WSSI respects your privacy. Whether you deal with WSSI as a customer, a consumer, a member of the general public, etc., you are entitled to the protection of your Personal Data. This data may relate to your name, telephone number, email address but also to other data, such as your Vehicle Identification Number (VIN), registration number, geo-location, etc. In addition, we may hold data pertaining to your vehicle during the time of your ownership. Finally, we will also hold information in relation to contacts made between you and WSSI Ireland. We may also monitor and record telephone calls made to and from us to assist in improving customer services, to evidence instructions or to prevent or resolve disputes.
In this General WSSI Privacy and Data Protection Policy (“this Policy”) we describe how we collect your Personal Data and why we collect it, what we do with your Personal Data, with whom we share it, how we protect it, and the choices you can make about your Personal Data. This Policy applies to the processing of your Personal Data in the framework of various services, tools, applications, websites, portals, promotions, marketing actions, social media platforms, etc. that are provided or operated by us or on our behalf. This Policy contains general rules and explanations. It is complemented with separate specific privacy notices relating to particular services. These privacy notices will be communicated to you whenever your Personal Data is needed in the framework of the activities mentioned above (for example, via websites, portals, individual communication services, newsletters, reminders, surveys, offers, events, etc.). This Policy applies to all your Personal Data collected by (or on behalf of) WSSI Ireland, referred to in this Policy as “WSSI”, “we”, “us” and ”our”. If you accept the provisions of this Policy , you are agreeing to us processing your Personal Data in the ways that are set out in this Policy. At the end of this Policy, you will find some definitions of certain key concepts used in this Policy and which are capitalised (for example, Personal Data, Processing, Data Controller…).
2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
The entity which is responsible for the processing of your Personal Data is: WSSI Ireland, Killeen Road, Dublin, D12 AW94, Ireland
3. WHO CAN YOU CONTACT IN CASE YOU HAVE QUESTIONS OR REQUESTS? THE DATA PROTECTION CONTACT POINT
We have organised a Data Protection Coordinator who will handle your questions or requests relating to this Policy, any specific privacy notice, your Personal Data (and its Processing). For any questions or requests or complaints concerning the application of this Policy or to exercise your rights, as described in this Policy, you may contact our Data Protection Coordinator at:
Data Protection Coordinator, Customer Relations Department, WSSI Ireland, Killeen Road, Dublin, D12AW94.
4. KEY PRINCIPLES
We value your Personal Data entrusted to us and we are committed to processing your Personal Data in a fair, transparent and secure way.
The key principles WSSI applies are as follows:
Lawfulness: we will only collect your Personal Data in a fair, lawful and transparent manner.
Data minimisation: we will limit the collection of your Personal Data to what is directly relevant and necessary for the purposes for which they have been collected.
Purpose limitation: we will only collect your Personal Data for specified, explicit and legitimate purposes and not process your Personal Data further in a way incompatible with those purposes.
Accuracy: we will keep your Personal Data accurate and up to date. Data security and protection: we will implement technical and organisational measures to ensure an appropriate level of data security and protection considering, among others, the nature of your Personal Data to be protected. Such measures provide for the prevention of any unauthorised disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of Processing.
Access and rectification: we will process your Personal Data in line with your legal rights. Retention limitation: we will retain your Personal Data in a manner consistent with the applicable data protection laws and regulations and no longer than is necessary for the purposes for which they have been collected.
Protection for international transfers: we will ensure that any of your Personal Data transferred outside the EEA is adequately protected.
Safeguards towards third parties: we will ensure that Personal Data access by (and transfers to) third parties are carried out in accordance with applicable law and with suitable contractual safeguards.
Lawfulness of direct marketing and cookies: when we send you promotional materials or place cookies on your computer, we will ensure that we do so in accordance with applicable law.
5. PROCESSING OF YOUR PERSONAL DATA: WHICH PERSONAL DATA DO WE COLLECT AND ON WHICH LEGAL GROUNDS
Whenever we require your Personal Data, we will always clearly inform you which of your Personal Data we collect. This information will be provided to you through a separate privacy notice which may, for example, be included in specific services (including communication services), electronic newsletters, reminders, surveys, offers, invitations for events, etc. We also collect personal data via our network of Authorised WSSI Dealers and Repairers. As members of the Society of the Irish Motor Industry (SIMI), our network use SIMI documentation and collect personal data in accordance with their recommendations. We may also collect your personal data where you apply for a job with WSSI Ireland, either directly from you or via a recruitment agency that you have dealt with. Please note that separate Privacy Policies apply for the WSSI FaceItDown application and the Yuko WSSI Car Club service along with summary privacy policies for our web forms. Please note that in accordance with applicable data protection law, your Personal Data can be processed if: You have given us your consent for the purposes of the Processing (as described in the privacy notice related to that particular Processing). For the avoidance of doubt, you will always have the right to withdraw your consent at any time; or it is necessary for the performance of a contract to which you are a party; or with such Processing, we pursue a legitimate interest that is not outbalanced by your privacy rights. Such legitimate interest will be duly communicated to you in the privacy notice related to that particular Processing. it is required by law.
6. FOR WHICH PURPOSES WE PROCESS YOUR PERSONAL DATA
We will only process your Personal Data for specified, explicit and legitimate purposes and we will not process your Personal Data further in a way that is incompatible with those purposes. We also collect personal data via our network of Authorised WSSI Dealers and Repairers. As members of the Society of the Irish Motor Industry (SIMI), our network use SIMI documentation and collect personal data in accordance with their recommendations. Such purpose can be the execution of an order you have placed, the improvement of your visit on one of our websites or portals, the improvement of our products and services more generally, the offering of services or applications, marketing communications and actions, etc. The purpose of each Processing of your Personal Data will be clearly defined in this document or the specific privacy notice relating to that particular Processing. This privacy notice will be accessible, for example, on a website or portal, on an application, in an electronic newsletter, etc.).
7. KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE
It is important for us to maintain accurate and up-to-date records of your Personal Data. Please inform us of any changes to or errors in your Personal Data as soon as possible by contacting us at the Data Protection Contact Point (see section 3 “Who can you contact in case you have questions or requests?”). We will take all reasonable steps to make sure that any inaccurate or outdated Personal Data is deleted or adjusted accordingly.
8. ACCESS TO YOUR PERSONAL DATA
You have the right to access your Personal Data which we are processing free of charge and, if your Personal Data is inaccurate or incomplete, to request the rectification or erasure of your Personal Data. If you require further information in relation to your privacy rights or would like to exercise any of these rights, please contact us at the Data Protection Contact Point (see section 3 “Who can you contact in case you have questions or requests?”). 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 two months and we will explain why.
9. HOW LONG DO WE KEEP YOUR PERSONAL DATA
We will keep your Personal Data in a manner consistent with applicable data protection law for a period of 7 years from the date of completion of a contract with a WSSI Authorised Dealer or Authorised Repairer or an interaction with WSSI Ireland. We will only keep your Personal Data for as long as necessary for the purposes for which we process your Personal Data or to comply with the law. If you apply for a job in WSSI Ireland, we will retain your personal data in this instance for as long as the recruitment process is underway and will delete it when this process has been completed. Our retention policy is in line with that recommended by the Society of the Irish Motor Industry (SIMI).
10. PROTECTING YOUR PERSONAL DATA
We have a set of technical and organisational security measures in place to protect your Personal Data against unlawful or unauthorised access or use, as well as against accidental loss or damage to their integrity. They have been designed taking into account our IT infrastructure, the potential impact on your privacy and the costs involved and in accordance with current industry standards and practice. Your Personal Data will only be processed by a third party Data Processor if that Data Processor agrees to comply with those technical and organisational data security measures. Maintaining data security means protecting the confidentiality, integrity and availability of your Personal Data: Confidentiality: we will protect your Personal Data from unwanted disclosure to third parties. Integrity: we will protect your Personal Data from being modified by unauthorised third parties. Availability: we will ensure that authorized parties are able to access your Personal Data when needed.
12. DISCLOSURE OF PERSONAL DATA
Depending on the purposes for which we collect your Personal Data, we may disclose it to the following categories of recipients, which will then process your Personal Data only within the framework of these purposes: a) Within our organisations and our brand environment: Our authorised staff members; Our affiliates and subsidiary companies; Members of our Authorised Retailers and Authorised Repairers network which you have indicated as preferred Authorised Retailers or Authorised Repairers or which are located near you (based on your postcode, address) or which you have been in contact with; WSSI Financial Services Ireland (to verify and administer your finance agreement with WSSI Financial Services); WSSI Motor Europe (to assist in administering warranty/service product details, customer relations queries and any other TME provided services) WSSI Motor Corporation (to assist with warranty, technical or customer relations matters) b) Third party business partners: Advertising, marketing and promotional agencies: to help us deliver and analyse the effectiveness of our advertising campaigns and promotions; Business partners: for example, trusted companies that may use your Personal Data to provide you with the services and/or the products you requested and/or that may provide you with marketing materials (provided that you have consented to receiving such marketing materials). We ask such companies to always act in compliance with applicable laws and this Policy and to pay high attention to the confidentiality of your personal information; Service providers of WSSI: companies that provide services for or on behalf of WSSI, for the purposes of providing such services (for example, WSSI may share your Personal Data with external providers of IT related services or fulfilment companies); c) Other third parties: – when required by law or as lawfully necessary to protect WSSI: to comply with the law, requests from authorities, court orders, legal procedures, obligations related to the reporting and filing of information with authorities, etc.; to verify or enforce compliance with WSSI policies and agreements; and to protect the rights, property or safety of WSSI and/or its customers; – in connection with corporate transactions: In the context of a transfer or divestiture of all or a portion of its business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or part of WSSI business. Please be aware that third party recipients listed under points b) and c) above –especially service providers who may offer products and services to you through WSSI services or applications or via their own channels– may separately collect Personal Data from you. In such case, these third parties are solely responsible for the control of such Personal Data and your dealings with them will fall under their terms and conditions.
13. SPECIFIC CONTACT WITH OUR AUTHORISED RETAILERS AND REPAIRERS
If you purchase a car or another product or service from one of our Authorised Retailers or Authorised Repairers or if you give them your personal information, you will have a separate relationship with this Authorised Retailer or Authorised Repairer. In this case, they become the data controller of your Personal Data, possibly together with us. For all questions or requests about the collection and use of your Personal Data by one of the Authorised Retailers or Authorised Repairers, please contact them directly. The preferred Authorised Retailer or Authorised Repairer is (1) the Authorised Retailer or Authorised Repairer that you have selected as your preferred one via a sales or service experience survey or (2) in case you did not make such selection, we will identify an Authorised Retailer or Authorised Repairer based on the history of your contacts with our network.
14. USE OF SOCIAL MEDIA
15. TRANSFERS OUTSIDE THE EEA
Your Personal Data may be transferred to recipients which may be outside the EEA, and may be processed by us and these recipients outside the EEA. An example of this would be the sharing of personal data with the WSSI Motor Corporation in Japan. In connection with any transfer of your Personal Data to countries outside the EEA that do not generally offer the same level of data protection as in the EEA, WSSI will implement appropriate specific measures to ensure an adequate level of protection of your Personal Data. These measures can for instance consist in agreeing with recipients on binding contractual clauses guaranteeing such adequate level of protection.
16. YOUR CHOICES AND YOUR RIGHTS
We want to be as transparent as possible with you, so that you can make meaningful choices about how you want us to use your Personal Data. How you contact us and how you will be contacted: To unsubscribe from communications please follow the unsubscribe instructions included in the communication you received or contact us at firstname.lastname@example.org Please note that by default, WSSI may communicate with you electronically and you will receive our communications at the normal frequency of the publication involved. Your Personal Data: You may always contact the Data Protection Coordinator (see section 3 “Who can you contact in case you have questions or requests?”) to find out what Personal Data we have concerning you. Under certain conditions, you have the right to receive your Personal Data, which you have provided to us, in a commonly used, structured machine readable format and to transmit your Personal Data to any third party of your choice.. Your corrections: If you find any mistake in your Personal Data or if you find it incomplete or incorrect, you may also require from us that we correct or complete it. Your restrictions: You have the right to request a restriction on the Processing of your Personal Data (for example, while the accuracy of your Personal Data is being checked). Your objections You may also object to the use of your Personal Data for direct marketing purpose by unsubscribing or to the sharing of your Personal Data with third party for the same purpose. You may withdraw your consent at any time to the continued Processing of the Personal Data that you have provided to us by contacting us the Data Protection Coordinator (see section 3 “Who can you contact in case you have questions or requests?”). Moreover, you may require us to erase any data concerning you (except in some cases, for example, to prove a transaction or when required by law). Please note that these rights are in some circumstances limited by data protection legislation. Finally, please note that you have the right to file a complaint against the Data Controller with the Data Protection Commissioner.
17. LEGAL INFORMATION
The requirements of this Policy supplement, and do not replace, any other requirements existing under applicable data protection law. In case of contradiction between what is written in this Policy and requirements in applicable data protection law, applicable data protection law will have priority. WSSI may amend this Policy at any point in time. Where this happens we will alert you of any changes and we will then ask you to re-read the most recent version of our Policy and to confirm your acceptance thereof. You can also check this Policy periodically on https://www.MSCGie/privacy to inform yourself of any changes.
In this Policy, the following terms have the following meanings: (a) Data Controller means the organisation which determines the purposes for which, and the manner in which, your Personal Data is processed. Unless we inform you otherwise, the Data Controller is WSSI Ireland, Killeen Road, Dublin, D12AW94, Ireland. Further information may be provided to you through a separate privacy notice which will, for example, be included in specific services (including communication services), electronic newsletters, reminders, surveys, offers, invitations for events, etc. (b) Data Processor means the person or organisation which processes your Personal Data on behalf of the Data Controller. (c) Data Protection Contact Point means the contact point where you can address your questions or requests regarding this Policy and/or (the Processing of) your Personal Data and which will handle such questions and requests. Unless we inform you otherwise, the Data Protection Contact Point can be reached as described in section 3 “Who can you contact in case you have questions or requests?”). (d) EEA means the European Economic Area (= member states of the European Union + Iceland, Norway, and Liechtenstein). (e) Personal Data is any information that may relate to your name, telephone number, email address but also to other data, such as your Vehicle Identification Number (VIN), registration number, (geo-)location, etc. In addition, we may hold data pertaining to your vehicle during the time of your ownership. We will also hold information in relation to contacts made between you and WSSI Ireland and to surveys completed by you. We may also monitor and record telephone calls made to and from us to assist in improving customer services, to evidence instructions or to prevent or resolve disputes.. (f) Processing means the collection, accessing and all forms of use of your Personal Data.