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Privacy Policy

Last updated: 18 January 2022

PLEASE READ THIS POLICY CAREFULLY BEFORE USING RENTDODO’S SERVICES
1. INTRODUCTION

Protecting your data, privacy and personal data is very important to Subbacultcha Limited (trading as RentDodo) (“RentDodo”, “us”, “our” or “we”). It is vitally important to us that our customers feel secure when using our services (the “Services”).

This Privacy Policy (the “Policy”), sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by RentDodo. Please read this Policy carefully to understand the types of data we collect from you, how we use that data, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.

When visiting RentDodo’s website (our “Website”) and using any of the Services offered via the Website, you will be asked to indicate your acknowledgment of, and where applicable your consent to, the practices described in this Policy.

Our Website contains links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.

2. DATA WE MAY COLLECT

Data that you provide to us.

You will be asked to provide us with your data when you:

fill in forms on our Website, or correspond with us by phone, email or otherwise;

register to use our Services, subscribe to our newsletter, promotional emails or other marketing materials;

use the Services;

report a problem with our Services; or

complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).

Data we collect about you.

The data you will be asked to provide to us for these purposes will include your name, address, date of birth, e-mail address, phone number, Personal Public Service (“PPS”) number, copy of pay slips, references from employers, copy of bank statements, references from landlords, copy of government issued photo identification, profile image, deposit payment details and rent payment details, or further data required to verify your identity. With regard to each of your visits to our Website we may automatically collect your IP address.

3. JUSTIFICATION OF USE OF YOUR DATA

Use of personal data under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your data:

Consent: where you have consented to our use of your data (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);

Contract performance: where your data is necessary to enter into or perform our contract with you;

Legal obligation: where we need to use your data to comply with our legal obligations;

Legitimate interests: where we use your data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and

Legal claims: where your data is necessary for us to defend, prosecute or make a claim against you or a third party.

4. HOW WE USE YOUR DATA - APPLICABLE TO ALL USERS

Type of data collected: Name, date of birth, email address, phone number.

Use of data: To provide you with access to our Website and to use our Services.

Justification: Contract performance.

Type of data collected: Name, email address.

Use of data: For customer service emails and surveys that are important to the proper functioning of our Website and its Services.

Justification: Contract performance.

Type of data collected: Name, email address.

Use of data: For marketing products and services that we believe will be of interest to you.

Justification: Consent (for marketing unrelated products or services or products or services of third parties).

Type of data collected: Email address, phone number.

Use of data: To notify you about changes to our Services.

Justification: Consent (to update our Services from time to time).

5. HOW WE USE YOUR DATA - APPLICABLE TO TENANTS

Type of data collected: Name, date of birth, email address, phone number, current address.

Use of data: To provide you with access to our Website and to use our Services.

Justification: Contract performance.

Type of data collected: data from linked accounts such as social networking sites.

Use of data: To administer our Services and identify more appropriate products and services that we may be of interest to you.

Justification: Consent.

Type of data collected: Identity confirmation, Personal Public Service number, date of birth, current address, pay slips, bank statements, employer reference, landlord reference.

Use of data: To provide you with the Services, specifically our Verified Status (which is your digital identity which you can share with Landlords).

Justification: Contract performance (to the extent required to provide the Services e.g. identity verification as required by Landlords / Agents before a tenancy agreement between Agent / Landlord and Tenant can be executed).

Type of data collected: Name, email address.

Use of data: For marketing products and services that we believe will be of interest to you.

Justification: Consent (for marketing unrelated products or services or products or services of third parties).

Type of data collected: Name, email address, payment details and bank account information.

Use of data: To administer our Services including deposit and rent payment processing services.

Justification: Contract performance (in respect of payment processing).

Type of data collected: Email address.

Use of data: To notify you about changes to our Services.

Justification: Consent (to update our Services from time to time).

6. HOW WE USE YOUR DATA - APPLICABLE TO LANDLORD

Type of data collected: Name, date of birth, email address, phone number and current address.

Use of data: To provide you with access to our Website and to use our Services.

Justification: Contract performance.

Type of data collected: Name, email address.

Use of data: For marketing products and services that we believe will be of interest to you.

Justification: Consent (for marketing our own similar products and services and any re-engagement campaigns).

Type of data collected: Identity confirmation, Personal Public Service number, date of birth, current address, Property Services Registration Authority registration data.

Use of data: To provide you with the Services, specifically our Verified Status (which is your digital identity which you can share with Tenants).

Justification: Contract performance (to the extent required to provide the Services e.g. identity verification as required by Tenants before a tenancy agreement between Agent / Landlord and Tenant can be executed).

Type of data collected: Name, email address, bank account information.

Use of data: To administer our Services including deposit and rent payment processing services.

Justification: Contract performance (in respect of payment processing).

Type of data collected: Residential Tenancies Board registration data.

Use of data: To administer our Services including listing the property on our Website and entering tenancy agreements with Tenants.

Justification: Contract performance; consent.

Type of data collected: Email address.

Use of data: To notify you about changes to our Services.

Justification: Consent (for marketing our own similar products and services and any re-engagement campaigns).

Type of data collected: Email address.

Use of data: To notify you about changes to our Services.

Justification: Consent (to update our Services from time to time).

7. HOW WE USE YOUR DATA - APPLICABLE TO LETTING AGENTS

Type of data collected: Name, date of birth, email address, phone number, current address.

Use of data: To provide you with access to our Website and to use our Services.

Justification: Contract performance.

Type of data collected: Name, email address.

Use of data: For marketing products and services that we believe will be of interest to you.

Justification: Consent (for marketing our own similar products and services and any re-engagement campaigns).

Type of data collected: Identity confirmation, Personal Public Service number, date of birth, current address, Property Services Registration Authority registration data.

Use of data: To provide you with the Services, specifically our Verified Status (which is your digital identity which you can share with Tenants).

Justification: Contract performance (to the extent required to provide the Services e.g. identity verification as required by Tenants before a tenancy agreement between Agent / Landlord and Tenant can be executed).

Type of data collected: Name, email address, bank account information.

Use of data: To administer our Services including deposit and rent payment processing services.

Justification: Contract performance (in respect of payment processing).

Type of data collected: Client landlord name, current address, Personal Public Service number.

Use of data: To administer our Services including preparation of tenancy agreements with Tenants.

Justification: Contract performance.

Type of data collected: Residential Tenancies Board registration data.

Use of data: To administer our Services including listing the property on our Website and preparation of tenancy agreements with Tenants.

Justification: Contract performance; consent.

Type of data collected: Name, email address.

Use of data: For marketing products and services that we believe will be of interest to you.

Justification: Consent (for marketing our own similar products and services and any re-engagement campaigns).

Type of data collected: Email address.

Use of data: To notify you about changes to our Services.

Justification: Consent (to update our Services from time to time).

We will not sell your personal data (or any other data you provide us with) to third-parties, however, we reserve the right to share any data, which has been anonymised and/or aggregated. You acknowledge and accept that we own all rights, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.

8. MARKETING

We may use data for marketing products and services to you in the following ways

A.

Newsletters and marketing emails relating to our Website and Services. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing.

Justification: Consent (to market our Website and Services - you have the right to unsubscribe at any time).

B.

To send you details about unrelated services or products or special offers and discounts which are being provided by our selected business partners. Where required by law, we will ask your consent at the time we collect your data to conduct any of these types of marketing.

Justification: Consent (which can be withdrawn at any time).

We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us.

9. WHERE WE STORE YOUR PERSONAL DATA

The personal data that we collect from you (including email addresses that form part of our prospective marketing database) is processed in the European Economic Area (“EEA”) and stored on Amazon Web Services (Europe) Cloud Servers. This data may however be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers. A full list of our third party sub-processors and details of their privacy policies can be requested. Countries outside the EEA may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data. In countries which do not provide appropriate safeguards, we shall transfer your data subject only to your consent except for transfers to and from: (i) any country with a valid adequacy decision from the European Commission; or (ii) any organisation which ensures an adequate level of protection in accordance with applicable data protection laws.

Your passwords are stored on RentDodo’s servers in encrypted form. We do not disclose your account details. It is your responsibility to keep your password secure. Unfortunately, the transmission of data via the internet is not completely secure. Although RentDodo will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website, any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent any unauthorised access.

Please contact us if you would like further details on the specific safeguards applied to the export of your personal data outside EEA.

10. DISCLOSURE OF YOUR PERSONAL DATA

We may also disclose your personal data to third parties in the following circumstances:

A.

We may disclose your personal data to our service providers and business partners, including payments processors, identity verification providers and database tool providers (to assist us in performing any contract we enter into with them or you, including providing the Website and the Services it enables), analytics providers, (to assist us in the improvement and optimisation of the Website) and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined by the Companies Acts.

Justification: Contract performance (to allow us to carry out our Services with the use of our service providers).

B.

If we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

Justification: Legitimate interest (to sell our business or assets); and where required by applicable law, Consent (for sensitive personal data).

C.

If RentDodo or substantially all of its assets are acquired by a third party, personal data about our customers will be one of the transferred assets.

Justification: Legitimate interest (to sell our business or assets); and where required by applicable law, Consent (for sensitive personal data).

D.

If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of RentDodo, our customers, or others. This includes exchanging data with other companies and organisations for the purposes of fraud protection.

Justification: Legal obligation; legitimate interest.

E.

Fraud prevention and other checks. We and other organisations may also access and use your personal data to conduct credit checks, identity checks and checks to prevent fraud. If false or accurate data is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies.

Justification: Legal obligation; legitimate interest. (to assist with the prevention of fraud and to assess your risk profile).

F.

As a Tenant we will share your following personal data with Letting Agents and Landlords: name, location.

With your prior consent on an individual case-by-case basis we will share your following personal data with a Letting Agent or Landlord: email address, phone number, current address, Personal Public Services number, pay slips, bank statements, reference from employers, references from landlords.

As a Landlord we will share your following personal data with Tenants and Letting Agents: name, location, Property Services Registration Authority registration, Residential Tenancies Board registration data.

With your prior consent on an individual case-by-case basis we will share your following personal data with a Tenant or Letting Agent: email address, phone number, current address, Personal Public Services number.

As a Letting Agent we will share your following personal data with Tenants and Landlords: name, location, Property Services Registration Authority registration, Residential Tenancies Board registration data.

With your prior consent on an individual case-by-case basis we will share your following personal data with a Tenant or Landlord: email address, phone number, current address, Personal Public Services number.

Justification: Consent

11. HOW LONG WE RETAIN YOUR PERSONAL DATA

We will hold the above data for as long as is necessary in order to provide you with the Services, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. Once your account is terminated or deactivated, we shall delete the personal data relating to your account within 72 hrs. If your account is inactive for 2 years, we may contact you to assess whether you want to continue to use the Services. Some personal data may need to be retained for longer than this to ensure RentDodo can comply with applicable laws and internal compliance procedures, including retaining your email address for marketing communication suppression if you have opted not to receive any further marketing.

If data is used for two or more purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose or purposes with a shorter period when that period expires.

We restrict access to your personal data to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your data that is no longer needed is either irreversibly anonymised (and the anonymised data may be retained) or securely destroyed.

12. YOUR RIGHTS

Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at privacy@rentdodo.com.

You have the following rights in relation to your personal data:

Right of access:

You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information:

A.

the purposes of the processing;

B.

the categories of personal data concerned;

C.

the recipients or categories of recipient to whom the personal data have been or will be disclosed;

D.

where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

E.

the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

F.

the right to lodge a complaint with a supervisory authority;

G.

where the personal data are not collected from the data subject, any available information as to their source;

H.

the existence of automated decision-making, including profiling and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where personal data is transferred to a third country or to an international organisation, you shall have the right to be informed of the appropriate safeguards relating to the transfer.

Right to rectification:

We will use reasonable endeavours to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.

Right to erasure / ‘Right to be forgotten’:

Asking us to delete all of your personal data will result in RentDodo deleting your personal data without undue delay (unless there is a legitimate and legal reason why RentDodo is unable to delete certain of your personal data, in which case we will inform you of this in writing).

Right to restriction of processing:

You have the right to ask us to stop processing your personal data at any time.

Right to data portability:

You have the right to request that RentDodo provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.

Right to complain:

Although we encourage our customers to engage with us in the event they have any concerns or complaints, you also have the right to lodge a complaint to the Irish supervisory authority: the Data Protection Commission (https://www.dataprotection.ie/).

Right to object to discussions based solely on automated processing:

You have the right to not be subject to a decision based solely on automated processing which produces legal effects concerning your or similarly significant effects and to obtain human intervention, to express your point of view or contest the decision.

RentDodo will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.

Asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use RentDodo’s Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use the Services.

Where you request RentDodo to rectify or erase your personal data or restrict any processing of such personal data, RentDodo may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example payment processing or insurance companies.

13. CHANGES TO THIS POLICY

Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email or notifications via the Website. We therefore encourage you to review it from time to time to stay informed of how we are processing your data.

14. CONTACT

Questions, comments and requests regarding this privacy policy are welcome and should be addressed to privacy@rentdodo.com.

For the purpose of the relevant data protection legislation, the data controller is Subbacultcha Limited, trading as RentDodo, with company no. 686534 and registered address at 3rd Floor, Broadmeadow Hall, Applewood, Swords, Co. Dublin.

Our data protection officer contact email is privacy@rentdodo.com.

15. COOKIES

RentDodo uses cookies to distinguish you from other users. This helps us provide you with a good experience when you use our Website, and also allows us to improve our Services. Please note that it is possible to disable cookies being stored on your computer by changing your browser settings. However, our Website may not perform properly or some features may not be available to you if you disable cookies.

For detailed information on the cookies we use and the purposes for which we use them see our Cookies policy here.

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RentDodo is made and hosted in Ireland.

Registered office: Broadmeadow Hall, Applewood, Swords, Co. Dublin. Company no.: 686534.

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