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    IRES Fund Management Limited Privacy Statement

    Updated & effective as of 17 April 2017

    Who are we?

    1. We are IRES Fund Management Limited, a company incorporated under the laws of Ireland under company number 539306 with our registered office at Unit 4B Lazer Lane, Grand Canal Square, Dublin 2, Ireland (“we” “our” or “us”).

    What do we do?

    IRES
    1. We are the investment & property manager of Irish Residential Properties REIT plc (“IRES REIT”), a company incorporated under the laws of Ireland under company number 529737 and also provide services to IRES REIT’s subsidiary IRES Residential Properties Limited (“IRES Residential Properties”), a company incorporated under the laws of Ireland under company number 552768.

    2. This means that if you are a customer of IRES REIT or IRES Residential Properties, including a tenant or prospective tenant, your day to day dealings with IRES REIT and IRES Residential Properties, as applicable, take place through us.

    3. References in this Privacy Statement to “IRES” mean either IRES REIT or IRES Residential Properties Limited with whom you have a relationship. For instance, if you applied to rent, or rented, an apartment from IRES REIT, references to IRES mean IRES REIT.

    4. We and IRES are joint data controllers, each independently responsible for protecting your data if you are an IRES customer, such as a tenant or prospective tenant. Accordingly, you can exercise your data protection rights against either us or IRES, with respect to the personal data we process as a part of the services which we provide to IRES, as jointly responsible data controllers. To access the IRES Privacy Statement, please go to www.iresreit.ie.

    Owner management companies

    5. We also provide property management services to certain owners’ management companies (“OMCs”) located in Ireland. This means that if you are a member of any OMC we manage, your day to day dealings with the OMC may take place through us. OMCs are data controllers in respect of your personal information and you can exercise your data protection rights against the OMC. We handle your personal information as the data processor of the OMC. Inquire with your OMC for more information about its privacy practices.

    We know your privacy is important to you.

    1. By submitting your personal data, you agree to this privacy statement including with respect to the transfer, storing or other processing of your data.

    2. This Privacy Statement explains how we process information, particularly personal data, that we receive or collect from or about you. Please read the following carefully to understand our approach and practices regarding your personal data and other information and how we treat it.

    3. This Privacy Statement will apply in respect of all such information, whether we are sole or joint data controller. When we refer to our “services” in this policy, this includes the rental of properties from IRES and other services provided by IRES.

    4. We are a data controller for the purpose of the Irish Data Protection Acts 1988 and 2003.

    5. We are jointly responsible with IRES for personal data that we process on behalf of IRES, in particular personal data of its customers, including tenants and prospective tenants of IRES.

    6. We are also a separate independent data controller with respect to any personal data we collect on our own behalf, such as with respect to all the companies that we engage to provide services to us or with respect to our employees.

    What information do we collect about you?

    1. Depending on the particular circumstances, we may collect and process a range of different information about you. This can include your name, gender, age, date of birth, address, phone number, email address, mobile phone number, family status, occupation, income, driver’s licence number, PPSN number (personal public service number), financial information (such as bank account details) and information about the properties you rent from IRES etc.. This list is not exhaustive and we may sometimes need to collect additional information, for example, as part of our authentication process when you want to speak to one of our customer service personnel.

    2. Some or all of the information that we collect or otherwise process may be considered “personal data” under the Irish Data Protection Acts 1988 and 2003. If such information is “personal data”, then every reference in this Privacy Statement to “information” shall also include “personal data”.

    How do we collect your information?

    1. We may collect and process information about you in a number of ways, including:

    1. directly from you, such as where you provide information to us in relation to a lease application or approval, completing a lease agreement for one of IRES’ properties or contacting us with a request or query;
    2. when you visit www.iresfund.ie, which information includes traffic data, location data, weblogs and other communication data and any resources you may access (please also refer to our Cookies Policy at www.iresfund.ie);
    3. from third parties, such as our related companies (including CAPREIT Limited Partnership), co-tenants, guarantors, business partners, or your nominated representatives;
    4. from our records or those provided by IRES regarding the properties you rent from IRES, or how you use IRES properties and or services;
    5. from publicly available sources of information; and
    6. when legally authorised to do so, for example, when we need to verify identity before disclosing information or registering tenancy with the RTB.

    2. If you choose not to provide certain information to us, IRES may not process your rental application or be able to provide you with the products or services you require and it may impact our ability to respond to your needs.

    What do we use your information for?

    1. We use your information for a range of different purposes, including:

    1. determining your suitability to rent an apartment from IRES (including background and credit-worthiness checks such as searching tenancy information databases, contacting landlord referees or verifying employment income in order to verify the information we or IRES receive about you in connection with your tenancy application), and to rent properties to you;
    2. to administer and manage the properties and services that IRES, or we, provide to you (which may include further processing of your information following the end of your relationship with IRES such as, for instance, for the purposes of returning a security deposit to you), to charge you for them, and to process payment and collect any amounts you may owe IRES;
    3. to provide you with information that you request from us or IRES about IRES’, or our, properties and services (and, where you have agreed to us doing so, that we feel may interest you), to assist you with enquiries, and to provide you with better customer service;
    4. to notify you about new properties and changes to IRES’, or our, properties and services which you acquire from IRES or which you otherwise subscribe to;
    5. to verify your identity, or to conduct appropriate checks for credit-worthiness and for fraud checking;
    6. to further enhance and improve the quality of the products and services which IRES, or we, offer, and to conduct research and analysis and better understand the profile of IRES tenants – we endeavour to ensure that we de-personalise any personal data before using such data for research, analysis and/or development purposes; or
    7. as authorised or required by any law applicable to us or IRES (such as reporting to the Private Residential Tenancies Board) or arising from your interaction with us or IRES or otherwise so we can comply with legal obligations applicable to us or IRES.

    For example, when you provide us with your personal data in connection with a lease with IRES, you consent to us collecting, utilising and disclosing your personal data in a manner necessary to determine your suitability for, and administer and enforce, your lease.

    How do we share your information?

    1. The information we collect from you may be disclosed or transferred in connection with operating our business, including, as applicable, to our related companies (including CAPREIT Limited Partnership), IRES REIT and its subsidiaries and certain OMCs. It may also be processed by these companies and/or by our and their respective employees and service providers. By submitting personal data, you agree to this transfer, storing or processing of your personal data by us. In addition, we may disclose your information to the following third parties:

    1. co-tenants (including when responding to a data subject access request by your co-tenant), guarantors or referees;
    2. our or IRES’ professional advisers, in order for them to provide us with advice and assistance;
    3. service providers, such as providers of information technology services, utility companies (such as where you ask us or IRES to open an account with a utility for you or in connection with the closure of the account or any outstanding payments), financing companies, lenders, credit reporting agencies, payment processors, debt recovery agencies or other suppliers, where necessary for them to provide us with services or to provide services that you have requested;
    4. business partners of IRES and/or possible acquirers or investors (or their advisors) in the context of a facilitating or implementing a business re-organisation or a transfer/sale of all or part of IRES’ assets or business or general investments – for instance, disclosure to IRES’ investors or potential investors may include aggregated information regarding the profile of particular properties, such as ratios of average tenants’ earnings against rent and other aggregate demographic information relevant to the profile of a property investment; and
    5. our regulators, the regulators of our related companies, and the regulators of IRES, or othergovernmental agencies with authority to obtain the information.

    2. We may provide information to a third party when we believe in good faith that we are required to do so for legal reasons; to protect the security of our website and related technologies; to prevent and minimise the effects of fraud; that this is necessary to prevent harm or injury to us, our staff, or members of the public or; or otherwise to protect our legitimate interests and our or IRES’ legal rights or the interests of our respective customers.

    Where do we store your information?

    1. We may store your information in hard copy or electronic format, in storage facilities which we own and operate ourselves, or that are owned and operated by our service providers. Some of the information about you that we hold may be transferred to outside the European Economic Area (EEA). We put in place appropriate measures to protect your data when transferring data to companies outside the EEA and any such transfers of personal data are undertaken in accordance with the requirements of the Data Protection Acts 1988 and 2003. These third countries may not provide the same level of protection as within the EEA (for example, your right to have your data deleted when it is no longer required). For instance, your information may be accessed or otherwise processed by non-EEA national security or law enforcement agencies without you being afforded rights of redress similar to those within the EEA.

    2. By submitting your personal data, you agree to this transfer, storing or other processing.

    For how long do we retain your personal data?

    We retain your personal data for so long as is reasonably necessary with regard to the purposes for which it was collected or lawfully further processed, or for so long as may be reasonably necessary in light of our legal obligations.

    How do we keep your information safe and accurate?

    1. We will take appropriate steps to ensure that your information is treated securely and in accordance with this Privacy Statement. We seek to ensure that we keep your personal data accurate and up to date. However, you are responsible for informing us of any changes to your personal data and other information (such as a change in contact details).

    2. While we take these steps to maintain the security of your information, the nature of the internet is such that we cannot guarantee the security of the information you transmit to us electronically, and any transmission is at your own risk. We store information you provide to us on secure servers and deploy appropriate technical and organisational security measures in the storage and disclosure of your personal data to try to prevent unauthorised access or loss.

    What are your rights?

    1. You have rights under the Irish Data Protection Acts 1988 and 2003. You have the right to ask us not to process your personal data for marketing purposes. You also have the right to access information held about you, and to request that we update, correct or delete any inaccuracies in your personal data. You may also request that we cease processing that is causing you harm. Your rights can be exercised in accordance with the Data Protection Acts 1988 and 2003. Any data subject access request may be subject to a statutory fee to meet our costs in providing you with details of the information we hold about you.

    2. With respect to your rights regarding any information for which we and IRES are jointly responsible as joint data controllers, you may contact either of us if you wish to exercise any of these rights.

    3. If you want to exercise your data protection rights with respect to any information held about you by an OMC or by us on behalf of an OMC, you should contact your OMC. Inquire with your OMC for more information in this regard.

    Definitions

    Any terms not defined in this Privacy Statement have the meanings given to such terms in the Data Protection Acts 1988 and 2003.

    Changes to our Privacy Statement

    From time to time, we may need to change this Privacy Statement. If we do so, we will publicly post an updated version of our Privacy Statement on this page and it will apply to all of your information held by us at the time. Although we are not required to notify you personally of changes, in some instances we may choose to do so (via email or other method) or by posting a notification on our website.

    Customer Service

    Please continue to place emergency calls, work orders and requests through your normal channels such as the site management office. But, should you feel a need to escalate your concerns, please contact the property manager IRES Fund Management Limited at Customerservice@iresfund.ie

    Contacting us

    If you have any questions, comments and requests regarding this Privacy Statement or our management of your information and you should address all correspondence to the Privacy Officer, IRES Fund Management Limited, Unit 4B Lazer Lane, Grand Canal Square, Dublin 2, Ireland or privacy@iresfund.ie. With respect to information that IRES and we are joint data controllers, you should contact either of us if you have any questions, comments or requests in relation to such information.









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