Privacy Policy

1. Introduction & Data Controller

Homebuyer's Hero Limited ("we", "our", "us") is committed to protecting and respecting your privacy. This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of your personal information when you use our website, applications, and services (collectively, "the Service").

For the purposes of the General Data Protection Regulation (GDPR), Homebuyer's Hero Limited is the Data Controller of the personal data you provide to our Service. This policy applies to all users, including prospective Home Buyers and Home Builders. By using our Service, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

We collect and process various types of information to provide and improve our Service to you. The information we collect includes:

2.1. Information You Provide Directly

• Personal Identification Information: Name, email address, phone number, and residential address.
• Financial Information: Information regarding your income, savings, bank balances, mortgage Approval in Principle (AIP), and details of any financial gifts. This is essential for assessing your "Readiness Level" on our platform.
• Housing Preferences: Details about the type, location, and price range of the home you are seeking.
• Home Builder Information: For Home Builders, this includes company details, professional track record, financial capacity information, and certifications.
• Team Information: If you form a team on our platform, we will collect personal information about your co-buyers or gift-givers, with their consent.
• Credit History Information: At later stages of the process, and only with your explicit and separate consent at that time, we may request access to your credit history from the Irish Credit Bureau (ICB) or facilitate such a check through a partnered regulated entity. This will not be requested at the initial application stage. For Home Builders, this check may be requested at an earlier stage to verify financial standing.

2.2. Information Collected Automatically

• Usage Data: We may collect information on how the Service is accessed and used, such as your computer's Internet Protocol (IP) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, and other diagnostic data.
• Cookies and Tracking Technologies: We use cookies and similar tracking technologies to track activity on our Service. For detailed information, please see our Cookie Policy.

2.3. Information from Third-Party Services

• ID Verification: At certain stages, we will require you to verify your identity. This process is handled by a specialist third-party provider. You will be directed to their secure service to submit your photo ID and complete a liveness test. We do not receive or store your ID documents; we only receive a confirmation signal (pass/fail) from the provider. Please review the privacy policy of our third-party ID verification partner during that process.

3. How We Use Your Information & Legal Basis for Processing

We use your personal data for the following purposes, relying on specific legal bases under GDPR:

• To Provide and Maintain our Service: To manage your application and subsequent profile, facilitate your participation in queues, and connect you with other users.
  Legal Basis: Performance of a contract (our Terms of Service) and taking steps at your request to enter into a future contract.
• To Assess Financial Readiness and Rank Users: We process your financial information to perform automated assessments and rank you in queues. This is a core function of our Service.
  Legal Basis: Explicit Consent (which you provide when you agree to this policy and our Terms at application) and our Legitimate Interest in operating a fair and effective platform.
• To Communicate with You: To send you service-related notifications, updates, and respond to your inquiries.
  Legal Basis: Performance of a contract and our Legitimate Interest.
• For Marketing Purposes: To send you news and promotional offers, if you have opted in.
  Legal Basis: Consent.
• To Improve Our Service: To analyse usage data and improve the user experience.
  Legal Basis: Legitimate Interest.
• For Security and Fraud Prevention: To protect the integrity of our platform.
  Legal Basis: Legitimate Interest and Legal Obligation.

4. Automated Decision-Making and Profiling

A core part of the Homebuyer's Hero Service involves automated decision-making, including profiling, to ensure a fair and efficient process for all users. It is essential you understand how this works.

4.1. What is Automated Decision-Making?

We use a proprietary algorithm to assess the information you provide (particularly financial data and application completeness) to generate a "Readiness Level" score. This automated process ranks you within our system and in specific project queues.

4.2. Logic and Significance

The logic involves assigning weightings to various factors, such as verified funds, mortgage AIP status, and how recently your information was updated. The resulting score has a significant effect on your experience, as it directly influences your position in a queue and your eligibility to be invited to make a binding commitment on a development. This system is essential to provide Home Builders with the confidence they need to proceed with new developments.

4.3. Your Right to Human Intervention

While our automated system is designed to be fair and objective, we recognise your rights under GDPR. If you believe an automated decision has incorrectly affected your status, or you wish to contest it, you have the right to request human intervention.

A member of our team will review the automated decision and the data it was based on. To exercise this right, please contact us through our Contact Us page or by using the chat facility available on our website, clearly stating that you are requesting a review of an automated decision.

5. Disclosure of Your Information

We do not sell your personal data. We may disclose your personal information in the following circumstances:

• To Home Builders: At the initial stages, we only share aggregated and anonymised data to show market demand. Personally identifiable information is only shared with a Home Builder at later stages of a specific project, and only with your consent.
• To Your Team Members: If you form a team, certain information will be visible to your designated team members as configured by you.
• To Service Providers (Sub-processors): We share information with third-party vendors who perform services on our behalf. These providers are contractually obligated to protect your data. More detail is provided in the next section.
• For Legal Reasons: We may disclose your information if required to do so by law or in response to valid requests by public authorities.

6. Third-Party Services (Sub-processors)

To deliver our Service, we rely on a number of third-party companies who act as our "data processors". We have vetted these providers to ensure they meet high standards of data security and compliance. Our key service providers include:

• Google Cloud & Google Workspace: For secure cloud hosting of our platform infrastructure and for internal business operations (email, document storage).
• Intercom: To provide customer support and communication services, including the live chat facility on our website.
• Wordpress: As the content management system for parts of our informational website.
• Cookiebot: To manage cookie consent on our website in a compliant manner.

This list is not exhaustive and may be updated. We will only share your data with these providers to the extent necessary for them to perform their services for us.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which we collected it. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, our legal obligations, and the potential risk of harm from unauthorised use or disclosure.

Specific retention periods or criteria include:

• Applicant & Profile Information: Retained while your application or subsequent user profile is considered active, and for a reasonable period afterwards, to allow for reactivation and to comply with our legal obligations.
• Financial & Transactional Data: Where applicable, data related to financial commitments will be retained for up to 7 years after the transaction is complete to comply with Irish tax and accounting regulations.
• General Communications: Retained for a reasonable period after your last interaction with us to ensure we have a record of our correspondence.

You can request the deletion of your data at any time, subject to our legal and regulatory obligations.

8. Your Data Protection Rights

Under GDPR, you have the following data protection rights:

• The right to access, update or delete the information we have on you.
• The right of rectification.
• The right to object to our processing of your personal data.
• The right of restriction.
• The right to data portability.
• The right to withdraw consent at any time.

To exercise any of these rights, please contact our Data Protection Officer using the details provided below.

9. Data Security

The security of your data is important to us. We have implemented appropriate technical and organizational measures to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

10. International Data Transfers

Your information may be transferred to — and maintained on — computers located outside of the European Economic Area (EEA), for example, by our third-party service providers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place, such as Standard Contractual Clauses.

11. Additional Agreements

Please note that your use of the Service is also governed by our Terms of Service. As you progress through the platform, you may be required to agree to further legally binding agreements (e.g., a Commitment Agreement). In the event of a conflict between this Privacy Policy and the terms of a more specific subsequent agreement, the terms of that subsequent agreement will prevail regarding the subject matter it covers.

12. Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

13. Children's Privacy

Our Service is not intended for anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18.

14. reCAPTCHA and Bot Protection

We use Google reCAPTCHA v3 to protect our website forms from spam and abuse. reCAPTCHA collects hardware and software information, such as device and application data, and sends it to Google for analysis. This information is used to distinguish humans from bots and prevent fraudulent activity.

The information collected by reCAPTCHA is subject to the Google Privacy Policy and Google Terms of Service.

By using our forms, you acknowledge that your interaction with those forms is subject to Google's reCAPTCHA analysis.

15. Contact Us & Complaints

Our designated Data Protection Officer is our CEO, Colm Casey. If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have any other privacy-related concerns, please contact our privacy team:

• By email: Loading...
• Via our Contact Us page

If you have a complaint about our use of your information, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you also have the right to lodge a complaint with the Irish Data Protection Commission (DPC) at www.dataprotection.ie.