Introduction
- OCP Residential B.V (trading in Ireland as OCP Residential Ireland) (“OCP”,”us“, “we” or “our“) respects the privacy of all users, and believe it is crucial that personal data which is disclosed to us be collected, processed, retained and secured in accordance with the applicable privacy laws. This Privacy Notice sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read this Privacy Notice carefully to understand our treatment and use of personal data. If you cannot agree to this, we recommend that you do not use the LIV Residential Platform.
- In this Privacy Notice, references to “you” means the person whose personal information we collect, use and process.
- We will use your personal data only for the purposes and in the manner set forth below, which describes the steps we take to ensure the processing of your personal data is in compliance with the Data Protection Acts 1988 and 2003 (as amended) and any subsequent data protection and privacy legislation, European Union Law including Regulation (EU) 2016/679, known as the General Data Protection Regulation or GDPR and any subsequent amendments (collectively referred to as “Data Protection Legislation”).
- We seek to maintain the privacy, accuracy, and confidentiality of data (including your personal data) that we collect and use concerning our users.
Identity of the controller of personal information
- For the purposes of Data Protection Legislation, the Data Controller is OCP Residential B.V (trading in Ireland as OCP Residential Ireland), a limited liability company and registered in Ireland (Registered Number 909323) and having its registered office address at 32 Leeson Street Lower, Dublin 2, Dublin, Ireland.
When does this privacy notice apply
- This Privacy Notice applies to personal information that we collect, use and otherwise process about you in connection with your relationship with us as a user or potential user.
Processing Of Your Personal Data
1. How and why do we process your personal data?
The personal data we collect from you or through our systems helps us manage our relationship with you, e.g. the provision of letting services, but also to comply with our legal obligations or for the conduct of our business. The personal data we collect, the basis of processing and the purposes of processing are detailed below. Sometimes, these activities are carried out by third parties (see “Sharing of Personal Data”section below).
| Personal data | Basis of processing | Purpose of processing |
| Personal data ( including first and last names, e mail address, telephone number, home address and an estimate of the joint income.) | It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. | We use the personal or other data disclosed by the user to provide letting services through the LIV Residential Platform. This may include the following services: a message service indicating the available rental homes which are consistent with the search profile stated by the user and a function to store rental homes. We may send you service messages, too. |
| Personal data ( including first and last names, e mail address, telephone number, home address and an estimate of the joint income.) | It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. | At the user’s request, personal data may be shared with property agents, which, using this information, may contact you. The property agent itself will be responsible for the personal data which it processes for its services. We will not be responsible for this, and advise users to look at the property agent’s privacy statement. This information can usually be found on the property agent’s website. |
| Personal data ( including first and last names, e mail address, telephone number, home address and an estimate of the joint income.) | It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. | We use personal data to display advertisements and send e mails. If the user has consented to this beforehand, we will use his/her e mail address to send electronic newsletters and other electronic messages about our products and services. The newsletter may contain messages from partners affiliated with us which are active in the property sector. |
| Personal data ( including first and last names, e mail address, telephone number, home address and an estimate of the joint income.) | It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. | If a user requests access to the LIV Residential Platform, the user may opt to link a Facebook account to the Platform. If the user does this, the user can also log in to the LIV Residential Platform through Facebook. We merely process data in this connection so that the user can log in to the LIV Residential Platform. Insofar as the user uses the Facebook platform for other activities, the user should refer to Facebook’s privacy policy (https://www.facebook.com/privacy/explanation) for information about these processing operations. |
| Personal data ( including first and last names, e mail address, telephone number, home address and an estimate of the joint income.) | It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. | Residential address data may also be used to generate traffic to the LIV Residential Platform. We have a legitimate interest in doing this, in order to provide the broadest possible information about available rental homes to people seeking homes. |
| Personal data ( including first and last names, e mail address, telephone number, home address and an estimate of the joint income.) | It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. | We may use the data from a user account and the data disclosed by the user on the LIV Residential-platform to construct a personal profile. With this profile, we can gear the content and advertisements on the Platform to the user’s interests, so the Platform will be more relevant to each individual user. You can unsubscribe at any time through privacy@livresidential.nl. |
| Personal data ( including first and last names, e mail address, telephone number, home address and an estimate of the joint income.) | It is necessary for the performance of our contract with you, or to take steps for entering into our contract with you. | The data from a user account and the data disclosed by the user on the LIV Residential Platform may be used by us for quality control and market research to improve our services. Finally, we place cookies on our website www.livresidential.nl. |
| Financial information (including bank and accounts details). | It is necessary for the performance of our contract with you, or to comply with legal obligations. | This is required to enable OCP to process your payment, to pay taxes and to comply with our legal obligations. |
2. Where does OCP obtain personal data from?
Most of the personal data we process is obtained directly by persons seeking rental homes, property agents or other interested parties through the use of the LIV Residential Platform (hereinafter: ‘user(s)’). Data is disclosed, for example, if an account is created with a search profile, a newsletter is registered for, a viewing is requested, necessary documents are uploaded or similar functions are utilised.
We may also collect and process your personal data when you visit our website. This may include traffic data, location data, weblogs and other communication data. Our systems record the IP address of the device through which you have visited our website. For more information on how we collect such personal data please see our Cookie Policy.
Sharing Of Personal Data
1. Disclosure to Processors
We furnish personal data to processors insofar as necessary to provide our letting services. In providing the services, your personal data will, where applicable, be processed by the processor on our behalf. These processors process the personal data in accordance with our instructions and under our responsibility.
We will check any processor that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your personal data. We will have written data processing agreements with them which provide assurances regarding the protections that they will give to your personal data and their compliance with our data security standards and international transfer restrictions.
2. Disclosure to Processors
We disclose personal data about people looking for rental homes to Hooke & MacDonald who act as our Letting Agent. We only do this if users have consented or instructed us to do so.
Transfers Outside The European Economic Area
- Your personal information may be transferred, stored and processed in one or more countries outside the European Economic Area (“EEA”), for example, when one of our service providers use employees or equipment based outside the EEA. For transfers of your personal data to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU commission’s model clauses.
- If you would like to see a copy of any relevant provisions, please contact the data protection officer (see “Contact Us” section below).
How Is My Personal Data Secured
- We operate and use appropriate technical and physical security measures to protect your personal data.
- We have in particular taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access, in connection with the customer relationship. Access is only granted on a need-to-know basis to those people whose roles require them to process your personal data. In addition, our service providers are also selected carefully and required to use appropriate protective measures.
Storage Of Personal Data
- We will keep your personal data for as long as it is necessary to fulfil the purposes for which it was collected as described above and in accordance with our legal and regulatory obligations. This may mean that some information is held for longer than other information.
Your Rights
- You may have various rights under data protection legislation in your country (where applicable).
These may include (as relevant):
| Your right | What does it mean? | How do I execute this right? | Conditions to exercise? |
| Right of access | Subject to certain conditions, you are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”). | Requests for such information should be made in writing to privacy@hookemacdonald.ie. If possible, you should specify the type of information you would like to see to ensure that our disclosure is meeting your expectations. | We must be able to verify your identity. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other users. Data solely retained for data backup purposes is principally excluded. |
| Right of data portability | Subject to certain conditions, you are entitled to receive the data which you have provided to us and which is processed by us by automated means, in a commonly-used machine readable format. | Requests should be made in writing to privacy@hookemacdonald.ie. If possible, you should specify the type of information you would like to receive to ensure that our disclosure is meeting your expectations. | The GDPR does not establish a general right to data portability. This right only applies if the processing is based on your consent or on our contract with you and when the processing is carried out by automated means (e.g. not for paper records). It affects only personal data that was “provided” by you. Hence, it does, as a rule, not apply to personal data that was created by OCP. |
| Rights in relation to inaccurate personal or incomplete data | You may challenge the accuracy or completeness of personal data which we process about you. If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate. | We encourage you to notify us of any changes regarding your personal data as soon as they occur, including changes to your contact details, telephone number, immigration status. Please always check first whether self-help tools are available. If no such tools are available, requests should be made in writing to privacy@hookemacdonald.ie. | This right only applies to your own personal data. When exercising this right, please be as specific as possible. |
| Right to object to or restrict our data processing | Subject to certain conditions, you have the right to object to or ask us to restrict the processing of your personal data. | Requests should be made in writing to privacy@hookemacdonald.ie. | This right applies only if the processing of your personal data is explicitly based on our so-called “legitimate interests” (see “basis of processing” above). Objections must be based on grounds relating to your particular situation. They must not be generic so that we can demonstrate that there are still lawful grounds for us to process your personal data. |
| Right to have personal data erased | Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”), e.g. where you think that the information we are processing is inaccurate, or the processing is unlawful. | Requests should be made in writing to privacy@hookemacdonald.ie. | There are various lawful reasons why we may not be in a position to erase your personal data. This may apply (i) where we have to comply with a legal obligation, (ii) in case of exercising or defending legal claims, or (iii) where retention periods apply by law or our statutes. |
| Right to withdrawal | You have the right to withdraw your consent to any processing for which you have previously given that consent. | Requests should be made in writing to privacy@hookemacdonald.ie. | If you withdraw your consent, this will only take effect for the future. |
Your Right To Lodge A Complaint With A Supervisory Authority
You have the right to make a complaint with the Data Protection Authority, in particular in the Member State of your residence, place of work or place of an alleged infringement, if you consider that the processing of your personal data infringes the GDPR. The Irish personal Data Protection Authority contact details are:
Data Protection Commission
Telephone: +353 (0)761 104 800 (10:00 – 12:00hrs Monday – Friday) or +353 (0)578 684 800 (14:00 – 16:00hrs Monday – Friday)
E-mail: info@dataprotection.ie
For further information please visit www.dataprotection.ie
Changes to this information
- We reserve the right to change this Privacy Notice at any time in our sole discretion. If we make changes, we will post an updated version of it on the website. We therefore recommend that you visit the website regularly, so that you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our services after we post any such changes, you accept and agree to this Privacy Notice as modified.
Questions and complaints
- For further information or if you have any questions or queries about this Privacy Notice, please contact OCP.
Email: privacy@hookemacdonald.ie.
Address: 32 Leeson Street Lower, Dublin 2, Dublin, Ireland.
Last Updated: 13 May 2021