Last updated: 9/1/19
This Policy is for Colman Grimes Estate Agents Limited T/A Colman Grimes Estate Agents. In this policy when we say, “the Group”, “we”, “us” and “our” we are referencing Colman Grimes Estate Agents Limited. The registered office for Colman Grimes Estate Agents Limited is 291 Templeogue Road, Templeogue Village, Dublin 6w, D6WEW97
Colman Grimes Estate Agents Limited is committed to protecting the personal data of our clients/customers and we take our data protection responsibilities and legal obligations, seriously.
The purpose of this policy is to inform you of the personal data that we might collect and use during our relationship with you and the use we may make of this data.
We collect and analyse certain statistical information about the use of our website http://www.colmangrimes.ie (the “Website”). When you visit the 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.
Live Chat on the Website
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 the Website
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 the 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.
Sources of Data
We only collect information from you directly e.g. from your interactions with us by phone, email and letter, through our direct involvement with you and/or through colmangrimes.ie with express permission to collect that data at the time of collection.
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, 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 relating to 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. It is important that we make you aware that if you invite us to value your property or if you should view, offer, purchase, let or rent through us we are legally required to retain a record of this for a minimum period of 6 years after the property transaction completes. Each of our communications will contain an opt out or unsubscribe so that you are fully in control of how we communicate with you.
Sharing of Personal Data
We may disclose your personal data to third party recipients if it is necessary to do so in order to carry your instructions under the terms of your contract with us and/or in connection with the purposes listed below:
To third parties who we engage to provide services to us, such as professional advisers, auditors, insurers and service providers;
To other members of our group or affiliates;
To third parties, their agents and professional advisors, subject to confidentiality obligations, for the purpose of a due diligence exercise by third parties in connection with any proposed merger, acquisition, re-organisation or transfer of our business and to any person proposing to participate in, promote, underwrite or manage any such arrangement; and
To competent regulatory or other authorities and bodies as requested or required by law.
What personal data do we collect when providing a property service? We may need you to provide us with personal data to allow us to provide that service, including:
your name and contact details, including your, email address, address and telephone number; ppsn; the information you provide for the purpose of entering into a contract with us;
personal data relating to you in connection with our on-going relationship with you, based on the services which we are providing to you or the estate agency activities which we are carrying out; where necessary information relating to your financial means, such as documentary proof of funds;
the information which we are required to collect to carry out anti-money laundering and identity checks and to comply with our legal obligations;
any other personal data which you provide to us directly.
Your rights and how to exercise them
Data protection legislation provides you with the right to obtain a copy of your personal data, this is called the right of access. You also have the right to withdraw consent to us processing your information, at any time, where the processing is based on consent.
Similarly, the legislation also gives you the right* to:
a) correct any information relating to you which is incorrect;
b) delete such Information;
c) restrict our use of that information;
d) object to our use of information relating to you; and
e) request that information relating to you is transferred to another data 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.
We might transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as an area that provides for an equivalent level of protection for personal data as is provided for in the European Union If, and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. In respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like to receive further details of the measures that we have taken in this regard, please contact us at firstname.lastname@example.org
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 data breaches. If you suspect any misuse, loss or unauthorised access to your personal data please contact us at email@example.com
Contact us and opting out
If you wish to contact us regarding your rights please email us at firstname.lastname@example.org or you can write to us at: Privacy Advisor, 291 Templeogue Road, Templeogue Village, Dublin 6w, D6WEW97. Please note that the email address noted above is manned between 9.00 am to 5.30 pm Monday to Friday and is not accessed outside of these hours. I
f you are not satisfied with our response you have the right to make a complaint to the Irish Data Protection Commission at www.dataprotection.ie
If you no longer wish to receive communications relating to your property requirements, or wish to amend your communication preferences, simply drop us an email to 291 Templeogue Road, Templeogue Village, Dublin 6w, D6WEW97 or you can call us on : 01-4670838 leaving your name and email address.
Colman Grimes Estate Agents and Data Protection
How do we use your personal data? Your personal data may be used by us or by third party service providers acting on our behalf for the purposes of:
a) liaising with you prior to your decision to engage us to provide property services to you or on your behalf;
b) carrying out estate agency activities on your behalf or in connection with a property which you own or are interested in acquiring, letting or bidding for.
c) to operate the Website, including the live chat function;
d) to respond to any questions or queries that you send to us;
e) carrying out research using aggregated and anonymised data which may be required to analyse trends in the property market in Ireland;
f) complying with legal obligations imposed on us;
g) to help prevent and detect fraud or loss;
h) to provide you with information on other relevant services available to you from each of our Group companies;
i) sending you property industry related newsletters and information; and
j) carrying out customer satisfaction surveys and sending you promotional materials, subject to any preference that you express.
You will only receive promotional material from Colman Grimes Estate Agents Limited if you have specifically opted in to received same. You can opt out of receiving such promotional materials at any time by emailing email@example.com or phone 014670838 or updating your preferences/unsubscribe on the communication received.
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 residential property business in a responsible and commercially prudent manner and in carrying out 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.
We will request your consent before collecting or processing your data where we are required to do so under the terms of current Data Protection Legislation. If you are not happy to grant your consent, our ability to provide information or services or to provide access to online services may be restricted.
Colman Grimes Estate Agents Limited does not collect the personal data of children under 16 without the express consent of a parent or guardian.
Changes to Policy