This statement lets you know how Cairn Homes plc (“Cairn” or the “Company”) and its third-party service providers, agents and others acting on our behalf use your personal information in connection with your relationship with Cairn as an investor (or someone acting on behalf of an investor).
How we collect your personal information
Your personal information may be collected directly from you, from your agent or from your nominee (including Euroclear Nominees Limited, the central securities depositary (or “CSD”) for shares in Cairn Homes plc held electronically). This can include:
- information obtained from identification documentation (including your name, email address, telephone number, address (including city, postcode, and country), nationality and national identity numbers (where applicable);
- your professional title and occupation;
- your age, date of birth and marital status;
- financial information, tax status, and bank account details;
- personal identifiers such as your social security number, national insurance number, tax file number, IP address or your internal electronic identifiers; and
- other information you provide in the course of your dealings with us or which we require you to provide so that we can deal with you as an investor (or on behalf of an investor) in Cairn.
Other information we collect or generate about you will include personal information:
- we produce as a record of our relationship with you, including contact history, and correspondence records;
- in communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements; and
- from publicly available sources, including third party agencies such as credit reference agencies, public databases, registers and records, such as the Companies Registration Office, and information obtained from sanction checking and background screening providers.
How we use your personal information
Meeting our regulatory, legal and other obligations to you as an investor
We use your personal information where necessary to make sure our regulatory and legal obligations and/or contractual commitments to you are met in respect of your holdings in Cairn Homes:
- identify you (or someone else) as the beneficial owner of shares in Cairn that are held on your or their behalf by a third party (including a nominee);
- permit, administer and record your holdings;
- process transactions in respect of which you are a counterparty or beneficiary (such as the sale or purchase of shares in Cairn);
- pay any sums due from us to you, including dividends; and
- manage your rights as a beneficial shareholder or other investor, including any rights you have to attend and vote at general meetings.
Cairn’s legitimate interests
Some of your personal information is used in our legitimate interests for the effective management of our relationship with you as an investor (or as someone acting on behalf of an investor), or the effective management of our business, including:
- the purposes listed in “meeting our legal and other obligations to you as an investor” where you are acting on behalf of the investor;
- to identify you (or someone else) as the beneficial owner of shares in Cairn Homes that are held on your or their behalf by a third party (including a nominee) where it is in our legitimate interest to do so, but where there may be no legal requirement to do so;
- sending corporate communications to you;
- generally managing and improving the quality of our relationship with you;
- internal management and reporting; and
- risk management purposes.
Where we process your personal information for purposes we consider to be in our legitimate interest, you have the right to object. You can do this by emailing us.
Meeting our general legal obligations
As a listed public limited company, Cairn has a number of legal obligations it must fulfil in respect of its shareholders and investors. Your personal information is used as necessary to ensure these legal obligations are met:
- maintaining and updating Cairn Homes’ records in accordance with statutory requirements;
- recording and reporting regulatory and tax related information to regulatory and tax authorities;
- carrying out anti-money laundering checks and related actions necessary to comply with legal obligations related to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, and tax evasion, and to identify persons who may be subject to economic or trade sanctions.
Who else receives your personal information?
We may share your personal information with the third parties detailed below. It is not shared with anyone else and is not transferred by Cairn outside the European Union (unless otherwise stated).
- representatives, agents, custodians, intermediaries and/or other third-party product providers appointed by you;
- third party agents and contractors for the purposes of them providing services both to us and to you (for example, professional advisers and IT and communications providers);
- any depositary, stock exchange, clearing or settlement system, counterparties, dealers, and others where disclosure of your personal information is required for the purpose of effecting, managing, or reporting transactions on your behalf or establishing a relationship with a view to such transactions;
- any regulatory, supervisory, or governmental authorities to the extent we are required by law or regulation to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud) or to establish, exercise or defend our legal rights; and
- tax authorities.
How long do we keep this personal information?
Unless stated otherwise, we keep your personal information for at least the period we are legally required to retain it, based on the following requirements:
- as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with Cairn;
- the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations;
- any retention period that is required by law; or
- the end of the period in which litigation or investigations might arise in respect of an investment in Cairn.
You have the right to:
- access your personal information;
- require us to delete it;
- rectify any personal information we hold that is incorrect; and/or
- have your personal information transmitted to another data controller.
If you want to exercise these rights please let us know, preferably in writing. You will need to provide enough information to verify and complete your request. We will complete your request within thirty days, subject to any legal or other requirements that requires us not to complete your request, in which case we shall inform you of this where we can.
Lodging a complaint
You can complain about our processing of your personal information with your local data protection authority:
Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois, Ireland
How do you contact us?
The data controller is Cairn Homes plc. You can write to Cairn Homes’ Company Secretary or data protection officer at: 7 Grand Canal, Grand Canal Street Lower, Dublin 2. You can email the data protection officer at: firstname.lastname@example.org