Privacy Policy
This privacy notice explains how we, Offr Limited of Unit 6e, Nutgrove Office Park, Rathfarnham, Dublin 14, D14 A0X2 with company number 615047 (we, us, our) process your personal data (you, your).
You should seek your independent professional advice in relation to your transaction. We do not provide advice within our service, this notice or otherwise.
1. Who does this privacy notice apply to?
This notice applies to:
- our website, widget and platform users;
- sellers/vendors;
- bidders and buyers/purchasers;
- estate agents;
- solicitors; and
- persons who interact with us, when you call us, email us or visit our offices.
This notice applies to you whether you act in your personal capacity or as employee or agent of an organisation.
2. What is personal data?
Generally, “personal data” refers to any information that identifies you or relates to you.
We will process personal data including your user details such as name, contact details such as your address and email, and image. When accessing our services, your device will automatically provide unique information such as mobile device ID, internet protocol (IP) address, cookie ID or online identifiers. Your browser may provide geolocation data, operating system, browser type and time zone setting. Our systems may generate usage data about how you navigate and engage with our services and download materials, security logs, and online activity data such as clickstream data, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences (including country and language), and methods used to browse away from our content or services. When we send you emails, we may collect technical email interaction information, such as open rates and if you clicked on any content.
If you are a seller, bidder or buyer, we may process information for due diligence purposes such as your user details, supporting information, such as (i) proof of ID such as passport or driver’s licence, (ii) proof of address, such as utility bills or bank statements, and (iii) proof of finance, such as agreement in principle and bank statements, property information from your seller questionnaire such as tax number (PPS Number for Irish individuals), property, estate agent and solicitor details, property images, co-owner details, asking price and property brochure prepared by the estate agent, transaction documents such as legal pack including contract of sale and title documents, pre-contract enquiries and pre contract replies, payment information such as your credit card details, bank account, IBAN number and other payment information, property viewing arrangement details and bid details. When you contact or visit us, we may process your image, professional details, relationship history, complaint details and details of your request, communications or other interaction.
3. How do we process your personal data and why?
The type of personal data we collect about you will depend on the circumstances and the content or services you are using.
3.1 Where we are a controller of the data
Generally, we will use your personal data as “controller” to (i) provide our services; (ii) respond to your queries; (iii) develop and promote our organisation and services; (iv) ensure the security and technical availability of our services; and (v) as further described in this notice.
We will update you about any new purposes of processing of your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.
It will be required for you to share information about others, such as your clients, advisors or the person you own or intend to own the property with, such as your spouse, friend, family or business partner. You should not provide to us information about others unless you have their permission to do so.
We will likely be unable to assist unless you provide the relevant personal data, and some personal data will be mandatory for our compliance with the law. Nevertheless, you should only provide the necessary personal data to us.
3.2 Where we are a processor of the data
We act as “processor” in relation to transaction documents uploaded by you in our vault if you are a solicitor, if you act in your professional capacity or if you act as a representative of a corporate seller or buyer. We process such transaction documents as processor on your instruction, and not use them for any other purpose.
If you are a buyer or seller, your solicitor processes and shares such documents and personal data about you in accordance with their own privacy notice or terms of engagement. Please speak to your solicitor about what information should or should not be shared.
4. Data Accuracy
We and other users will rely on the information provided by you as accurate, complete and up to date, and we shall be grateful if you would inform us of any changes.
Although we take appropriate steps to verify information, we cannot ensure the accuracy of information provided by other users, such as sellers, bidders or buyers information. In this case, the estate agent will be responsible for vetting sellers and approving bidders, and the solicitor will be responsible for the accuracy of transactional information.
5. What data we collect and why
5.1 Data about website, widget or platform users
Offr only shares your information with others in certain circumstances such as:
| Purpose | Personal data | Legal grounds for processing |
|---|---|---|
| To provide our services such as our website, content, widget, app including dashboard and features. |
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Necessary for the performance of our contract with you. |
| To send you information which you have requested about our services, requests from other users and to send you notifications about matters relevant to your use of our services and your engagement with us, such as events, surveys, changes in our terms, etc. |
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Service notifications are necessary for the
performance of our contract with you.
Other notifications are necessary for our legitimate interest in satisfying your requests, enabling collaboration between our users, providing help and guidance to our users, facilitating our services and organising related business activities. |
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To send you promotional information through various marketing channels including email, social media, telephone, sms, push notification, etc. about our services and our organisation, registering and reviewing campaign performance and profiling your information for direct marketing purposes. For example, we may send you our newsletter,insights email or use your contact details to display relevant ads on Facebook or Instagram and other social media platforms. |
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Where you signed up for our newsletter or other content or event, we will send you relevant information based on your consent. Where consent is not required, we may send you marketing communications based on our legitimate interest in promoting our business, satisfy your requests, to understand your interests based on the information available to us and to provide you with offers of relevant services. We may use cookies and similar technologies if you provided consent, and combine information with your user details, online activity & usage data and interests known, observed or inferred for direct marketing purposes. |
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We will use anonymised information including sex, age, finance type, property listing data, bidding patterns and other information to create market intelligence reports and similar materials for statistical and commercial purposes. |
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Necessary for our legitimate interest in understanding the effects of the market, informing business decisions, exploring business opportunities and developing and sharing knowledge. |
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To improve and develop our service functionality, including to:
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Necessary for our legitimate interest in delivering our services properly, efficiently and improving our business. We will use cookies and similar technologies if you provided your consent |
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To ensure proper administration of our business, including to:
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Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our services and debt collection or necessary for compliance with a legal obligation to which we are subject. We will use cookies and similar technologies if you provided your consent. |
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To share your information with our third party providers who facilitate the provision of our services and the fulfilment of essential service functions, such as web hosting, cloud storage, analytics, engagement tools, marketing, payment, plugin, communications providers, accounting or security tools and others. |
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Some are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring proper operation of our services. |
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To monitor our networks, websites, apps, widgets and systems for suspicious activities, test and audit our systems and deploy security measures. |
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Necessary for our legitimate interest to ensure the security of our organisation, people and services or necessary for compliance with a legal obligation to which we are subject. |
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To monitor operations, user activity and networks for fraud prevention and crime detection purposes, including information from third parties who may alert us about suspicious activities. |
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Necessary for our legitimate interest in detecting and preventing fraud and illegal conduct or necessary for compliance with a legal obligation to which we are subject. |
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To share information within our offices and our group companies. |
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Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our content and services, run our organisation and decide on future strategies. |
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To share data with a successor or partner legal entity in accordance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business. |
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Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations. |
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To process information as is required for our compliance with the law or to establish, exercise or defend legal claims. To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order. |
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Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims or, where appropriate and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws. |
5.2 Data about sellers / vendors
| Purpose | Personal data | Legal grounds for processing |
|---|---|---|
| See above for information processed about seller as a user. | As above | As above |
| To pass your due diligence based on information provided by you in your seller questionnaire or otherwise and by third party background screening providers. |
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Necessary for our legitimate interest in maintaining accuracy of information and good standard of service and for fraud prevention or necessary for compliance with a legal obligation to which we are subject. |
| To share information about you with your estate agent for due diligence purposes, and to enable the estate agent to ask you additional questions. |
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Necessary to take steps initiated by you in our service and for the performance of a contract with you. |
| To share information about you with potential bidders. |
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Necessary for the performance of our contract with you. |
| To monitor activity in relation to your property to send you, and share your information with the estate agent to enable the estate agent to send you, notifications about your property. |
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Service notifications are necessary for the performance of our contract with you. |
| To share materials uploaded by your solicitor with the estate agent, the buyer and their solicitor. We act as “processor” on your solicitor’s instruction. |
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Necessary for the performance of our contract with you and to comply with your solicitor’s instructions. |
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To enable us to, and to share your information with the estate agent to enable the estate agent to, market your property. Please speak to your estate agent about the marketing of your property. |
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Necessary for the performance of our contract with you. |
5.3 Data about bidders and buyers/purchasers
| Purpose | Personal data | Legal grounds for processing |
|---|---|---|
| See above for information processed about bidder/buyer as a user. | As above | As above |
| To pass your due diligence based on information provided by you and by third party background screening providers. |
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Necessary for our legitimate interest in maintaining accuracy of information and good standard of service and for fraud prevention. |
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To share information with each estate agent for due diligence purposes, e.g. if you ask for permission to bid or if you wish to make an offer, to enable the estate agent to review your supporting information. Please note: The supporting information provided by you may be shared with multiple estate agents if you wish to bid or place offers on one of their properties. |
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Necessary to take steps initiated by you in our service and for the performance of a contract with you or necessary for compliance with a legal obligation to which we are subject. |
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To share information with estate agent about proposed viewing arrangement. |
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Necessary for the performance of our contract with you. |
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To facilitate your payment of booking deposit or auction deposit. |
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Necessary for the performance of our contract with you. |
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To share information about your interest, bids or offers and contact details with the estate agent and seller. This will include sharing your connection status and the country from which you are connecting to the internet with the estate agent if you participate in an auction. This information will help determine how to assist you if you have lost connection at a critical stage of the auction. |
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Necessary for the performance of our contract with you and necessary for our legitimate interest in keeping our users informed about relevant activity. We will share information about the country from which you are connecting to the internet if you provided your consent. |
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To share materials uploaded by your solicitor with the estate agent, seller and their solicitor. We act as “processor” on your solicitor’s instruction. |
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Necessary for the performance of our contract with you. |
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To facilitate third party services, such as mortgage services, and share your details with third parties upon your instruction. |
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We will share your details upon consent. |
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To monitor your interest and share your information with the estate agent to send you, and enable the estate agent to send you, notifications about properties you might be interested in, new bids in an auction, auction progress of termination. |
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Service notifications are necessary for the performance of our contract with you, and other notifications are necessary for our legitimate interest in keeping our users informed about relevant activity. |
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To provide details of your and your solicitor’s interaction with the vault, including downloads, to the seller and seller’s solicitor. |
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Necessary for our legitimate interest in providing meaningful functionalities and records. |
5.4 Data about estate agents
| Purpose | Personal data | Legal grounds for processing |
|---|---|---|
| See above for information processed about estate agent as a user. | As above | As above |
| To pass your due diligence before your account is activated based on information provided by you, third party background screening providers and public records. |
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Necessary for our legitimate interest in maintaining accuracy of information, good standard of service and fraud prevention. |
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To share your details and email address with other users and potential bidders. |
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Necessary for our legitimate interest in maintaining transparency of service and fraud prevention. |
| To send you notifications about activity in relation to your client’s properties. |
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Service notifications are necessary for the performance of our contract with you. |
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To send you and others in your organisation emails, notifications and display ads to market our services. |
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Necessary for our legitimate interest in promoting our business. |
5.5 Data about solicitors
| Purpose | Personal data | Legal grounds for processing |
|---|---|---|
| See above for information processed about solicitor as a user. | As above | As above |
| To pass your due diligence before your account is activated based on information provided by you, third party background screening providers and public records. |
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Necessary for our legitimate interest in maintaining accuracy of information, good standard of service and fraud prevention. |
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If you act for the seller, share your details with estate agent who will invite you to the platform. If a bidder inputs your details, Offr will invite you to the platform. Please alert us without delay if you do not act for a person who provided your details. |
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Necessary for our legitimate interest in maintaining accuracy of information, good standard of service and fraud prevention. |
| Send you notifications about activity in relation to your client’s transactions. |
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Service notifications are necessary for the performance of our contract with you. |
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Share your details and email address with other users and potential bidders. |
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Necessary for our legitimate interest in maintaining transparency of service and fraud prevention. |
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To enable your access to the vault. We act as “processor” on your behalf in relation to transaction documents. |
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Necessary for the performance of our contract with you. |
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Provide details of your interaction with the vault, including downloads, to the other party. |
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Necessary for our legitimate interest in providing meaningful functionalities and records. |
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Share the details of your transaction with other solicitors in your law firm, subject to instructions from your law firm’s super user. |
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Necessary for our legitimate interest in delivering a relevant service, maintaining transparency of service and fraud prevention. |
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To send you and others in your organisation emails, notifications and display ads to market our services. |
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Necessary for our legitimate business interest in promoting our business. |
5.6 Data about our contacts and visitors
| Purpose | Personal data | Legal grounds for processing |
|---|---|---|
| See above for processing for the administration of our business. | As above | As above |
| To assist and contact you in relation to your enquiry. |
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Necessary for our legitimate interest in responding to queries, maintaining business relationships and administering our business. |
6. Sharing your data
We will generally not share your information except with (i) other users of our platform as explained above, (ii) with our third party service providers, commercial partners and group companies for the purposes set out above, (iii) where we are compelled by law, and (iv) other third parties where you have provided your consent.
Please note we will not share information with other users other than through the platform. Although we ask every user to commit to confidentiality, we cannot be responsible for other users sharing information by other means outside the platform.
7. Third parties may process your data
If you are represented by or interact with an estate agent or solicitor, you should refer to their privacy notice for further detail about how they process your personal data, including in our vault.
Our service may contain links to other websites, third party services and plugins. You should check the privacy statements of these third party providers before you use them as Offr is not responsible for how they may process your personal data.
8. How long is your personal data kept?
We will keep your personal data for as long as is necessary for the purposes listed above or longer, as may be required by law. Generally, the retention periods below will apply. You may contact us for further details or request deletion of your personal data at any time.
| Category of personal data | Retention period |
|---|---|
| user details, contact details | 6 years from collection or 1 year following account closure. |
| online activity, usage, browser and device data, bid history, interaction data | 6 years from collection. |
| supporting information | 180 days from upload, unless otherwise instructed by you. |
| transaction documents in the vault | Generally, 1 month following completion, unless otherwise instructed by you or your solicitor. |
| all other personal data | 6 years from collection. |
Please note that we ask every user to commit to confidentiality and compliance with data protection laws. However, we are not responsible the retention periods adopted by estate agents and solicitors.
After the retention period, your personal data will either be securely deleted or anonymised and it may be used for analytical purposes. You must back up your data if you wish to keep it for longer.
9. How we secure your personal data?
We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of personal data. We also seek to ensure our service providers do the same.
We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation, where appropriate.
Our staff will access your personal data on a need to know basis.
10. Where is your personal data processed?
We may transfer your personal data to our group companies, suppliers and other third parties in countries different to your country of residence. Generally, our data is held in the Republic of Ireland.
Where we transfer your personal data outside the European Economic Area (EEA) or the UK, we will only do so, where we are satisfied that your data protection rights are adequately protected by appropriate technical, organisational and contractual safeguards in accordance with data protection laws.
These safeguards may include the standard contractual clauses adopted by the European Commission or the Information Commissioner’s Office and where transfers are to the United States of America, we will ensure that the appropriate contractual mechanisms are in place.
You may request further information on the measures used for the international transfers or access to your personal data from outside the EEA or the UK.
11. Your right to opt out
If you would like us to stop sending you marketing communications and to process your personal data for direct marketing purposes, please let us know.
You can stop our communications at any time by clicking on the unsubscribe link at the bottom of the message.
12. Your data protection rights
Subject to certain exemptions, limitations and appropriate proof of identity, you will generally have numerous rights in relation to your personal data, including the following:
- Right to information about matters set out in this notice.
- Right to make an access request to receive copies of personal data.
- Right to rectification of any inaccurate or incomplete personal data.
- Right to withdraw consent previously provided.
- Right to object to our processing of personal data based on our legitimate interests, and any automated processing and profiling.
- Right to erasure of personal data, within limited circumstances.
- Restriction on the processing of personal data.
- Right to data portability from one service provider to another, where applicable.
- Right to lodge a complaint with your country’s data protection authority, such as the Data Protection Commissioner (An Coimisinéir Cosanta Sonraí).
All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period we shall explain why and process it as soon as possible thereafter.
13. Contact us
Please contact Offr if you have any queries or concerns about how we use your personal data. You can contact us using the details below. Offr will try to resolve your query as quickly as we possibly can.
If you are not happy with the response you obtain from Offr you can contact the data protection authority. Please see the ‘how to contact us’ section on its website.
14. Updates
If we make any changes to our notice you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.
If you do not agree to the changes, please do not continue to use our content or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.