Data Protection Policy
Westbrook Motors Ireland Ltd Data Protection Statement
This Statement describes how we use your personal information in connection with this contract with you. Please take the time to read it carefully. You have a number of rights in relation to your information including the right to object to processing of your personal information where that processing is carried out for our legitimate interests.
When you purchase a motor vehicle from us and/or sell a vehicle to us and/or arrange for service or repair of your vehicle and/or instruct us to arrange finance for your vehicle purchase, we, Westbrook Motors Ireland Ltd, will be one of the companies responsible for
handling your personal information (known as a “controller” under data protection law).
The personal information collected by us includes your name, address, contact information, telephone number, email address, finance information, car details and registration number and any other details furnished by you in completing this form.
1. The purpose and legal basis for processing your information
We collect your personal information to enter into a contract with you to sell a motor vehicle to you and/or to purchase a motor vehicle from you and/or to service or repair a motor vehicle and/or supply parts and/or to arrange finance. We may also use your personal information to provide you with a finance or leasing quotation for a motor vehicle.
In order to process your personal information for this purpose, the processing is necessary to enter a contract to which you are a party.
We may use your personal information for direct marketing purposes to make you aware of products and services which may interest you or for customer satisfaction surveys where you have not objected to us doing so. As part of our marketing activities, we may also use your personal
information (including, where permitted by you and your finance provider, any finance details) to
analyse your suitability for trade-ins or upgrades. We may do this by phone, post, email, text or through other digital media. Where we do so we rely on the lawful processing ground of legitimate interest and our legitimate interest is to develop relationships with our existing customers and to assess our performance and standards.
When you purchase a new motor vehicle or a used vehicle not previously registered in the Statefrom us we will use your personal information to register the motor vehicle with the Revenue Commissioners to pay any VRT and VAT on the vehicle or,
where applicable to apply for a VRT, VAT and/or motor tax exemption on your behalf, as required
by law. Where you purchase a used previously registeredvehicle we will use your personal information to transfer the ownership of the vehicle to you. We may also use your personal information to comply with any obligation under anti-money laundering legislation, for the purposes of any statutory audit or for any other legal obligation to which we are subject.
We may also use your personal information to manage our everyday business needs, including accounting and to prevent fraud. Where we do so we rely on the lawful processing ground of
legitimate interest and our legitimate interest is in the effective management of our business.
If you do not provide us with the information we request we may not be in a position to perform the contract we have or are trying to enter in to with you or to perform our legal obligations. We will notify you of this at the time if this is the case.
2. Your Information and Third Parties
· Manufacturer of Your Vehicle & Their Distributor: We pass your personal information on to the manufacturer of the vehicle you purchase and/or their appointed distributor in Ireland for the purposes of warranty, safety, recall and customer satisfaction surveys. If you consent we will also pass your information to the manufacturer distributor of the vehicle you purchase or their appointed distributor in Ireland for marketing activities. The manufacturer or its appointed distributor may contact you separately about their use of your information.
· The Revenue Commissioners: We may sometimes share your information where we do the first registration of your motor vehicle or where we apply for exemptions from VRT, VAT and/or motor tax for you.
· Third Party Service Providers: We may share your personal information with third party service provides that perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, lawyers and other business advisors, marketing companies who carry out marketing campaigns on our behalf and providers of security and administration services.
· Potential Sale of the Dealer: We may also transfer your personal information to companies we plan to merge with or be acquired by.
· An Gardai, Government Bodies or officials: We may share your personal information with an Gardai or other government bodies or agencies where required to do so by law.
· Within our Company Group: Where we form part of a company group we may share your information internally within the group for administrative efficiencies.
· Finance and leasing Companies: We may share your information with finance and leasing companies in order to obtain a quotation for you.
3. Storage Periods
We may hold your personal information for a period of 7 years from the date of completion of this contract or from the end date of any warranty period, whichever is the later. We may hold this data for a longer period if we are legally required to do so.
4. Transfers outside of the European Economic Area
We may transfer your personal data outside of the European Economic Area. These countries do not always afford an equivalent level of privacy protection and in such circumstances we will take specific steps, in accordance with data protection law, to protect your personal information. In particular, for transfers of personal data, outside the EEA where there is no adequacy decision by the European Commission we may rely on contractual protections approved by the European Commission.
5. Your Rights
You have several rights under data protection law in relation to how we use your personal information. You have the right, free of charge, to:
1. check what type of personal data we hold about you and what we do with that information.
You are also entitled to receive a copy of this information
2. rectify any inaccurate personal information we hold about you.
3. erase personal information we hold about you.
4. stop us from using your personal information in certain cases, including if you believe that the
personal information we hold about you is inaccurate or our use of your information is
unlawful. If you exercise this right, we will store your personal information and will not carry
out any other processing until the issue is resolved.
5. object to us using your personal information where we rely on our legitimate interests to use
your information. We will stop using your personal information unless we can demonstrate
overriding legitimate grounds for the continued processing of this information; and
6. receive your personal information in a structured, commonly used and machine-readable format and to have that data transmitted to another data controller.
These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights please contact us using the contact details contained in this order form. We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will explain why.
You also have the right to lodge a complaint to the office of the Data Protection Commission. See www.dataprotection.ie
6. Marketing from Westbrook Motors – Opt out
If you do not wish to hear from us about special offers and promotions by way of post, email, phone, text or digital media you may opt out at any time by contacting firstname.lastname@example.org or 018744000.
You have the right to opt out of the receipt of direct marketing at any time and you can do this by contacting us at the details set out above.
7. Customer Satisfaction Surveys
If you do not wish to hear from us for customer satisfaction surveys by post, email, phone you may opt out at any time by contacting email@example.com or 01 8744000.
If you do not wish to hear from the manufacturer of the vehicle you purchase or it’s appointed distributor in Ireland for customer satisfaction surveys by post, email, phone you may opt out at any time by contacting firstname.lastname@example.org or 01 8744000.
8. Marketing from the Manufacturer or its appointed Distributor
If you do not wish to hear from the manufacturer or its appointed distributor about special, offers and promotions by way of post, email, phone, text or digital media you may opt out at any time by contacting email@example.com or 01 8744000.
Our premises are monitored by CCTV cameras for security & safety purposes, therefore your image and potentially your vehicle registration will be captured and stored. We have strict retention policies in respect of CCTV footage and process data captured by CCTV for security and safety purposes in our legitimate interest.
If finance is required when purchasing a vehicle, we will be required to collect further details including your marital and housing status, number of dependents, previous address, occupation, employer, business address and bank details as well as a copy of your driver’s licence, a proof of address (i.e. a utility bill) and any other relevant documentation. This information will be passed by Westbrook Motors Ireland Ltd with your permission to finance companies and if you are approved for finance the copies of your documentation will be securely shredded after 12 months. Your personal information will be stored on your order form which will be kept for 7 years after which it will be removed.
We review our data retention periods regularly and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.
Our website 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 policies. When you leave any of Westbrook Motors pages.
The Website may offer you the opportunity to share or follow information about us (or the website or our services) using third party social networking functionality (such as through “share this”, “like” or “follow” buttons).
We offer this functionality in order to generate interest in us, the website and our services among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about us with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly-available, including through Internet search engines.
Access to Your Information
You may request, at any time, a copy of the personal information the Company holds about you, at no cost. Should you wish to access or update the personal information that we hold, please contact us by sending a written request to Customer Services Department, Westbrook Motors Ireland Ltd, 23/24 Parkgate Street, Dublin 8 or firstname.lastname@example.org. If you wish to have the information the Company holds on your person removed, please request this in writing to Customer Services Department, Westbrook Motors Ireland Ltd, 23/24 Parkgate Street, Dublin 8 or email@example.com – as long as your information is not pertinent to the completion of a contract or required for any legal reason it will be removed.