This document also outlines our approach to compliance with the General Data Protection Regulation (GDPR) and all other relevant data-protection legislation. It also sets forth your privacy rights. Please take a moment to familiarise yourself with our privacy practices.
Data protection officer
We have appointed an internal data protection officer (DPO) for you to contact if you have any questions regarding this privacy statement, our privacy practices or if you wish to exercise your legal data rights. Please contact our email@example.com.
Information we collect and how we use it
We collect and use your personal information for a variety of reasons including:
If you register,or subscribe to one of our Services
To create an account with us
To save property searches, set up property alerts or to upload a property to any of our Services you will need to create an account with us. This typically involves you providing us with your name, email address, phone number, password and payment information where relevant. Where payment information is needed we require your address to comply with EU VAT legislation. We may use this personal information to authenticate you and to provide you with the service you have requested from us and as per the terms and conditions you accept when creating an account.
If you set up an account with us we will send you welcome emails, designed to inform you of the benefits of your account, and to help you get the most out of your account.
We will also use your information to deliver the benefits of your account to you including, saving searches, sending you property alerts, saving notes and rating, placing and editing an advert, advert expiry reminders, advert refresh reminders and to deliver email newsletters.
When you place an advert with us, all personal information which you include in the text of the advert will be published on our site.
To pay for the Services you have requested from us
We may collect your payment information to pay for any Services you have requested from us, such as advertising a property on our site. This includes but is not limited to your credit and debit card number, card expiry date, CSV /CV2 number, BIC (Bank Identifier Code), IBAN (International Bank Account Number), direct debit mandate authorisation and cheques. Credit and debit card information is processed directly by PCI-compliant payment providers who perform payment services on our behalf. Occasionally, our employees receive payment information from customers over the phone. When this occurs, the payment information is entered as instructed into the relevant payment system and all other copies are deleted or destroyed immediately.
To deliver marketing, promotions, content and to conduct research
To receive marketing communications
With your consent, we may periodically send promotional emails about features, events, exclusive offers and competitions to the email address you have provided. To receive marketing emails from us, you will need to provide us with at least your email address and in some cases, your first name and last name. We have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing communications tailored to your interests.
You may at any time choose not to receive marketing communications from us by following the unsubscribe instructions included at the end of each email communication.
For competition and promotional purposes
We regularly run competitions or similar promotions that you can voluntarily enter. In most cases, to enter a competition you will need to provide us with your name, email address, phone number and county information. We ask for your county information to help distinguish between entrants with the same name when selecting a winner. In some cases, the competition entries will be shared with the promoter and this will be specified when you enter. If you win a competition you enter, you will be notified by phone call and we will publish your name on our website or digital apps and indicate the prize you have won. In the event that you share the same name with another competition entrant, we will publish your county alongside your name. We use your personal information to administer the competition or similar promotion and as per the terms and conditions you accept when you enter.
Providing you with an email newsletter
We offer a number of email newsletters to non-account holders. You can voluntarily sign up for them by providing us with at least your email address and in some cases, your first name and last name. We will use this information to send you the newsletter you have requested and in some cases to personalise the email we send. We will only send you these general newsletters with your explicit consent. You can opt out at any time by unsubscribing at the bottom of each email newsletter communication.
We provide tools that enable users of our services to share our content to a nominated email address. If someone else shares our content with you, we may temporarily collect your email address for the purpose of sharing the requested content. Gaffs.ie will only use this information to fulfil the sharing request and this contact information is not retained by us. By providing us with your email address, the third party that initiates the sharing request indicates they have your consent to share our content with you.
In correspondence with us
If you correspond with us, we will collect information such as your name, address, phone number and email address and any other personal information contained within the correspondence and use it to respond to your enquiry. We process this information in pursuit of our legitimate interests, which include developing and maintaining relationships with our users.
To participate in a survey or poll
We conduct surveys and polls that we use to produce original research from our users. Your participation is entirely voluntary. You may consent to us contacting you at the email address provided to participate in this research. We do not track individuals but look at the information in the aggregate. Any opinion you express, therefore, is anonymous. The type of information we collect varies and is wholly dependent on the individual survey or poll. If you would like more information about the type of information we collect in our surveys and polls, please contact us at firstname.lastname@example.org.
From time to time, upon completing a survey or poll, we may ask for your email address and in some cases your full name for competition, promotional or gifting purposes. Participation is entirely voluntary and this information is processed and stored separately from the information you provide us for the survey or poll. Where you provide this information to us, it will be processed only to administer the competition or promotion.
We use some of the information you provide to personalise your experience with us as you use our services, such as addressing you personally on our services and making navigation on our sites easier. We use aggregate information we collect about you to suggest and recommend tailored content. Where we collect this information by way of cookies or other similar technologies, we only collect this information with your consent, which you can withdraw at any time. However where we further process this information, we rely on the lawful processing ground of legitimate interest in delivering relevant content to our users.. You have the right to object to this processing if you wish – please contact us at email@example.com if you wish to object.
To provide an alert service
Gaffs.ie offers a number of email alert services. With your consent, we will process your personal details for the purpose of sending you the alert service you have requested. If you prefer not to receive these alerts, you can opt out at any time by unsubscribing at the bottom of each email communication or logging into the relevant alert service and disabling the alert.
To understand how you use our services
To track how you gain access to or read our content
We collect information relating to your use of our services to track how you gain access to or read our content. We typically collect this data in a form that does not, on its own, permit direct association with any specific individual and therefore cannot be reasonably used to identify you. Aggregated and anonymous data is considered non-personal information for the purposes of this privacy statement. If we can link usage data with your personal information and identify you, we will treat that linked data as personal information for as long as it remains combined.
We use log-in information, cookies and similar technologies, device information and internet protocol (“IP”) addresses to log your use of our services as follows:
• We log certain technical information that your browser sends us including: the internet protocol (IP) address; browser type and version; time-zone setting; access time; browser plug-in types and versions; operating system; and platform and device type
• We log usage information about the use of our website and Services, including: a history of the pages you view and other actions you take while visiting us, including the full Uniform Resource Locators (URL) clickstream to, through and from our site; articles, content and products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page and any phone number used to call our customer service number
• Technical information, including: the type of mobile device you use; unique mobile identifies, such as the devices IMEI number; mobile network information; your mobile operating system; the type of mobile browser you use; and the time-zone setting
• Details of your use of our mobile applications including but not limited to: traffic data; location data; weblogs; and other communication data and the resources that you access
• We may also use GPS technology to determine your location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use a particular feature, you will be asked to specifically consent to your data being used for this purpose. This consent can by withdrawn at any time.
• When you sign up for or subscribe to one of our services, we will track and aggregate non-personal information previously collected about you through our services with the personal information provided when you register or subscribe. If we link other data with your personal information and can identify you, we will treat that linked data as personal information for as long as it remains combined
To measure the effectiveness of our email communications
We use such technologies to determine whether you’ve opened an email communication from us or clicked on a link contained in an email. Collecting information in this manner allows us to gather statistics about the usage and effectiveness of our services and products, including our email newsletters and direct marketing communications, in our legitimate interest.
To support our advertising services
Third-party vendors, including Google, display advertising on our Services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site. This type of behavioral advertising is targeted towards groups of users in an anonymous and aggregated manner as opposed to you as an individual. Such online advertising helps support the content, products and services we provide.
We and third-party vendors use first-party cookies and third-party cookies together to inform, optimise and serve ads based on your browsing activities and interests. Any information we disclose to advertisers and advertising networks is non-personally identifiable.
To attend one of our events
We host many events throughout the year. These include but are not limited to breakfast briefings, live content events, live lectures, podcast recordings, training, conferences and seminars. If you register for one of our events, we will collect your name and contact information and in some cases your address and payment details and use this information to register for the event, process your payment and provide you with information and services associated with the event. In some cases, we make audio or video recordings of these events and we may record information about you as a consequence. We will always inform you in advance if the event is being recorded so that you can choose not to participate if wish. Registration for our events is voluntary. Once you register, however, we process your personal information as per the terms and conditions of that specific event.
To manage our everyday business needs
We may use your personal information to manage our every business needs, including accounting, interval reporting needs and market research, to progress and respond to legal claims, to ensure appropriate IT security and to prevent fraud in our legitimate interest. Our legitimate interest is the effecting management of our business.
To verify your identity
To exercise your data rights, we may need to collect additional personal information from you to verify your identify. We will verify your identity by reference to acceptable identification documentation supplied by you, which may include copies of your current passport, driving licence or Public Services Card.
When you provide services to us
You may provide us with your personal information if you provide professional services to us. This typically includes your contact information, address, phone number, your VAT registration number and maybe your banking information. We process this information so we can administer, manage and pay for the relevant services you provide and as per the terms and conditions of our contract. In some circumstances, your services may extend to delivering live lectures or involvement in our live events, in which case we may make audio or video recordings of you.
Anonymous information we process
We integrate with approved Apple and Android partners which maintain a list of anonymous devices that are opted into to receive push notifications from us. Gaffs.ie uses push notifications to inform you about breaking news, live event coverage and other top stories. We may occasionally use push notifications to send you marketing material which may be of interest to you. You may receive these notifications based on your location, operating device and/or interests that are derived from your use of our services. You can control your push notification, location and Bluetooth, and settings directly on your mobile device. It should be noted that iOS apps require a user to grant permission for an app to send them push notifications, while Android does not. We do not process any personal information and cannot establish the identity of the users who have subscribed to receive these notifications.
The purpose and legal basis for processing your information
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
To enter into and perform a contract with you
We use your personal information to carry out our obligations arising from any contracts entered into between you and us or to take the necessary steps at your request prior to entering into a contract with us including:
• To provide you with a Gaffs.ie account, services, alerts or products you have requested
• To process your payment information
• To authenticate and verify your account
• To provide customer and technical support
• To administer competitions or similar promotions
• To administer, process and pay for the services you may deliver to us
• To send important notices such as communications relating to payment, delivery services, changes to our terms, conditions, and policies and to notify you about changes to our service. We may do this by phone, post, email, SMS text or through other digital media
• To keep you informed of the benefits of your account
• To ensure you get the most out of your account
• To deliver exclusive content and benefits to our account holder
With your consent, which can be withdrawn at any time
We will, in certain circumstances, such as where we send you direct marketing rely on your explicit consent to process your personal data. Where we do, you have the right to withdraw your consent at any time. In most circumstances, your consent can be withdrawn by following the unsubscribe instructions included at the end of each email communication from us. You can also contact us at firstname.lastname@example.org and we will be happy to facilitate your request.
Processing based on our legitimate interests
We process your personal information for carefully considered and specific purposes which are in our legitimate interests and enable us to enhance the services we provide, but which we also believe benefit our customers. Our legitimate business interests do not automatically override your interests. You have the right, free of charge, to object to our use of your personal information for our legitimate interests. Please bear in mind that if you do object, this may affect our ability to carry out certain tasks for your benefit.
Where you object to our use of your personal information for our legitimate interests, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so. We will always ensure there is a fair balance between our legitimate interests and your fundamental right and freedoms.
We process personal information for the following legitimate business purposes:
• To manage our everyday business needs and for internal purposes such as auditing, data analysis, troubleshooting, accounting, providing customer service, auditing, technical support and fraud prevention
• To provide you with a more personalised experience, such as making content recommendations. By understanding which content you find useful or interesting, we can recommend more content that you might also like, as well as continuing to produce the most valuable content to meet your needs
• In the event that we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, in which case the personal information we hold on you may be one of the transferred asset
• To support our advertising services
• To determine the effectiveness of promotional campaigns, email campaigns and advertising
• To research and improve Gaffs.ie products, services, and customer communications
• To ensure content from our site and mobile applications is presented in the most effective manner for you and for your device
• To develop and maintain relationships with our users
• To implement customer-retention and win-back strategies
• To better understand and improve the usability, performance, and effectiveness of our services
• We may process your information to protect you against fraud when transacting on our services and to detect, prevent, investigate security or technical issues to ensure our services are secure
• To understand the demographics of our users
You have the right to object to this processing, and if you wish to do so please visit the My Preferences section of My Account or contact us at email@example.com.
When and how your information is shared
Within our group
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries and use it in a manner that is consistent with this privacy statement.
With third parties
We may share your personal information with third parties for a number of reasons as outlined below. We do not sell your personal information to anyone and only share it with third parties who are facilitating the delivery or fulfilment of our services and or are working on our behalf. We contractually require that our suppliers protect such information from unauthorised access, use, and disclosure.
Third-party service providers
We may share your personal information with third-party service providers which perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, payment providers, lawyers, providers of security and administration services and other business advisers.
Third-party service partners
We provide certain services and run promotions in conjunction with third parties and we may share your personal information if the service you have requested is fulfilled by them. Examples include but are not limited to currency advice and mortgage quotes. These third parties have their own security and privacy policies. You are advised to review these separately.
We disclose non-personally identifiable aggregate information to third-party advertisers and to help advertisers reach the kind of audience they want to target. We share summary aggregate reports for our advertisers to measure the effectiveness of the ads they have served.
Social networking sites
Where we display social media plugins on our site this may allow social media operators to set cookies in other technologies when you visit the site. We are not responsible for how social media operators use your data and you should review their privacy policies separately. These cookies will only be set with your consent, which can be withdrawn at any time
Data storage and retention
Gaffs.ie will retain your personal information as needed to fulfil the purposes for which it was collected. We will retain and use your personal information no longer than is necessary to comply with our business and legal obligations. Where we enter into a legal contract with you, we will hold your personal information for a period of seven years from the date of completion of this contract by reference to the statute of limitation for a legal claim under contract.
We may transfer your personal data outside the European Economic Area. These countries do not always afford an equivalent level of privacy protection and in such circumstances we take specific steps, in accordance with data protection law and to protect your personal information. In particular, for transfers of personal data, outside the EEA where there is no adequacy decision by the European Commission we may rely on contractual protection approved by the European Commission.
Your data rights
You have several rights under data-protection law in relation to how we use your personal information. You have the right, free of charge, to:
• Request a copy of the personal information we hold about you in a structured, commonly used and machine readable format
• Rectify any inaccurate personal information we hold about you
• Withdraw your consent where we have relied upon your consent to process your information
• Erase the personal information we hold about you subject to certain exceptions
• If technically feasible, have your personal information transmitted to another data controller in a machine readable format at your request
• Restrict processing of your personal information in certain circumstances
• Object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes
• Not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
• Lodge a complaint with the appropriate data-protection authority if you have concerns about how we process your personal data
These rights are in some circumstances limited by data-protection legislation. If you wish to exercise any of these rights please contact us at firstname.lastname@example.org
We will take measures to verify your identify which we will do by reference to acceptable identification documentation supplied by you. These include but are not limited to copies of your current passport, current driving licence or current Public Services Card.
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will contact you and explain why.
Consequences of not providing information
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services which you have requested). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
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.