This Data Protection Statement is effective as and from 25 May 2018
This statement describes how we process your personal information. 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 on for our legitimate interests and where we process your information for direct marketing.
In this statement we use the terms “we”, “our” and “us” to refer to Jaguar Land Rover Ireland Limited (“JLRI”). Where this statement refers to the term “dealer”, this means the car dealership authorised to sell or service JLRI vehicles.
1. Who we are and how to contact us
Jaguar Land Rover Ireland Limited, Arena Road, Sandyford Business Park, Dublin 18, D18 is the company responsible for your personal data known as “controller” under data protection law.
If you have any questions about this data protection statement, including any request to exercise your legal rights, please contact us by writing to us at Data Compliance Officer, Arena Road, Sandyford Business Park, Dublin 18, D18 C9X6 or emailing us at firstname.lastname@example.org.
2. Categories of personal data and how we use it
We may collect, use, store and transfer different kinds of personal information about you as follows and use it for a variety of different purposes
|Information type||Example of how we use it|
|Name, contact details (to include postal address, email address, telephone numbers).||We use this information to send you information about products and services, to send you information which you have requested such as brochures, to verify orders from our dealers, to contact you about safety, warranty and recall issues. And to contact you for the purposes of customer satisfaction surveys, which you have the right to opt of at any time and for marketing purposes, where you consent.|
|Information about your vehicle including your vehicle identification number, vehicle registration number, mileage, vehicle model, diagnostic information, work carried out on your vehicle.||We use this information for warranty, safety, service, repair and recall issues.|
|Trade in vehicle type, gender, information which you manifestly make public for example through social media and the products and services in which you are interested in or have purchased.||We use this information on an aggregate basis for market research purposes to help understand our customer base.|
|Interactions with our staff and officers, including notes of your calls with our staff on our database.||We use this information to keep a record of your interactions with us, to monitor and train our staff.|
|Financial Information.||We may receive financial information about your finance agreement with your bank or finance provider in respect of your vehicle, where we are under an obligation with the bank or finance house to source a dealer to buy back your vehicle at the end of your finance arrangement.|
|Information about your experience with the dealer collected through customer satisfaction surveys carried out by us, or through audits that we carry out on our dealer.||We use this information to monitor our dealer performance and for driver improvement.|
|Your 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 any website operated by us, information about how you use our websites.||To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. To monitor the effectiveness of our website.|
We also collect, use and share aggregate data such as statistical or demographic data. Aggregate data is information gathered and expressed in a summary form for purposes such as statistical or demographic analysis. Aggregate data may be derived from your personal data but is not data that directly or indirectly reveals your identity. For example, we may aggregate your usage data of our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregate 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 data protection statement.
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. However, if it is necessary to collect special categories of personal information and/or criminal conviction information, we will only do so with your explicit consent and we will explain the purpose for which the information will be used at the point when we ask for your consent.
3. How we obtain your information
We may collect your information from a dealer from whom you purchase a vehicle or from who you obtain other services such as service, warranty work or repair or with whom you make an enquiry. We may obtain this information directly from a dealer or the dealer management platform or in the course of carrying out an audit on the dealer.
We may also collect your information though our website or where you provide it to us, such as where you enter competitions with us, fill out forms, request a service from us such as a brochure or booking a test drive or contact us. We may also collect information from you at events and brand displays, such as at shopping centres etc.
We may also collect your information where we carry out customer satisfaction surveys of your customer experience with our dealers.
We may also collect information about you from publically available sources, such as social media, where you have manifestly made that information publically available. We may combine this with other personal information we hold about you.
We operate CCTV in our premises to protect the safety and security of our staff. As such, we may collect your personal information through CCTV, in our legitimate interest.
4. The purpose and legal basis for processing your information
Under data protection law we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information:
a) To enter into and perform a contract with you
We may process your information in order to enter into a contract with you or to provide you with a service which you have requested from us.
For example, we need to process your personal information in order to manage the warranty which we have provided in respect of your vehicle or to provide you with a brochure or information about a product where you have requested it.
b) To comply with our legal obligations
We are required to process your personal information to comply with certain legal and regulatory obligations to which we are subject. For example, we are required to obtain certain business records in accordance with company and revenue law which may include your personal information.
c) For our legitimate business interests
We may use your personal information for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.
We may use your personal information to manage our everyday business needs, including accounting, internal reporting needs, and market research, to progress and respond to legal claims, security of our premises and staff through use of CCTV, to process rebate claims, to ensure appropriate IT security and to prevent fraud, to monitor and audit warranty claims, to update you on our service and dealer network in our legitimate interest. Our legitimate interest is the effective management of our business.
We may use your personal information to monitor the performance of our dealers and verify dealer orders, including the carrying out of audits on our dealers and contacting you for customer satisfaction surveys by post, email or phone, in our legitimate interest. Our legitimate interest is ensuring that our dealers our complying with our high standards when selling vehicles and servicing JLRI vehicles.
We may use your personal information to send you warranty or service reminders or vehicle health check reminders, in our legitimate interest. Our legitimate interest is connecting with our customers.
We may use your personal information in an aggregate form to classify our customers and to acquire an aggregated overview of our customer base in our legitimate interest. Such processing does not assess individual characteristics. Our legitimate interest is to grow our business, understand our customer base and provide products and services of interest to our customer base as a whole.
We may use your information which we collect, including personal information we obtain from publically available sources such as social media, to help us understand our customers and provide products or services which may be of interest to them, in our legitimate interest. You have the right to object to this at any time.
We may also contact you in the event of the closure of your local Sales or Aftersales Dealer, to give you the details of all other authorised dealers and repairers available to you in the JLRI network, who can carry our warranty work or provide you with information on JLRI products. We do this in our legitimate interest in order to keep our customers updated of changes within our dealer network.
We may obtain information about your finance arrangements in respect of your vehicle from your finance provider in order to arrange buy back of the vehicle. We do this in our business legitimate interest of arranging the reconciliation of finance agreements.
d) With your consent
We will only use your information to marketing you by post, text, email or phone where we have your consent to do so. You can withdraw this consent at any time by writing to us at Data Compliance Officer, Arena Road, Sandyford Business Park, Dublin 18 or emailing us at email@example.com.
e) To protect your vital interests
We will in certain circumstances use your personal information to protect your vital interests, for example we will contact you in the event of a recall or safety issue with your vehicle.
5. Your information and Third Parties
Third party service providers
We may share your personal information with third party service providers that perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, debt collection agencies, valuers, lawyers and other business advisors, marketing companies who carry out marketing campaigns and market research on our behalf and providers of security and administrative services. For example, we may provide your personal information to GfK NOP for the purposes of carrying out customer satisfaction surveys.
Dealers within our network
We may also share your personal information with a member of our dealer network in order to provide you with a product or service which you have requested, such as a test drive or to deal with warranty, repair or service issues and to assist the dealer with diagnostic issues.
An Garda Síochána, government or quasi-government bodies, courts and tribunals
We may share your personal information with these organisations and bodies, where required to do so by law.
OHM Group and other OHM Group entities: We are part of the OHM Group. Where we convert your information, such as information you provide in the course of a customer satisfaction survey, into statistical or aggregate data in such a way as to ensure that you are not identified or indefinable from it, we may pass this information on to OHM Group and other OHM Group entities, such as dealers and distributors for analytical and statistical purposes.
Jaguar Land Rover Limited and entities within Jaguar Land Rover Limited: There are circumstances where we may share your information with the manufacturer and any independent auditor appointed by the manufacturer, in order to fulfil orders and transactions, to provide you with a service or information which you have requested.
Potential sale or merger
If we sell any part of our business and/or integrate it with another organisation, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs, the new owners of the business will only be permitted to use your information in the same or similar way as set out in this data protection statement.
6. Storage Periods
The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where, for example, we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in the event of a legal claim.
7. Transfers outside the European Economic Area
We may transfer, store or process your personal information to countries outside the European Economic Area. Where the laws of such countries do not afford an equivalent level of protection of personal information as the laws of Ireland, we take specific steps in accordance with data protection law to protect your personal information.
We'll use one of these safeguards:
- Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA.
- Put in place a contract (in a form that is approved by the European Commission) with the recipient of the personal information that means they must protect it to the same standards as the EEA.
- Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
8. How we use automated processing
We may analyse your personal information by automated means for the purposes of market research, analysing our customer database and for our marketing activities. You have the right to object to this at any time.
9. 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 a test drive). 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.
10. 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.have any inaccurate personal data which we hold about you updated or corrected;
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.withdraw your consent at any time where our processing is based on your consent. For example, you can withdraw your consent to the use of your personal information for direct marketing purposes. Where you withdraw your consent, we will stop using your personal information for this purpose;
6.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 ground for the continued processing of this information; and
7.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.
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 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 period of two months and we will explain why.
You also have the right to lodge a complaint to the Office of the Data Protection Commission. For further information please see www.dataprotection.ie
11. Opting out
You can ask us to stop sending you marketing messages at any time by emailing firstname.lastname@example.org .
Land Rover respects the privacy of every individual who visits its websites. Any information collected about you will be used to fulfil any service you might request, to inform you about new products and services and also to improve how we serve you. Your data will be treated in accordance with relevant European Union and local country legal provisions. Your information will not be disclosed to anyone outside of Land Rover, its affiliated or associated companies, and its dealers, agencies and licensees of any of these companies, and any other companies with which Land Rover has directly or indirectly arranged services for your benefit.
Land Rover will not collect personal information about you using cookies however by enabling cookies or keeping cookies enabled, you are providing your consent to Land Rover storing cookies on your browser. Please note that disabling cookies is likely to impact website functionality and your experience of the Land Rover website.
Due to the international nature of Land Rover’s business, Land Rover processes and stores personal data outside the EU. We are obliged to ask you to agree to this. If you do not wish to, unfortunately we will not be able to process any request you make through this website.
We protect the data in strict accordance with the Principles of the European Union Data Protection Framework Directives, in particular EU Directive 95/46/EC.
Any information that you choose to provide us with about yourself will be held on a secure computer server in the United Kingdom. The server software (SSL) encrypts all the information you supply us.
This ensures, among other things, that data we hold about you is processed lawfully and fairly. We aim to ensure that the personal data stored will be accurate, relevant and not excessive. We will keep the data up to date and not retain the information longer than is necessary. We will keep data securely to prevent unauthorised access by other people. You have the right to see what is held about you and correct any inaccuracies.
Land Rover will not share or loan any identifiable information about you to any third party without your consent. We may share generalised information about site visitor patterns with partners or other parties in such a way that individual visitors can never be identified. It is possible to view our site without providing any personal details. However, without registering your details you will not be able to receive further communications from us.
WHAT PERSONAL INFORMATION IS COLLECTED
We collect your personal information on a registration form.
This information may include data such as your name, email address, country and preferred language.
We use this information:
1. To help make your visit more enjoyable
2. To send you relevant information about products and services
3. To email you from time to time about promotions or products and services which we think may be of interest to you
If you choose to receive information or other communications from us, you can select that option by ticking the relevant box on the registration form. You can also contact us at any time if you don't want to receive any more communications from us by using the Contact Us link on the website.
If you have allowed us to use your personal information for the purposes above, we may from time to time disclose this information to any company or organisation to which we pass the responsibility to handle email or other direct marketing communications on our behalf. Should this happen, we ensure that any third party companies who handle your information comply with the relevant Data Protection legislation.
OTHER INFORMATION COLLECTED DURING YOUR VISIT TO OUR SITE
Whenever you browse the http://www.landrover.ie website, read pages, or download information, our computers automatically record certain information about your visit from the computer you use to access our site.
This information does not identify you personally. It just tells us how many visitors come to our site and the types of computers they use. With this information, we can improve our site for all our visitors and make it more useful to you.
The information includes the following:
1. The date and time you access our site.
2. How many and which pages you visit during a 'session' on our site and how long you were on the site.
3. Your Internet domain name (this might be your internet service provider such as aol.com or your place of work) and the 'IP' address (this is a number assigned to your computer whenever you are surfing the web) which allows you to access our website.
4. The Internet browser you use (e.g. Microsoft Explorer or Netscape) and your computer's operating system (e.g. Windows 98).
5. The site you were on before you linked to rangerover.com / landrover.com (e.g. Yahoo if you found us from a search engine).
PROTECTION OF EMAIL ADDRESSES
Your email address is only used for the purposes of replying to you unless you have given consent as detailed above.
DATA PROTECTION ON PIXEL TAGS
We may use "pixel tags," which are small graphic files that allow us to monitor the use of our websites. A pixel tag can collect information such as the IP (Internet Protocol) address of the computer that downloaded the page on which the tag appears; the URL (Uniform Resource Locator) of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, we may use "format sensing" technology, which allows pixel tags to let us know whether you received and opened our e-mail.
MORE QUESTIONS ABOUT PRIVACY?
You have the right as an individual to find out what information we hold about you and make corrections if necessary. You also have the right to ask us to not use the information by choosing not to give your consent on the registration form.
If you have any specific questions that are not covered in this section, or want to know what information we currently store on you, please mail your enquiry to:
Subject Access Request
Land Rover Administration