1. General information

1.1. We are Heatherview Court Student Accommodation Old Dublin Road, Bunavalley, Athlone Co. Westmeath. We are committed to giving visitors to this website information about how their personal data are processed. This privacy policy aims to give you more information about why we collect your personal data, how it is stored, retained, used, disclosed etc.

1.2. By using this website, you do so on the basis of this Privacy Policy. We reserve the right to change this policy from time to time. You will be bound by the current policy in place at the time you use this website. If you do not agree with these terms, please do not use our website.

2. Personal data collected through this website. Information We Collect From You

2.1. Personal data you voluntarily provide

When you visit this website, you may choose to apply for student accommodation using the online form on this website. If you chose to provide your personal data to us by completing the student accommodation application form, this will result in us receiving the following personal data:

(a) Your name,
(b) Your email address,
(c) Your postal address & postcode/eircode,
(d) Your mobile phone and landline number or other contact information.
(e) Date of Birth
(f) We will ask you to tick a box to clarify whether you are a TUS student.
(g) such other information as may be relevant to your application.

2.2. Information collected when you visit the website:

Our website collects information to give us further information about who visits our website, learn about visitor numbers, website traffic, pages of interest etc. This is so that we can improve our website design and functionality, to develop our website based on users’ interests, and to ensure our website displays correctly.  The information obtained includes:

• IP address from which you access our website
• The type of browser you used to visit the website
• Operating system used
• Top-level domain name used (eg. .ie, .co.uk, etc)
• The date and time of the visit
• Pages visited

This information is gathered using “cookies” which are small files that a site or its service provider uses.

3. Use of Your Personal data/Information

3.1. In relation to the Information collected when you visit the website (per 2.2 above), we use that to analyse website visitors, analyse preferences, for statistical purposes, to troubleshoot any issues, to improve the effectiveness of our website, and for internal business purposes.  We also analyse information provided by you and others to help us administer, support, and improve our business. The processing of this information is based on the legitimate basis of legitimate interests.

3.2. In relation to the personal data you voluntarily provide (per 2.1 above), we use that personal data in order to respond to the query you have raised or to deal with your accommodation application.

3.3. If you apply for student accommodation via our website and are unsuccessful then the personal data we will have collected on you is set out at (2.1) above. For further information regarding our retention policy, please see section 7 of this Privacy Notice.

3.4. If you apply for student accommodation via our website and are successful, we will collect and process the following classes of personal data in order to offer you a room in Heatherview Court pursuant to the Licence Agreement:

• Your parents’ contact details (per the terms of the guarantee attached to the Licence Agreement),
• Payment details (to process any deposit and/or licence fee payment);
• Any documentation relating to medical needs, allergies, illnesses, access issues that need to be accommodated.
• Any other information as may be relevant to your accommodation and/or as may be necessary for us to deliver accommodation services to you.

On the day of check-in, the applicant will be asked to fill out an In Case of Emergency (“ICE”) form providing details of illness/medical conditions/allergies, together with next-of-kin details, and authorising Heatherview Court to contact your next-of-kin in case of emergency. This form will be stored securely on a student’s file for the duration of their accommodation with Heatherview Court. Thereafter, it will be retained in accordance with our retention policy – see section 7 of this Privacy Policy.

3.5. During your time as a resident of Heatherview Court we will continue to process your personal data, including the items, set out at (2.1) and (3.3) above, together with the following:

• Your photograph/images for ID/Access card to access the residential block;
• Your images for CCTV purposes (see our CCTV policy);
• The number of the Room to which you are allocated;
• Information about behaviour, fines, complaints, health and safety, etc.
• Any other information relevant to your accommodation.

3.6. In respect of the personal data specified at (2.1) above, we will process that personal data on the following legal basis:

• Contract – the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. The contract referred to is the Licence Agreement that successful applicants will be asked to sign.

3.7. In respect of the personal data specified at (3.3) and (3.4) above, we will process that personal data on the following legal bases:

• Contract: (specifically, the Licence Agreement);
• Legal obligation;
• Legitimate interests;
• Vital interests; 

3.8. In respect of the personal data specified at (3.3) and (3.4) above, we will use that personal data for purposes including:

• to process your application for student accommodation;
• to contact you during your stay at Heatherview Court;
• to undertake any of the actions/steps set out in the Licence Agreement including but not limited to payment of fees, running fire drills, managing complaints etc;
• for the proper administration and management of the student accommodation undertaking;
• to care for and protect our staff and other residents;
• to process payments of licence fees and fines;
• to comply with our legal obligations and our contractual obligations to our insurance company;
• to process appeals;
• to ensure that relevant matters are taken into consideration where Heatherview Court receives subsequent applications from persons who were formerly residents (but whose licence was terminated for any reason);
• to resolve disputes, to vindicate our legal rights including taking and/or defending litigation etc.

4. Disclosure of Personal data and Data-Sharing:

We will share/disclose your personal data where it is necessary to fulfil a contract (specifically the Licence Agreement) for example, to facilitate your payment of the licence fee by transferring your personal data to a payment service provider. Where you have applied for student accommodation (whether successful or not) and during your time as a resident of Heatherview Court, we may share your personal data with third parties, including:

• Your parent/guardian (eg. accident, illness, welfare concerns, payment issues under the Guarantee, damage to property, eviction etc).
• Payments solutions providers to facilitate the receipt of fees and the payments of fines.
• With TUS, if you are a student there, eg to make a complaint relevant to the university’s complaints process.
• Only at the request of the student, to future prospective landlords for the purposes of giving an Accommodation Reference. Please note that this is only done upon receipt of a valid written request from the resident. The reference is handed directly to the resident.
• Heatherview Court on-site security provider. This is only done where it is relevant to a health and safety and/or anti-social behaviour issue.

We also share your personal data with other third parties where it is necessary for our internal business purposes and for the proper and efficient management of the student residences, for example with our insurers (including their duly appointed agents), our email platform (Office 365), IT service providers, support services, our insurers, our legal advisors. We will disclose your personal data to comply with law or any Court order, to enforce any contractual agreements between us and our customers, to initiate or defend any legal claims, to obtain legal advices or otherwise vindicate our legal rights. If we are restructured or undergo any internal corporate reorganisations, your personal data will be transferred to or acquired by another legal entity as part of those restructuring processes. We will share your personal data with bodies including An Garda Síochána and/or TUSLA where we consider same to be necessary to our legitimate interests, for public interests, and/or for the protection of your vital interests (or those of another person) including to protect physical integrity or life. We reserve the right to disclose your personal data/information to other law-enforcement authorities (eg. police organisations from another State) and other appropriate bodies (eg. Revenue Commissioners, etc) without notice to you where it is required for safeguarding the security of the State, or protecting the international relations of the State, or where it is required for the purpose of preventing, detecting or investigating offences, apprehending or prosecuting offenders or assessing or collecting any tax, duty or other money owed or payable to the State. In respect of the data referred to at (2.1) insofar as it relates to cookies and is gathered by website analytics companies (eg. Google Analytics).

5. Security

5.1. We take appropriate security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. This includes our taking reasonable technical security measures and organisational measures.

5.2. Although this website enables you to contact us, please note that communications across an electronic network is not a secure form of communication. Due to the risk of online fraud and the potential for unauthorised interception, we respectfully request that you never send us any sensitive personal data or financially sensitive information (eg. bank account details) using the “Contact Us” page of our website or by email. It may be possible for unauthorised third parties to hack the website, or otherwise unlawfully intercept such communications. We take no responsibility whatsoever in the event of any email or communication from you to us being intercepted or changed by an unauthorised person. We accept no liability for any losses resulting from same.

6. Retention

6.1. Retention periods are calculated on the basis of why the data/information was provided to us, and the reasons for our data processing.

6.2. Some personal data is only kept for a short period (eg. we will destroy at the end of an academic year because it is no longer needed). Some data we retain for a longer period (eg. retained after you leave).

6.3. For example, there may be some records that become immediately obsolete at the end of an academic year (eg. cleaning rota, fines notice, receipt for payment of fees). There may be some records that continue to be required until after year-end for financial audit purposes.

6.4. In general, we retain unsuccessful applicants’ records for at least 2 (two) months following the start of the academic year in which they applied. This is to ensure we can contact the unsuccessful applicant if a vacancy subsequently arises. Those records are shredded once no longer required. We reserve the right to retain records for longer than this period to ensure we can resolve disputes, to vindicate our legal rights including taking and/or defending litigation.

6.5. In general, we retain successful applicants/residents’ records for at least 2 (two) years following the completion of their accommodation. This is to ensure we can provide residential references to former residents to assist them in accessing private rental accommodation (such references only to be given upon receipt of a valid written request from a former resident), pursue outstanding account balances etc. We will also retain personal data during this 2 (two) year period to use same for all the purposes set out in 3.8 of this Privacy Policy. We reserve the right to retain records for longer than this period to ensure we can resolve disputes, to vindicate our legal rights including taking and/or defending litigation.

7.

You can contact the Data Protection Commissioner or consult their website for further information:
Data Protection Commissioner
Canal House
Station Road
Portarlington
Co.Laois
Telephone: Lo-Call 1890 252231
www.dataprotection.ie