Tom Murphy Car Sales takes the safeguarding of personal data very seriously. This policy describes how Tom Murphy Car Sales meets its obligations under the General Data Protection Regulation (GDPR) in relation to the processing of personal data. Please read this policy to understand why we collect personal data from you, how long we keep it and how we use it to transact out business. We pledge to ensure that all personal data provided by your will be processed lawfully, fairly, securely and transparently.
This policy was updated on 15 June 2021
Our website is designed to comply with the following legislation with regards to data protection and user Privacy:
EU General Data Protection Regulation 2018 (GDPR)
ePrivacy Regulations 2011 (S.I. 336 of 2011)
WHAT DEALERSHIPS ARE COVERED BY THIS POLICY.
Tom Murphy Car Sales
Phone: 051 301 222 Email: firstname.lastname@example.org
What Tom Murphy Car Sales Do:
Tom Murphy Car Sales is an authorised Volkswagen Passenger Cars, Volkswagen Commercial Vehicles and Mercedes Sales, Service, Parts & Bodyshop franchise in Waterford and transacts the following businesses:
- Sells Volkswagen, Used and New Cars, Mercedes Motor Cars
- Provides Parts, Repairs, Bodyshop, Servicing of all Volkswagen cars, Mercedes cars and Volkswagen vans
- Provides customers with finance options to cover vehicle purchase via Volkswagen Financial Services Ltd
- Delivers high quality customer service in respect of car sales, aftersales, repairs and services
Data Protection/Controller Officer:
Tom Murphy Car Sales Data Controller
Cork Road, Waterford
The Data Controller,
Tom Murphy Car Sales
Phone: 051 301 222
If you are dissatisfied with this policy or are use of your personal information, you have the right to complain to The Data Protection Commissioner email@example.com
HOW WE USE YOUR INFORMATION.
This following outline our use of your personal 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 by way of a trade in. The Contract we enter into with you requires this personal information, (with the exception of an email address). If you do not provide us with contact details we may not be able to perform our contract, for example, we will not be able to call you when your vehicle arrives.
When you purchase a motor vehicle from us, we, the Dealer, will be one of the companies responsible for handling your personal information (known as a "controller" under data protection law).
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 or in the communication preference you consent to. 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, standards and control quality of our service.
When you purchase a new motor vehicle from 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.
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 will use your information which you have provided to us directly and via reputable third parties for the following uses:
Customer Support, Enquiries, Feedback and Experience
To respond to your inquiry with information on our products and services as requested
For General Administration to complete your contract of purchase and or sale, trade-in
To help us identify you and your vehicle when you contact us
To learn from your use of our service so that we can continue to improve and refine our products and service.
To identify potential other products and services which may be of interest to you and to inform you about other services and products, where you have consented
To provide information that helps our website, its content, and its navigation – so you get the best experience and interaction
To improve the quality of our products and the services we provide to our customers
To carry out analysis for customer profiling and research so that we can continue to improve our service and tailor communications that are relevant and useful
To help Volkswagen Group & Mercedes Companies, service providers and agents to tailor appropriate customer service, feedback and product enhancement
To keep you informed of news, launches, vehicle enhancements, and offers, where you have consented.
To allow you to interact with our services and tailor it to your preferences, when you choose to do so
To notify you of changes to our services
Vehicle Sales & Service
To process your purchase/sale per your specifications, service your vehicle or repair your vehicle, as required.
When you purchase, service or repair a vehicle, the information generally which we will collect includes: Contact details, Vehicle Configuration details, Vehicle Technical Information and Sales and Services Information.
OTHER USES OF YOUR PERSONAL INFORMATION.
When you have consented to us using your data for the permitted uses on our customer form.
When you have sent Tom Murphy Car Sales an inquiry, service request or other request via email, phone call or SMS.
When you have visited Tom Murphy Car Sales for a test drive at our locations and have consented for us to further contact you
When you have written to Tom Murphy Car Sales with a inquiry or update
When you visit our website, including, but not limited to traffic data, location data, weblogs and other communication data
When you call us to inquire about a vehicle or aftersales service – telephone calls to us may be recorded and monitored for training purposes only
When we receive your information from our partners Volkswagen Group Ireland, MDL Motors (Mercedes) or occasionally from other third parties who may lawfully pass to us the information about you, when you make an inquiry on our products via their channels.
When you complete a survey from us and tick the consent box
Where we need to use it to comply with our legal obligations
Where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include promoting the Tom Murphy Car Sales business and tailoring news and offers to your profile, research and development of aftersales services, assessing your credit-worthiness, detecting fraud and criminal activities)
Where necessary for us to defend, prosecute or make a claim against you, us or a third party
HOW WE COLLECT YOUR PERSONAL INFORMATION.
If you contact Tom Murphy Car Sales directly via our websites or via our phones or email and request information about our products and services.
If you purchase a product or service directly from us (e.g. Vehicle, Service, parts).
If you respond to our direct marketing campaigns (e.g. filling out a response card or customer survey, refer a friend, competitions).
When you are having your vehicle serviced or repaired, your vehicle data (incl. vehicle identification number) is transferred to Volkswagen Ireland/AG or Mercedes Ireland/AG
When we acquire your data from other sources with your permission – competitions etc.,
When you apply for finance with Volkswagen Financial Services Limited
If you attend an event and allow consent to be contacted about future offers and events
Via Social Media Sites when you have inquired on a product or service and we have requested your contact details
When you are on our website, we collect information via google analytics on your journey to our website, your operating system, age and whether male, female, time on site and pages visited, etc., We also use pixels to re-target and re-market when you leave the website with Display ads relevant to your interest expressed on the site.
WHO WE SHARE YOUR INFORMATION WITH.
Personal information may be transferred to third parties as outlined below, where you have given your consent or where it is a required part of the process. This is shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.
We have access to customer personal information via Mercedes or Volkswagen Customer Systems, which is only accessed by those who need to use it and via secure password and username provided by Volkswagen or Mercedes
The following is a list of the third parties we may need to share your information:
The manufacturer (Volkswagen, Mercedes) of your Vehicle and or their distributor
The Revenue Commissioners
Third Party Service Providers
An Gardai, Government bodies or officials
The Manufacturer of your Vehicle & Their Distributor: We will pass your information onto Volkswagen or Mercedes, the manufacturer of the vehicle you purchase and/or their appointed distributor in Ireland so that we can ensure its warranty, safety, recall and customer satisfaction.
Only if you consent, we will pass on your information to the manufacturer, distributor of the vehicle you purchase or their appointed distributor in Ireland for marketing activities which may include; offers, VIP events, Surveys and feedback.
Volkswagen or Mercedes may contact you directly, and separately about their use of your personal 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; these may include: our accountants, insurers, IT service providers, printers, lawyers and other business advisors and providers of security and administration services.
Marketing and Communications: We share your information with the following in order to provide you with a quality service and to keep you informed on offers, launches and events:
Marketing agencies who run and manage marketing campaigns on our behalf
Marketing Research Agencies who profile our customers
Event Management companies who run and manage sponsored events on our behalf
Data Management Agencies who ensure our databases are secure, clean and up to date
We use the following third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. They are based in the USA and are EU-U.S Privacy Shield compliant.
SMS: to send customers details on offers, deals and services only where consent has been given. Conlans Group use an on-premises device for SMS sending. This device connects directly with the ADP Database System. Data is not stored on the SMS device itself.
Potential Sale of the Dealer: We may need to transfer your personal information if we merge or are acquired by another company.
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.
Other instances, where we are obliged to pass on your information to third parties:
When we have been asked to provide information for legal of regulatory purposes
Where it is relevant to existing or future legal proceedings
In the process of selling one or more of our businesses or assets, or transferring our rights under the customer agreement we have with you
For the purpose of preventing, fraud or loss and thus pass it onto Fraud Prevention Agencies
To assess your eligibility for finance and administer its repayment with Volkswagen Financial Services (VWFS), you must provide required personal information to Tom Murphy Car Sales.
This information will need to be shared with Credit Reference and Fraud Prevention Agencies to help them decide whether to offer you finance. This is necessary so that Volkswagen Financial Services can make a decision. If you do not provide this information, Volkswagen Financial Services may not be able to offer you finance.
The find out how your information will be used by Volkswagen Financial Services click here
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.
HOW WE KEEP YOUR PERSONAL INFORMATION SAFE.
We use a variety of security measures, including encryption and authentication tools, to help protect and maintain security, integrity and availability of your personal information.
These security features are:
We restrict access to your data to only those employees and third parties, who require it to fulfill your contract, service and is on a “need to know” basis only.
All our collected classified customer data is kept in encrypted form in our database
Highly confidential data is stored only in encrypted form - e.g. credit card information
We have a firewalled IT system to prohibit unauthorised access e.g. from hackers
Our IT personnel monitor access to IT systems so that we can detect and prevent misuse of personal data.
All our passwords are kept secure and not shared externally.
THE KIND OF INFORMATION THAT MAY BE COLLECTED ABOUT YOU.
The following are the types of personal information that may be collected:
Vehicle Purchase Details, Specification and Price
Finance Requirements and Monthly Payment
The type of vehicles and years of vehicles you are interested in.
Consents and Preferred Communication
How you wish to be contacted in the future and whether you wish to be included in communications of events, offers, discounts and news (consent)
Repair and Services Information
Your comments relating to purchases, services and repairs, including complaints, claims and scoring of customer service.
Follow-up of complaints and issues
History of Issues and solutions
Which establishes your identity, such as driving licences, passports and utility bills
Information about transactions, requests for credit and non-payment of debts with us and third parties and credit ratings from credit reference agencies
Credit Card details for purchases and deposits
Fraud, offences, suspicious transactions, politically exposed person and sanctions lists where your details are included.
HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR.
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. We restrict access to your information to only those persons who need to use it for the relevant purpose.
Our retention periods are based on business needs.
When your information is no longer needed, it is either irreversibly anonymised or destroyed securely.
Use for marketing:
We keep customers updated with discounts, offers, VIP Events, launches and services and repairs. We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for. You retain the right to remove this consent at any time. Click here to remove consent.
Use to perform a contract:
In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus one year to deal with any queries or claims thereafter.
Where Claims are contemplated:
In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.
HOW TO CHANGE YOUR PRIVACY PREFERENCES.
You have several rights under data protection law to view the personal information we hold in respect of you.
You have the right 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, subject to a small fee (the Current Statutory Fee is € 6.35)
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 over-riding legitimate grounds for the continued processing of this information;
6. Receive your personal information in a structured, commonly used and machine-readable format and to have that data transmitted to another data controller.
7. You can request we remove you from any marketing lists by withdrawing your consent
8. You can change your form of contact (SMS, Email, Phone Call, Letter) and your consent for communications at any time.
9. You can change your form of contact with Tom Murphy Car Sales at any time.
VIEW OR CHANGE YOUR CONSENTS, DIRECT MARKETING OPTIONS, Tom Murphy Car Sales
Contact Tom Murphy Car Sales to change your consents
VIEW OR CHANGE YOUR PERSONAL INFORMATION,
Contact Tom Murphy Car Sales to change your personal information
If you wish to view Personal information held by Volkswagen or Mercedes (our Manufacturers), contact Tom Murphy Car Sales
These rights are (in some circumstances) limited by data protection legislation.
If you wish to exercise any of these rights please contact us here.
We will aim 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.
Your exercise of these rights is subject to certain exemptions which safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and the rights of third parties.
If you are dissatisfied with our use of your information or our response to any exercise of these rights you have the right to complain to The Data Protection Commissioner firstname.lastname@example.org
Whenever you browse our website, view products pages, or download information, our computers automatically records certain information about your visit from the computer you used 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 eircom 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 our site (e.g. Yahoo, google, Bing if you found us from a search engine).
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.