1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include in case of registered Buyer Accounts : (your name, email address, and IP), in the case of registered Seller Accounts : (your name, email address, telephone numbers, address, your property’s map location, IP). The source of the account data is the data you provided on registering for our services and some data provided by your web browser on login (e.g. IP). The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5 We may process information contained in any enquiry you submit to us regarding our property ads or other services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
2.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, the transaction amounts(s) and dates. The transaction data may be processed for the purposes of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.7 We may process information that you provide to us for the purposes of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.8 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9 We may process information contained in any communication Account Holders voluntarily send to us (“verification data"). This data may include data which verifies ownership of a property (e.g. recent utility bills). The source of this data is the registered Account holder. This data may be processed for verification purposes and to verify accounts. The legal basis for this processing is consent OR our legitimate interests, namely our interest in the proper verification of accounts, proper administration of our website and business.
2.10 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group (this means our subsidiaries, our holding company, lessees, assignees etc.) insofar as reasonably necessary for the business purposes, and on the legal bases, set out in this policy.
3.2 Financial transactions relating to our website and services are handled by our payment services providers, (Paypal, Stripe, etc.). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/ie/webapps/mpp/ua/privacy-full and https://stripe.com/ie/privacy.
4. International transfers of your personal data
4.1 We do not currently knowingly/intentionally transfer your personal data to any party in countries outside the European Economic Area (EEA).
5. Retaining and deleting personal data
5.1 We will generally keep your personal data only as long as it is required to fulfil our obligations to you. After we have fulfilled our obligations, to meet our statutory obligations under Irish law, we may need to keep certain data records for a further 6 years. After this period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information.
5.2 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may but are not obligated to notify you of changes to this policy by email.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to rectification;
(b) the right to erasure;
(c) the right to withdraw consent.
(d) the right to access;
7.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.5 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.6 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data. You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the payment of a fee (currently fixed at EUR 25); and
(b) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a certified photocopy of your passport/drivers licence plus an original copy of a utility bill showing your current address).
7.7 You may exercise any of your rights in relation to your personal data by written notice to us by email at firstname.lastname@example.org.
9. Data Security
9.1 In line with Industry Standard IT Security practices we take all reasonable steps including appropriate technical and organisational measures to protect your Personal Data. We use sophisticated encryption methods to protect personal data, and our web hosting company (where we host your personal data) has achieved the Cyber Essentials Security Certification Standard.
9.2 Given the open nature of the internet, no company/organization can fully guarantee that they can prevent the unauthorized use (or misuse) of personal data by others. Notwithstanding our best endeavors to secure your personal data on our platforms, you acknowledge that personal data which you submit through our website or services may in certain circumstances, despite our best efforts, be accessed by unauthorized parties.
10. Our details
10.1 This website is owned by Blackbridge Enterprises Ltd.
10.2 You can contact us at:
Blackbridge Enterpises Ltd, 12 Lower Hatch Street, Dublin 2, D02 R682
Credit : This document was created using a template from SEQ Legal