1. Who Are We?

We are Co-operative Housing Ireland (“CHI”, “us”, “we”, or “our”) with an address at 11-12 Warrington Place Dublin, D02 E221. CHI are the data controller who determines the purposes and means of the processing of personal data.

For Data Protection related queries, our Data Protection Officer can be contacted at dpo@cooperativehousing.ie.

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2. Purpose of this Notice

This notice sets out the basis on which any personal data we collect from you, or from others, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

We are committed to protecting your information responsibly and using appropriate security measures. In this policy, we explain how we look after your Personal Data when you:

• Visit our website;
• Use our services; or
• Enquire about our services.

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3. Helpful Definitions

“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Data Controllers” are the people or organisations who determine the purposes for which, and the manner in which any personal data is processed. They are responsible for establishing practices and policies in line with the relevant laws and regulations. CHI is the data controller of all personal data used in our business for our own commercial purposes.

“Data Processors” include any person or organisation that processes personal data on our behalf and on our instructions. Employees of data controllers are excluded from this definition, but it could include suppliers which handle personal data on CHI’s behalf.

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4. What Personal Information Do We Collect from You?

We have set out below the types of personal data which CHI may collect:

Category	Personal Data Processed
Members	Full Name, Address, Contact details (phone number and/or email), Date of Birth, Gender, PPS Number, Details of dependants, Financial information, Income details, Call recordings, Ethnicity Details
Website User Details	IP address, Device type, Browser type
Communications Data	Name & Contact details, Details in relation to your feedback/query/comment/complaint. We may also communicate with you with information relevant to your tenancy.
Cookie Data	Cookie preferences, Duration of visit, Pages visited
CCTV Data	Images and Recordings of you entering/on the premises

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5. Purposes for Collection and Our Lawful Basis For Processing

We collect information from you for the following purposes:

• Processing your application for housing and providing this service on an ongoing basis.
• Contacting you by phone, mail, SMS, or email with statements on account, balance queries, and other important information.
• Contacting you by phone, mail, SMS, or email about maintenance & safety items relevant to your property.

Our legal basis for processing your personal information varies depending on the type of information and context in which we process it. We typically rely on the following:

• Contractual Necessity to process information when you become a CHI member and to provide you with our services;
• Consent when placing cookies on your device on the web (through Our cookie consent manager);
• Our Legitimate Interests to process your information when providing customer service support, effectively providing our services, managing your tenancy, and for fraud prevention and security purposes.

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6. Who Do We Share This Information With?

We will only use or share your personal information for the primary purposes for which it was collected, for directly related secondary purposes which you might reasonably expect (or that we have told you), or as required or permitted by law.

We may also disclose your Personal Data where we have a duty:

• To comply with a legal obligation;
• To protect and defend the rights or property of Co-operative Housing Ireland;
• To prevent or investigate possible wrongdoing in connection with the Service;
• To protect against legal liability; or
• To protect the rights, property, or safety of CHI, our members, or others.

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7. Transfers of Data Outside the European Union or European Economic Area

We may (in very limited circumstances) transfer personal data to a country outside the European Economic Area (“EEA”), provided that one of the following conditions applies:

• The country to which the personal data are transferred ensures an adequate level of protection and appropriate safeguards in place for the data subjects' rights and freedoms.
• The data subject has given their consent.
• The transfer is legally required on important public interest grounds or for the establishment, exercise, or defense of legal claims.
• The transfer is authorized by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects' privacy, their fundamental rights and freedoms, and the exercise of their rights.

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8. How Long Do We Keep Hold of Your Information?

The time periods for which we retain your information depend on the type of information and the purposes for which we use it. We will keep your information for no longer than is required or permitted. A copy of our Retention Policy is available upon request.

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9. Automated Decision-Making and Profiling

CHI does not carry out Automated Decision-Making and Profiling.

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10. What Are Your Rights With Respect to Your Personal Data?

You have the following rights:

• To know what information is being processed by us (Right to be Informed).
• To receive a copy of your personal data that is being processed by us (Data Access Request).
• To request correction or updating of your personal data.
• To request deletion of your personal data where it is no longer necessary for us to process (Right to be Forgotten).
• To request the restriction of processing of your personal data.
• To request your data be provided to a third party (Data Portability).
• To object to the processing of your information and to unsubscribe from receiving marketing materials.
• To withdraw your consent to processing (which was based on your consent) at any time.
• To make a complaint to the Data Protection Commissioner. You may exercise any of the above rights by contacting our DPO at dpo@cooperativehousing.ie.

You may lodge a complaint with your local supervisory authority with respect to our processing of your personal data. The local Supervisory Authority in Ireland is the Data Protection Commission. The website is www.dataprotection.ie.

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11. Changes To This Privacy Notice

We may update our Privacy Notice from time to time. We will notify you of any changes by posting the new Privacy Notice on this page.

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12. Contact Us

If you would like to exercise any of your data protection rights or if you have any questions about this Privacy Notice, contact our Data Protection Officer using the methods below:

• Email: DPO@cooperativehousing.ie
• Address: 11-12 Warrington Place, Dublin 2, D02 E221