HPEIF ICAV (“we”, “our” or “us”) is committed to preserving the privacy of all visitors to https://hsq.ie/ (the “Website”) and of those who contact us through the communications channels on our website. Please read the following Privacy Statement to understand how we use and protect the information that you provide to us.
Who We Are
HPEIF ICAV is an Irish Collective Asset-Management Company with its headquarters at 32 Molesworth Street, D02 Y512, Ireland. Our aim is to develop and manage our properties to generate the strongest possible return for investors.
We play a limited role as a data controller. Notwithstanding this, where individuals choose to provide us with their personal data through the Website or by contacting us directly, we have adopted this Privacy Statement so as to ensure that such individuals (“you”) are aware of how we comply with applicable data protection laws (including the General Data Protection Regulation or “GDPR”).
Information we may collect from you
We may collect and process the following personal data about you:
- Information that you provide while using our Website. This includes your use of the communications channels on our Website to make an enquiry or to request further information or services from us.
- Like most websites, we also use analytics tools to track usage of our site to assess which pages are being accessed, how the Website is performing etc. We do this on an aggregated basis and we do not attempt to link use of our Website to specific individuals unless they have chosen to give us their contact details.
How we use the information we collect
We collect different types of information about our users for the following reasons:
- to personalise the way our content is presented to you and to ensure that content from our Website is presented in the most effective manner for you;
- to help us to monitor and improve our business, including this Website;
- to meet any legal obligations arising from your interaction with the Website; and
- to allow you to participate in interactive features of our services that we may offer from time to time, when you choose to do so.
Lawful basis for our use of your data
The lawful basis we rely on to support our processing of your data is usually your consent (where you have volunteered the information to us) and/or our legitimate interest (where we are using your information in line with the purposes for which you would reasonably expect, for example to respond to an enquiry you make by email or through our website). You can withdraw your consent or object to our legitimate interests as detailed below under “Your Data Protection Rights”.
An IP address is a number that is assigned to your computer automatically when you use the internet. When you visit a particular page on the Website, our servers log your IP address. We may use your IP address to help diagnose problems with our server, and to administer our Website. Your IP address is also used to help identify you and to gather broad demographic information. We do not profile individual users for advertising purposes.
Your data protection rights
The GDPR confers certain rights in favour of data subjects. The rights in question are as follows:
- The right to receive the information in this Privacy Statement;
- The right to access your personal data. This includes knowing whether or not personal data are being processed and, if so, having access to the personal data plus the information contained in this Privacy Statement such as information about the purposes of the processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data have been or will be disclosed, retention periods etc;
- The right to rectify or erase personal data (right to be forgotten);
- The right to restrict processing;
- The right of data portability. i.e. the right to receive personal data concerning you in a structured, commonly used and machine readable format and have the right to transmit those data to another data controller.
- The right of objection; and
- The right to object to automated decision making, including profiling;
Data Subject Rights
If you wish to exercise your Data Subject Rights you should write to us at firstname.lastname@example.org, setting out in detail which Data Subject Right you wish to exercise and providing us with sufficient information to respond.
You are also entitled to complain to the Irish Data Protection Commission if you believe we have not complied with our obligations under data protection laws. See www.dataprotection.ie
Cases where we may use your Personal Information to contact you
We may contact you:
- To respond to any communication you send us;
- Thereafter to keep you updated about Company information;
- Where you have subscribed to a newsletter, you will be able to unsubscribe at any time by following the unsubscribe link at the foot of any of our newsletter emails.
Disclosure to Other People
We may disclose your personal information to any company or other corporate entity under our control and direction. They will use your information in the same manner as described in this Privacy Statement.
We may pass aggregate information on the usage of our Website to selected third parties, but this will not include information that can be used to identify you.
In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If all or substantially all of our assets are acquired by a third party, the personal data held by us will be one of the transferred assets.
Unless required to do so by law or as otherwise set out in this Privacy Statement, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
Where we store your personal data
The data that we collect form you may be transferred to, and stored at, a destination outside the European Economic Areas (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. By submitting personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
All information you provide to us is stored on our servers and will be backed up in a secure cloud environment.
We employ appropriate security measures to protect your personal information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We ensure that when we outsource any processes that the service provider has appropriate security measures. However, as no data transmission over the Internet is completely secure, we cannot ensure or warrant the security of any personal information you transmit to us and you transfer the data at your own risk.
We will retain your personal information for no longer than is necessary for the purpose for which it is collected or as long as the law requires (typically up to 7 years).
Changes to Our Privacy Statement
Any changes to our Privacy Statement in the future will be posted to the Website or, where appropriate, through e-mail notification.
32 Molesworth Street
D02 Y512, Ireland
T +353 1 241 8400
F +353 1 661 9678