GENERAL DATA PROTECTION REGULATION

Davis Hunter Auctioneers

Privacy Policy

We are DavisHunter Auctioneers of 1 Portside, Marina Commercial Park, Cork .

We take our responsibilities under applicable data protection law, including the General Data Protection Regulation and implementing legislation such as the Data Protection Act 2018 (“Data Protection Law”) very seriously. The purpose of this notice is to inform you of the data relating to you that we may collect and use and the uses (including disclosures to third parties) we and the Davis Hunter Group may make of such data.

If you have any questions about our use of your personal data, please contact us at the above address or by emailing info@davishunter.ie

Website Usage Data

We collect and analyse certain statistical information about the use of our website. When you visit our website, the following information is retained about that visit:

• the Internet Protocol (IP) address from which you access the website in a format that does not enable us to identify who you are
• the previous webpage from which you accessed the website;
• the identity of any search engine used to access the website, and any search terms used;
• the type of browser, device and operating system used to access the website;
• the date and time of your access to the website;
• a list of all the pages visited while in the website; and
• the page you exit the website from.

Such information is collected on an aggregate basis. None of this information is associated with you as an individual and we do not track individual e-mail addresses, usage of web pages or any other information personally identifying you. Most information is collected via cookies or other analysis technologies. To learn more about our use of cookies, please see below.

Cookie Policy

Cookies are small data files placed on your computer or internet enabled device by websites to add functionality. Cookies help to improve the usage and effectiveness of the website, for example, by remembering preferences expressed by a user or tracking a user’s use of the website for statistical analysis.

Cookies on Davishunter.ie

Java session cookies: These cookies facilitate access to your user account and do not store or pass any personal information to any 3rd parties

Google Analytics cookies: We use these cookies to track statistical data about the usage of our website including user sessions. These cookies do not store personal data nor do they send it on to any 3rd parties through the use of Google Analytics.

If you would like to restrict the use of cookies, you can turn off the cookie acceptance option in your browser settings. Please note that disabling cookie support may prevent the website

from functioning properly and you may not be able to fully utilise all its features and services.

We will update our Cookies Policy to reflect any changes in data protection legislation. Any updates or changes that may affect how we use cookies or how you as a user can manage cookies will appear on this page.

Website Usage Data

Sources of data

In addition to the information we receive from you, by phone, email, letter and / or through our direct involvement with you, web based property portals, new home development websites and social media we may also receive or obtain information relating to you from, third parties such as lenders, receivers, landlords, agents and property managers to enable us to provide our services.

We may collect and process data relating to you during the course of our relationship with you. Such data may include:

• your name and contact details, including your address, email address and telephone number;
• information which you enter in any of our application forms which you complete for the purpose of entering into a contract with us.;
• personal data relating to you in connection with our ongoing relationship with you, such as via correspondence and calls with you and based on the services which we are providing either to you or the estate agency activities which we are carrying out in respect of a property which you either own or have made enquiries in respect of;
• information which we are required to collect to carry out money laundering and identity checks and to comply with legal obligations;
• where necessary (e.g. where you are looking to purchase or rent property), information relating to your financial means (such as documentary proof of funds);
• any other personal information you have provided directly to us. For example, in certain circumstances, where relevant to our relationship with you, we may collect information relating to your accommodation needs, including, for example, where, you have specific accommodation needs because of mobility issues which affect you or a member of your family or household.

How do we use your personal data?

Your personal data may be used by us, DavisHunter group companies or by third party service providers acting on our behalf for the purposes of:

1. liaising with you prior to your decision to engage us to provide real estate services to you or on your behalf;
2. carrying out real estate agency activities on your behalf or regarding a property you are connected with;
3. to respond to any questions or queries that you send to us;
4. where you act as a bidder, disclosing your identity and any supporting information in your proposal to the vendor as part of the bidding process generally, or any ‘Best Bids’ process, specifically;
5. searching credit reference agencies in order to verify your identity and conduct credit checks on you;
6. carrying out research, (using aggregated and anonymised data only), which may be required to analyse trends in the property market in Ireland;
7. carrying out statistical analysis of the property market in Ireland, including in relation to the status of buyers and property prices;
8. verifying, on a spot-check basis, franchisees are providing services to its customers in a manner consistent with the standards required by the Group and with applicable legal requirements; and
9. the investigation and processing of complaints and conflict checks; and
10. facilitating cross-referrals across the franchise network, where appropriate.
11. processing and oversight on transactions which we distribute nationally throughout our Network
12. complying with legal obligations imposed on us e.g. to retain information and communications on viewings and biddings.
13. to help prevent and detect fraud or loss;
14. to provide you with information on other relevant services available to you from each of the Davishunter companies;
15. sending you property industry related newsletters and information; and
16. carrying out customer satisfaction surveys and sending you promotional materials, subject to any preference that you express. You can opt out of receiving promotional materials from us at any time by emailing info@davishunter.ieor 02142230100 or updating your preferences/unsubscribe on the communication received.
17. Transferring of utility bills to / from your name on your behalf.
18. relevant registration with statutory bodies (eg PRTB).

The legal bases on which we collect, process and transfer your information in the manner described above are:

• the performance of our contract with you;
• to take steps at your request prior to entering into a contract with you;

our legitimate interests in conducting our commercial real estate business in a responsible and prudent manner and in carrying our meaningful research in relation to the status of the property market in Ireland. We will not process

• your personal data for these purposes if to do so would constitute an unwarranted interference with your own interests, rights and freedoms;
• to comply with our legal and regulatory obligations (e.g. to undertake Anti Money Laundering checks and our obligation to keep records of bids and bidders on property transactions as required by the Property Services (Regulation) Act, 2011); and
• in limited circumstances, where you have given your consent to such processing.

The legal bases on which DavisHunter collects and processes your information are its legitimate interests in managing its franchise network and other businesses in a responsible and commercially prudent manner, ensuring that its franchisees provide services to its customers to the standards required by Davishunter and the compliance with its legal obligations.

Requirement to Provide Data

Generally, you are not under a statutory or contractual obligation to provide us with any personal data. However, some of the information required by our application forms is necessary in order for us [to comply with our obligations under applicable law] and to provide services to you and, if you do not provide us with these required details, then we may not be in a position to provide you with our services.

Sharing of Personal Data

We may disclose your personal data to third party recipients in connection with the above purposes, including:

• to third parties who we engage to provide services to us, such as professional advisers, auditors and outsourced service providers; or
• to other members of the DavisHunter  or affiliates.
• to competent regulatory authorities and bodies as requested or required by law.

We store your personal data on IT systems which are provided to us on a shared basis by DavisHunter.  DavisHunter has access to your personal data which is stored on these IT systems. For further details on the uses which the DavisHunter may make of your personal data, please email info@davishunter.ie

How do we safeguard your personal data?

We are committed to taking all reasonable and appropriate steps to protect the personal information we hold from misuse, loss or unauthorised access. We do this by having a range of measures in place. These measures include the ability to deal with suspected databreaches.

If you suspect any misuse, loss or unauthorised access to your personal data please contact us on info@davishunter.ie

Retention

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 of time 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 in connection with 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.

How the DavisHunter uses your information

DavisHunter may access and process your data for the purposes of:

• contacting you by email for the purposes of carrying out customer satisfaction surveys;
• carrying out statistical analysis of the property market in Ireland, including in relation to the status of buyers (e.g. whether first-time buyers, investors, etc.) and property prices;
• verifying, on a spot-check basis, whether its franchisees are providing services to its customers in a manner consistent with the standards required by DavisHunter and with applicable legal requirements; and
• to carry out compliance audits in respect of its franchisees for the purposes of ensuring that franchisees are complying with their legal obligations;
• for the investigation and processing of complaints and conflict checks; and
• to facilitate cross-referrals across the franchise network, where appropriate.

The legal bases on which DavisHunter  collects and processes your information are its legitimate interests in managing its franchise network and other businesses in a responsible and commercially prudent manner, ensuring that its franchisees provides services to its customers to the standards required by DavisHunter and the compliance with its legal obligations.

DavisHunter will keep your data fully secure and will only retain it for as long as is reasonably necessary in accordance with applicable DataProtection Law.

You have the following rights*, in certain circumstances and subject to certain restrictions, in relation to your personal data –

• the right to access your personal data;
• the right to request the rectification and/or erasure of your personal data;
• the right to restrict the use of your personal data;
• the right to object to the processing of your personal data;
• the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.

*Please note that these rights can be subject to certain restrictions, we are legally obliged to retain records of all viewings and offers made on a property for a minimum of 6 years after the transaction so a request to delete cannot be actioned until that legal timeframe has passed.

In order to exercise any of the rights set out above, you can contact us at Unit 1 Portside, Marina Commercial Park, Centre Park Road, Cork Tel: +353 (0)21 4223100 or by emailing info@davishunter.ie

If you are not happy with the way we or DavisHunter have used your information or addressed your rights, you have the right to make a complaint to the Data Protection Commission by emailing info@dataprotection.ie.

Changes to Policy

We may change this Privacy Policy from time to time, to reflect how we are processing your personal information. We will publish the updated version on our website. If we make any significant changes we will highlight them to you.