we may disclose your personal information under strict duties of confidentiality to a potential buyer, transferee, merger partner or seller and their advisers, so long as they agree to keep it confidential and to use it only to consider the possible transaction. If the transaction goes ahead, the buyers, transferee or merger partner may use or disclose your personal information in the same way as set out in this Data Privacy Notice.

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 Property Button 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 cookies in accordance with our Cookie Policy.
• 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. 

5. How we use automated processing or “analytics” & our legal basis

We use automated statistical analysis of the information we collect about you as part of our business 

• • Automated analysis of our customer information (including your information) as a whole helps us to manage our business for our legitimate interests. It enables us to:
  • Make more informed business decisions, including improving the quality of products and services we can offer (including for the purposes of direct marketing, unless you have objected to us using your details in this way).
  • Test and maintain the stability and performance of our systems.
  • Carry out long-term statistical modelling, provided that such modelling does not affect any decision we make about you.
  • We will only automatically process your information to enable us to undertake the following activities where we have your consent:
  • Send electronic messages to you about product and service offers from us and/or our selected trusted partners.
  • Share your data with third parties so that they may send you electronic messaging about their products and offers.
  • 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 this with the activities outlined above.

6. 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:

• Your authorised representatives:
• These include your attorney (under a Power of Attorney) and any other party authorised by you to receive your personal data.
• Third parties who deliver domestic services to which you subscribe or wish to subscribe (for example, utility services, waste collection services)
• 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.
• 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
• Those who are interested in or participating in buying or selling assets of Property Button or in connection with a funding arrangement for Property Button. 

7. 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 product we have arranged on your behalf.

• Those factors include:
• The regulatory rules contained in laws and regulations or set by authorities in, for example, the Consumer Protection Code.
• 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 an active user. In most cases this period is one (1) year.

8. 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 services to you and fulfil our obligations to you, to other service users and to third parties to which you have been introduced.
• Manage our business for our legitimate interests.
• Comply with our legal obligations.
• 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.
• We may not be able to assess your suitability for a property, product or service, or, where relevant, give you a recommendation. 
• When we request information, we will tell you if providing it is a contractual requirement or not, and whether or not we need it to comply with our legal obligations.

9. The legal basis for using your information

We will use your data and share that data where:

• Its use is necessary in relation to a service or a contract that you have entered into or because you have asked for something to be done so, you can enter into a contract with or through us.
• Its use is in accordance with our legitimate interests outlined in this notice.
• Its use is necessary because of a legal obligation that applies to us (except an obligation imposed by a contract).
• You have consented or explicitly consented to the using of your data in a specific way. 

10. Processing your information outside the EEA

Your information is stored on secure systems within Bank premises and with providers of secure information storage. We may transfer or allow the transfer of information about you and your products and services with us to our service providers and other organisations outside the European Economic Area (EEA), but only if they agree to act solely on our instructions and protect your information to the same standard that applies in the EEA. 

11. 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:

You have the right to:

• 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.

We are obliged to respond without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons why. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you ask us otherwise. 

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:  https://www.dataprotection.ie/docs/Contact-us/b/11.html

Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231

Fax: +353 57 868 4757

E-mail: info@dataprotection.ie

 

Postal Address:
Data Protection Commission,
Canal House,
Station Road,
Portarlington,
R32 AP23,
Co. Laois. 

12. How to contact us

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 us at:

Telephone: +353 (0)1 969 6091

E-mail: support@propertybutton.ie

Postal Address:
Property Button,
The Boulevard Centre,
Quinsborough Road,
Bray,
A98 R6D7
13. 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 page and, where appropriate, notified to you by SMS, e-mail or when you log onto our website or applications.

 

Dated: 22 March 2019