PRIVACY NOTICE

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us, including identity documents, financial details, government identifiers, and tenancy-related data.

We collect personal information that you voluntarily provide to us when you register on the Services, submit a tenancy application, sign a lease, contact our helpdesk, submit a maintenance request, or otherwise interact with us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• Names (first name, last name)
• Email addresses
• Phone numbers
• Postal addresses
• Date of birth
• Nationality and country of origin
• Preferred language for communications
• Monthly net income
• Employment details
• Previous landlord reference information
• Housing Assistance Payment (HAP) status and supporting documentation
• Vehicle registration numbers (up to 2 per tenant)
• Pet registration details
• Household member and co-applicant details
• Promotion and referral codes
• Guest parking registration details (name, email, vehicle registration, vehicle type)
• Communal space booking records
• Customer satisfaction survey responses and comments

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Personal Public Service Number (PPSN): Collected during the lease-signing process for RTB registration as required by the Residential Tenancies Acts 2004–2024. Your PPSN is encrypted at rest using AES-256-GCM. Only senior managers can view unblurred PPSN values; all other admin roles see permanently blurred data.
• International Bank Account Number (IBAN): Collected during the lease-signing process for rent payment administration. Your IBAN is encrypted at rest using AES-256-GCM with the same access restrictions as PPSN. IBAN is validated using the Ibandit library at the point of entry.
• Biometric data (facial comparison): During identity verification, a selfie you provide is compared against the photograph on your identity document using AWS Rekognition. The comparison returns a similarity score. No biometric template is stored beyond the comparison event. This processing is based on your explicit consent.
• Identity document data: Passport or driving licence images are processed by AI (Google Gemini) to extract your name, date of birth, nationality, document number, expiry date, and country of issue. Only passports and driving licences are accepted; other document types are rejected.
• Vulnerability flags: Where a tenant is identified as vulnerable, a flag may be set on their account to ensure appropriate escalation in our out-of-hours voice helpdesk system.

Tenancy Records. We collect and maintain records related to your tenancy, including:

• Apartment and building details, lease dates, rent amounts
• Digitally signed lease documents
• Lease addendums, renewals, and shared lease arrangements
• RTB registration numbers
• Move-in and move-out inspection records, condition assessments, and photographs
• Maintenance request descriptions, photos, and resolution records

Support and Communication Data. When you contact our support services, we collect:

• Helpdesk ticket content (email, in-app, and web submissions), including attachments
• Voice call recordings and transcripts from our out-of-hours telephone helpdesk (see Section 6 for details on AI triage)
• SMS messages sent and received
• Push notification delivery records
• Email correspondence and audit logs

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera (for selfie verification and maintenance/inspection photos), and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
• Push Notifications. We may request to send you push notifications regarding your account, helpdesk tickets, maintenance updates, lease events, guest parking registrations, space booking confirmations, and emergency alerts. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected from third parties

We also collect information about you from the following third-party sources:

• BoldSign, FairDocs OS: Lease execution status and signed document records.
• Co-applicants: If you are invited to a shared lease application, the lead applicant provides your email address.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, verify your identity, manage your tenancy, ensure resident safety, and comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To verify your identity. We process your identity documents and selfie images using AI and facial comparison services to confirm you are who you claim to be, as part of our fraud prevention and application assessment processes (see Section 6).
• To assess tenancy applications. We process your application data (income, employment, ID verification status, HAP eligibility) against pre-configured eligibility criteria. A human administrator reviews all applications before a decision is communicated to you.
• To screen applicants against regulatory records. We search your name against the RTB dispute database to identify any prior dispute determinations. Flagged applications are reviewed by a senior property manager (see Section 6).
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service, including lease creation, rent invoicing, maintenance management, and communal space bookings.
• To manage rent collection and arrears. We process financial data imported to calculate balances, issue invoices, and manage RTB-compliant arrears escalation workflows. All formal notice actions require human approval (see Section 6).
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. This includes AI-assisted reply drafting and sentiment analysis for prioritisation (see Section 6).
• To triage and escalate out-of-hours calls. When you call our out-of-hours helpdesk, your call is recorded, transcribed, and analysed by AI to classify the urgency of your issue and route it to the appropriate human responder (see Section 6).
• To send emergency alerts. In a building emergency, we use automated systems to contact all affected residents simultaneously via telephone and/or SMS using text-to-speech in your preferred language (see Section 6).
• To conduct property inspections. We process inspection data, condition assessments, and photographs as part of move-in, move-out, and routine property inspections.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, lease reminders, invoice notifications, and other similar information.
• To request feedback. We may process your information when necessary to request feedback via customer satisfaction surveys and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see Section 10.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm. This includes emergency call escalation and building-wide emergency broadcasts.
• To comply with legal obligations. We process your PPSN for RTB registration, manage arrears escalation in compliance with the Residential Tenancies Acts, generate tamper-proof audit certificates, and obfuscate personal data of former tenants in accordance with GDPR data minimisation principles.
• For internal operational analytics. Our internal operations team uses an AI-powered search tool to query aggregated operational data (occupancy, maintenance, support performance) for property management purposes. The same role-based access controls apply (see Section 6).

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent (Article 6(1)(a) and Article 9(2)(a) GDPR). We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. In particular, we rely on your explicit consent for the processing of biometric data during facial comparison (selfie vs. identity document). You can withdraw your consent at any time by contacting us at support@mail.vestaliving.ie. Please note that withdrawing consent for facial comparison may prevent us from processing your tenancy application.

Performance of a Contract (Article 6(1)(b) GDPR). We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you. This includes tenancy application processing, lease creation and management, rent invoicing, maintenance request handling, communal space bookings, and IBAN collection for rent payment administration.

Legitimate Interests (Article 6(1)(f) GDPR). We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Verify your identity and prevent fraud (AI document extraction, facial comparison fallback to manual review)
• Screen applicants against publicly available RTB dispute records
• Draft helpdesk replies, analyse sentiment, and extract maintenance task details using AI assistance
• Record and triage out-of-hours voice calls to ensure resident safety
• Conduct property inspections and maintain photographic condition records
• Operate guest parking registration and visitor management
• Measure and improve service quality through CSAT surveys
• Generate operational analytics and portfolio reporting
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience

Legal Obligations (Article 6(1)(c) GDPR). We may process your information where we believe it is necessary for compliance with our legal obligations. This includes:

• Collection and retention of PPSN for RTB registration under the Residential Tenancies Acts 2004–2024
• Management of rent arrears escalation in compliance with RTB statutory requirements
• Filing of statutory notices with the RTB.
• Generation of tamper-proof audit certificates (SHA-256 hashed, stored with S3 Object Lock for 7-year COMPLIANCE retention)
• GDPR data obfuscation for former tenants after the retention period expires
• Cooperation with law enforcement or regulatory agencies as required

Vital Interests (Article 6(1)(d) GDPR). We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party. This includes:

• Emergency escalation of out-of-hours voice calls classified as emergencies or security incidents
• Mass emergency broadcast calls and SMS to all residents in an affected building (fire, gas leak, flooding, security alerts)
• Automatic escalation override for calls from residents flagged as vulnerable

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties. We never sell your personal data.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we share personal information with are as follows:

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. This data helps Google Maps provide directions, but it is not always perfectly precise.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, and tools powered by artificial intelligence, machine learning, or similar technologies. These are used to enhance service delivery and resident safety. All consequential decisions are reviewed by a human.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, ‘AI Products’). These tools are designed to enhance your experience, improve operational efficiency, and ensure resident safety. The terms in this Privacy Notice govern your use of the AI Products within our Services.

All personal information processed using our AI Products is handled in line with this Privacy Notice and our data processing agreements with third-party AI providers. This ensures high security and safeguards your personal information throughout the process.

Our AI Products

Our AI Products are designed for the following functions:

(a) Identity Document Extraction.

When you upload a passport or driving licence, we use Google Gemini to extract structured data from the document image, including your name, date of birth, nationality, document number, and expiry date. Only passports and driving licences are accepted; other document types are rejected. The extracted data is used to pre-populate your application and is verified by our staff. The AI does not make any tenancy decisions. Legal basis: Legitimate interest — fraud prevention (Article 6(1)(f) GDPR).

(b) Facial Comparison.

We use AWS Rekognition to compare your selfie against your identity document photograph. The service returns a similarity score. A match confirms your identity; a non-match prompts you to retake the selfie. If AWS Rekognition is unavailable, your selfie is saved and the comparison is flagged for manual admin review. No biometric template is stored beyond the comparison event. Legal basis: Explicit consent (Article 9(2)(a) GDPR).

(c) RTB Dispute Screening.

When you submit a tenancy application, your name is searched against the Residential Tenancies Board (RTB) dispute database. If disputes are found, a risk classification (High, Medium, or Low) is automatically generated based on the number of disputes and total awards. All flagged applications are reviewed by a senior property manager before any decision is made. The screening note is authored by an automated bot account and is clearly distinguishable from human notes. Legal basis: Legitimate interest (Article 6(1)(f) GDPR).

(d) Helpdesk AI Assistance.

Our helpdesk uses Google Gemini to: (i) draft suggested replies for our support agents, which are always reviewed and edited before sending; (ii) analyse the sentiment of incoming support communications to help prioritise urgent issues; (iii) extract maintenance task details (description, priority, location) from support ticket conversations; and (iv) scan and rewrite helpdesk macros (reusable response templates). These are assistive tools for our staff and do not autonomously communicate with tenants or make decisions about your tenancy. Legal basis: Legitimate interest (Article 6(1)(f) GDPR).

(e) Voice Call Triage and Escalation.

When you call our out-of-hours support line, your call is recorded and transcribed by Telnyx. The transcript is then analysed by Anthropic Claude Haiku to classify the nature of your issue. The AI determines one of four outcomes:

• Emergency — immediate outbound call to the on-call property manager (and backup if no answer). Triggered by fire, flood, violent incidents, or when sentiment score exceeds the configurable panic threshold, or for any issue reported by a resident flagged as vulnerable.
• Security — immediate outbound call to the building security contact. Triggered by break-ins, intruders, or suspicious activity.
• Ticket — a helpdesk ticket is created for next-business-day follow-up. Triggered by noise complaints, maintenance, and general queries.
• Incomplete — an SMS is sent to the on-call manager as a fallback. Triggered when no transcript is available, AI classification fails, or no escalation policy is configured.

The outbound call delivers a text-to-speech summary in the on-call manager’s language and collects DTMF confirmation. All escalation attempts are logged. Legal basis: Legitimate interest (Article 6(1)(f) GDPR); Vital interests (Article 6(1)(d) GDPR) for emergency escalation.

(f) Arrears Detection and Escalation.

Financial data is processed automatically to calculate rent balances, detect overdue payments, and trigger escalation workflows. This includes automated delinquency detection, a configurable new-invoice grace period, compliance countdown timers, and a 9-state escalation state machine. However, all substantive actions — including the issuance of warning notices, notices of termination, and RTB filings — require human review and electronic signature by a property manager. No formal legal notice is sent without human approval. Legal basis: Contract (Article 6(1)(b) GDPR); Legal obligation (Article 6(1)(c) GDPR).

(g) Mass Emergency Broadcasts.

In a building emergency (fire, gas leak, flooding, security alert), an admin can trigger an automated broadcast that simultaneously calls all residents in the affected building using Telnyx text-to-speech technology. The message is delivered in each resident’s preferred language. Residents confirm receipt by pressing a key on their phone (DTMF). Residents without a phone number on file receive an SMS instead. This system is always initiated by a human administrator. Legal basis: Vital interests (Article 6(1)(d) GDPR).

(h) Operational Analytics.

Our internal operations team uses an AI-powered search tool to query aggregated operational data such as occupancy metrics, arrears trends, maintenance backlogs, and helpdesk performance. This tool can execute read-only database queries with strict safeguards (5-second timeout, 50-row limit, allow-listed methods only). Where individual tenant records are accessed, the same role-based access controls that apply to the standard admin panel are enforced. This tool is not tenant-facing. Legal basis: Legitimate interest (Article 6(1)(f) GDPR).

(i) AI Image Generation.

We use Google Gemini to generate illustrative images for building announcements and communications. These images do not contain or depict any tenant personal data. Legal basis: Legitimate interest (Article 6(1)(f) GDPR).

Human Oversight Commitment

We are committed to responsible AI use. The following safeguards are in place:

• No fully automated decisions with legal effect. No tenancy application is approved or rejected solely on the basis of automated processing. A qualified human administrator reviews all applications before a decision is communicated to you.
• Human-in-the-loop for formal notices. All formal notices (including rent arrears warnings and notices of termination) require human review and electronic signature by a property manager before issuance.
• AI-assisted, not AI-decided. Where AI is used to draft communications (such as helpdesk replies or maintenance task descriptions), these drafts are reviewed and edited by our staff before being sent.
• Emergency escalation safeguards. When the voice triage system classifies a call as an emergency, it triggers an immediate outbound call to a human on-call manager. The AI classification is a routing mechanism, not a substitute for human emergency response.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, RTB registration, or other legal requirements).

The following table sets out our standard retention periods:

Our automated GDPR data obfuscation process (UserDataObfuscatorService) runs daily at 04:00 and anonymises personal data for former tenants whose retention period has expired. This includes replacing names, email addresses, phone numbers, and other identifiers with anonymised values.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures, including encryption at rest for sensitive data.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. Key measures include:

• Encryption at rest: PPSN and IBAN values are encrypted using AES-256-GCM via Rails Active Record Encryption. Direct database access reveals only ciphertext. Loss of the encryption keys renders the data unrecoverable.
• Encryption in transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher.
• Role-based access control: Five distinct admin roles with graduated access to sensitive data. Only the highest tier can view unblurred PPSN/IBAN values. The Security role is GDPR-constrained to name-based tenant search only, with no access to email, DOB, financial, or lease data.
• Two-factor authentication: All admin accounts require two-factor authentication (TOTP-based via devise-two-factor).
• OAuth2 authentication: Tenant API access is secured via Doorkeeper OAuth2 tokens.
• Webhook signature verification: Inbound webhooks (e.g., Telnyx Ed25519, BoldSign HMAC) are cryptographically verified before processing.
• Audit logging: Arrears escalation events are hashed with SHA-256 for tamper detection. On closure, all events are serialized into a PDF Audit Certificate stored in S3 with 7-year COMPLIANCE-mode Object Lock.
• EU hosting: Our application is hosted on Render in the Frankfurt (eu-central-1) region. Our primary database is PostgreSQL hosted in the same region.
• Error monitoring: We use Honeybadger for application error tracking. Error payloads are sanitised to exclude personal data.
• Automated data obfuscation: Daily scheduled job anonymises personal data for former tenants beyond the retention period.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@mail.vestaliving.ie.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include:

• Right of access (Article 15 GDPR): You have the right to request a copy of the personal data we hold about you. We will respond within one month.
• Right to rectification (Article 16 GDPR): You have the right to request correction of any inaccurate or incomplete personal data.
• Right to erasure (Article 17 GDPR): You have the right to request deletion of your personal data where there is no compelling reason for continued processing. This is subject to legal retention obligations (e.g., 7-year RTB and Revenue requirements). You can request account deletion through the mobile app, which triggers an automated eligibility check. If eligible, an admin processes the deletion with a full audit trail; if ineligible (e.g., active lease, 7-year retention period), you are informed of the reason.
• Right to restrict processing (Article 18 GDPR): You have the right to request restriction of processing in certain circumstances.
• Right to data portability (Article 20 GDPR): You have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format.
• Right to object (Article 21 GDPR): You have the right to object to processing based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds.
• Rights regarding automated decision-making (Article 22 GDPR): You have the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. We do not make any fully automated decisions with legal effect — all consequential decisions are reviewed by a human (see Section 6). You have the right to obtain human intervention, express your point of view, and contest any decision.

You can make such a request by contacting us at support@mail.vestaliving.ie or using the contact details provided in Section 13.

We will consider and act upon any request in accordance with applicable data protection laws. We may ask you to verify your identity before processing your request. We will respond within one month, or inform you if an extension is needed (up to two additional months for complex requests).

Supervisory authority: If you are located in the EEA and you believe we are unlawfully processing your personal information, you have the right to complain to the Data Protection Commission (An Coimisiún um Chosaint Sonraí), 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland. Website: www.dataprotection.ie. Phone: +353 (0)761 104 800.

If you are located in the UK, you may contact the Information Commissioner’s Office (ICO). If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information (e.g., biometric facial comparison), you have the right to withdraw your consent at any time by contacting us at support@mail.vestaliving.ie. This will not affect the lawfulness of the processing before its withdrawal nor the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in Section 13. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Update your profile through the mobile app or web portal
• Request account deletion through the mobile app (triggers automated eligibility check)
• Contact us using the contact information provided in Section 13

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements (including the 7-year RTB and Revenue retention obligations for PPSN, IBAN, and lease data).

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at support@mail.vestaliving.ie.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated ‘Last updated’ date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at notices@twinlite.com, or contact us by post at:

Twinlite Services Limited

Data Protection Officer

4th Floor, Phibsborough Tower

Phibsborough Road

Dublin, D07XH2D

Ireland

If you have any further questions or comments, you may also contact us by post at the following corporate address:

Twinlite Services Limited

4th Floor, Phibsborough Tower

Phibsborough Road

Dublin, D07XH2D

Ireland

Phone: (+353) 1 827 3662

For data protection and privacy rights requests: support@mail.vestaliving.ie

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, you can:

• Email us at support@mail.vestaliving.ie with a data subject access request
• Request account deletion through the Vesta mobile app (triggers automated eligibility check with reasons for any ineligibility)
• Contact us by post at the address in Section 13

We will respond to your request within one month in accordance with applicable data protection laws.