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PRIVACY POLICY

1. INTRODUCTION AND GENERAL TERMS

This Privacy Policy relates to our use of any personal information you provide to us through the website (the “Site”). We have separate statements for customers that enter into a contract with us for vehicles sales or servicing.

This privacy policy explains the following: what types of information we collect from you, how it is used by us, how we share it with others, how long we keep your information for, your rights, how you can manage the information we hold and how you can contact us.

We require and use your information in order to fulfil and deliver services associated to your vehicle and its maintenance. As a business we sometimes communicate product information, offers and services; however, we will only do this if you have already given us the appropriate permission.

We will not send you unsolicited ‘junk’ email or communications or share your data with anyone else. We do not sell your information to third parties, but we do work with closely selected partners who help us to provide you with the information, products and services that you request from us.

The Site may contain hyperlinks to sites owned and operated by third parties. These third party sites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information you submit or are collected by cookies whilst visiting these sites. We do not accept any responsibility or liability for the privacy practices of such third party sites and your use of such sites is at your own risk.

2. WHAT INFORMATION WILL COUNTY MOTIVE POWER LIMITED T/A CAPITAL MOTORS COLLECT ABOUT ME?

We collect information in the following ways:

Information you give us, about you and your vehicle when you engage with us, or via our websites and applications. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

Information we get from your use of our services or service providers. We collect information about you or your vehicle when you use our website and applications. We also obtain information about you or your vehicle from the manufacturer or distributor. Some of this information does not identify you personally but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you).

The information we collect includes some or all of the following:

· Name (including title)

· Address including Eircode

· Phone number

· Date of birth (only where and if strictly necessary)

· Email address

· Vehicle information (including registration number, VIN, service reminders, mileage and warranty-covered repair information)

· The date and time you used our services

· The pages you visited on our website and how long you visited us for

· Your IP address

· The internet browser and devices you are using

· Cookie, Pixels or Beacon information (for more information please see our Cookies policy)

· The website from which you accessed our website

· Details of any transactions between you and us

· Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details

· Any information within correspondence you send to us

· CCTV in our premises.

3. HOW WILL WE USE THE INFORMATION COLLECTED ABOUT YOU?

We will only process information that is necessary for the purpose for which it has been collected. If you do not provide us with the information we require, relevant and appropriate to the reason for which we request it, this may prevent you from fully availing of our services. We may use the personal data we gather for any or all of the following purposes:

Purpose

Description

Lawful Basis for Processing

Purchasing a Vehicle or Part – Customer Administration

When a customer orders a vehicle or motor part from us, information is collected by us for the fulfilment of warranties and services associated to the purchase of the vehicle or parts/accessories.

The processing is necessary for the performance of a contract to which the customer is party.

Requesting a Quote/ Requesting a brochure / Booking a Test drive

When a customer visits our website, and requests a brochure or a quote for specific vehicle, or when booking a test drive, essential identification and contact details are collected in order to deliver the requested material.

The processing is in our legitimate interests in developing business leads with potential customers.

Registering interest

When a customer visits our website and registers interest in any of our products, essential identification and contact details are collected in order to provide the information over time and, where and if applicable, those details may be sent to the relevant dealer for follow up.

The customer has given explicit consent to the processing.

CCTV

We operate a CCTV system on our premises to protect the safety and security of our staff, visitors and property.

The processing is in our legitimate interests as a private company regarding safety and security.

Safety Incidents / Product recall

We may use your personal data to contact you regarding an urgent safety measure and / or a product recall.

The processing is necessary for compliance with a legal obligation to which the controller is subject.

Staff Data

For data subjects who are Employees of the Company, we may use your personal data during our operations such as for human resources, payroll purposes business continuity and health & safety.

The processing is in our legitimate interests as a private company as well as to fulfil legal requirements in connection to Employment and Industry.

4. HOW LONG WILL YOU KEEP MY PERSONAL INFORMATION?

When we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

We do not retain personal information in an identifiable format for longer than is necessary.

We may need your information to establish, bring or defend legal claims. In these cases, we will always retain your personal information for 7 years after the date of the contract with us.

The only exceptions to this are where the law requires us to hold your personal information for a longer period, or delete it sooner;

You exercise your right to have the information erased and we do not need to hold it in connection with any of the reasons permitted or required under the law.

5. HOW DO YOU SHARE MY INFORMATION?

We may, where applicable and if relevant, disclose your information to companies or organisations to which we pass the responsibility to handle services on our behalf such as our accountants, IT Service provider, lawyers and other business advisors, direct marketing communications.

We ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do.

We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.

Your data will not be passed to any third-party for their own independent marketing purposes. If there are any instances where your information is processed or stored outside of the EU, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.

6. WHAT ARE MY RIGHTS?

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within one month after we have received any request.

a) Right of confirmation

You have the right to obtain from the controller the confirmation as to whether or not personal data which concerns you is being processed. Should you wish to avail of this right of confirmation, you may, at any time, contact our Data Protection Compliance Officer (DPCO).

b) Right of access

You have the right to obtain from the controller free information about your personal data stored at any time and a copy of such information. Should you wish to avail of this right of access, you may, at any time, contact our Data Protection Compliance Officer (DPCO).

c) Right to rectification

You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data which concerns you.

Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Should you wish to exercise this right to rectification, you may, at any time, contact our Data Protection Compliance Officer (DPCO).

d) Right to erasure (Right to be forgotten)

You have the right to request from the controller the erasure of personal data which concerns you without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

· The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

· The customer withdraws consent to which the processing is based and where there is no other legal ground for the processing.

· The customer objects to the processing and there are no overriding legitimate grounds for the processing.

· The personal data has been unlawfully processed

· The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.

If one of the aforesaid reasons applies, and you wish to request the erasure of personal data stored by us, you may, at any time, contact our Data Protection Compliance Officer (DPCO), who shall promptly ensure that the erasure request is complied with immediately.

e) Right of restriction of processing

You have the right to request from the controller restriction of processing where one of the following applies:

· The accuracy of the personal data is contested by the customer, for a period enabling the controller to verify the accuracy of the personal data.

· The processing is unlawful and the customer opposes the erasure of the personal data and requests instead the restriction of their use instead.

· The controller no longer needs the personal data for the purposes of the processing, but they are required by the customer for the establishment, exercise or defence of legal claims.

· The customer has objected to processing, pending the verification whether the legitimate grounds of the controller override those of the customer.

If one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by us, you may at any time contact our Data Protection Compliance Officer (DPCO), who will arrange the restriction of the processing.

f) Right to data portability

You have the right to receive the personal data which concerns you, which was provided to a controller, in a structured, commonly used and machine-readable format. In order to assert the right to data portability, you may at any time contact our Data Protection Compliance Officer (DPCO).

g) Right to object

You have the right to object, on grounds relating to your particular situation, at any time, to processing of personal data which Capital Motors shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the customer, or for the establishment, exercise or defence of legal claims.

If we process personal data for direct marketing purposes, you have the right to object at any time to processing of personal data which concerns you for such marketing. This applies to profiling to the extent that it is related to such direct marketing.

If you object to us processing for direct marketing purposes, we will no longer process the personal data for these purposes.

In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data which concerns you by us for scientific or historical research purposes, or for statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, you may directly contact our Data Protection Compliance Officer (DPCO). Furthermore, you are free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use your right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

As a responsible company, we do not use automatic decision-making or profiling. Each customer shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the customer and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the customer's rights and freedoms and legitimate interests, or (3) is not based on the customer's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the customer and a data controller, or (2) it is based on the customer's explicit consent, we shall implement suitable measures to safeguard the customer's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the customer wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Data Protection Compliance Officer (DPCO).

i) Right to withdraw data protection consent

You have the right to withdraw your consent to the processing of your personal data at any time. Should you wish to exercise the right to withdraw the consent, you may at any time directly contact our Data Protection Compliance Officer (DPCO).

j) Right to lodge a complaint

We aim to resolve all queries or complaints that you may have. If you have any specific data protection concerns or a complaint, you can contact our Data Protection Compliance officer.

If we cannot resolve your query, you have the right to contact the Office of the Data Protection Commissioner by using the details below:

Data Protection Commissioner
Canal House
Station Road
Portarlington
R32 AP23
Co. Laois