Knight Frank Group Privacy Statement

Information covered by this Statement

This Privacy Statement applies to the use and processing of Personal Information collected and used by HT Meagher O’Reilly Limited and HT Meagher O’Reilly New Homes Limited trading as Knight Frank (Knight Frank) in Ireland through your use of our site www.knightfrank.ie.  For information concerning the collection, use or processing of Personal Information by any other entities within the Knight Frank Group or any of our affiliates, business partners or suppliers (whether or not trading under the name “Knight Frank”) please contact the relevant office directly (Knight Frank Offices). By using the Knight Frank website or otherwise providing your Personal Information to Knight Frank, you agree to the collection, use and sharing of your information in accordance with this Privacy Statement. Please read this Privacy Statement carefully and contact us if you have any questions. Personal Information is information, or any combination of separate pieces of information, that could be used to identify you. Should you have any queries in respect of this Statement or our use of Personal Information, please contact Knight Frank Data Protection Officer at [email protected]

Information Knight Frank collects from You and Why

We may collect information about you from a variety of sources. This includes information we collect directly from you when you choose to engage in our services, call or email us or otherwise provide information directly to us and participate in our offers and programs; and information we collect when you visit our sites, view our online content or use our other services; and information we collect about you from other sources including information from publicly available sources such as Companies Registration Office and the Electoral Register.

Why do we collect your data?

All data that we collect and hold about you as an individual (your “Personal Data”), which might include your name, address, email and telephone number, is held and processed by us in accordance with the law and in accordance with our Privacy Statement. This means that Knight Frank will only ever use your Personal Data for the purposes for which it is collected and only keep it for as long as necessary to fulfil those purposes (unless legally obliged to keep it for longer). Since you are interested in buying, selling or renting property, we will only use your Personal Data in order to help you sell, let or find your desired property (unless you tell us otherwise). We will also ask for your consent to send you marketing information and inform you about our other services.

Information we collect directly from you

We collect information directly from you when you choose to participate in our offers and programs, create an account on our websites or call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:

• Name
• Email address
• Postal address
• Username and password
• Telephone and/or mobile number
• Date of birth
• Demographic information
• Payment information (such as a credit card) and bank account details
• Where necessary information relating to your financial means, such as documentary proof of funds.
• Information required to complete anti-money laundering and identity check legal obligations.
• Your previous landlord reference and current work reference to protect the Landlord’s own financial or property interests.
• Photo identification
• PPS Number for registration
• CCTV data
• Future communication preferences
• Telephone number and recordings when you call our customer service line

If we are providing a service to you

Where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).

Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information.

If you are selling or buying a property through us:

• We will collect a contact telephone number to get in touch with you about organising viewings and updating you on any offers received for your property.
• Where you are not the legal owner of the property we will request details from you as to your ability to sell the property such as a Power of Attorney or Grant of Probate
• If you wish to purchase a property we are listing for sale where you have specifically provided us with these:
  • We will collect personal information relating to any specific requirements you may have in relation to a property so that we can find a property that is suitable for your needs.
  • We will also collect personal information required to source a property for you and, where required, negotiate the purchase of a property on your behalf.

Property Management

• Where we engage with you to manage property on your behalf we will ask for additional emergency contact information in case we need to get in touch with you outside of working hours or in the event there is a matter requiring your urgent attention.
• Where you are a tenant in a building managed by Knight Frank, we may need to share your personal information with the property owner.

Investment Management

Where you engage with us as an individual investor we will collect information required to identify you to meet anti-money laundering and counter terrorist financing requirements. If the investor is an entity such as a company, trust or charity, we may need to collect personal information about the controllers and the beneficiaries of the entity.

Other

If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details about the sector in which you work and the type of content that you would like to receive.

Information we collect when you visit our sites, view our online ads or promotions, or other services

We use cookies and other technologies to collect information when you visit our sites, view our online advertisements or promotions, or use our other services. The following are examples of information we may collect with these technologies:

• Information about your device browser and operating system
• IP address
• Web pages you view
• Links you click
• Knight Frank emails you open

Information collected through Mobile Applications

When you download our mobile applications to your mobile device, we may also collect information that you provide. We also automatically collect information through our applications. The following are examples of the types of information we may automatically collect through our applications:

• Marketing ID or similar identifier
• Information about your devices’ operating system
• Information about the way you use the application

Your Choices about information collection through Mobile Applications

You can opt out of continued information collection by our mobile application by deleting the application from your device.

Precise Location Data

Our mobile applications may collect precise location information from your device if you consent to the collection of this information. We may use third-party service providers to provide location services using the location data you provide. You may opt out at any time to the continued collection of this information by adjusting the settings on your device.

Information Knight Frank collects from other sources

We may obtain information about you from other sources, including publicly available sources, such as the Land Registry, social media platforms or referral agents, etc. Examples of information we may collect from other sources are:

• Name
• Postal address
• Email address
• Publicly observed activities or information made available by you to the public, such as blogs, videos, internet postings, and user generated content

How Knight Frank uses this information

We use the information we collect to provide you with products, offers and services, to deliver to you advertisements, offers or other content tailored to your interests, and to conduct other Knight Frank business operations. The following are examples of how we may use the information we collect:

• Answer your questions or respond to your requests
• Develop new products and services
• Enrol you in contests, programs, or offers that you request
• Create and manage your account
• Process payment for purchases or other services
• Protect against or identify possible fraudulent transactions
• Send you email and/or postal messages with information about Knight Frank brands and other content we think may be of interest to you
• Telephone you about Knight Frank’s brands and other content we think may be of interest to you
• Develop and provide Marketing tailored to your interests, including interest-based marketing
• Personalise your experience on our websites by presenting products and information tailored to you
• Allow you to participate in social sharing on our websites
• Analyse the use of, and develop, our products, services and marketing. Enforce our terms and conditions and otherwise manage our business

Knight Frank will only process your information in pursuance of our legitimate interest if we receive any requests related to, for example, a product or service, a call-back, or specific marketing materials; we will use your Personal Information to fulfil your request. Where we need to manage your account and protect you against or identify possible fraudulent transactions, we will do so in accordance with our legal obligation placed on us under law. We will seek consent from you if we need to process your data for solely identified purposes. To ensure meaningful consent is obtained from you, Knight Frank will provide you with reasonable notice ensuring that your consent is provided on an informed basis.

Buying, Selling, Letting, Renting

• We use your personal information for the purposes of fulfilling our obligations to you to buy, sell, let or rent your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.
• If you are purchasing a property where we are acting as agents for the sale of or selling a property through us, we will share your personal information with your appointed solicitors and the solicitors acting for the other side of the deal as is necessary to facilitate the sale or purchase. We may share your details with the builder as well, to arrange access for final finishes to your newly acquired property.
• Where you have enquired about buying, letting or selling a specific property, we will use your contact details to respond which may include us sending you alternative properties to help with your search.

Property Management

Where we are managing property on your behalf we may need to pass your personal information from time to time on to third party contractors whom we have engaged to carry out maintenance on your properties (i.e. contact details to organise access for maintenance checks)

Investment

Where you engage us for portfolio management services we will share your personal information with third party lenders as is necessary to allow us to fulfil our obligations to you, to raise finance for you and to properly manage and advise you on your property investments.

Other uses of your personal information

• We will share personal information as may be required from time to time in order to comply with our regulatory and legal obligations.
• Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
• We may share your personal information with any person working within the Knight Frank Group on a need to know basis to ensure we are able to perform our obligations to you.
• We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by Knight Frank to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.

What happens if you do not provide the information we request

We need some of your personal information to perform the services you have requested from us. For example:

• Where we are selling a property on your behalf we need to know your contact information so that we can update you with information on viewings, offers and the progress of the sale; or
• Where you have asked us to find you a property which meets certain access requirements, we may need to know some further details about your particular circumstances so that we can find you a suitable property.

We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering. If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.

Information sharing

The success of our business depends on your trust, and we do not sell your Personal Information to marketers outside of Knight Frank. We share your Personal Information within the Knight Frank Group and as described in this Statement. We do not share Personal Information with marketers outside of Knight Frank unless you consent to such sharing, or as described within this Statement.

Co-promotions with carefully selected business partners

We from time to time may collect personal and other information for a co-promotion or joint program with a business partner and share your information with that business partner. For these programs we will make clear at the point of collection that the information will be shared with Knight Frank and the participating business partner and ask for your consent as required by applicable laws.

Third-party service providers

We engage third-party service providers to perform a variety of business operations on our behalf. In so doing, we may share your Personal Information with them. We provide our service providers with only the Personal Information they need in order to perform the services we request, and we contractually require that they protect this information appropriately and not use it for any other purpose.

For example, we may rely on a 3rd party service provider to:

• Fulfil your service requests and answer your questions.
• Professional advisors including solicitors, bankers, auditors and insurers.
• Host our sites and deliver our email or other communications.
• Contact contest winners, manage payments or take other actions on our behalf.
• Analyse our data, sometimes combined with data from other sources, to send you communications.
• Conduct research and analyse data to improve our products, services and sites.
• Perform other services that we request.

Where permitted by law, we combine Personal Information about you that Knight Frank has collected with Personal Information about you that a business partner has collected so we can jointly send tailored promotional communications to you. In such instances, our business partner will not be permitted to use Knight Frank data or the combined data for its own, independent marketing purposes. Our service provider will only be allowed to use the combined set of information to send you joint communications that we hope will be of interest to you. If you prefer not to receive these joint communications, you can always opt out by following the instructions provided in any such communication or through this Privacy Statement as indicated above.

Other situations.

We may transfer or otherwise process your Personal Information:

• As part of the sale of a Knight Frank brand to another company.
• When we have received your instruction to pass the sale of your property to another agent
• To protect, defend or exercise the rights and property of Knight Frank (including enforcing our Terms and Conditions).
• When required by law and/or government authorities.

You and your information

To the extent provided for by applicable law, you have certain rights in respect of the management of the personal data we hold about you.

Right to access

We take steps to keep your personal information accurate. To access or update your personal information please contact [email protected]. Knight Frank does not charge for this service and responds to reasonable requests in an appropriate timeframe.

This will erase any personal information in your account that we have about you. It will also mean any data about how you’ve used the online account will be made anonymous.

Right to transparency

You have the right to be informed; Any processing of personal data should be lawful, fair, and transparent.

Right to rectification

You can request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate

Right to be forgotten

Clients may request that any information held on them is deleted or removed if there are no legitimate reason for Knight Frank to keep it. Any third parties who process or use that data will comply with the request. Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies.

You can delete your Knight Frank online account at any time. Email your data deletion request to [email protected]. This will erase any personal information in your account that we have about you. And it will mean any data about how you’ve used the online account will be made anonymous. Deleting your online account won’t delete any data you’ve shared with Knight Frank for reasons that aren’t connected with your online account. If you wish us to erase your data which is unconnected with your online account, please contact us as described below and we will deal with your request as necessary under applicable law

Right to Data Portability

You may request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information.

Automated processing

You have the right to not be subject to a decision based solely on automated processing. Processing is “automated” where it is carried out without human intervention and where it produces legal effects or significantly affects you.

Right to opt-out

Knight Frank will inform individuals that information is being collected and used for these purposes prior to doing so. Individuals have the right to opt-out of any specific type of data processing. We will cease processing the information unless we have a legitimate business interest that prevents this.

Right to restrict processing

You may ask us to restrict our information processing activities where you consider that:

• your personal information is inaccurate.
• our processing of your personal information is unlawful.
• where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim.
• where you have raised an objection to our use of your personal information.

Consent

Where you have provided consent for our processing of your personal data, you may withdraw that consent at any time by contacting us at [email protected]. We will cease processing your personal data as soon as reasonably practicable following our receipt of your withdrawal. Please note that we will keep a record of the fact that you have made a request to exercise your rights, and our response to your request, in order to demonstrate compliance with our data protection obligations and so that we can handle any queries, complaints or claims in relation to your request. This record will be kept in accordance with our retention policies.

Personal Information Retention Period

We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim. Be aware that if you invite us to value your property or if you should view, offer or purchase through us we are legally required to retain a record of this for a minimum of 6 years after the property transaction completes.

Aggregated and non-Personal Information.

We share aggregated and/or anonymous information that does not identify you for Knight Frank business purposes. For example, we may disclose the number of visitors to Knight Frank sites or services. We may also share aggregated and/or anonymous information with our business partners for their own business purposes.

Your communication options

We give you choices about how we communicate with you.

Email Communications

You can stop receiving promotional email messages from Knight Frank by following the opt-out instructions provided in any such message you receive. You may also contact directly at [email protected].

Postal Mail

You can stop receiving promotional postal mail from Knight Frank by following the opt-out instructions that may be included within those communications. You may also contact us directly at [email protected].

Mobile Text Messages

We only send you promotional mobile text messages if you explicitly ask to receive these (you opt in). You can stop receiving promotional text messages by following the instructions to opt out provided within that text messaging program.

Telephone Marketing

We only call you if you explicitly ask us to (you opt in). You can stop receiving telephone marketing calls by either telling us when we call you, or you can call us at +353(0)1 634 2466 or email [email protected].

PLEASE NOTE: We will honour your request to stop receiving promotional email, text and postal messages from Knight Frank as practicable. However, we may continue to send you service-related communications. We may keep information for record keeping to ensure we fulfil your request not to send particular types of messages.

Complaints

If you consider that we have processed personal data in violation of applicable law, please contact us at [email protected]. or +353(0)1 634 2466. If you consider that we have processed personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the Data Protection Commissioner.

Cookies and other technologies

Knight Frank and our third-party service providers use a variety of technologies to assess how our sites or mobile applications are used, to personalize your experience and to deliver you marketing, including online content, tailored to your interests. Some technologies we may use include the following:

Cookies

A cookie is a small file placed on your device when you visit a site that can be understood by the site that issued the cookie. We use the information collected by cookies to remember who you are to log you in and your preferences, to provide you advertisements, offers or other content tailored to your interests and to assess how our sites are used. You can accept or decline cookies through your browser settings. To learn more, please look at the cookie settings available in your specific web browser(s). Please note, however, that without cookies you may not be able to use all of the features of our Sites or other websites and online services. Please click here for a list of all Knight Frank Cookies.

Other technologies

In conjunction with gathering information through cookies, web beacons and Javascript, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. We also may record information such as the address of the web page that referred you to our Sites and the IP address of the device you use to connect to our Sites. We may log information about your interaction with the Sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with our Sites.

We may use third-party web analytics services on our Sites, such as those of Google Analytics. These service providers help us analyse how visitors use the Sites. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers.

The providers of third-party plug-ins and widgets on our Sites, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Sites and your interactions with the plug-ins and widgets. We may also receive information you have made available to those third party services, including the geographic location of your mobile device and other information about you (such as name, email address, gender, locale, time zone, languages, social media profile URL, personal website URL, biographical information, birthday, photo, list of devices, education history, work history, hometown, interests, current city, political views, favourite athlete and teams, relationship status and information, religion, name of significant other, and certain security settings information) and your contacts on those services. This information is subject to the privacy policies or notices of the third party providers of the plug-ins and widgets.

Interest-based marketing

You may receive interest-based marketing, offers or other content as you interact with websites or mobile applications. Interest-based Marketing is online Marketing from Knight Frank brands and/or from our carefully selected business partners that is tailored to your interests and sent to your device using a cookie or other identifier assigned to your device. These cookies or other identifiers are placed in general interest categories that we infer from information such as:

• The web pages you view and links you click on Knight Frank websites and other websites you visit.
• Mobile applications you use.
• The Knight Frank brand emails you view and links you click in the email.
• Demographic data.
• Offline and online purchase data.

We have designed our interest-based marketing systems to deliver such ads to you based only on data that does not personally identify you.

We respect your privacy

You can limit your receipt of interest-based marketing on Knight Frank websites or in our mobile applications by different means.

Your choices regarding receipt of interest-based Marketing on websites

You can visit the Preference Centre where you can choose to opt out from receiving interest-based marketing. Knight Frank will honour that choice.

Your choices regarding receipt of interest-based Marketing in mobile applications

Some newer mobile device operating systems allow you to limit the use of information to deliver interest-based marketing in mobile applications. You can check the settings on your device for such options in your devices’ operating system.

Links to Third Party Sites and Social Media

Knight Frank sites may include links to third-party sites. Knight Frank does not control these third-party sites, and we encourage you to read the Privacy Statement of every site you visit.

Social Networks and Third-Party Plug-ins

Our websites may include plugins from social networks or other third parties. An example of a plugin is the Facebook “Like” button. Where legally permitted, these plugins may communicate with and send information to the party that provided the plugin, even if you do not click on the plugin. This information may include your IP address, information about your browser and device, and the address of the web page you are visiting on our site. Loading, using or clicking the plugins may also place, read and transmit cookies. These cookies may contain a unique identifier the social network or third-party assigns to you. The loading, functionality and your use of the plugins are governed by the Privacy Statement and terms of the party that provided the plugin.

User Generated Content

Please remember that any information you submit or post as user-generated content to Social Media sites become public information. You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts. Knight Frank cannot prevent others from using such information in a manner that may violate this Privacy Statement, the law, or your personal privacy and safety. Knight Frank is not responsible for the results of such postings.

Information Security

Knight Frank is committed to keeping Personal Information secure. We have implemented technical, administrative and physical procedures designed to protect Personal Information from loss, misuse or alteration. We limit access to Personal Information to those who have a business need. We keep Personal Information only for so long as deemed reasonably necessary.

Data Transfers

We may transfer the Personal Information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred Personal Information in accordance with this Privacy Statement. We have implemented a General Data Transfer Agreement (GDTA) procedures and controls to help ensure that Personal Information is protected no matter what country it is stored in or transferred to.

Children’s privacy

Our Site is not directed to children under the age of thirteen and we do not knowingly collect Personal Information from children under the age of thirteen on our Site.

Links to other websites and apps

Our Sites may provide links to other websites and apps for your convenience and information. These websites and apps may operate independently from us. Linked sites and apps may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.

Updates to our Privacy Statement

We will post changes to this Privacy Statement and indicate the effective date when this Privacy Statement is updated. If we make any material changes to this Privacy Statement, we may notify you by e-mail, and by posting notice of the changes on this site.

For further information concerning what Personal Data we hold about you, how you can access it and our use of Personal Data generally, please email our Data Protection Officer at [email protected].