Primera Capital (“Primera Capital”, the “Firm”, “we” or “us”) is committed to respecting and protecting your privacy and cares about the way in which your personal information is treated.
In this Privacy Statement we set out:
(i) what personal information we collect about you;
(ii) how we obtain your personal information;
(iii) how we use your personal information;
(iv) on what basis we use your personal information;
(v) how long we keep your personal information;
(vi) who we share your personal information with;
(vii) how we protect your personal information;
(viii) which countries we transfer your personal information to;
(ix) your rights regarding your personal information.
When we refer to “Primera Capital” we are referring to Primera Capital, the real estate investment and advisory services provider and all entities which form part of the Primera Capital group. See ‘Data controllers’ below for more information on the Primera Capital entities that control and process personal data.
We may collect personal information from you (and, through you, from your directors, officers, partners, employees, secondees, representatives, agents and contractors) in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our real estate or other services or as a result of your relationship with one or more of our staff and clients.
(i) basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person;
(ii) contact information, such as your postal address, email address, phone number(s), IP address, URL and browser type;
(iii) financial information, such as payment-related information;
(iv) technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically;
(v) information you provide to us for the purposes of attending meetings and events, including access and dietary requirements;
(vi) identification and background information provided by you or collected as part of our business acceptance processes;
(vii) personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data such as, but not limited to, financial information (eg. if you are an investor); and
(viii) any other information relating to you which you may provide to us.
We collect information from you as part of our business acceptance / client take on processes and about you and others as necessary in the course of providing real estate services.
We also collect your personal information while monitoring our technology tools and services, (including our website and email communications sent to and from Primera Capital) and we gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff, providing a business card or registering on one of our digital platforms or applications.
We may also collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.
We collect and process personal information about you in a number of ways, including through your use of our website and in the provision of services by us. We use that information:
(i) to provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients;
(ii) to manage and administer our relationship with you and our clients;
(iii) to provide information requested by you;
(iv) to fulfil our legal, regulatory and risk management obligations,
(v) to promote our services, including sending updates, publications and details of events;
(vi) for the purposes of recruitment; and
(vii) to provide and improve our website, including auditing and monitoring its use.
Our website uses Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing small text files called ‘cookies’ on your device. The information that the cookies collect, such as the number of visitors to the site, the pages visited and the length of time spent on the site, is aggregated and therefore anonymous. Please also see ‘Marketing and other emails’ below.
We use personal information to understand whether you read the emails and other materials, such as publications, that we send to you, click on the links to the information that we include in them and whether and how you visit our website after you click on that link (immediately and on future visits). We do this by using software that places a cookie on your device which tracks this activity and records it against your email address. Please see ‘Cookies’ for more information on cookies and how to manage and remove them.
We may also use a relationship management tool, where permitted by applicable law, to assess the strength of the relationship between individuals in Primera Capital and our clients or potential clients based on the frequency of email contact between them. We use that information in order to assess, analyse and improve the services that we provide.
We also collect and process personal information about you in relation to your attendance at our office or at an event or seminar organised by Primera Capital. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. We will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks. We will also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work. Please also see ‘Who we share your personal information with’ and ‘Which countries we transfer your personal information to’ below.
(i) engaging with an individual to provide services;
(ii) to comply with legal and regulatory obligations;
(iii) for legitimate business purposes. Please see ‘How we use your personal information’ for more detail;
(iv) where, if required, you have consented to our use.
Your personal information will be retained in accordance with our global data retention policy which categorises all of the information held by Primera Capital and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and Primera Capital’ business purposes.
We may share your personal information with other related entities of Primera Capital who provide company secretarial services as well as certain trusted third parties in accordance with contractual arrangements in place with them, including:
(i) our professional advisers and auditors;
(ii) suppliers to whom we outsource certain support services such as document or record retention, word processing, translation, photocopying and document review;
(iii) IT service providers to Primera Capital;
(iv) third parties engaged in the course of the services we provide to clients and with their prior consent, (v) third party providers of AML / CTF and similar services;
(vi) third parties involved in hosting or organising events or seminars.
Where necessary, or for the reasons set out in this statement, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new Primera Capital entities or to third parties through which the business of Primera Capital will be carried out.
We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws. However, although we will do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to us or to our website. Any transmission of personal information is at your own risk.
As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee the complete security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the internet. We have however implemented strict internal guidelines to ensure that your privacy is safeguarded at every level of our organisation and will continue to update policies and implement additional security features as new technologies become available.
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. EU standard contractual clauses are in place between Primera Capital and its related entities that share and process personal data. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.
The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects.
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event within one month of receipt of your request. We may request proof of identification to verify your request. All requests should be addressed to email@example.com
You also have the right to lodge a complaint in relation to our processing of your personal information with a local supervisory.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your personal information’) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by emailing us at firstname.lastname@example.org
There are a number of entities through which Primera Capital provides real estate services. Most of our main IT systems are located in Ireland and are controlled by Primera Capital. Depending on the location where services are provided, another undertaking or entity listed in the Contact Us section of our website may be the data controller in relation to your personal data. Please visit the Contact section of our website for details of the Primera Capital offices through which we provide real estate services.
Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those websites, please note that those websites have their own privacy policies and we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal information to those websites.
We reserve the right to change this Privacy Statement from time to time at our sole discretion. If we make any changes, we will post those changes here and update the “Last Updated” date at the bottom of this Privacy Statement. Your continued use of this website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Statement periodically for updates.