Privacy Policy HeyDay

1. Who We Are

Heyday Carmans Hall managed by Orla Student.

2. Applicable Legislation

EU General Data Protection Regulation (“EU GDPR”)
Data Protection Act 2018 (“DPA 2018 (Ireland)”)
Data Protection Acts 1988 & 2003
ePrivacy Regulations 2011

3. How we Collect Your Information

Heyday (referred to herein as “we”, “us”, or “our”), recognise the importance of protecting the privacy of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or device (“Personal Data”), particularly our consumers or users (referred to as “you” or “your” in this Privacy Notice).

This Privacy Notice applies to information we collect as a data controller/data processor (on behalf of an OpCo or a PropCo)/joint controller, and information is collected in the following ways:

through websites operated by us;
through other websites and online services that we own, operate, or make available and that link to this Privacy Notice;
when you apply to live/currently live/have lived at a property which is managed by us (please note that, in some instances, we may be a data processor);
when you apply for a job with us. B. there are separate privacy notices for current staff members (on our intranet) and prospective staff (available when you apply to work with us);
when you are one of our prospective, current or former clients;
when you engage/have engaged with us as a third-party vendor or contractor;
through other general enquiries we receive (including postal mail, electronic mail, telephone requests, and in person).

This Privacy Notice describes what Personal Data we gather, how we use it, how it is shared and how you can access, delete, correct, change, and limit our use of it. If you are asked to submit details via any of our websites or apps, you may be requested to agree to additional terms regarding our use of your Personal Data, and those additional terms will apply in that context. Any additional terms will be provided for your review at the time that you submit your information.

4. The Personal Data we Collect

To provide you services, we collect, or you may choose to provide Personal Data that may identify you or relate to you as an individual. Depending upon the type of relationship you have with us, we may collect the Personal Data described in general terms below.

a) When you interact with us

When you visit our websites, create an account with us, call our Sales Team or Out of Hours Call Centre, or contact us via our social media platforms or our Live Chat feature, we will collect the following data, depending on the platform:

first name, last name;
account login credentials;
marketing preferences;
your contact details depending on how you reach us (i.e. phone number or email address), details about your enquiry, further information needed to identify you;
your activity on our website, behaviour, and interests including the pages you visit;
your name as it appears publicly on a social media platform, public profile image and message history;
the phone number you are calling from (unless this is withheld), the date, time, and duration of the call, and an audio record of the call. N.B. calls to our property teams are not recorded;
your Live Chat ID, your preference to disable Live Chat and any information you give us through Live Chat.

This data may be collected for the following purposes:

calls to our Sales Team are recorded for training and monitoring purposes;
directly from you to communicate with you and respond to your enquiry, improve our service where we can and allow us to ask security questions to ensure we are speaking with the right person;
directly from you and Live Chat performance cookies to provide live customer service chat on our website and identify the device during visits;
directly from you if you take part in any online surveys on our website and website user testing;
we use your marketing preference to send you discounts, offers and direct relevant adverts to you. When you opt-in to email marketing, we share your email address with third party advertising platforms (including Google Ads and Facebook Ads) who choose the advert you see on your social media platforms;
from web application cookies – for instance, if you set up your privacy preferences or log into your account, for the website to function, or to implement cookies which act on your cookie preferences;
from optional targeted advertising cookies and optional performance cookies to optimise performance of our website, track and report conversions from Google, remarket a product, personalise our adverts on Facebook or target adverts through paid Google advertising.

b) When you book one of our rooms

When you book one of our rooms after creating an account, depending on the type of booking, we may collect the following information from you or a group booking if booking direct, or from your institution, or a booking agent if they are making the booking on your behalf:

title, first name, middle name, last name, preferred name;
mobile phone number;
date of birth;
gender;
nationality;
university ID number (if applicable);
passport number;
landline number;
phone contact preference;
current living status;
email address;
home address;
year of study (if applicable);
name of university attending, course subject, course title (if applicable);
alternative email address, phone number and address;
photograph;
disability or medical information (if disclosed and consent given);
written communications between you and the agent (if booking via an agent);
pre-sessional start/end date (if applicable);
course dates (for short-term lets);
preference of city and property (for group bookings);
invoice address (if booking via a third-party website);
direct marketing preference(s).

We use this information to:

get you set up on our student accommodation management system and administer your tenancy;
facilitate your access to internet connection during your tenancy;
contact you about other products and services we think may be of interest to you (only where you have given your consent);
help you book a suitable room or ensure you have the necessary aides, equipment or PEEP (Personal Emergency Evacuation Plan) for your stay;
conduct surveys and studies to help us measure satisfaction and our performance (surveys only), improve our service where we can and better understand our customers year on year;
provide evidence to local authorities for council tax exemption or the provision of electoral roll services;
register and protect your deposit, and send you your deposit protection certification (if applicable);
keep a record of what has been agreed with the agent and track referred customers for debt collection and commission purposes (if applicable);
provide a cashback reward on an eligible booking;
conduct Sanctions, Politically Exposed Persons and other checks on all applicants, tenants, authorised residents, and guarantors.

c) During your stay with us

Once you have moved into your new home, we will collect and use other information from or about you depending on how you use our services and what happens during your stay with us. This includes:

your conversation history in our KliQ App, initials, tenancy address, phone number and location, to provide you with the App features, if you have downloaded the App. This information may be shared with the other occupants of your (future) flat who have installed the App and third-party security services, if contracted for your building, if you report a lock-out;
your name and room number on a parcel, to notify you of a delivery and for our internal parcel management records;
video recording of you in the property or an external area covered by our CCTV cameras. We use CCTV to prevent and detect criminal activity, fraud and misuse of or damage to our property and investigate any allegations, misuse or damage. Where and when used, body-worn cameras will record video and audio. We use these when undertaking safety and security tasks to reduce the risk to our employees and customers facing aggressive or threatening behaviour. Please note that, upon receipt of a valid request, CCTV footage/images are shared with the police;
in certain properties, we collect environmental data about your room (only applicable if your room has a smart meter); information about the heat, humidity, carbon dioxide levels, electricity consumption, and open windows of your room are collected to understand the energy efficiency of the room and assess ongoing issues with the conditions of a room, flat or floor. We aggregate and anonymise this information for our Environmental, Social and Governance (ESG) reporting;
relevant account information and details of any accident or incident you are involved in that is reported to us. We use this to carry out an investigation and may also be given information by any third party that was also involved;
details about a concern regarding your health or wellbeing which you disclose to us. Where it is appropriate to ask for your consent and you choose to give it, we will share this data with an agreed individual or organisation so they can support/continue to support you;
your account details, account balance, name, email address and tenancy address; these will be used if you fall into arrears. We will try to collect arrears internally or via your agent (if applicable), however, if unsuccessful and depending on where you are in the arrears process, we may share this data with:
– our service provider/s;
– your Guarantor (if applicable);
– an external firm to initiate the eviction process (as required);

data relating to a complaint (this may come from you or from the Property Services Regulatory Authority (Ireland) (PSRA) via their complaints process. If we have received a complaint from you, if necessary, we will share details of this and your identity with PSRA;
your name, customer number and accommodation block to provide notifications and a personalised experience within the KliQ App, using a third-party engagement platform (who then use aggregated, usage data for service performance purposes);
your name, customer number and email address to invite you to leave a review, which is administrated by a third-party;
your name, age, university (if applicable), property, nationality, booking type and year of study. We share a selection of data from these categories, as necessary, with third-party data insight providers to enable them to provide us with aggregated, non-identifiable information about our customers, which is used to help improve and inform our customer experience and business strategy;
your image where you are attending an event at your property. You will be notified of this so that you can opt-out if preferred.

d) After your stay

If you need us to provide a reference after you move out, we will provide information relating to your tenancy as requested by the landlord or letting agent, with your consent. The information shared will vary depending on the reference request and may include tenancy start/end dates, tenancy address, weekly/monthly rent price, confirmation that your payments are up to date, and confirmation of any damage charges you have incurred.

If you are eligible for a refund of your deposit, we will share your name, email address, phone number, customer ID number and amount to be refunded with the deposit provider to enable them to facilitate your refund.

If you are in arrears after you have moved out, we may share your account details, account balance, name, email address, phone number, home address, and your Guarantor’s contact details with a third-party debt collection company.

e) Resident Wardens

In certain circumstances, we offer residents the opportunity to become Resident Wardens. This ensures that there is always someone available who can be called on in an emergency. In order to perform their duties, the Wardens will have access to certain personal data. This includes: name, room numbers, issue they have been asked to get involved in. They have signed up to a non-disclosure agreement regarding the processing of this data.

f) Guarantors, or an emergency/key contact

If you have agreed to be a guarantor, emergency contact or the named person for a customer, depending on your role, we may collect the following information from you:

title, first name, last name;
email address;
contact phone number;
relationship to customer;
gender;
date of birth;
nationality;
home address;
level of account access;
ID details.

If you are a guarantor on the account, this may be used to:

confirm your identity and respond to account-related queries;
contact you and arrange payment if the customer has failed to make a payment. If referred after the tenancy has ended, we may share your data with a third-party credit collection company (guarantor);
notify you if the customer has breached their tenancy agreement and subsequent updates;
notify you of any unforeseen changes to the tenancy;
conduct Sanctions, Politically Exposed Persons and other checks.

If you are an emergency/key contact on the account, this may be used to:

prove you are 25 years or older, interested in the customer’s wellbeing and have an existing relationship with them;
contact you in an emergency situation or a non-emergency situation (if we have consent to do so). B. where vital interests are used, we will not require consent;
in the event of an emergency, we may share your contact information with the medical or emergency services as necessary, enabling them to reach and update you about an incident affecting the customer.

g) Our clients

We may obtain the following types of personal data about Clients:

clients’ names, postal and e-mail addresses and phone numbers;
employment information (e.g., job titles) relating to clients;
gender, age, nationality, and date and place of birth of clients;
clients’ communication preferences;
financial information.

As a matter of practice, we will not collect any Special Category personal data relating to Clients. To the extent that there is a need for us to process such Special Category data, we will obtain the Client’s prior consent through the relevant communication channels within Orla Living Limited, along with outlining the reason for collecting this information.

We may use the personal data we obtain about Clients (OpCo/PropCo) to:

manage our past/existing prospective client relationships;
perform the contract for services which we are engaged to carry out;
communicate with representatives (for example, about services we offer or intend to offer or in connection with events);
perform accounting, auditing, billing, and collection activities;
safeguard and defend our interests;
comply with applicable legal requirements, industry standards, and our policies;
emails exchanged;
meeting records.

h) Our Suppliers

We may obtain the following types of personal data about our Suppliers:

full name; job title/role; company name and business ID;
work address; work phone number; work email address;
background check results (if relevant to the contract);
certificates or licenses;
bank account details;
security training or policy attestation;
emails exchanged;
meeting records;
portal activity logs (e.g., onboarding platforms, OneTrust, vendor management systems).

We may use the personal data we obtain about Suppliers for the following purposes:

managing the supplier relationship;
contracts, performance, and administration;
payment, invoicing, and financial administration;
legal, regulatory, and compliance obligations;
security and access management;
risk management and due diligence;
dispute resolution and enforcement.

This information may be considered personal data where it can be linked to an individual.

i) Aggregated data

Occasionally, we provide aggregated statistics about our sales, customers, traffic patterns and other site information to third parties, but these statistics do not include any information that could personally identify you.

5. Our Lawful Bases for Processing

We are required to have a lawful basis for using your personal data. At least one of the following must apply: consent, contract, legal obligation, legitimate interest, public interest or vital interests. In this section we explain which one we commonly rely on when we use your data in a certain way, as detailed in the previous sections.

We use your information for the performance of our contract with you:

when you create an account, or when you or a third-party acting on your behalf signs a tenancy agreement with us or registers a group booking;
when you are in are arrears;
to notify you of a parcel delivery or other service-related message;
when you are a guarantor for one of our residents;
when you are our client and we are delivering services to you.

We use your information for our legitimate business interests for the following:

When you visit our website or log in to your account – our legitimate interests are to operate a secure and effective website, ensure account functionality, prevent fraud or misuse, and understand how visitors use our services so we can improve them.
When you contact us with an enquiry, a complaint, or provide other feedback to us on any channel – our legitimate interests are to respond to your queries, resolve issues, record interactions, and improve the quality of our services.
When you sign up to use our KliQ App – our legitimate interests are to provide you with access to the app’s features, verify your identity, maintain account security, and support your use of our accommodation services.
When using our Netcall contact centre – our legitimate interest is to respond to your queries, manage bookings, ensure service quality, and maintain accurate records of our interactions with you.
When we provide you with internet connection – our legitimate interests are to deliver essential connectivity services as part of your accommodation, ensure network security, and prevent misuse of our systems.
To conduct customer satisfaction surveys – our legitimate interests are to measure satisfaction, understand customer needs, and improve our buildings, services, and overall resident experience.
To use CCTV and body-worn cameras inside and outside the buildings we manage – our legitimate interests are to ensure the safety and security of residents, visitors, and staff; protect our property; and prevent and detect crime or anti-social behaviour.
To share your data with a debt collection company if you are in arrears – our legitimate interests are to recover outstanding payments, manage financial risk, and ensure fair and consistent enforcement of tenancy obligations.
When you volunteer with us as a Resident Warden – our legitimate interests are to manage your role, support the residential community, ensure building safety, and maintain appropriate records relating to your duties.
Where applicable, to process data on your energy consumption of the room – our legitimate interests are to monitor and manage energy usage, allocate costs fairly where required, support sustainability initiatives, and maintain efficient building operations.
To obtain aggregated, statistical information about our customers – our legitimate interests are to analyse trends, improve our services, plan resources effectively, and monitor business performance without identifying individuals.
When you are an emergency/key contact – our legitimate interests are to safeguard residents by contacting you in the event of an emergency or welfare concern relating to the individual who has named you.
To use photography at an event which you may be attending – our legitimate interest is to promote our properties. You will be notified that photographs are being taken so that you can opt-out if preferred.

We gain your consent to use your data for the following purposes:

to market directly to you about other products and services we think may be of interest to you and to show articles or other content on the KliQ app we think are relevant based on your city or property;
to process any medical, disability, general health or wellbeing information we hold on you (if disclosed). The exception is where we use vital interests as our legal basis.

We have a legal obligation to use your information:

as evidence to local authorities for council tax exemption or the provision of electoral roll services;
to support authorities with managing a local outbreak of disease;
to register and protect your deposit (if applicable)
to ensure your room is safe for you and to assist you with a Personal Emergency Evacuation Plan (PEEP) (if applicable);
as part of any accident or incident investigation and records involving you;
when you check in for a hotel booking;
to share data with the police for the purposes of the prevention and detection of crime.

Please note that these lists are not exhaustive.

6. Disclosure of Information

We may share your Personal Data with third parties in the following ways:

with our affiliates – we may disclose personal data/other data with our affiliated companies as necessary to communicate with you, provide you services, fulfil our contract with you and to accomplish our business purposes;
service providers – we may disclose personal data/other data to third parties who perform services such as hosting our websites, processing payments, conducting research and analytics, providing on-site services, providing benefits, conducting financial, identity and other legal checks and providing professional advice. All such contractors and sub-contractors shall be contractually required to ensure that they adhere to the requirements imposed by the relevant data protection legislation;
Property Companies/Operating Companies – as Managing Agent, we may be required to disclose personal data/other data to the other parties with an interest in the properties we manage. They may use this data for their own purposes and legal obligations;
partners – we may disclose personal data/other data to our advertising partners or to sponsors of events and promotions in which you have expressed interest or for which you have registered;
business transitions – if we go through a business transition, such as a merger, being acquired by another company, or selling all or part of its assets, personal data may be transferred as part of that transition.
to protect of defend our legal rights/the legal rights of others – we may also use and disclose personal data as necessary to comply with applicable laws, respond to requests or requirements from government authorities, enforce our terms and conditions, or to otherwise protect the rights, property, or safety of our employees, residents and other persons, including exchanging information with third parties for fraud protection, credit risk reduction and Council Tax purposes;
new Managing Agent – if a property is transferred to another Managing Agent we will securely transfer personal data to them to allow for a smooth transition of services;
safeguarding – we may need to share information with other organisations (for example a university) for safeguarding reasons;
the police – for the purpose of detection and prevention of crime;
in an emergency – using ours/a third-party’s vital interests;
your guarantor – if you are a tenant and you fail to pay your rent, we may contact your guarantor and inform them of this failure when exercising our rights under the guarantee;
marketing – if you have agreed that we may do so, we will share your Personal Data with identified third-parties so that they can contact you with details of their products and services.

We may also provide accumulated statistics about our sales, customers, traffic patterns and other site information to third parties, but these statistics will not include any information that could personally identify you.

7. International Transfers

We usually store and process your personal data within the United Kingdom and the European Economic Area (EEA). However, in some circumstances we may transfer your information to countries outside the UK or EEA. This may happen where:

we use service providers or cloud platforms whose systems are located outside the UK/EEA;
our group companies or partners involved in delivering our services operate internationally; or
you are located outside the UK/EEA and we need to communicate with you or your nominated contacts.

When we transfer your personal data outside the UK or EEA, we ensure that an equivalent level of protection is applied. This means we will only make such transfers where one of the following safeguards is in place:

the destination country has been deemed by the UK or European Commission to provide an adequate level of data protection compliance;
we have put in place appropriate contractual safeguards, such as the UK International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses (SCCs), or the EU SCCs themselves; or
another lawful transfer safeguard under the data protection laws applies.

You may request more information about the international transfers we undertake and the safeguards we use by contacting us using the details provided in this Privacy Notice.

8. How Long we Keep your Information

The periods for which we keep your information will vary according to the purpose for which we use the information. To work out how long we keep each data record for, we consider why we hold it, how sensitive it is, how long the law says we need to keep it, and what the risks are.

Unless there is a specific legal requirement to keep your information, we will not keep it for longer than necessary for the purposes for which it was collected or for which it is to be further processed. We have an internal data retention schedule that details how long we keep each data record, and we will securely delete your information in line with this.

9. Your Rights in Relation to your Personal Data

You have various rights relating to your personal data, which we have summarised below. To exercise any of these rights, please contact at the email addresses below. We process and respond to all requests regarding personal data within one calendar month, but if the request is going to take longer to process, we will advise you of this.

We may ask for additional information to verify your identity to ensure we are sharing personal data with the correct person or that we believe is necessary to comply with a request. Please note that whilst we will carefully assess every request we receive, we may not always have to comply. When this happens, we will explain why.

Your right to be informed – you have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. We are providing you with this information in this privacy notice. If you need any further information, please contact us as the email address below.
Your right of access – you have the right to access the personal data we hold about you.
Your right to correct the personal data we hold about you – you have the right to correct, amend or update your personal data if it becomes inaccurate or incomplete.
Your right to erase your personal data – you have the right to ask us to erase your personal data although, for legal reasons, we might not always be able to do it.
Your right to restrict the processing of your personal data – you have the right to restrict, ‘block’ or suppress further use of your information if:
the accuracy of your personal data is contested;
your personal data has been processed unlawfully by us, but you do not want to request erasure; or
we no longer need your personal data for our original purpose, but it is required to establish, exercise or defend legal rights.

When processing is restricted, we can still store your information but may not use it further. We keep records of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in the future.

Your right to consent and/or withdraw consent – if you have given your consent to allow us to process your personal data, you also have the right to withdraw your consent at any time. Please note that withdrawal of consent does not affect the lawfulness of processing that happened before the withdrawal.
Your rights in relation to automated decision-making including profiling – automated decision making is a decision made by automated means, without any human involvement, which has legal consequences or something to a similar effect (e.g. credit checking). We don’t typically carry out any such processing, but if we were to, we would make it clear where such decisions are being made.
Your right to data portability – you have rights to obtain and reuse your personal data for your own purposes in a commonly used machine-readable format, and to have your personal data transferred to another data controller on your request.
Your right to object to processing – you have the right to object, on grounds relating to your situation at any time, to the processing of your personal data that is based on us exercising our legitimate interests. If we can show compelling legitimate grounds for processing your personal data which we consider override your interests, rights and freedoms, or we need your personal data to establish, exercise or defend legal claims, we can continue to process it. Otherwise, we must stop using the relevant information.

Should you wish to exercise any of these rights, including your right to opt-out of Marketing, can contact us either in writing or via email – details provided below.

10. How we Protect your Information

We have several security measures in place to protect our information, including:

the encryption of the personal data submitted by you and collected by us via our website and other online platforms is maintained to the highest industry standard level. Where you have a password, which enables you to access your account and certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password(s) with anyone.
Strict security procedures covering the storage and disclosure of this information in order to prevent unauthorised access. Our employees can only access data that is appropriate and necessary for their role and we carry out identity verification checks before disclosing any Personal Data to them.
Where we use third party service providers, we disclose only the Personal Data necessary for them to deliver the required services. We carry out security due diligence to ensure they have satisfactory security and confidentiality measures in place, and contracts are in place to ensure they only use it for the purpose for which it was intended.

PLEASE NOTE THAT WE WILL NEVER TELEPHONE/EMAIL YOU TO ASK YOU TO PAY FOR YOUR ACCOMMODATION. Please alert us via the email addresses below if you receive any such requests.

11. Your Right to make a Complaint

If you are unhappy about the way in which we have used your personal data, please let us know by contacting us as detailed below and we will try to resolve your complaint. If we are unable to resolve your complaint to your satisfaction, you have the right to lodge a complaint about the way we handle or process your personal data with the Data Protection Commission.

In the first instance, please contact us using the details provided below. If we are unable to resolve your complaint, you have the right to complain to the Data Protection Commission here: https://www.dataprotection.ie/en/individuals/exercising-your-rights/raising-concern-commission.

Data Protection Commission

Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231

E-mail: [email protected]

For further information please visit www.dataprotection.ie

12. Updates to this Privacy Notice

If we change the way in which we use or share your Personal Data, we will send you a just-in-time notice or update this Privacy Notice.

Contact Us

Questions, comments and requests regarding this Privacy Notice and your personal data are welcome and should be addressed to us at the below email and/or postal address:

Email: [email protected]

Address: Heyday–Carmans Hall, Dublin 8, Ireland.

Privacy Policy

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