1. Introduction
This is the privacy policy of Deposify Limited. When we say “Deposify”, “we”, “our” or “us”, we mean Deposify Limited.

We know that you take your privacy seriously. We want you to understand and be comfortable with the ways in which we collect, process and use your personal information that we create or collect from you or others (such as tenants, landlords, estate and letting agents and the Residential Tenancies Board) in connection with our services. When we talk about our “services” we mean our website (www.www.deposify.com) and apps and the services we provide through them.

Whenever we collect your personal data, we are legally obliged to use it in line with the Irish Data Protection Acts 1988 and 2003.

Please make sure that you read this privacy policy carefully. By using our services or otherwise providing information to us, you consent to us using your personal information in the ways we describe in this privacy policy.

2. Who are we?
Deposify Limited is a company with limited liability registered in Ireland under company number 546442. Our registered office is at Mews 1, 73 Pembroke Lane, Dublin 4, Ireland. Our VAT number is 3331016QH.

We provide an online platform to landlords and tenants so that we can independently hold rental deposits in escrow and facilitate the resolution of deposit related disputes between landlords and tenants.

We are a data controller for the purposes of the Irish Data Protection Acts 1988 and 2003 and are registered with the Irish Data Protection Commissioner. We are authorised by the Department of Justice to carry out the provision of trust services under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (as amended).

 

3. Our privacy principles
We know you value your privacy. When you use our service we appreciate that you trust us to keep the personal information we collect and process safe and secure. We are committed to earning and maintaining that trust. We do this by following a set of basic privacy principles. These principles are a set of “do’s” and “don’ts” that underpin how we think about privacy and how we operate our business.

These are our privacy principles:

  • We don’t share your personal information with unauthorised third parties
  • We don’t collect personal information that we don’t need
  • We are transparent and upfront about the ways in which we use personal information
  • We only retain personal information for so long as is necessary, and then we delete it
  • We delete personal information upon request (unless we’re required by law to keep it or need to keep it to protect us or others)
  • We deploy appropriate security to keep personal information safe and secure
  • We adopt a “privacy by design” philosophy: privacy influences how we think about and build our services.

4. What information do we collect?
We collect information in a number of ways and may combine and link that information, even if we collect the information in different ways (e.g. online and offline) or from different sources:

Information you provide us: We collect information that you provide to us through our service or otherwise.   You may do this in a number of ways. For instance, you may give us information about you:

  • by registering with us, creating an account and filling in forms on our website or apps;
  • by corresponding with us by phone, e-mail or otherwise;
  • when you make payments to us (though normally we do not collect any credit or debit card details from you, but instead enable you to provide those details directly to our payment processor);
  • when using our dispute resolution service;
  • when providing us information for knowing our customers/anti-money laundering purposes;
  • when you participate in discussion boards (including social media) or use the message and other functions available through our services; and
  • when you enter a competition or participate in other promotions or our surveys.

The information you give us includes your name, details regarding the properties you own, are renting or are managing (e.g. address, rent and deposit amount or, when you are using our dispute resolution services, details regarding any dispute), e-mail address and phone number.

Information others provide us: We may also receive information about you from others such as your landlord or letting agent or tenants or the Residential Tenancies Board. They may do this in a number of ways. For instance, they may provide information about you or your rental to us:

  • when creating an escrow contract with us in respect of a property owned, managed or being rented by you;
  • if you’ve specifically told them to give it to us, such as where you tell your landlord or letting agent to give us your rental and other information that they hold about you to pre-populate forms on our website or apps (so you don’t have to when signing up to our services); or
  • in connection with a dispute regarding your rental when you are using our dispute resolution service or otherwise in connection with performance of our services generally.

Again, this information may include your name, details regarding the properties you own, are renting or are managing (e.g. address, rent and deposit amount or, when you are using our dispute resolution services, details regarding any dispute), email address and phone number.

We also work closely with trusted third parties like our banking partners and payment processors who may also provide us with information about you. For instance, our banking partners and/or payment processors may provide us with limited information to confirm that you have made a payment.

Device information: We collect information from or about the computers, phones, or other devices where you install or access our services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices. For example, we may collect device information like:

  • Any phone number used to call us in which case we will link this to your registered account and/or name.
  • Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.
  • Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals.
  • Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
  • How your device interacts with our services, such as what pages were visited, for how long and how often you return to them.

This may be collected by us through the use of cookies, SDKs, and related technologies. How this is done is explained in more detail in our cookie policy.

5. What do we use your information for?
We use a combination of your information for the following purposes:

  • Service performance and improvement: We use your information to provide our services to you and others and to carry out our contractual obligations under our terms of service. We also use it to improve and develop our services. For instance, we are able to deliver our services, personalise content and make suggestions for you by using this information to understand how you use and interact with our services and the people or things you’re connected to and interested in on and off our services.
  • Know your customer: We collect information to verify your identity in line with our legal obligations under anti-money laundering legislation.
  • Deposify marketing communications: We use your information to send you marketing communications and recommendations, by email or text message or in-app push notifications, regarding our services and products similar to those you’ve purchased or asked about, unless you’ve asked us not to. If you’ve asked us to do so, we may also send you such messages with respect to others’ products and services. We may also sometimes track who opened and clicked on the links in the marketing communications or personalised recommendations that we send so that we can measure a campaign’s success.
  • Marketing communications from trusted partners: We may give your contact details and other information to trusted partners such as our banking partners so that they can send you information about their products and services that they think may be of interest to you.
  • Show and measure ads and services: We want our advertising to be as relevant and interesting as possible. With this in mind, we use a combination of all of the information we have about you to improve our advertising and measurement systems so we can show you relevant ads from us and our trusted partners on and off our services and measure the effectiveness and reach of ads and services.
  • Service administration updates: We may send you service emails and in-app push notifications to administer our services, notify you about service issues and changes and changes to our legal terms and cookies and privacy policies.
  • Protection of Deposify and others: We may also use information we collect as authorised or required by any law applicable to us or arising from your interaction with our services. For instance, where permitted by law we reserve the right to use or release personal data without your consent and/or without consulting you when we believe that this is appropriate or necessary:
    • to protect those using, and the security of, our service;
    • to bring unlawful behaviour to the attention of the appropriate authorities (e.g. the Gardai); and
    • to otherwise protect our legitimate interests and/or the legitimate interests of the other users of our service or other third parties

6. How do we share your information?
We keep your information private. We don’t sell your personal information. However, we may share your information with third parties in some circumstances. These are set out below:

  • With your express consent: We share your information with others if you have told us that you want us to do so. For example, if you give your opt-in consent to the receipt of marketing communications from our trusted partners, such as our banking partners, we may provide them with your contact details.
  • With our service providers: We may share personal information with our trusted and carefully selected service providers, particularly where this is necessary to provide our services to you. These service providers are required to keep your personal information safe and secure. We may also share personal information with our legal counsel, particularly in cases where there has been a breach of our terms of service.
  • With analytics and search engine providers: We may share your personal information with analytics and search engine providers that assist us in the improvement and optimisation of our website and apps.
  • With credit reference agencies: We may share information with credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
  • With advertisers and advertising networks: We may share your information with advertisers and adverting networks so that we or they can show you relevant and interesting ads on and off our services. However, we do not share information that personally identifies you (personally identifiable information is information like name or email address that can by itself be used to contact you or identifies who you are) with advertising, measurement or analytics partners unless you give us permission. We may provide these partners with information about the reach and effectiveness of their advertising without providing information that personally identifies you, or if we have aggregated the information so that it does not personally identify you. For example, we may tell an advertiser how its ads performed (e.g. 500 men aged under 30 have clicked on their ad on any given day).
  • For legal and safety reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons or that this is necessary to prevent harm or injury to our users, members of the public, our staff, ourselves or others, or if we need to do so to defend our legal rights or to enforce our terms of service. In this case, we may do this without your consent and/or without consulting you. For example, we may provide personal information if we are ordered by a court to do so
  • Merger: If someone buys or takes control over Deposify or a part of our business, we may provide your information to that person.

See our Cookies Policy for more information about how third parties like advertisers and analytics providers collect information through cookies and similar technologies.

7. Your Deposify account
You should keep your Deposify account password safe and secure. If you suspect its integrity has been compromised or someone else is using your account, let us know immediately at support@deposify.com.

8. Payments
We use bank level security and infrastructure when handing your money and information. Our banking solution is powered by Bank of Ireland and our payments solution by BOI Payment Acceptance.

9. Your choices
We’ve designed our services so that you can make choices about the communications we send to you:

  • Deposify marketing communications: You can opt-out of marketing communications by email through your Deposify account settings, through the unsubscribe link in the marketing communications we send or by emailing us at support@deposify.com.
  • In-app push notifications: We only send you in-app push notifications if this is enabled on your device. You can change your choice in this regard at any time through your device settings.
  • Cookies and related technologies: See our Cookies Policy for details of you can exercise choices regarding cookies and related technologies.
  • Marketing communications from our trusted partners: We only disclose your contact details and other information to our trusted partners if you have opted-in to this. You can change your mind in this regard at any time through your Deposify account settings or by emailing us at support@deposify.com. However, you’ll still need to directly opt-out from future marketing communications from the trusted partners to whom we have already given your information in this case.

Please note that you cannot opt-out of service administration updates such as with respect to change to our privacy policy or other aspects of the service.

10. Where do we store your information?
We may store your information in hard copy or electronic format, in storage facilities which we own and operate ourselves, or that are owned and operated by our carefully selected service providers. This may be within or outside Europe.

We will handle your personal data in the manner described in this privacy policy and in accordance with the Irish Data Protection Acts 1988 and 2003, even in countries whose laws don’t provide the same level of protection as in the European Economic Area. Any such transfers of personal data to outside the European Economic Area will comply with the requirements of the Irish Data Protection Acts 1988 and 2003.

All information you provide to us is stored on secure servers. Any payment transactions are encrypted by our payment processor using SSL technology.

11. For how long do we retain your personal data?
We retain your personal data for so long as is necessary with regard to the purposes for which it was collected or lawfully further processed, or for so long as may be necessary in light of our legal obligations.

12. How do we keep your information secure?
We recognise that the security of your information is important to you. We take all steps we deem to be reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy.

Unfortunately, as the internet, and likewise no product or online service, are completely secure and as a result, we cannot absolutely guarantee the security of your personal information, we have implemented reasonable industry standard physical, electronic and organisational measures to safeguard the security of personal data.

Where you have created a Deposify account, please play your part in keeping your personal information secure by choosing a strong password and by keeping your log-in details secret. Please also be aware that, in some cases, information you provide through our service may be made public. For instance, where you post comments on our comments or discussion board (including social media), these may be made public as mentioned above.

13. What are your rights?
You have the right to access information held about you, and to request that we update, correct or delete any inaccuracies in your personal data. You may also request that we cease processing where such processing is causing you harm.

Your rights can be exercised in accordance with the Irish Data Protection Acts 1988 and 2003 by writing to or emailing us at support@deposify.com. Any access request may be subject to a statutory fee to meet our costs in providing you with details of the information we hold about you.

See the Your Choices section for how to opt-out of marketing communications.

14. What are your responsibilities?
We seek to ensure that we keep your personal data accurate and up to date. However, you are responsible for informing us of any changes to your personal data and other information (such as a change in contact details) as this is out of our control.

You are also required to comply with our terms of use and our terms of service.

15. Third party privacy practices
Our website or apps may, from time to time, contain links to and from the websites of our trusted partners and trusted networks, advertisers, and affiliates. If you follow a link to any of these websites or ask us to provide your information to a third party, please note that such third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies or such parties’ privacy practices or conduct.

16. Changes to our privacy policy
From time to time, we may need to change this privacy policy, for instance to reflect any changes in technology, legislation or our data uses which may affect the way in which we process your personal information.

If we do so, we will post an updated version of our privacy policy on our website and we may notify you through our apps, by email or other means (or a combination of these means). The revised privacy policy will apply to all of your information held by us at the time.

Contacting us
If you have any questions, comments and requests regarding this privacy policy or our management of your information, please contact us at support@deposify.com.