Privacy Policy

November 2018

Introduction

This privacy policy aims to give you information on how Kilcoole Garage Ltd. t/a Hill’s of Bray collects and processes your personal data, including any data you may provide when you access this website or other websites controlled by a company within our group, when you enquire about a product or service, when you purchase a product or service from us, through your dealings with our staff, enter a competition, promotion or survey and when you report a problem with our website.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal 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.

Who we are and how to contact us

Throughout this document, “we, “us, “our and “ours refer to Kilcoole Garage Ltd. t/a Hill’s of Bray

“Kilcoole Garage Ltd. t/a Hill’s of Bray means:

Kilcoole Garage Ltd. incorporated in Ireland with limited liability having its registered office at Killarney Road, Bray, Co. Wicklow.

We have appointed a data protection compliance officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data protection compliance officer using the details set out below.

Email address:​​[email protected]

Postal address:​Data Protection Compliance Officer, Killarney Road, Bray, Co. Wicklow, Ireland.

Contact:​087 9870031

What information may be collected about you?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data​includes first name, last name, username or similar identifier, title, date of birth and gender.

Contact Data​includes address, email address and telephone numbers.

Technical Data​includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Usage Data​includes information about how you use our website, products and services.

Marketing and Communications Data​includes your preferences in receiving marketing from us and our third parties and your communication preferences, occupation, vehicle details, gender and transaction history.

Vehicle Details:​We may collect information about your vehicle, including your mileage and VIN (Vehicle Identity Number) for service and warranty issues.

Transaction Data​includes data about your transactions with us such as the purchase of a vehicle.

Financial Information:​Detailed financial information including contact details; income details; marital status; date of birth; gender; residential status; employment details; linked relationships; presence of a controlling interest in one or several companies in Ireland; partnerships in one or several companies in Ireland; previous customer or employee of a company that is a customer; bank details; payment method; and motor details.

Interactions Data:​information about your interactions with us, including correspondence and phone calls between us and you.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We may also anonymise data so that it is no longer personal data. For example we may anonymise the quote we provided for a used vehicle.

Our website is powered by Digital Odyssey Limited (“CarsIreland.ie), our third party web services provider. Digital Odyssey is committed to ensuring that data is processed in accordance with applicable data privacy laws, and is kept secure. Digital Odyssey is certified to the standard of ISO27001 (an international standard for information security). Digital Odyssey uses Amazon Web Services Inc. & Blacknight hosting solutions as its cloud platform provider.

When someone visits one of our websites, Digital Odyssey collects standard internet log information (your IP address, browser, and type of device) and details of visitor behaviour patterns (where you joined our site from, the path you take through our site and where you leave). These are stored against unique ids (which are strings of numbers). Digital Odyssey collects this information for the legitimate business purpose of monitoring the number of visitors to the various parts of the site, the general geographic location of visitors and engagement levels, which in turn enables it to make improvements to its websites and services, and provide business intelligence. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

Digital Odyssey also uses Google Analytics & Extreme Tracker to collect standard internet log information and details of visitor behaviour patterns, which are stored against unique ids (i.e. strings of numbers). We collect this information for the legitimate business purpose of monitoring website traffic and engagement levels, which in turn enables us to make improvements to our website and the way we sell our cars and services. This information is only processed in a way which does not identify anyone. It is kept indefinitely.

Changes To The Privacy Policy And Your Duty To Inform Us Of Changes

Any changes we make to this privacy policy in the future will be posted to this website. Please check back frequently to see any updates or changes to this privacy policy. It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third Party Links

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 website, we encourage you to read the privacy policy of every website you visit.

How your personal Information is Used

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

·Where we need to perform the contract we are about to enter into, or have entered into with you.

·Where it is necessary for our legitimate interests (or those of a third party) and your interests, and fundamental rights do not override those interests.

·Where we need to comply with a legal or regulatory obligation.

·Where we rely on consent to process your personal data, you have the right to withdraw consent at any time. If you are making an enquiry either through our website, by phone or in our dealerships and you are not a customer, we will not use your personal data for marketing purposes without your consent.

We may use your personal information for the reasons set out below.

Activity

Type of data

Lawful basis for processing

 

 

including basis of legitimate

 

 

interest

 

 

 

To process and provide you with a

(a) Identity

Necessary for performance of a

quotation for any service, including

 

contract with you

the purchase of a vehicle, the

 

 

 

 

 

provision of finance or leasing of a

(b) Contact

 

vehicle, any insurance products,

Information

 

repair or service of a vehicle, test

 

 

drive, product information

 

 

 

(c) Financial

 

 

 

 

To register you as a new customer

(a) Identity

Performance of a contract with

 

 

you

 

 

 

 

(b) Contact

 

 

Information

 

 

 

 

To provide you with a product or

(a) Identity

Performance of a contract with

services, such as the sale of a

 

you

vehicle, repair or service of a

 

 

vehicle of the sale of parts

(b) Contact

 

 

Information

 

 

 

 

 

(c) Financial

 

 

 

 

To register your vehicle for VRT

(a) Identity

To comply with a legal obligation

and VAT purposes

 

 

 

 

 

 

(b) Contact

 

 

Information

 

 

 

 

To manage our relationship with

(a) Identity

Necessary for our legitimate

you which will include:

 

interests (to measure our

 

 

customer satisfaction, keep our

 

 

customer records up to date)

 

 

 

Customer Satisfaction Surveys

(b) Contact

 

 

Information

 

 

 

 

 

(c)Vehicle

 

 

Information

 

 

 

 

To monitor and train our staff and

(a) Interaction

Necessary for our legitimate

to deal with customer disputes

 

interests and to monitor and

 

 

train our staff.

 

 

 

To Manage our everyday business

(a) Identity

 

needs, including accounting,

 

 

sharing your information within our

 

 

company group for administrative

(b) Contact

 

purposes, and to prevent fraud.

 

 

Where we do so we rely on our

 

 

legitimate interest in the effective

(c) Financial

 

management of our business

 

 

 

 

 

To enable you to partake in a prize

(a) Identity

Performance of a contract with

draw or competition

 

you

 

 

 

 

(b) Contact

 

 

 

 

 

(d) Usage

 

 

 

 

 

(e)Marketing and

 

 

Communications

 

 

 

 

To deliver relevant ​website​content

(a) Identity

Necessary for our legitimate

and advertisements to you and

 

interests (to study how

measure or understand the

 

customers use our

effectiveness of the advertising we

(b)Contact

products/services, to develop

serve to you

 

them, to grow our business and

 

 

to inform our marketing strategy)

 

(c) Profile

 

 

 

 

 

d) Usage

 

 

 

 

 

(e) Marketing and

 

 

Communications

 

 

 

 

 

(f) Technical

 

 

 

 

To use data analytics to improve

(a) Technical

Necessary for our legitimate

our ​website​, products/services,

 

interests (to define types of

marketing, customer relationships

 

customers for our products and

and experiences

(b) Usage

services, to keep our ​website

 

 

updated and relevant, to

 

 

develop our business and to

 

 

inform our marketing strategy)

 

 

 

To administer and protect our

(a) Identity

(a) Necessary for our legitimate

business and this website

 

interests (for running our

(including troubleshooting, data

 

business, provision of

analysis, testing, system

 

administration and IT services,

maintenance, support, reporting

 

network security, to prevent

and hosting of data)

 

fraud and in the context of a

 

 

business reorganisation or

 

 

group restructuring exercise)

 

 

 

 

(b) Contact

(b) Necessary to comply with a

 

 

legal obligation

 

 

 

 

(c) Technical

 

 

 

 

To provide you with marketing

(a) Identity

Where you are a potential

communications by post, text and

 

customer will we only provide

email.

 

you with direct marketing where

 

 

you have consented. You can

 

 

withdraw this consent at any

 

 

time.

 

 

 

 

(b) Contact

Where you are a customer will

 

 

provide you with direct

 

 

marketing where you have not

 

 

opted out of the receipt of direct

 

 

marketing. We rely on our

 

 

legitimate interest.

 

 

 

 

(c) Marketing

 

 

 

 

Legal obligation

All personal data we

We may use your personal data

 

collect

to fulfil legal obligations to which

 

 

we are such as complying with

 

 

anti-money laundering

 

 

obligations.

 

 

 

All of our premises are monitored by CCTV cameras for security purposes. We have strict retention polices in respect of CCTV footage, and process data captured by CCTV for security purposes in our legitimate interest.

If You Fail To Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the

contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

You will receive marketing communications from us if you have purchased goods or services from us and you have not opted out of receiving that marketing. Where you have not purchased goods or services from us, we will only send you marketing material where you have consented. You can withdraw this consent at any time.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of Kilcoole Garage Ltd. t/a Hill’s of Bray.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

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.

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.

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.

Transfers outside the EEA

Some of our third party providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer outside of the EEA. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Who We Share Your Personal Information With

Third Party Service Providers:​We may share your personal information with third party service provides that perform services and functions on our behalf such as our accountants and other business advisors, IT service providers, printers, marketing companies who carry out marketing campaigns on our behalf, and providers of security and administration services.

New Owner: ​We may also transfer your personal information to companies that buy our company or our business.

Finance companies, leasing companies, insurance companies and other third party providers: ​Where you have asked for a quote to include the cost of financing, leasing or any other third party product, we may pass your personal information to that third party in order to obtain a quotation on your behalf.

Manufacturer of Your Vehicle & Their Distributor:​We may pass your personal information on to the manufacturer of the vehicle and/or their appointed distributor in Ireland for the purposes of warranty, service issues and recalls, ordering process and customer satisfaction surveys. The distributor and/or manufacture may aggregate your personal data, such as information relating to gender to understand its customer base. The manufacturer may contact you separately regarding their use of your information An Gardaí, 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.

How Long We Keep Your Personal Information For?

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.

Your Legal Rights

You have a number of rights under data protection law in relation to how we use your personal information. You have the right, free of charge, to:

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);

Have any inaccurate personal data which we hold about you updated or corrected; Erase personal information we hold about you;

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;

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 an overriding legitimate grounds for the continued processing of this information; and

Receive certain aspects of your personal information in a structured, commonly used and machine readable format and to have that information transferred to you or another data controller.

How To Change Your Privacy Preferences

These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights please contact us at [email protected]. We will endeavour to respond to your request within one month. If we are unable to deal with your request within one 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. Please visit ​www.dataprotection.ie​for more information.

How We Keep Your Personal Information Safe

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.