1. General
1.1 Company Information
1.2 Legislation
1.3 Queries and Complaints
2. How do we collect information?
3. What do we use information for?
To enable us to support customers with sales and other enquiries
To support us in understanding customers’ and drivers’ needs
Processing is necessary for product development purposes (for example to improve vehicle quality, performance and safety)
Processing is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns
Processing is necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
Legal Obligation
Not Providing Information
4. Who do we share information with?
5. What type of information is collected?
6. How long do we retain information?
7. What are your rights?
Where do I send requests?
How long will a request take to complete?
Right of Access
Right to Rectification
Right to be Forgotten
Right to Restriction
Right to Data Portability
Right to Object
Right not to be subject to Automated Decision Making, including Profiling
Gerry Caffrey Motors Ltd is committed to protecting all personal and special categories of data (also referred to as sensitive personal data) held on you.
Our mission is to execute professional management of the processes related to the sales of cars, parts and accessories, as well as servicing and complementary services, such as roadside assistance, we collect process and store copious quantities of personal data from our customers on an ongoing basis.
We also want you to be clear as to what rights you can invoke to help you to protect your privacy.
In this regard, it is important that you read this Privacy Statement and understand our use of your personal data.
Please note that we reserve the right to update this Privacy Statement as required. The most recent version of this document can be found on our website through the following link: www.gerrycaffreymotors.ie/privacy
References to “Gerry Caffrey”, “us”, “our”, and “we” mean Gerry Caffrey Motors Ltd and any associated companies from time to time.
Rest assured that all personal data we gather will be processed in accordance with all applicable data protection laws and principles, the EU General Data Protection Regulation 2018 and the Data Protection Acts 1988 and 2003.
If you are unhappy with the way we have handled your personal information and wish to complain or if you simply want further information about the way your personal data will be used, please contact us by any of the following options:
Gerry Caffrey
Gerry Caffrey Motors Ltd
106 - 112 Terenure Road North,
Dublin
D6WWR13
Ireland
sales@gerrycaffreymotors.com
You have the right to lodge a complaint with the Office of the Data Protection Commissioner. To contact the Office of the Data Protection Commissioner, please use the following details:
Data Protection Commissioner
Canal House
Station Road
Portarlington
County Laois
Telephone: +353 (0)761 104 8000
Telephone: +353 (0)57 868 4800
Email: info@dataprotection.ie
LoCall Number: 1890 252 231
Fax: +353 57 868 4757
Please note that we will take all appropriate steps to keep your personal data safe. In the unlikely event that we have a security breach, we will notify you without undue delay about the circumstances of the incident in accordance with our legal obligations.
We collect personal data to provide our services to you. This data may be collected directly by our staff, our website, any applications used by us, or indirectly through a third-party service provider on our behalf.
The personal data we collect will be gathered and stored as set out in this Privacy Statement. This will be done directly by our Sales, Administration, Service, Parts and Technical staff. The categories of personal data that we gather are listed in Section 5 ‘Data Collected’ below.
We gather personal data, to market and sell our products and services, servicing facilities to you, our customer.
We mainly use your personal information so that we can provide you with quality car sales and services together with finance and leasing services’ options when requested by you.
We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, the AA who provide roadside assistance on our behalf.
However, more specifically, we may use the personal data we gather for any or all the following purposes):
| Process | Description | Lawful Basis for Processing |
| Purchasing a Vehicle or Part / Booking Vehicle Service | When a customer books a vehicle service, and / or orders a vehicle or motor part from us, we obtain and enter the relevant personal data into our Dealer Management System (DMS). | The processing is necessary for the performance of a contract to which the data subject is party. |
| Car Financing / Leasing | We assist customers in obtaining car financing and / or leasing from a variety of Financial Institutions from time to time. | The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract to which the data subject is party. |
| Marketing to Potential Customers | Information is collected by our Sales, Service and/or Marketing staff when any customer, or potential customer, contacts the dealership.We record this data in our Customer Relationship Management System and/ or DMS and use the data to market to you.This data is then sent to third party service providers such as Cemac Group, SharpSpring, and Phonovation or similar organisations | Where you are a potential customer:The data subject has given explicit consent to the processing.Where you are a customer:The data subject has given explicit consent to the processing. |
| Customer Satisfaction Survey | We send out customer satisfaction surveys based on the personal data which is extracted regularly from our DMS.This includes customers and potential customers who are inputted into CRM System/DMS.Additionally, all individuals who interact with us can be surveyed on their experience with us. | Where you are a potential customer: The data subject has given explicit consent to the processing.Where you are a customer: The processing is in our legitimate interests to ensure the quality of services provided by our staff. |
| Quality Improvement / Staff Training | All phone-calls, written communications and related details stored on our internal server.Similarly, all communications / queries received through our Web Site are kept on our server.These communications are stored for both quality improvement and staff training purposes. | The processing is in our legitimate interests in providing a high standard of services to our customers, by assessing the ongoing development and identifying areas for improvement. |
| CCTV | We may operate a CCTV system on our premises to protect the safety and security of our staff and property. | The processing is in our legitimate interests as a private company regarding Safety and Security. |
| Anti-Money Laundering | We use your personal data to comply with anti-money laundering regulations.In the event of a customer wishing to pay us with personal funds more than €10,000, a regulatory form must be completed containing personal data. | The processing is necessary for compliance with a legal obligation to which the controller is subject. |
| Change of Ownership Documentation | We process change of ownership documentation (i.e. vehicle registration certificates) for customers through the Revenue Online Service. | The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract to which the data subject is party. |
| 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 dealership, we may use your personal data during our operations such as for human resources and payroll purposes. | The processing is in our legitimate interests as a private company as well as necessary for compliance with a legal obligation to which the controller is subject. |
We may also process your data for other purposes in line with our data protection policies
1. To respond to correspondence you send to us and fulfil the requests you make to us (for example: test drives, service requests, brochure requests or information about specific vehicles);
2. To provide vehicle support and services (for example warranty services);
1. To analyse, evaluate and improve our products and services so that your visit and use of our website, applications, customer service centre and authorised repairer network are more useful and enjoyable (we will generally use data amalgamated from many people so that it doesn’t identify you personally);
2. To undertake market analysis and research (including contacting you with customer surveys) so that we can better understand you as a customer and provide tailored offers, products and services that we think you will be interested in. We will only send marketing communications to you if you have provided your consent for us to do so or which we have obtained in the ways mentioned in the paragraph above;
1. In some cases, we may use automated methods to analyse, combine and evaluate information that you have provided to us (including the sharing of your personal information with the manufacturer. We collect and analyse this information in this way so that we can deliver the most appropriate customer experience to you by tailoring and making relevant all our service and communications (for example, when your mileage suggests your vehicle is due for a service);
1. To send you marketing information from time to time after you have purchased a product or service from us or made a purchasing enquiry, closed your browser with items in your shopping basket or requested a test drive, brochure or other information of interest. We will only contact you with information about our own products and services (and in ways the law allows), which we hope you will like. You have the right to object to us sending you this information at any time;
2. To contact you from time to time with marketing information (unless you object) if you have expressly indicated to us that you are acting on behalf of a business or where we have obtained your business contact details from our authorised repairer network or an online or public business directory. In relation to any such information we send
3. by email or SMS, we will include an option allowing you to object to receiving future messages by unsubscribing;
4. To contact you with targeted advertising delivered online through social media and other platforms operated by other companies, unless you object. You may receive advertising based on information about you that we have provided to the platform or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it has received from us. To find out more, please refer to the information provided in the help pages of the social media and other platforms on which you receive advertising from us;
5. To identify and record when you have received, opened or engaged with our website or electronic communications;
6. To administer competitions and promotions that you enter with us from time to time and to distribute prizes.
1. To verify the accuracy of information that we hold about you and create a better understanding of you as a customer;
2. For network and information security purposes i.e. for us to take steps to protect your information against loss, damage, theft or unauthorised access;
3. To comply with a request from you regarding the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists to be able to comply with your request);
4. To inform you of updates to our terms and conditions and policies.
We may process your personal information to comply with our legal requirements (for example to register your car with the relevant authorities.
If you do not provide us with all the information we require, the resulting action may be that we are not able to fully offer you our services.
Furthermore, some services provided by us require certain categories of information, without which, we may not be able to provide you with the service.
There are various circumstances where we may share personal data with other parties. Generally, this includes your representatives and our representatives, and some pre-advised third parties.
We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf:
We take steps to 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.
There are circumstances where we share your information with the Manufacturer to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested.
Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.
Any party you have given us permission to speak to (such as a relative or friend), your motor insurance company and other people or companies associated with you;
Our employees and employees within our business and contractors including companies that provide services in relation to telecommunications and postage, data storage, document production and destruction, IT and IT security, customer loyalty programmes.
Other motor insurance companies, external advisors (such as solicitors and accountants) and auditors, third parties with which we may choose to improve our processes, products or services or to investigate the possibility of new processes, products or services and prospective sellers or buyers if we decide to sell or buy any business or assets; and
The State department (i.e. The Irish Revenue) for the notification of change-of-ownership for a used vehicle, and/or transfer of leasing commitments. The Regulatory Authority, (i.e. the Financial regulator) for Anti-money laundering compliance.
Please feel free to contact us (details in Section 1 'General' above) if you would like more details about the parties with whom we share your information.
Where we choose to have certain services provided by carefully selected third parties, we take precautions regarding the practices employed by the service provider to ensure your personal data is stored and processed legally and securely. We stipulate that such third parties shall have made every possible effort to achieve a state of readiness for GDPR.
We operate as a Data Processor for our partners, the Manufacturer, and as Data Controller, for our non-manufacturer business operations. We will use every effort to protect your personal data and we will not sell your personal information to any third-party companies.
As a car dealership we need to collect many categories of personal data (about you and other parties) for the purposes set out in this Privacy Notice.
While the type of personal data may change occasionally, we believe it is important you are aware of the types of personal data we gather and use. The following table is a non-exhaustive list and provides an indication of the categories and types of personal data we use to perform our duties.
Please note that information listed under one category may be used for the performance of a task or in relation to activities under another heading or as outlined under Section 3.
We have a comprehensive record retention schedule. The retention periods differ depending on the purpose of the processing and the nature of the information. How long we keep data is primarily determined by how long we need it for the purposes we told you we were going to use it for, time periods set out in law and the period we need to keep it to defend ourselves against legal action.
Generally, we keep information for the periods set out in the table below:
However, in some cases we may need to keep personal data longer than the above periods. Examples of these situations include legal cases and system barequired for disaster recovery.
We also retain certain limited details beyond the above time periods to validate and handle any motor insurance claims we receive after the statute of limitations has expired (late claims) and any claims we receive where the claimant was not aware of the injuries until a long time after they were caused (latent claims).
After the periods set out above, we will anonymise or delete the personal data. Anonymisation means that we will delete certain aspects of the information we hold (such as name and street address) so that we can no longer determine who the data relates to.
Please feel free to contact us if you would like more information about data retention periods.
As a data subject, you will have the following rights, as outlined in this section. However, restrictions may apply in certain situations
Please send all your requests to the contact details provided in Section 1, with as much detail as possible about your requirements to allow us to deal with your request efficiently. To answer your request, we may ask you to provide identification for verification purposes.
Upon receipt of a request, we will have 30 days to provide a response, with an extension of two further months if required. If we require more time to deal with your request, we will notify you of the delay, and the factors resulting in the delay, within 30 days of the receipt of the request. If we refuse your request, we will notify you within 30 days of the receipt of the request accompanied by the reason for refusal.
We will not charge a fee for any requests, provided we do not consider them to be unjustified or excessive. If we do consider these to be unjustified or excessive, we may charge a reasonable fee (also applicable for multiple copies) or refuse the request.
You are entitled to contact the Office of the Data Protection Commissioner if we refuse your request.
You have a right to know what personal data we hold on you, why we hold the data, and how we are processing the data.
When submitting your request, please provide us with information to help us verify your identity – in particular please provide us with details of any vehicle you may have purchased from us or had serviced with us. Please provide a registration number and approximate date of sale and or service. If your request does not relate to a sale or service please submit the details of the nature of your request in as much detail as possible to help us identify the information you wish to access (i.e. date range, subject of the request).
Please note that an access request is free of charge, however, where we determine a request to be unjustified or excessive, we may charge you a reasonable fee.
You have a right to request that the personal data held in relation to you is up to date and accurate.
Where information is inaccurate or incomplete, we encourage you to contact us to have this information rectified. Upon receipt of request, we will ensure that the personal data is rectified and as up to date as is reasonably possible.
You have the right to seek the erasure of personal data relating to you in the following circumstances:
Please be aware that in certain circumstances we may need to retain some information to ensure your preferences are respected in the completion of our duties. For example, we cannot erase all information about you where you have also asked us not to send you marketing material. Otherwise, your preference not to receive marketing material would be erased.
You have the right to restrict the extent of personal data processed by us in circumstances where:
When processing is restricted, your personal data will only be processed: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important to public interest.
We will contact you to confirm where the request for restriction is fulfilled and will only lift the restriction after we have informed you that we are doing so.
You have the right to the provision of all personal data held in relation to you in a structured, commonly used and machine-readable format where:
You may also request that we send this personal data to another data controller where technically feasible.
You have the right to object to the processing of your personal data. However, the processing must have been undertaken on the basis of legitimate interest by us.
If you wish to object to the processing of data, please contact us with your request. We will then stop the processing of personal data unless it is required for legal proceedings.
You have a right not to be subject to a decision based solely on automated processing or profiling, where such decisions would have a legal effect or significant impact on you.
Occasionally we use profiling.
Where we (or one of our third-party processors) use profiling, which produces legal effects for you or otherwise significantly affects you, you will have the right to object to such processing.
This is the Cookie Policy for Gerry Caffrey Motors Ltd, accessible from www.gerrycaffreymotors.ie
This Website may use “cookies” for optimizing our services. Cookies do not generally contain personal information, unless you have provided this information on the Website.
What is a “cookie”?
A cookie is a small piece of data sent from a website and stored in a user's web browser while a user is browsing a website. When the user browses the same website in the future, the data stored in the cookie is sent back to the website by the browser to notify the website of the user's previous activity.
We use the following cookies:
a) Strictly Necessary Cookies
These are cookies that are required for the operation of our Website. They include, for example cookies that enable you to log into certain areas of our Website.
b) Analytic and Performance Cookies
They allow us to recognise and count the number of visitors and how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example by ensuring the users are finding what they are looking for easily.
c) First Targeted Cookies
These cookies record your visit to our Website, the pages you have visited and the links that you have followed. We will use this information to make our Website more relevant to your interest. We may also share this information with third parties for this purpose.
d) Third Party Cookies
These are cookies found in other companies’ internet tools which we are using to enhance our site. Third party advertising cookies may be used to anonymously target advertising to you on other websites, based on your visit to Windsor.ie and are controlled by the third-party companies.
The following are links to the main third party advertising, analytics, targeting, personalization, survey and commenting platforms we use, each of which provides instructions on how to disable cookies.
Google Ads: https://ads.google.com/
Google Analytics: http://www.google.com/intl/en/analytics/index.html
Doubleclick.net: https://marketingplatform.google.com/about/enterprise/
If you would like to disable "third party" cookies generated by advertisers or providers of targeted advertising services, you can turn them off by going to the third party's website and getting them to generate a one-time "no thanks" cookie that will stop any further cookies being written to your machine. You can also visit the trade body representing these advertising bodies for more information on how to opt out of these cookies: https://optout.networkadvertising.org/?c=1
What are they used for?
To gather Website tracking information. We track how many people have visited our Website and how often as well as if they are new or repeat visitors.
To track responses to our online advertising formats in relation to clicks.
By using this Website you are agreeing to the use of cookies as detailed above.
Enabling and disabling cookies and similar technologies
You have the choice whether to accept or decline cookies on websites you visit by changing the settings in your internet browser.
These settings will normally be found in the “options” or “preferences” section of your browser.
Please note that certain features and the full functionality of this Website will not be available once cookies are disabled.
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