Privacy Policy

Introduction

This Privacy Policy lets you know how Homely will look after your personal information. This includes what you tell us about yourself and what we learn by having you as a client. This Privacy Policy explains how we do this and tells you about your privacy rights and about how the law protects you where we process your personal data.

In particular, this Privacy Policy describes:

the types of information we collect about you and how we use it;
the legal grounds for how we use personal information;
the rights which individuals have in relation to the information we hold about them; and
how we keep information secure.

Who we are

Our full corporate name is Homely Technologies Limited (company number is 724457). Our registered office address is located at 17 Pembroke Street Upper, Dublin 2, Ireland.

Our privacy commitment

We need to collect and process information about individuals, including clients and other business contacts, in order to conduct our business.

We commit:

to keep your personal data safe and private;
not to sell your personal data; and
to give you ways to manage and review your personal data at any time.

This Privacy Policy sets out most of your rights regarding personal data. We will process all personal data in accordance with the following principles:

all personal data will be processed lawfully, fairly and in a transparent manner;
all personal data will be collected for one or more specified, explicit and legitimate purposes and not processed in a manner incompatible with those purposes;
all personal data collected will be restricted to what is adequate, relevant and limited for those purposes;
all personal data will be kept accurate and up to date (and reasonable steps will be taken to erase or rectify inaccurate personal data);
all personal data will be kept for no longer than is necessary for those purposes; and
all personal data will be protected by appropriate technical and organisational security measures to prevent unauthorised or unlawful processing and accidental loss, destruction or damage.

Homely as the data controller will be responsible for compliance with these principles and will be able to demonstrate its compliance with them at all times.

What this Privacy Policy relates to

This Privacy Policy relates to all Homely clients and potential clients who are individuals, and to all third party businesses and individuals who work with Homely to provide a service.

Collection of personal information

When providing you with our services, we will collect personal information about you. In the case of third party businesses and individuals who work with Homely to provide a service, we will collect personal information about individuals connected to your business. This information may be collected from you or other independent sources. All relevant individuals will have access to this Privacy Policy and if you, or anyone else on your behalf, has provided or provides personal information to us about an individual connected to you or your business, you or they must first ensure that you or they have the authority to do so, and that you have provided them with access to this Privacy Policy to ensure that they are informed of its contents.

This Privacy Policy applies to all products and services that are offered and provided by Homely. Homely will only request details that are genuinely required in order to provide information or services that you have requested, or to comply with our contractual or legal obligations in relation to you or the services that we provide, or for the purposes of maintaining a balanced, genuine business relationship between you and us, including making contact on an unsolicited basis (unless you have requested that we do not do so). We will only collect and process personal data when the collection and processing of that personal data is permissible in accordance with applicable law.

Your personal data that we collect, process and retain may include:

Name, address, mobile and landline numbers, email address and gender;
Business contact details including mobile and landline numbers, email address and business address;
Job title, salary, responsibility details and any additional information around the nature of your role (which may include qualifications and experience that you wish to tell us about);
Rental history;
CCTV footage if you attend our premises;
Open data / public records which includes data that you have made freely available in a public domain such as via social media or publications and news articles;
Permissions – so we can record how you would like to receive information from us, or if you would prefer not to; and
Any extra information that you choose to tell us.

Your personal data will be collected, stored and processed for the following purposes:

To provide our products and services to you;
To comply with applicable statutory requirements for the prevention of money-laundering;
To maintain adequate accounting and financial records and to invoice you as and when appropriate;
To carry out research activities;
To provide you with marketing and other information about us and other goods and services that we may offer;
To obtain credit checks and/or references in relation to you (where necessary in connection with the provision of our services and where not prohibited by applicable legislation);
To allow us to invite you to any events organised alone or jointly by Homely;
To carry out any other activities that may be ancillary or related to the above (for example, to contact you by email and/or text message for marketing, advertising or research purposes);
To make your personal data available (but only to the extent absolutely necessary) to third parties who provide products or services to us, or to potential purchasers of our business.

Lawful processing basis

Under the General Data Protection Regulation (GDPR) (EU) 2016/679, we must justify a lawful basis for processing your personal data. The most common bases are as follows:

Legitimate interest – using people’s data in ways that they would reasonably expect in the context of our business and which would have a minimal privacy impact, or where there is a compelling justification for the processing.

Contractual – where we need to fulfil our contractual obligations to you, or where you have asked us to do something before entering into a contract (e.g. provide a quote).

Consent – asking individuals to ‘opt-in’ as a preference to signing up to a newsletter or networking event, for example. Where consent is not a lawful processing basis, it will not be relied upon.

Legal / Statutory obligation – using your data because we are statutorily required to do so, e.g. retaining invoices based on tax legislation.

For further information, please visit the Data Protection Commission website (www.dataprotection.ie).

Reasons for processing your personal data

We will use your personal data in order to carry out activities, some of which will include marketing purposes, event invitations and the carrying out of our contractual and statutory duties to you.

All personal data is regarded as company confidential data and will be handled appropriately at all times. All staff working for Homely will have controlled, role-based access to your personal data, but only on a strictly ‘need-to-know’ basis, for the purposes described in this Privacy Policy. The following list gives details regarding the type of activity and what we process, why we process it and the lawful basis for our doing do.

What we mean by marketing

Using your personal information for contact details in order to inform you about new services and events;
Profiling your data in order for us to justify why we have previously processed your data and why we would continue to do so;
To identify what type of marketing information we believe may be of use to you and what you may be interested in;

We will only use your information for marketing purposes when we determine that our basis for doing so is a lawful basis (under either the ‘legitimate interest’ or ‘consent’ basis). We will only use your information for marketing purposes where you have not ‘opted out’ or otherwise indicated a preference not to hear from us. We may periodically ask you to review your preferences about how we contact you and will make it easy for you to change your mind.

Your rights under the GDPR

Your rights under the GDPR include:

Asking us to tell you what data we hold about you and requesting a copy. This is called a Subject Access Request. We will not charge for this unless a request is manifestly unfounded or excessive, particularly if it is repetitive, or if further copies are requested. We will have one month in which to comply with your request unless circumstances allow for an extension.

Objecting to your personal information being processed. You may also ask us to delete it (known as ‘the right to be forgotten’) and we will consider all such requests. If there are legal reasons for us keeping your personal data despite your request, we will notify you of this. These rights are not absolute rights and there may be reasons for retaining the personal data.

Asking us to amend or stop using your information because it is inaccurate, incomplete or you want to restrict how we process it.

The right to be informed about the collection and use of your personal data.

Asking us to move, copy or transfer your personal data easily from one IT environment to another, in a safe and secure way, without hindrance to usability when you have provided to us your personal information.

Please contact us if you wish to speak to us about the above.

Consequences of not providing us with certain data

Providing Homely with certain levels of personal data is the choice of the individual to which that data belongs. You may choose not to give us certain information we ask for, or ask us to delete or stop using information that we already hold in regard to you, and it is your right to do so. However, we may have overriding interests or obligations concerning certain data and so we must also highlight some possible consequences of our not being able to process certain data belonging to you, as follows:

We may not be able to keep you informed about our new products and services or any relevant changes to our products or services;

We may not be able to keep you up to date with industry or regulatory changes, news and market reports;

We may not be able to keep you informed in regard to any upcoming events;

We may not be able to fulfil our contractual obligations to you in order to provide our service;

We may not be able to allow you to continue using our products or services;

We may not be able to consider new business with you.

Withdrawing your consent

If we have asked for your consent at any time and you now wish to withdraw it, please contact us and we will update our records accordingly.

Please remember that if you withdraw your consent we may not be able to continue offering you our products and services. However, if this is the case we will discuss this with you.

If we are processing your personal data using the lawful processing basis of ‘legitimate interest’, withdrawing your consent will mean that you will no longer have given us ‘consent’ to process this data. For the avoidance of doubt, you will always have the right to object (see the section entitled ‘Your rights under the GDPR‘).

If you have any questions on the above, please contact us.

How to complain

If you are not happy that we are processing, or have processed, your personal information in accordance with the GDPR, then you can raise a complaint with us or the Data Protection Commission. Also, if you have instructed us around how to process your personal data in terms of your individual rights and you are not happy, please let us know.

How long we will keep your data for

Whilst you are still an active client of Homely, and where you haven’t instructed us to delete your data, we will continue to retain your personal data in a secure environment. We will retain, cleanse and delete your data in line with our data retention policy – in this regard, see as follows:

Document Type	Retention Period
Risk Assessments	3 years from last review date
Documents of External Origin	6 years
Emails and other electronic information	Relevant client/third party related data – 6 years
Property documents such as leases and lease termination agreements	6 years after lease termination
Client/third party feedback/complaints	7 years
Invoices	7 years
Client project related records	15 years

Unless the circumstances otherwise require, your personal data will be deleted at the end of the relevant retention period at which time your rights may be limited as Homely will no longer have your personal data. Circumstances that will result in our keeping your personal data outside of these retention periods includes legal and regulatory requirements and other commercial reasons (including ongoing contractual disputes).

How we keep your data secure

Security of your personal data is vitally important to Homely and we strive to maintain security in many ways, as follows:

Testing and reviewing our systems, networks and locations that process data;
Maintaining security policies and procedures which are tested and reviewed periodically;
Ensuring employees are given the tools and training to handle data responsibly;
Ensuring employees are under a statutory or contractual obligation of confidentiality;
Controlling access to data across various levels including as regards system and application access, physical access and third party access, and robust password management procedures;
Access, at all levels, is role-based and only granted on a ‘need to know’ basis;
Ensuring data is periodically cleansed, archived or deleted in line with policy;
Employees undergo screening upon joining Homely and training is mandatory for topics such as information security and data protection;
Information assets are logged and equipped with up to date antivirus software;
Data is regularly backed up and stored in a secure environment;
Data breaches and security incidents are reported in line with policy and are followed up with analysis, risk assessments and corrective action where necessary.

In line with our security obligations, we would also ask that you notify us of any changes to your data so that we can keep our records as accurate as possible.

Parties we share data with

We may share your personal data with entities such as the following:

Regulators and other government authorities or law enforcement agencies;
Any party linked with you;
Parties providing services to Homely (whether working on a matter for your benefit or otherwise), such as contractors and consultants;
Our external advisors, such as auditors, accountants or lawyers where they are under a duty of confidentiality;
Companies who conduct requested credit checks on our behalf;
Organisations that introduce you to us;
Companies that we introduce you to, where appropriate to do so;
Companies with whom you ask us to share your personal data.

Where we share your personal data with any of above parties, we will ensure that your personal data is subject to controls at least as stringent as those that apply to Homely when it collects, processes or stores your personal data.

We may also have to share information or data in order to:

Comply with any applicable law, regulation, legal process or enforceable governmental request;
Meet our contractual obligations for the purpose of legally required audits;
Enforce our policies, including investigations into potential violations of those policies;
Detect, prevent or otherwise address fraud, security or technical issues;
Protect against harm to the rights, property or safety of our clients, the public or to Homely and/or as required or permitted by law.

Use of cookies

Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when an individual registers to use our websites, subscribes to our service, or makes an enquiry.

Changes to our Privacy Policy

We may need to make changes to our policies and notices from time to time, where the processing of personal data is impacted, within the limitation set out by the GDPR and the applicable data protection legislation. When we have made changes, we will update the Privacy Policy on our website for you to read.

Homely contact details

If you have any questions, require further information or wish to complain, please contact us by email at info@ownhomely.com

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