Privacy Policy

Effective date: 15th September 2020


1.1 We are Xestra Asset Management Limited (“us”, “we”, or “our”) and we operate the [] website (the “Service”). We are the controller in relation to Personal Data (defined below) collected on this Service.

1.2 We are committed to safeguarding the privacy of our website visitors and service users. This Privacy Policy informs you of how we collect, use, and disclose your Personal Data when you use our Service and the choices you have associated with that data.

1.3 It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. Please do not use our site or send us any personal data if you do not want your data to be used in the way set out in this Privacy Policy.


2.1 Personal Data

2.1.1 While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). This may include:

(a) First name and last name
(b) Home address
(c) Email address
(d) Phone number
(e) Cookies and Usage Data
(f) Photographs
(g) Videos

2.1.2 We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.1.3 The lawful basis for processing of your Personal Data is the performance of a contract with you, our legitimate interest and/or compliance with a legal obligation.

2.2 Usage Data

2.2.1 We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s internet protocol address (i.e. IP address), geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.

2.2.2 The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 Cookies Data

2.3.1 We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

2.3.2 Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

2.3.3 For more information on the cookies used by us please see our cookie policy: [INSERT HYPERLINK].

2.4 Communication with you

2.4.1 We may process information contained in, or attached to, any communication that you voluntarily send to us (“general communication data”). This data may include data which verifies ownership of a property (e.g. recent utility bills). The legal basis for this processing is the performance of a contract with you, our legitimate interests and/or compliance with a legal obligation.

2.4.2 We may process information that you provide to us for the purposes of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. We will only send you notification data if you opt in to receive notification data or if we have a contract with you and you can opt out at any time.


3.1 We use the collected data for various purposes, including our legitimate business interests, the performance of a contract with you and/or compliance with a legal obligation, to:

3.1.1 allow us to analyse website performance;
3.1.2 provide and maintain the Service;
3.1.3 notify you about changes to our Service;
3.1.4 allow you to participate in interactive features of our Service when you choose to do so;
3.1.5 provide customer care and support;
3.1.6 provide analysis or valuable information so that we can improve the Service;
3.1.7 monitor the usage of the Service; and
3.1.8 detect, prevent and address technical issues.

3.2 We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

3.3 If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

3.Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


4.We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

4.2 To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure of your data, the purposes for which we process your data and whether we can achieve those purposes through other means and the applicable legal requirements.

4.3 Details of retention periods for different aspects of your data are available in our retention policy which you can request from us by contacting us.


5.1 We may disclose your Personal Data in the good faith belief that such action is necessary to:

5.1.1 comply with legal requirements;
5.1.2 comply with a legal obligation;
5.1.3 protect and defend our rights or property;
5.1.4 prevent or investigate possible wrongdoing in connection with the Service;
5.1.5 protect the personal safety of users of the Service or the public;
5.1.6 protect against legal liability; or
5.1.7 track the performance of certain paid advertising channels.

5.2 We may also disclose your Personal Data with:

5.2.1 any member of our group (this means our subsidiaries, our holding company, lessees, assignees etc.) insofar as reasonably necessary for the business purposes, and on the legal basis, set out in this policy; and

5.2.2 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.

5.3 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.


We do not transfer your personal data outside the European Economic Area (EEA).


The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.


8.1 We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

8.2 These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.


We may use third-party Service Providers to monitor and analyse the use of our Service.


10.1 Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

10.2 We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


11.1 Our Service does not address anyone under the age of 18 (“Children”)

11.2 We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your child/children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take all reasonable take steps to remove that information from our servers.


12.1 Under certain circumstances, you have rights under data protection laws in relation to your data. These rights are to:

12.1.1 request access to your data;
12.1.2 request correction of your data;
12.1.3 request erasure of your data;
12.1.4 object to the processing of your data;
12.1.5 request restriction of your data; and
12.1.6 request transfer of your data.

12.2 In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.

12.3 We will respond to your request in writing, or orally if requested, as soon as practicable and in any event within one month of receipt of your request. 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. We may request proof of identification to verify your request.

12.4 You will not have to pay a fee to access your data (or to exercise any of the other rights) but we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.


13.1 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.

13.2 We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

13.3 You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


For full details of our Cookie Policy covered under this please click {HL}


If you have any questions about this Privacy Policy, please contact us:

By email: at

By Post: C/o Xestra Asset Management, 11 Hume Street, Dublin 2.

You have the right to make a complaint at any time to the Data Protection Commission , the Irish supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission, so please contact us in the first instance.

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