Data Privacy Policy

This privacy policy describes how Glandore processes (collects, uses, stores, discloses) your personal data. All data is collected in connection with your use of Glandore services such as this website, member’s portal, applications and products. The Glandore website includes links to Suesey Street Restaurant www.sueseystreet.ie and 25 Fitzwilliam Place Private Dining www.25fitzwilliamplace.ie. Both businesses are in common family ownership with Glandore Business Centres and are located adjoining Glandore Business Centre at Fitzwilliam Place, Dublin 2.

If you have any queries about this policy, you can contact your local Glandore reception team or email us on info@glandore.ie.

General Statement

At Glandore we respect the importance of data privacy. Any personal data processed by Glandore will be held securely and will only be used for the purposes described in this document. Glandore has never, and will never, sell your data to any 3rd party.

Operating in both the EU and UK, Glandore is committed to compliance with all relevant EU and UK law in respect of personal data, and the protection of the “rights and freedoms” of individuals whose information we collect and process. We are committed to protecting and respecting personal data. We wish to be transparent on how we process personal data and demonstrate that we are accountable with the relevant legislation in relation to our processing of the data

In accordance with the EU GDPR definition of the roles of ‘controller’ and ‘processor’ Glandore, in the delivery of its services to members is a ‘processor’ of Personal Data on its own behalf as ‘data controller’. Glandore is not a provider of data processing services to third parties and specifically, is not a data ‘processor’ on behalf of Glandore’s members.

Personal Data we collect

Collection of personal data by Glandore arises in one of three ways:

1. Personal Data provided by you

2. Personal Data provided by a third party (such as your employer, an agent working on your behalf or an individual you have an existing business relationship with that feels you may benefit from our services)

3. Personal Data collected from your device through the use of our services, such as cookies or other network and internet technologies

Personal Data provided by you:

1. When registering as a user with Glandore such as your first name, last name, company name, job title, e-mail address, phone number, username and password of your choice.

2. When registering (typically via an online form but also via email, phone call, chatbot etc.) an interest in our services such as your first name, last name, e-mail address and any other information you elect to provide us.

3. Members can avail of our online members portal which enables and encourages client companies and their staff to engage with each other for mutual benefit, including via the online portal. The portal is also used to log requests and issues. To be visible to other members in the online directory – and thereby be able to receive communications via the portal from other members – requires your specific consent. You are invited to provide this consent on becoming a member.

4. In the event of a workplace accident Glandore uses an accident report form to accurately log any accidents or injuries which occur on its property inclusive of staff, clients, visitors and contractors. We will collect name, email, phone number, emergency contact information, description of injury & event.

5. In the interests of doing business and to establish a business relationship such as through business networking events where typical contact details are voluntarily exchanged.

6. On becoming a member, Glandore may, where required by law, collect sufficient details to confirm the identity of the client organisation.

7. On becoming a member, financial data including bank account and payment card details will be collected to facilitate payments for services.

8. We require that all member companies nominate an emergency point of contact including name and phone number of that contact.

Personal Data provided to us by a third party:

1. Companies who are members at Glandore will provide Glandore with sufficient data to allow you (their employee) to avail of Glandore services such as meeting rooms, events and notifications. Typically, this is your first name, last name, company name, job title, phone number, e-mail address.

2. Glandore members may provide us with your name and email address when you are visiting them at our offices.

3. An agent (such as real estate agent) acting on your behalf may provide us with your contact details in the event you are considering signing up to Glandore’s services.

4. Digital analytics services, such as google analytics, collects information on your browsing activity. This information e.g. IP address is not combined with other personal information.

Personal Data we collect about you:

1. When your device uses a Glandore network device identifiers, such as IP address & MAC address are required in order to provide network and internet connectivity. This information is used only for the delivery of that service, is not combined with any other data and is not subjected to any analysis other than in the course of normal troubleshooting.

2. Information about your online activity through the use of standard Internet technologies, such as cookies, pixels, web beacons, logs, and other Internet technologies.

3. CCTV monitors the perimeter, entry/exit points and common areas of the buildings. These recordings may be accessed by Glandore authorised staff, authorised third parties and may be shared with competent authorities in accordance with applicable

laws, if required. The recordings are retained for a limited period of time (approx. 3 months) but may be kept longer where Glandore determines that it is appropriate, for example in connection with the investigation of an incident, or when competent authorities request them to be retained for longer.

How we store your data

Glandore uses a variety of market leading cloud service providers for the processing and storing of data. Irrespective of the service we use, we have put in place appropriate security measures to protect your personal data from being accidentally lost, used or accessed in an unauthorised way.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties necessary to the delivery of good service. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Use of Personal Data

Your personal data that may be processed for the following purposes:

1. To provide you with the information and services that you have requested.

2. To provide you with the information and services necessary in the fulfilment of our contractual obligations to you.

3. To contact you in response to communications you might send us.

4. To contact you in relation to our services, events programme, general news from Glandore, promotional updates and other communications from Glandore deemed to be of probable interest to you, as an individual and/or company. Such promotional correspondence will always include the facility to unsubscribe.

5. As a client company, to provide contact information for your company in the company/team section of the online members directory.

6. To use data analytics to improve our site, products/services, marketing, customer relationships and experiences.

7. As a member, notifications may be sent to you from the online members portal under two main headings:

a. Necessary administrative notifications e.g. fire drill notifications, holiday arrangements, etc.

b. Optional administrative notifications, where you can select which notifications you wish to receive or not.

8. As a member, where you have given your consent to be visible in the members online directory, to include your name and company name in the members directory.

Legal Basis

The legal basis for collecting and using the personal information described here will depend on the personal information concerned and the specific context in which we collect and process it.

1. Information required to deliver our services to you as contractually obliged such as name, contact details, employer, relies on Performance of Contract as the legal basis for processing.

2. In accordance with anti-fraud legislation, we may be obliged to collect sufficient data to verify the identity of a client company. This data relies upon Legal Obligation as the basis for processing.

3. We rely on Legitimate Interests as the legal basis for the processing of certain information where it is necessary for the purpose of maintaining the established business relationship with ex-members and/or other business contacts. This processing only occurs where not overridden by your data protection interests or fundamental rights and freedoms.

4. We also rely on Consent as the legal basis for processing to add your details to our online members portal and make your profile visible to other members.

Sharing of personal data

We may disclose your personal data in the following circumstances to the following parties:

1. Within Glandore companies. Glandore operates more than one corporate entity and the specific Glandore company that provides service to you may depend on where you are located or what service you avail of. For Glandore to carry out its operations effectively across its various Glandore entities, there may be occasions when it is necessary to transfer personal data from one Glandore entity to another. Glandore may share your personal data within the Glandore companies for the purposes described here and in accordance with this Data Privacy Policy.

2. The Glandore Member Community. Our services include the Glandore online members portal which enables you to share information and connect with other Glandore members. Where you consent to be visible in the members online community your name and company name will be visible to other members, who will be able to engage with you. You are offered the facility to expand your profile with additional information about yourself, which is shared within the Glandore member community in the online members directory.

3. Service Providers. We avail of third-party service providers to perform a variety of services on our behalf e.g., provision of access control systems, hosted application systems, catering services etc. In such circumstance we utilise their services to process your information for the purposes described above in “Use of personal data”. Where Glandore uses 3rd party service providers we require that they adhere to, and operates in accordance with, both this Data Privacy Policy and the GDPR.

4. Other parties where required by law and as necessary in the provision of our services and to protect our rights, property, and the safety of our customers, employees and business partners.

5. Other parties at your company’s request. We may share information about you with third parties when your company requests such sharing.

6. Corporate transactions. In the event of a corporate transaction such as merger, acquisition the companies reserves the right to provide necessary data to relevant parties as may be required in such an event.

Retention of personal data

Glandore will retain your information for the duration of the relevant contractual agreement. Following the cessation of that agreement Glandore retains the minimum personal information necessary for the purpose of maintaining the established business relationship. The data is necessary for Glandore to deliver service of appropriate standard to returning clients and to continue the established business relationship with our ex-members.

Where legally required or if it is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we retain some of your information for a limited period as required, even after you have closed your account, or it is no longer needed to provide the services to you. We are required by law to retain certain financial information for 6 years as per the Tax Act 1997 and due diligence information for 5 years as per the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010.

What are your data protection rights?

Glandore would like to make sure you are fully aware of all of your data protection rights. Everyone whose data we process is entitled to the following:

· The right to access – you have the right to request copies of your personal data.

· The right to rectification – you have the right to request that we correct any information you believe is inaccurate and complete the information you believe is incomplete.

· The right to erasure – you have the right to request that we erase your personal data, under certain conditions.

· The right to restrict processing – you have the right to request that we restrict the processing of your personal data, under certain conditions.

· The right to object to processing – you have the right to object to our processing of your personal data, under certain conditions.

· The right to data portability – you have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at any of: info@glandore.ie

+353 (1) 6694700 Fitzwilliam Hall, Fitzwilliam Place, Dublin 2, Ireland.

+44 (28) 90447100 41 Arthur Street, Belfast, BT1 4GB, Northern Ireland

Links to external websites

There is a section in the members online portal that provides links to third party websites, from which you may avail of their services. These are clearly identifiable as such. We provide these links as a convenience to our members. In addition, this site provides links to third-party sites such as, Facebook, Instagram, Twitter. All such services are subject to their own privacy policies, and we are not responsible for the content or the privacy policies of these third-party websites.

International Data Transfers

Glandore uses applications and services provided by 3rd parties for the performance of some administrative functions such as visitor sign in and receptionist console. With regard to data transfers between the EU and UK, pertaining to both EU and UK residents, Glandore is cognisant, and will monitor the status, of relevant adequacy rulings between the two jurisdictions.

Where Glandore uses applications or services that host data outside of the EEA or UK we require that the service provider adheres to, and operates in accordance with, both this Data Privacy Policy and the EU and UK GDPR.

Collection of data from children

Our services are provided to the business community and public organizations and are not directed towards children. We do not knowingly collect personal data from children.

Changes to our Data Privacy Policy

Any changes to this Data Privacy Policy will be posted on this website and dated so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.