1. Introduction
    • We fully respect your right to privacy in relation to your interactions with us. Data Protection Legislation provides rules which apply to the collection, use and processing of information concerning individuals. It also gives individuals certain rights in relation to personal data that is held about them.
    • The purpose of this Policy is to set out how we process your personal data and to ensure that you are aware of your rights under Data Protection Legislation. This Policy applies to personal data collected from tenants and guarantors (including prospective tenants and guarantors), relating to any tenancy at Hubble Living.
    • We will handle your Personal Data in accordance with Data Protection Legislation[1]. Exeter US Advisor LLC is the data controller (as defined in Data Protection Legislation) in relation to any Personal Data which we collect from you.
  2. Information we gather from you
    • If you are a tenant or prospective tenant the information that we process relating to you includes:
    • basic information such as your first and last name;
    • contact information such as your address, email address and phone number;
    • Passport photo
    • financial information including, bank account or card details and bank account details for payment processing purposes;
    • any other information relating to you which you may provide to us.
    • If you are a guarantor the information that we process relating to you includes:
    • basic information such as your first and last name;
    • contact information such as your address, email address and phone number;
    • We endeavour to keep your personal data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible.
    • If you are aged under 18, please get your parent/guardian’s permission before you provide your personal data to us.
  3. Purpose And Legal Basis Of Processing
    • We will only collect the minimum information necessary in order to; (1) assess the prospective tenant’s/students application for accommodation at Hubble Living, (2) enter into a letting agreement with the tenant and guarantor, (3) deal with any issues with arise during the tenancy and (4) comply with our legal obligations.  
    • The primary legal basis for which we process your personal data is in order to enter into a contract and perform a contract with you in accordance with Article 6(1) (b) GDPR. Should you choose to provide us with medical or health information we will process this data on the basis of your consent.
    • In some circumstances, we may also process your data to comply with our statutory obligations, pursuant to our legitimate interests (for example to contact you for marketing purposes) or for the purposes of seeking legal advice.
  4. Sharing Of Your Personal Data
    • Your personal data will be shared with third party service providers as well as with the property management agent Red Amethyst Limited who may process your personal data for the purposes of communicating with you about any issues, to maintain a fire register and to ensure the maintenance and security of the property.
    • Your personal data could be shared with other third parties such as your registered third level institution and An Garda Síochána in the event of suspected antisocial or criminal behaviour.
    • CCTV/Bodycams and microphones are in operation at the Hubble Living premises’ for the purposes of:
      • Detecting and investigating crime and anti-social behaviour;
      • To ensure the security of students, staff and visitors;
      • To protect the premises and assets;
    • CCTV/Body Cam footage is retained for a period of 31 days unless required to be retained for a longer period in the context of an investigation or legal proceedings.
  6. Data security
    • We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. We will put in place, and maintain and upgrade as necessary, procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if it agrees to comply with those procedures and policies, or if it implements adequate alternative measures.
  7. Data Retention
    • Your personal data will be retained for no longer than it is required for the purpose for which it was obtained. Your personal data will be retained for a maximum of 5 years from the date of collection unless specific circumstances exist which require us to retain the data for a longer period under Data Protection Legislation.
  8. Your Rights Under The Legislation
    • Data Protection Legislation gives you specific rights in relation to the personal data that we process about you.
    • As a data subject, you are entitled to:
      • Obtain access to the personal data which is held about you, subject to limited exceptions;
      • Request the rectification or erasure of the personal data held about you;
      • Request the restriction of processing of any personal data concerning you;
      • Object to the processing of any personal data;
      • Exercise your right to data portability (where applicable);
      • Request us to stop contacting you with direct marketing and;
      • Lodge a complaint with the Data Protection Commission.
    • These rights are not absolute and every request will be considered on case by case basis in line with all Data Protection Legislation.



[1] “Data Protection Legislation” means the Data Protection Acts 1988 to 2018, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and any other applicable law or regulation relating to the processing of Personal Data and to privacy, including the E-Privacy Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“E-Privacy Regulations”), as such legislation shall be supplemented, amended, revised or replaced from time to time.

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