Privacy Policy

This Privacy Policy sets out how we, 5S Property, collect, store and use information about you when
you use or interact with our website, https://www.5S.ie/ (our
website)
and where we otherwise obtain or collect information about you. This Privacy Policy is effective from May 25th 2018.

Contents

• Summary
• Our details
• Information we collect when you visit our website
  
• Information we collect when you contact us
  
• Information collected or obtained from third
  parties
• Our use of automated decision-making and profiling
  
• Disclosure and additional uses of your information
• How long we retain your information
• How we secure your information
• Transfers of your information outside the European Economic
  Area
• Your rights in relation to your information
• Your right to object to the processing of your information for certain
  purposes
• Sensitive Personal Information
• Changes to our Privacy Policy
• Children’s Privacy
• California Do Not Track Disclosures
• Copyright

Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general
overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding
full sections of this Privacy Policy.

• Data controller: Alan O’Dowd

• How we collect or obtain information about you:
  • when you provide it to us (e.g. by contacting us or placing an order in relation to our goods or services),
  • from your use of our website, using cookies and similar technologies, and
  • occasionally, from third parties.

• Information we collect: name, email address, contact number, contact address, payment
  information, IP address, information from cookies, information about your computer or device (e.g. device and
  browser type) and information about how you use our website (e.g. which pages you have viewed, the time when you
  view them and what you clicked on, the geographical location from which you accessed our website (based on your
  IP address) and company name.

• How we use your information: for administrative and business purposes (particularly to contact
  you, to improve our business and website, to fulfil our contractual obligations, to advertise our goods and
  services, to analyse your use of our website, and in connection with our legal rights and obligations.

• Disclosure of your information to third parties: only to the extent necessary to run our
  business, to our service providers, to fulfil any contracts we enter into with you, and where required by law or
  to enforce our legal rights.

• Do we sell your information to third parties (other than in the course of a business sale or purchase or
  similar event): No

• Use of automated decision-making and profiling: we use automated decision-making through our
  use of remarketing advertisements, but we do not use profiling. For further information, please see the main
  section below entitled Our use of automated decision-making and profiling.

• How long we retain your information: for no longer than necessary, taking into account any
  legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using
  your information (e.g. your consent, performance of a contract with you or our legitimate interests as a
  business). For specific retention periods in relation to certain information which we collect from you, please
  see the main section below entitled How long we retain your information.

• How we secure your information: using appropriate technical and organisational measures such as
  storing your information on secure servers, encrypting transfers of data to or from our servers using Secure
  Sockets Layer (SSL) technology and only granting access to your information where necessary.

• Use of cookies and similar technologies: we use cookies and similar information-gathering
  technologies on our website including functional, analytical and advertising cookies. For more information,
  please visit our cookies policy here: https://www.5S.ie/cookie-policy

• Transfers of your information outside the European Economic Area: in certain circumstances we
  transfer your information outside of the European Economic Area, including to the United States of America.
  Where we do so, we will ensure appropriate safeguards are in place, e.g. the third parties we use who transfer
  your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S.
  Privacy Shield.

• Your rights in relation to your information
  • to access your information and to receive information about its use
  • to have your information corrected and/or completed
  • to have your information deleted
  • to restrict the use of your information
  • to receive your information in a portable format
  • to object to the use of your information
  • to withdraw your consent to the use of your information
  • to complain to a supervisory authority

• Sensitive personal information: we do not knowingly or intentionally collect what is commonly
  referred to as ‘sensitive personal information’. Please do not submit sensitive personal information
  about you to us. For more information, please see the main section below entitled Sensitive Personal
  Information.

Our details
The data controller in respect of our website is Alan O’Dowd, trading as 5S Property (registration number
9270268I), of Roxboro House, Raleigh Row, Galway City, Co. Galway
You can contact the data controller by writing to 5S Property, Roxboro House, Raleigh Row, Galway City, Co.
Galway
or sending an email to [email protected].
If you have any questions about this Privacy Policy, please contact the data controller.

 

Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled
Disclosure and additional uses of your information.

Web server log information
We use a third-party server to host our website called Heaventree, the privacy policy of which is available here: https://www.heaventreedesign.com/privacy-policy/.
Our
website server automatically logs the IP address you use to access our website as well as other information about
your visit such as the pages accessed, information requested, the geographical location, the date and time of the
request, the source of your access to our website (e.g. the website or URL (link) which referred you to our
website), and your browser version and operating system.
Our server is located in Germany.

Use of website server log information for IT security purposes
Our third-party hosting provider collects and stores server logs to ensure network and IT security and so that the
server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised
access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by
detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting
provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are
subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational
measures to ensure a level of security appropriate to the risk of our processing of information about individuals.
Recording access to our website using server log files is such a measure.
Legal basis for processing: our and a third party’s legitimate interests
(Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we and our third-party hosting provider have a legitimate interest in using
your information for the purposes of ensuring network and information security.

Cookies and similar technologies
Cookies are data files which are sent from a website to a browser to record information about users for various
purposes.
We use cookies on our website, including functional, analytical and advertising cookies. For further information on
how we use cookies, please see our cookies policy which is available here: www.5S.ie/cookie-policy
You can reject some or all of the cookies we use on or via our website by changing your browser settings but doing
so can impair your ability to use our website or some or all of its features. For further information about cookies,
including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

 

 

Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section
entitled Disclosure and additional uses of your information.

Email
When you send an email to the email address displayed on our website we collect your email address and any other
information you provide in that email (such as your name, telephone number and the information contained in any
signature block in your email).
Legal basis for processing: our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to
enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for example,
providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information
We store emails you send us on our third-party website server, Heaventree, as well as our third-party email
provider, Gmail (Google, Inc.).
Emails you send us will be transferred and stored outside the European Economic Area on our third-party email
provider’s (Google, Inc.’s) servers in the United States of America or any of their other data centres
around the world. Their privacy policy is available here: https://policies.google.com/privacy?hl=en
For further information about the safeguards used when your information is transferred outside the European Economic
Area, please see the section of this privacy policy entitled Transfers of your information outside the European
Economic Area.

Contact form
When you contact us using our contact form, we collect your name, email address, contact number and any information
you include in
the subject and message fields. We also collect any optional information you provide to us.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the
contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to
enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for example,
providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information
We store messages you send us via our contact form on our third-party website server, Heaventree, in Germany as well
as our email provider, Gmail (Google, Inc.).
Messages you send us via our contact form will also be transferred and stored outside the European Economic Area on
our third-party email provider’s (Google, Inc.’s) servers in the United States of America or any of
their other data centres around the world. Their privacy policy is available here: https://policies.google.com/privacy?hl=en
We also transfer and store messages you send us via our contact form on a third-party server, Daft.ie (Daft Media
Limited), within the European Economic Area. Their privacy policy is available here:  http://www.daft.ie/privacy. Daft.ie may transfer information you provide
on our contact form outside the European Economic Area. Where they do so, they will put appropriate safeguards in
place.
For further information about the safeguards used when your information is transferred outside the European Economic
Area, please see the section of this privacy policy entitled Transfers of your information outside the European
Economic Area.

Payment
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe: Their Privacy Policy can be viewed at stripe.com/us/privacy

Phone
When you contact us by phone, we collect your phone number and any information provide to us during your
conversation with us.
Legal basis for processing: our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to
enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for example,
providing you with information about such goods and services), we will process your information in order to do so.

Transfer and storage of your information
Information about your call, such as your phone number and the date and time of your call, is processed by our
third-party telephone service provider which is located in Ireland.

Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send
us.
Legal basis for processing: our legitimate interests (Article
6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of
correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to
enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with
goods or services or taking steps at your request prior to providing you with our goods and services (for example,
providing you with information about such goods and services), we will process your information in order to do so.

Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.

Information received from third parties
Generally, we do not receive information about you from third parties. The third parties from which we receive
information about you will generally include other businesses and clients we work with from time to time who may
recommend our services to you. These could be businesses in any industry, sector, sub-sector or location.
It is also possible that third parties with whom we have had no prior contact may provide us with information about
you.
Information we obtain from third parties will generally be your name and contact details, but will include any
additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at
your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you
to us (such as your name and email address) in order for us to provide services to you, we will process your
information in order to take steps at your request to enter into a contract with you and perform a contract with you
(as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data
Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the
purpose of sharing that information is not related to the performance of a contract or services by us to you, we
will process your information on the basis of your consent, which you give by asking the third party in question to
pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the
General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not
consented to the sharing of that information, we will have a legitimate interest in processing that information in
certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a
sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is
the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any
of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate
and pursue any such potential infringement.

Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing
that information, we will delete your information.

Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we
require to provide you with a service) we will obtain information about you from certain publicly accessible
sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business
directories, media publications, social media, and websites (including your own website if you have one).
In certain circumstances, we will also obtain information about you from private sources, both EU and non-EU.
Legal basis for processing: necessary to perform a contract or to take steps at
your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested
that we enter into a contract with you, in certain circumstances, we will obtain information about you from public
sources in order to enable us to understand your business and provide services to you or services to a sufficient
standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us
to send you information by email but we do not possess the information or we need to confirm that we have recorded
your email address correctly.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the
General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining
information about you from public and private sources. For example, if you have infringed or we suspect that you
have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information
about you from such sources in order to investigate and pursue any suspected or potential infringement.

 

Our use of automated decision-making and profiling
We use automated decision-making, but do not use profiling.
You have the right to object to our use profiling described in this section. You can do that by opting-out of
cookies and similar technologies in accordance with the method described in the relevant section below. If you
do not want us to process your actual IP address (usually the IP address assigned to you by your Internet
Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such
as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we
use them) and how to opt out from them in our cookies policy, which is available here: www.5S.ie/cookie-policy

Automated decision making
Automated decision making is decision making by technological means (i.e. by a machine) without human
involvement.

Use of automated decision-making for display advertising
We automate the display advertisements containing our products and services on other websites you visit, you
based on the fact that you have visited our website using cookies. For further information on the cookies we
use, please see our cookies policy which is available here: www.5S.ie/cookie-policy
Logic involved: automatically displaying advertisements to individuals who have visited our
website results in increased efficiencies and costs savings for us than manually displaying advertisements or
displaying advertisements by different means.
Significance and envisaged consequences: cookies will be used to recognise the fact that you
have visited our website in order to display advertisements to you (unless you have blocked such cookies) and
will collect information about your online behaviour.
How to object: you can block these cookies by using the cookies control management tool on your
site (if you use one) or by opting out of seeing personalised ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB.
For further information, please see our cookies policy: www.5S.ie/cookie-policy
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection
Regulation).
Consent: you consent to our use of automated decision-making by turning on remarketing cookies
using our cookie control tool.

Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and
any additional purposes for which we use your information.

Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to
assist us with running our business and who process your information for us on our behalf. These include the
following:

• Telephone provider,
• Email provider,
• IT service provider,
• Web developer, and
• Hosting provider.

Apart from our email service provider, which is located in theUSA, and our hosting provider, which is located
in Germany, our service providers are located in the UK or the Republic of Ireland.
Your information will be shared with these service providers where necessary to provide you with the service
you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display the identities of all of our service providers publicly by name for security and
competitive reasons. If you would like further information about the identities of our service providers,
however, please contact us directly by email and we will provide you with such information where you have a
legitimate reason for requesting it (where we have shared your information with such service providers, for
example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the
General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in
a context other than where is necessary to perform a contract (or take steps at your request to do so), we
will share your information with such third parties in order to allow us to run and manage our business
efficiently.
Legal basis for processing: necessary to perform a contract and/or to take
steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection
Regulation).
Reason why necessary to perform a contract: we may need to share information with our
service providers to enable us to perform our obligations under that contract or to take the steps you have
requested before we enter into a contract with you.

Disclosure of your information to other third parties
We disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc.
Google collects information through our use of Google Maps on our website. Google uses this information,
including IP addresses and information from cookies, for a number of purposes, such as improving its Google
Maps service. Information is shared with Google on an aggregated and anonymised basis. To find out more
about what information Google collects, how it uses this information and how to control the information sent
to Google, please see the following page: https://www.google.com/policies/privacy/partners/
Legal basis for processing: our legitimate interests
(Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to these third parties under
our terms of service and other contracts with them.
You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Newsletter

We use MailChimp to send our newsletter and administer our mailing list, MailChimp’s privacy policy can be viewed here.

Information you submit when you subscribe to our newsletter is stored outside the EEA on MailChimp’s servers in the USA.

Further information about the safeguards used when your information is transferred outside the EEA, see the section of this privacy policy below entitled
Transfer of information outside the EEA.

Transfer and storage of your information
Information collected by Google Maps is stored outside the European Economic Area on their respective
servers in the United States of America.
For further information about the safeguards used when your information is transferred outside the European
Economic Area, see the section of this privacy policy below entitled Transfers of your information
outside the European Economic Area.

Sharing your information with third parties, which are either related to or associated with the running of
our business, where it is necessary for us to do so. These third parties include our accountants,
advisors, affiliates, business partners, independent contractors, and insurers. Further information
on each of these third parties is set out below.
Legal basis for processing: our legitimate interests
(Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

Accountants
We share information with our accountants for tax purposes. For example, we share invoices we issue and
receive with our accountants for the purpose of completing tax returns and our end of year accounts.
Our accountants are located in the Republic of Ireland.

Advisors
Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and public
relations professionals. We will share your information with these third parties only where it is necessary
to enable these third parties to be able to provide us with the relevant advice.
Our advisors are located in the Republic of Ireland.

Affiliates
Affiliates are individuals or entities we work with to promote our business or their own business by various

means, including by advertising our services on their websites, for example. Affiliates will share
information with us and we will share information with them where you have expressed an interest in our
products or services.
Our affiliates include the following businesses: Acquaint.ie, Klyant.ie, Daft.ie and Myhome.ie.
Our affiliates are located in the Republic of Ireland.

Business partners
Business partners are businesses we work with which provide goods and services which are complementary to
our own, which allow us to provide goods or services which we could not provide on our own, or which we have
a mutual interest in recommending. We share information with our business partners where you have requested
services which they provide whether independently from, or in connection with, our own services.
Our business partners are generally located in the Republic of Ireland or elsewhere in the European Economic
Area.

Independent contractors
Occasionally, we use independent contractors in our business. Your information will be shared with
independent contractors only where it is necessary for them to perform the function we have hired them
perform in relation to our business.
Our independent contractors are located in the Republic of Ireland.

Insurers
We will share your information with our insurers where it is necessary to do so, for example in relation to
a claim or potential claim we receive or make or under our general disclosure obligations under our
insurance contract with them.
Our insurers are located in the Republic of Ireland.

Sharing your information with a prospective or actual purchaser or seller in the context of a business or
asset sale or acquisition by us, a merger or similar business combination event, whether actual or
potential.
Legal basis for processing: legitimate interests (Article 6(1)(f) of the
General Data Protection Regulation).
Legitimate interest(s): sharing your information with a prospective purchaser,
seller or similar person in order to allow such a transaction to take place.

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain
circumstances need to contact an appropriate authority, such as the police. This could be the case, for
instance, if we suspect that a fraud or a cyber-crime has been committed or if we receive threats or
malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by
such an incident in some way.
Legal basis for processing: our legitimate interests
(Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

In connection with the enforcement or potential enforcement our legal rights
We will use your information in connection with the enforcement or potential enforcement of our legal
rights, including, for example, sharing information with debt collection agencies if you do not pay amounts
owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have
entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law
or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data
Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal
rights.

In connection with a legal or potential legal dispute or proceedings
We may need to use your information if we are involved in a dispute with you or a third party for example,
either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar
process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data
Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

For ongoing compliance with laws, regulations and other legal requirements
We will use and process your information in order to comply with legal obligations to which we are subject.
For example, we may need to disclose your information pursuant to a court order or subpoena if we receive
one.
Legal basis for processing: compliance with a legal obligation (Article
6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part
of the laws of the Republic of Ireland or if they have been integrated into Ireland’s legal framework
(for example in the form of an international agreement which the Republic of Ireland has signed).
Legal basis for processing: our legitimate interests
(Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country
and have not been integrated into Ireland’s legal framework, we have a legitimate interest in
complying with these obligations.

 

How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods
where possible. Where that has not been possible, we have set out the criteria we use to determine the
retention period.

Retention periods
Server log information: we retain information on our server logs for 30 days.
Order information: when you place an order for goods and services in relation to our website, we
retain that information for 6 years, in accordance with our legal obligation to keep records for tax
purposes.
Correspondence and enquiries: when you make an enquiry, or correspond with us for any reason,
whether by email or via our contact form or by phone, we will retain your information for as long as it
takes to respond to and resolve your enquiry, and then a further year, after which point we will delete
your information.

Criteria for determining retention periods
In any other circumstances, we will retain your information for no longer than necessary, taking into
account the following:

• the purpose(s) and use of your information both now and in the future (such as whether it is
  necessary to continue to store that information in order to continue to perform our obligations
  under a contract with you or to contact you in the future);
• whether we have any legal obligation to continue to process your information (such as any
  record-keeping obligations imposed by relevant law or regulation);
• whether we have any legal basis to continue to process your information (such as your consent);
• how valuable your information is (both now and in the future);
• any relevant agreed industry practices on how long information should be retained;
• the levels of risk, cost and liability involved with us continuing to hold the information;
• how hard it is to ensure that the information can be kept up to date and accurate; and
• any relevant surrounding circumstances (such as the nature and status of our relationship with you).

How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect
it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject
  to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information;
• verifying the identity of any individual who requests access to information prior to granting
  them access to information;
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any
  forms on our website; and
• only transferring your information via closed system or encrypted data transfers.

Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any
information to us over the internet (whether by email, via our website or any other means), you do
so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages,
liabilities or any other form of loss or damage suffered by you as a result of your decision to
transmit information to us by such means.

 

Transfers of your information outside the European Economic
Area
Your information will be transferred and stored outside the European Economic Area (EEA) in the
circumstances set out below. We will also transfer your information outside the EEA or to an
international organisation in order to comply with legal obligations to which we are subject
(compliance with a court order, for example). Where we are required to do so, we will ensure
appropriate safeguards and protections are in place.

Email
Information you submit to us by email is transferred outside the EEA and stored on our
third-party email provider’s servers. Our third-party email provider is Gmail (Google,
Inc.). You can access their privacy policy here: https://policies.google.com/privacy?hl=en-GB&gl=uk

Country of storage: United States, Taiwan, Singapore and/or Chile. These countries are
not subject to an adequacy decision by the European Commission. You can find out more about
Google’s data centres: https://www.google.com/about/datacenters/inside/locations/index.html.
Safeguard(s) used: Google transfers your information outside the EEA to entities which
have either self-certified themselves as compliant under the EU-U.S. Privacy Shield or have put
EU-approved model contract clauses are in place.
The EU-U.S. Privacy Shield is available here: https://www.privacyshield.gov/welcome. The
EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General
Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data
Protection Regulation. you can access the European Commission decision on the adequacy of the
EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

EU-approved model clauses are standard data protection clauses adopted by the European
Commission in accordance with its committee examination procedure under Article 93(2) of the
General Data Protection Regulation. This is permitted under Article 46(2)(b) of the General Data
Protection Regulation

Contact form
Information you submit to us via our contact form is transferred outside the EEA and stored on
our third-party email provider’s servers. For further information, please see
‘Email’ above.
We also transfer and store messages you send us via our contact form on a third-party server,
daft.ie (Daft Media Limited), within the European Economic Area. Their privacy policy is
available here: http://www.daft.ie/privacy.
Daft.ie may transfer information you provide on our contact form outside the European Economic
Area. Where they do so, they will put appropriate safeguards in place.

Google Maps
Google transfers information collected by its Google Maps service (your IP address and
information about you use our website) outside the EEA and stores that information on its
servers in the United States of America. You can view Google’s privacy policy here https://www.google.com/policies/privacy/
and how the use the information collected by cookies here: https://www.google.com/policies/privacy/partners/

Countries of storage: United States of America. The United States of America is not
subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google transfers your information outside the EEA to entities which
have self-certified themselves as compliant under the EU-U.S. Privacy Shield.
The EU-U.S. Privacy Shield is available here: https://www.privacyshield.gov/welcome. The
EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General
Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data
Protection Regulation. you can access the European Commission decision on the adequacy of the
EU-U.S. Privacy Shield here:   http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

Buildium
Buildium transfers information collected outside the EEA and stores that information on its
servers in the United States of America. You can view Buildium’s privacy policy here https://www.dropbox.com/privacy

Countries of storage: United States of America. The United States of America is not subject to an adequacy
decision by the European Commission.

Dropbox
Dropbox stores, processes, and transmits information in the United States and locations around the world. You can view Dropbox’s privacy policy here https://www.buildium.com/privacy-policy/

Countries of storage: United States of America and locations around the world. The United States of America is not subject to an adequacy
decision by the European Commission.

 

Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation
to your information, which you can exercise by writing to 5S Property, Roxboro House, Raleigh Row, Galway City,
Co. GalwayF or sending an email to [email protected]:

• to request access to your information and information related to our
  use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly
  used and machine-readable format (e.g. a CSV file) and the right to have
  that information transferred to another data controller (including a third-party data
  controller);
• to object to the processing of your information for certain purposes
  (for further information, see the section below entitled Your right to object to the
  processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time
  where we rely on your consent to use or process that information. Please note that if
  you withdraw your consent, this will not affect the lawfulness of our use and processing
  of your information on the basis of your consent before the point in time when you
  withdraw your consent.

In accordance with Article 77 of the General Data Protection Regulation, you also have the
right to lodge a complaint with a supervisory authority, in particular in the Member State
of your habitual residence, place of work or of an alleged infringement of the General Data
Protection Regulation.
For the purposes of Ireland, the supervisory authority is the Office of the Data Protection
Commissioner (An Coimisinéir Cosanta Sonraí) (the DPC), the contact details
of which are available here: https://www.dataprotection.ie/docs/EN/Contact-us/m/11.htm

Further information on your rights in relation to your personal data as an
individual
The above rights are provided in summary form only and certain limitations apply to many of
these rights. For further information about your rights in relation to your information,
including any limitations which apply, please visit the following pages on the DPC’s
website:

• https://www.dataprotection.ie/docs/A-guide-to-your-rights-Plain-English-Version/r/858.htm;
  and
• https://www.dataprotection.ie/docs/Accessing-Your-Personal-Information/r/14.htm.

Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable
measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity
fraud, identity theft or general unauthorised access to your information.

How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your
identity using that information.
If it is not possible to identity you from such information, or if we have insufficient
information about you, we may require original or certified copies of certain documentation
in order to be able to verify your identity before we are able to provide you with access to
your information.
We will be able to confirm the precise information we require to verify your identity in
your specific circumstances if and when you make such a request.

 

Your right to object to the processing of your
information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may
exercise by writing to 5S Property, Roxboro House, Raleigh Row, Galway City, Co. Galway or sending an email to
[email protected]:

• to object to us using or processing your information where we use or process it in
  order to carry out a task in the public interest or for our
  legitimate interests, including ‘profiling’ (i.e. analysing
  or predicting your behaviour based on your information) based on any of these
  purposes; and
• to object to us using or processing your information for direct marketing
  purposes (including any profiling we engage in that is related to such
  direct marketing).

You may also exercise your right to object to us using or processing your information for
direct marketing purposes by:

• clicking the unsubscribe link contained at the bottom of any
  marketing email we send to you and following the instructions which appear in your
  browser following your clicking on that link; or
• sending an email to [email protected],
  asking that we stop sending you marketing communications or by including the words
  “OPT OUT”.

For more information on how to object to our use of information collected from cookies
and similar technologies, please see the section entitled How to accept or reject
cookies in our cookies policy, which is available here: https://www.5S.ie/cookie-policy

Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that
reveals their racial or ethnic origin, political opinions, religious or
philosophical beliefs, or trade union membership, genetic information, biometric
information for the purpose of uniquely identifying an individual, information
concerning health or information concerning a natural person’s sex life or
sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from
individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal
information to us, you will be considered to have explicitly consented to us
processing that sensitive personal information under Article 9(2)(a) of the General
Data Protection Regulation. We will use and process your sensitive personal
information for the purposes of deleting it.

Changes to our Privacy
Policy
We update and amend our Privacy Policy from time to time.

Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy
Policy with a new effective date stated at the beginning of it. Our processing
of your information will be governed by the practices set out in that new
version of the Privacy Policy from its effective date onwards.

Major changes to our Privacy Policy or the purposes for which we process your
information
Where we make major changes to our Privacy Policy or intend to use your
information for a new purpose or a different purpose than the purposes for which
we originally collected it, we will notify you by email (where possible) or by
posting a notice on our website.
We will provide you with the information about the change in question and the
purpose and any other relevant information before we use your information for
that new purpose.
Wherever required, we will obtain your prior con
sent before using your information for a purpose that is different from the
purposes for which we originally collected it.

 

Childrens Privacy
Because we care about the safety and privacy of children online, we comply
with the Children’s Online Privacy Protection Act of 1998 (COPPA).
COPPA and its accompanying regulations protect the privacy of children using
the internet. We do not knowingly contact or collect information from
persons under the age of 18. The website is not intended to solicit
information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under
the age of 18 by the fraud or deception of a third party. If we are notified
of this, as soon as we verify the information, we will, where required by
law to do so, immediately obtain the appropriate parental consent to use
that information or, if we are unable to obtain such parental consent, we
will delete the information from our servers. If you would like to notify us
of our receipt of information about persons under the age of 18, please do
so by sending an email to [email protected].

 

California Do Not Track
Disclosures
“Do Not Track” is a privacy preference that users can set in
their web browsers. When a user turns on a Do Not Track signal in their
browser, the browser sends a message to websites requesting that they do
not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

At this time, we do not respond to Do Not Track browser settings or
signals. In addition, we use other technology that is standard to the
internet, such as pixel tags and other similar technologies, to track
visitors to the website. Those tools may be used by us and by third
parties to collect information about you and your internet activity,
even if you have turned on the Do Not Track signal. For information on
how to opt-out from tracking technologies used on our website, see our
cookies policy which is available here: https://www.5S.ie/cookie-policy

Copyright
The copyright in this Privacy Policy is either owned by, or licensed
to, us and is protected by copyright laws around the world and
copyright protection software. All intellectual property rights in
this document are reserved.