Conveyance Tracker Privacy Policy for Solicitors’ Clients

Introduction
1. Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy controls and your rights in connection with our website (Conveyance Tracker, the Tracker). Conveyance Tracker is headquartered in the Republic of Ireland and our Services are provided to you by Dricko Limited. When you upload data to the Tracker, you are the owner of this data, your solicitor is the controller of it and Conveyance Tracker is the data processor. Information uploaded by you to the Tracker for your solicitor’s attention is stored on the Tracker.
2. This privacy notice aims to give you information on how the Tracker collects and processes your personal data through your use of this platform, including any data you may provide through this platform when you sign up to our platform and/or use the website.
3. This platform is not intended for children and we do not knowingly collect data relating to children.
4. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
In order to progress your conveyance file, you upload data to the Tracker. This information is made available to your solicitor. You and your solicitor engage collaboratively in the Tracker in order to progress your conveyancing file. In relation to the data that you share on the Tracker, you are the data owner, your solicitor is the data controller and the Tracker is the data processor.
Contact details
Our full details are:
Full name of legal entity: DRICKO LIMITED,
Name or title of data privacy manager: Eddie O’Driscoll
Email address: info@conveyancetracker.ie
Postal address: 17 - 18 French Church Street, Cork, Ireland
Complaints: You have the right to make a complaint at any time to the Data Protection Commissioner's Office (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We would, however, appreciate the chance to deal with your concerns before you approach the DPC so please contact us in the first instance info@conveyancetracker.ie
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 3rd November 2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Information Conveyance Tracker Collects
1. Overview: Conveyance Tracker collects information about the data and files that you upload to the Tracker such as but not limited to proof of ID & address documentation, marriage/divorce certificates, LPT statements, signed ATR requests, financial statements, NPPR statements, planning documentation pertaining to their properties in sale or that you are purchasing and any other documentation you upload to progress their conveyancing file with you.
2. Account, Profile, Activity, and Use Information: We collect basic account information such as your name, email address, phone number, username and password and payment information that helps secure and provide you with access to our Services.
3. Messaging: The Tracker provides a messaging service for you to interact with your solicitor via the Tracker. The data in these messages is collected in the Tracker. This includes strictly confidential communications between you and your solicitor.
4. Technical Information and Log Files: We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information. The Services use log files. The information stored in those files includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track usage in the aggregate, and gather broad demographic information for aggregate use. IP addresses may be linked to account information and device identifiers.
5. Other Information: We may collect information from you through third parties, such as when we collect your feedback through surveys.
How Conveyance Tracker Uses Information: Conveyance Tracker uses the information we collect and receive as described below.
1. To provide the Services: We use the information that we collect to facilitate you and your solicitor to collaborate on conveyancing files in order to improve the efficiency with which these files are managed.
2. To customize your experience: We use some of the information you provide to personalise your experience with us as you use our services, such as addressing you personally on our services and making navigation on our sites easier. We use aggregate information we collect about you to suggest and recommend tailored content. Where we collect this information by way of cookies or other similar technologies, we only collect this information with your consent, which you can withdraw at any time. However where we further process this information, we rely on the lawful processing ground of legitimate interest in delivering relevant content to our users.. You have the right to object to this processing if you wish – please contact us at info@conveyancetracker.ie if you wish to object.
3. To improve our Services: We also use the information we collect to analyze, develop and improve the Services. To do this, Conveyance Tracker may use third-party analytics providers to gain insights into how our Services are used and to help us improve the Services.
4. To communicate with you: We use the information we collect to provide support in response to your requests and comments.
5. To process your account: We use the information we collect to process your end user account to access the platform.
6. For you to provide services to us or our users: if you are a third party service provider, operating on our marketplace, you confirm that you or your employees and agents have provided their consent for us to collect data from you in accordance with this policy.
Aggregate Information
1. We do not sell your personal information. The Tracker may aggregate the information you and others make available in connection with the Services and post it publicly or share it with third parties, including the Metadata pursuant to our Terms
How Information is Shared: In addition to sharing aggregated data about our users as described above, we also share personal information in accordance with your preferences, as needed to run our business and provide the Services, and where required for legal purposes, as set forth below.
1. Service Providers: We may share your information with third parties who provide services to Conveyance Tracker such as supporting, improving, promoting and securing the Services, processing payments, or fulfilling orders. These service providers only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf, so that we or they may promote the Tracker or display information that may be relevant to your interests on the Services or other websites or services.
2. Third Party Business via API or Other Integrations: We enable you to share your information with third parties who work with Conveyance Tracker to offer an integrated feature, such as a BER Assessor or an Engineer on the marketplace. When you click on a service provider on the marketplace you choose to permit us to share your profile data with that service provider, so that they can communicate with you in relation to the provision of services. Information collected by these third parties is subject to their terms and policies. Conveyance Tracker is not responsible for the terms or policies of third parties.
How We Protect Information: We take several measures to safeguard the collection, transmission and storage of the data we collect. We employ reasonable protections for your information that are appropriate to its sensitivity. The Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Conveyance Tracker engages providers that are industry leaders in online security, including Services verification, to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm Conveyance Tracker’s identity before any personal information is sent. In addition, Conveyance Tracker’s secure servers protect this information using advanced firewall technology.
Managing Your Settings
1. Privacy Controls: Conveyance Tracker offers several features and settings to help you manage your privacy and share your activities.
2. Updating Account Information: You may correct, amend or update profile or account information at any time by adjusting that information in your account settings.
3. Deleting Information and Accounts and Downloading Your Data: After you make a deletion request, we permanently and irreversibly delete your personal data from our systems, including backups. Once deleted, your data, including your account cannot be reinstated and a new account will need to be set up by you. Following your deletion of your account, it may take up to 90 days to delete your personal information and system logs from our systems.
  Note that content you have shared with us, such as photos of your property may also remain visible after you have deleted your account or deleted specific information for a period.
Your Legal Rights in the EEA: If you are habitually located in the EEA, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information.
1. Our Legal Bases: Conveyance Tracker relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:
  - as necessary to provide the Services and fulfil our obligations pursuant to the terms of service;
  - where you have consented to the processing;
  - where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  - to protect your vital interests, or those of others, such as in the case of emergencies; and
  - where necessary for the purposes of Conveyance Tracker’s or a third party’s legitimate interests, such as our interests in protecting our users, our partners’ interests in collaborating with our users, and our commercial interests in ensuring the sustainability of the Services.
Retention of Information:
1. We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until your account is deleted. In addition, you can delete some items of information (e.g., profile information) and you can remove individual activities from view on the Services without deleting your account.
2. Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Conveyance Tracker, such as statistics of the use of the Services.
Privacy Policy Information: Conveyance Tracker reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Conveyance Tracker makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.
Third-party links: This platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our platform, we encourage you to read the privacy notice of every website you visit.
Marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
1. Promotional offers from us: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you including our tools and information, routes, offers and other Services. This is how we decide which content, products, and services may be relevant for you (we call this marketing). You will receive marketing communications from us if you have registered on the Platform or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing you will receive content from our business partners (push notifications and email – you will still see banner advertising).
2. Cookies: You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy for more information.
Disclosures of your personal data: We may have to share your personal data with the parties set out below for the purposes set out above.
- Internal Third Parties (other companies in the Conveyance Tracker group acting as joint processors and who are based in the USA or elsewhere and provide IT and system administration services.
- External Third Parties (Service providers acting as processors based in the USA and elsewhere, who provide IT and system administration services).
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers
1. We share your personal data within the Conveyance Tracker group and to certain third party service providers. This will involve transferring your data outside the European Economic Area (EEA).
2. Our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
3. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
4. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details.
5. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Your legal rights: Under certain circumstances, you have rights under data protection laws in relation to your personal data.
1. No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
2. What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
3. Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
4. California Residents: This Privacy Policy complies with the California Consumer Privacy Act (CCPA), which requires that Conveyance Tracker provide California residents with notice that you have the right to: opt-out of the sale of personal information; know about personal information collected, disclosed or sold; to request the deletion of personal information; and to be treated without discrimination should you exercise these rights. More information regarding the sources from which we collect personal information can be found in this section and the Privacy Policy; business and commercial purposes for which we collect your personal information can be found in this section and in the Privacy Policy; and categories of recipients with whom personal information is shared or sold can be found in this Agreement and the Privacy Policy. To make a request under the CCPA, or for any questions or concerns about this Privacy Policy or practices, please contact Conveyance Tracker at info@conveyancetracker.ie