Privacy Policy

Introduction

Flairside Limited trading as Lanthorn (“Lanthorn“) is committed to protecting and respecting your privacy. We wish to be transparent on how we process your data and show you that we are compliant with the General Data Protection Regulation 2016 and Data Protection Act 2018 (“GDPR“) in relation to processing your data and ensuring you understand your rights as a client. This privacy notice explains when and why Lanthorn collects personal data, how it is used, the condition under which it may be disclosed to others and how it is kept secure.

Who we are

1. The primary activities of Lanthorn consist of the proposition and management of property investments for clients.
2. For the purposes of GDPR, Flairside Limited is the data controller and our contact details are:

   GDPR Owner: Eimear Fox
   Address: 22 Kildare Street, Dublin, D02 Y044
   Email: info@lanthorn.ie

3. Your privacy is important to us. If you have any comments or questions regarding this statement, please contact us on the details provided above.

What Personal Information Do we Collect and Why?

1. We collect data about you when you apply for our services or visit our website. Data is collected only to provide you with our services, to comply with relevant laws and regulations and via cookies on our website. More details on the cookies we collect and your choices in that regard are included in our Cookies Policy.
2. Data is retained and processed to provide you with one of our services, and to comply with relevant laws and regulations, including internal operating procedures and compliance checks.
3. We may collect data under a number of categories, including:
   1. Identification & Contact Information, including your Name, Date of Birth, Gender, Marital Status, PPS Number, Address, Email Address, Home Phone Number, Work Phone Number, Mobile Number
   2. Financial Details & Financial Information, including your Occupation, Job Title, Total Remuneration, Employment Details, Employer Name, Bank Details, Tax Residence, your Income, Assets and Liabilities.
4. We do not collect special categories of personal data as defined within the GDPR, such as health information, however if this changes we will ensure that we require this information, and that we have your explicit consent and/or authorisation prior to our collection.

Information We Automatically Collect

We sometimes automatically collect certain types of information when you visit our website and through e-mails when we communicate with you. Automated technologies may include the use of web server logs to collect IP addresses, “cookies” and web beacons. Other cookies such as functional cookies, marketing cookies and analytical cookies will only be used with your express consent. Further information about our use of cookies can be found in our Cookie Policy.

Our Lawful Basis

1. We need to ensure that we process your personal data lawfully. We rely on the following legal grounds to collect and use your personal data:
   1. To provide the service(s) we have contracted to provide to you;
   2. To comply with a legal or regulatory obligation such as e.g. the requirement to carry out anti-money laundering customer due diligence;
   3. Where we collect special category personal data as defined by GDPR such as health information we can only do so on receipt of your explicit consent. We may also rely on your consent to send direct marketing to you. We will ensure that we present this to you concisely. We will also ensure that we use clear and plain language and if you give us your consent you can withdraw this easily at any time.
2. The consent for the lawful basis for controlling and processing (i.e. collect, store & use) your personal information is given when you apply for our services.

Sharing Your Data

1. We will keep your personal data confidential but may pass it on to third-party services contracted to Lanthorn in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide to us.
2. We may also share your data with regulatory and other governmental bodies where required by or under any enactment or rule of law or court order, including, but not limited to, the Revenue Commissioners and the Companies Registration Office.
3. We do not currently transfer personal data outside the EEA. If we do so in the future, we will ensure that such transfers comply with data protection law, for example by relying on a European Commission adequacy decision or Standard Contractual Clauses.

What Are Your Rights Around Data?

1. At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
2. 1. Right of access: you have the right to request details of and/or a copy of the information that we hold about you.
   2. Right of rectification: you have a right to correct data that we hold about you that is inaccurate or incomplete.
   3. Right to be forgotten: in certain circumstances you can ask for the data we hold about you to be erased from our records.
   4. Right to restriction of processing: where certain conditions apply to have a right to restrict the processing.
   5. Right of portability: you have the right to have the data we hold about you transferred to another organisation.
   6. Right to object: you have the right to object to certain types of processing such as direct marketing.
   7. Right to object to automated processing, including profiling: you also have the right to be subject to the legal effects of automated processing or profiling.
   8. Right to judicial review: In the event that Lanthorn refuses your request under rights of access, we will provide you with a reason as to why.
3. All of the above requests will be forwarded on should there be a third party involved as we have indicated in the processing of your personal data.

How Long Do We Hold Personal Information For?

1. We retain personal information for only as long as we are required to either/or to provide the service(s) you have asked us to provide or to comply with regulatory or legal obligations. Our default retention period, in line with statutory requirements, is currently 6 years following the cessation of a client relationship.
2. Personal data will be disposed of securely.

If You Have A Complaint

1. If you wish to make a complaint about how your personal data is being processed by Lanthorn or how your complaint has been handled, you have the right to lodge a complaint with our GDPR Owner whose contact details are provided above.
2. You also have the right to complain to the Office of the Data Protection Commissioner at:

   Data Protection Commission
   21 Fitzwilliam Square South,
   Dublin 2. D02RD28

   Web: www.dataprotection.ie
   Email: info@dataprotection.ie

Privacy Policy Statement Changes

Lanthorn may change this privacy policy from time to time. When such a change is made, we will post a revised version online. Changes will be effective from the point at which they are posted. It is your responsibility to review this privacy policy periodically so you’re aware of any changes. By using our services you agree to this privacy policy.

Last Updated: September 2025