Key Details

• Policy prepared by: EVARH Committee
• Approved by Executive Committee on: 14/5/19
• Policy became operational on: 25/5/19
• Next Review Date: 26/8/19

Introduction

In the normal operations of the Association, Eagle Valley Association of Residents & Home Owners (EVARH) needs to gather and use certain information about members, officers and other people the Association has a relationship with or may need to contact. This policy describes how this personal data must be collected, handled and stored to meet the Association’s data protection standards and to comply with the law.

The Eagle Valley Association of Residents & Home Owners is committed to protecting and respecting your privacy. For any personal data you provide for the purposes of your membership, Eagle Valley Association of Residents & Home Owners is the Data Controller and is responsible for storing and otherwise processing that data in a fair, lawful, secure and transparent way.

EVARH may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 25^th May 2019.

Why this policy exists

This privacy policy ensures that EVARH:

• Complies with the data protection law and follows good practice

• Protects the rights of Members, Officers and Partners

• Is open about how it stores and processes individuals’ data

• Protects itself from the risks of a data breach

General Data Protection Regulation (GDPR)

General Data Protection Regulation (GDPR) requires that any organisation that collects, stores, processes and shares personal data about EU citizens must have permission to do so and that permission must come from the person to whom the data applies. It is also a requirement that each person should be aware of what specific data is being stored and how it is processed.

What data is being collected?

You may give us information about you by filling in forms online on our website properties, at an event, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register with the Association, participate in events, discussion boards on our website and forums, or provide directly to Officers of the Association.

When you become a Member of or renew your membership, you and the other persons whom you have registered as associated with your House, will automatically be registered as a Member of EVARH with access enabled to our online EHARH Member Portal. This will enable you to sign into and update your Eagle Valley details and be kept up to date on the Association’s activities, forums, events etc. It is vital, therefore, that a valid email address and mobile phone number is given, so that you can ensure that your data is correct and so that you can set your own privacy settings. If you have any questions about the continuing privacy of your personal data when it is shared with EVARH, please contact association@eaglevalley.ie

The information you give us may include your

• name
• date of birth
• address
• e-mail address
• phone numbers
• gender
• name of the Eagle Valley house with which you are associated and your role in relation to that house
• job title/position and any skills you may wish to volunteer to the Association
• personal photographs.
• billing address and billing details
• what we learn about you from communications between us
• Consent – if you provide us with information based on your consent, any consents you provide to us
• Information you provide to our Members, Officers, and Administrators

As part of your House Membership of the Association, you may also give us information to register additional people associated with your House i.e. House Owners, Family Members, Tenants, Rental Agencies/Agents, other Residents of the House

We may also ask for other information relevant to the running of the Association and its services, activities and events.

For each House in Eagle Valley, the Association also collects the publicly available Ownership data i.e. name and postal address from LandDirect.ie and the Register of Deeds with the Property Registration Authority of Ireland (PRAI). The Association may also request Landlord Owners details from the Residential Tenancies Board Ireland (RTB)

How Will The Information Be Used?

We maintain a database for all members, and this will enable us communicate with you as and when necessary. The reason we need your Data is to be able to support the centralised record keeping of the EVARH, to administer your membership and to provide the membership services you are signing up to when you register with the Association.

We, Eagle Valley Association of Residents & Home Owners, make use of the myClubhouse software supplied by Simmetrics Ltd to process personal data we include on our  
EHARH Member Portal /MyClubhouse website in accordance with our privacy policy here. Simmetrics Ltd processes your personal data on our behalf and they can only do so in accordance with our written instructions. You can find the details of our data processor’s privacy policy here (http://www.myclubhouse.co.uk/Home/PrivacyPolicy).

Our lawful basis for processing your personal information is that we have an obligation to you as a Member to provide the services you are registering to the Association for which involve:

• Internal record keeping and subscription management
• We may use the information to improve our services.
• We may periodically send information which we think you may find interesting using the email address and mobile number which you have provided.
• From time to time, we may also use your information to contact you for Member research purposes.
• We may contact you by email, phone, mobile or post.
• We may use the information to customise the website according to your interests and feedback.
• Enabling you with access to communicate with other members on the Association’s online Member forums on Facebook and www.eaglevalley.ie/Member-login

I Want To Keep My Contact Details Private

On the EHARH Member Portal, only Administrators and Committee Members can see all Members' details. Area Representatives can only see the details for the Members in their Area.

The visibility of your information to other Members is controlled on an opt-in basis; we call this 'sharing' of contact details. By default, no contact details will be visible. Members can explicitly select which of their details will be visible. So, for example, they could make their email address visible or just their mobile phone number.

How Can Members Contact Other Members Directly

Where a Member hasn’t shared their contact information on the EHARH Member Portal , myClubhouse has a 'Message Me' facility which allows members to send an email to a single other Member without knowing what their email address is. Naturally, the sender will have to reveal their own email address in the process though. This feature allows communication between members without members having to worry about being spammed.

In offline communications, where one Member seeks the unpublished contact details of a second Member, they can make a written request to the Association at association@eaglevalley.ie explaining their purpose and an Officer of the Association will contact the Member for their permission to release their contact details.

Members Can Manage Their Own Data

As with most online systems, Members manage their own profiles (and those of their children and family group members). Their profile includes:

• Username and password
• Full name
• Address
• Home, work and mobile phone numbers
• Up to two email addresses
• Date of birth
• A photograph or avatar
• Parent details (if parents also registered on the system)
• The Subscription Payment history associated with the Member House in line with our Subscription Policy
• The Eagle Valley House with which they are associated and their role in relation to that Household (e.g. Owner Resident, Owner Landlord, Owner Family Member, Tenant, Rental Agency/Agent)

Information Sharing

Except as provided in this Privacy Policy, we will not provide your Personal Information to third parties.

In order to provide you with technical assistance or advice or guidance in connection with our services, we may share your Personal Information with organisations we use to provide our services to you and which may host your Personal Information on our behalf. We will only do this if they agree to keep your Personal Information safe and secure. In addition, we may disclose your Personal Information:

• to other third parties such as regulators and law enforcement agencies;
• to the extent that we are required to do so by law;
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud and crime prevention and detection) reducing credit risk).

International Data Transfers

The Association’s data processing requires your personal data to be transferred outside of Ireland for the purpose of cloud hosting. Where the Association does transfer your personal data overseas it is with the appropriate safeguards in place to ensure the security of that personal data.

We will ensure that, to the extent that any Personal Information transferred by us outside the European Economic Area (EEA) is transferred:

• only to a country or countries that the European Commission has determined ensures an adequate level of protection; or
• where we have put in place appropriate safeguards, for example by using a contract for transfer which contains specific provisions relating to data protection that have been adopted by the European Commission or competent national data protection authority; or
• where you have consented to this or there is another lawful basis on which are entitled to rely to make the transfer.

How Long Will the Data be Stored for?

We aim to retain Personal Information only for as long as it is required for the specific purposes for which it was collected, as described in this Privacy Policy. Where we are required, for example, as a result of a legal or regulatory obligation, to store Personal Information for longer, Personal Information will be dealt with in accordance with this Privacy Policy.

Your Rights Regarding Your Personal Data

As a data subject you may have the right at any time to request access to, rectification or erasure of your personal data; to restrict or object to certain kinds of processing of your personal data, including direct marketing; to the portability of your personal data and to complain to the Data Protection Commissioner’s Office about the processing of your personal data. As a data subject you are not obliged to share your personal data with the Association. If you choose not to share your personal data with us, we may not be able to register or administer your membership.

Controlling Your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways:

• whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at association@eaglevalley.ie
  
  We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Acts 1988 and 2003. A small fee may be payable. If you would like a copy of the information held on you please write to association@eaglevalley.ie

If you believe that any information that we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

Security

We will take reasonable technical and organisational precautions in accordance with applicable data protection laws to prevent the loss, misuse or alteration of Personal Information provided to us.

We will store all Personal Information provided to us on our secure (password- and firewall-protected) servers.

All electronic transactions entered into via the website will be protected by encryption technology.

You are responsible for keeping your password and other login details confidential. We will not ask you for your password (except when you log in to our websites).

Whilst we have security processes in place to help protect your Personal Information and to prevent unauthorised access to and use of your Personal Information, you acknowledge that Personal Information that is transmitted over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Children

We do not knowingly collect, use or otherwise handle Personal Information relating to children under the age of 18 and our websites are not targeted at children under 18.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Third Party Websites

Where our sites contain links to third party websites, for example, social media channels like Facebook, Twitter, you should review the privacy policy of that channel before clicking on the relevant link to learn more about what Personal Information that channel will collect, use and otherwise handle about you. We are not responsible for the privacy policies or practices of third party websites.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version on our website. You should check this page occasionally to ensure you are happy with any changes. All changes will take effect as soon as the updated policy is published, subject to all applicable law.

We may also notify you of material changes to our Privacy Policy by email where we have already collected Personal Information about you and/or where legally required to do so and may request that you agree to these changes.