Spirit Motor Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform what we do with your personal data that you and others may provide us, why we collect it and the rights which you have in relation to it.

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 out for our legitimate interests and where we process your personal information for direct marketing.

In this regard, it is important that you read this Privacy Statement and understand our use of your personal data.

1.Who we are and how to contact us

The terms “we”, “us”, “our” throughout this document refer to Spirit Motor Group and any associated companies from time to time.

Spirit Motor Group means Spirit Motor Group Limited, incorporated in Ireland with registered office at Spirit Motor Group, Arena Road, Sandyford Business Park and all associated companies.

Members of Spirit Motor Group include Spirit Skoda Limited, Spirit Foster Motors Limited, Spirit Ford Limited, Spirit Volvo Limited, Spirit Jaguar Land Rover- Sales and Service and Parts, Spirit Lillis O’Donnell, Spirit Premium, Spirit Burton.

If you have any questions about how your information is stored or managed, any questions about this statement or wish to exercise any of your privacy rights please contact our data compliance officer at:

Arena Road, Sandyford Business Park, Dublin 18.

Email: dco@ohm.ie

• Transfers outside of the European Economic Area
• Marketing

We collect your personal information for a number of different purposes and rely on a number of different legal grounds to do so.

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 may also use your personal information for our everyday business needs, such as auditing and business management.

However, more specifically, we may use the personal that we gather for any or all the following purposes):

Purpose	Description	Lawful Basis for Processing
Purchasing a Vehicle or Part / Booking Vehicle Service	We may process your personal data to make a booking and send you a reminder of that booking. Or when you order a part and we contact you to inform you that your part is available.	The processing is necessary for the performance of a contract to which the data subject is party.
Service and warranty reminders	We may use your personal information to remind you when your service is due or to advise you when your warranty is due to expire.	We rely on our legitimate interest to connect with our customers.
Car Financing / Leasing	We assist customers in obtaining car financing and / or leasing from a variety of third parties	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 and Customers	Information is collected by our Sales, Service, Parts and/or Marketing staff when any customer, or potential customer, contacts the dealership.	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 not opted out of the processing.
Customer Satisfaction Survey	We carry out customer satisfaction surveys, by post, phone and email to ensure we are providing a good service to customers and potential customers.	The processing is in our legitimate interests to ensure the quality of services provided by our staff.
Quality Improvement / Staff Training	All, written communications and communications received through the web are stored by us.	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 operate a CCTV system on our premises to protect the safety and security of our staff and property and for health and safety purposes.	The processing is in our legitimate interests as a private company regarding Health, Safety and Security.
Anti-Money Laundering	We use your personal data to comply with anti-money -laundering regulations.	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.
Legal obligation	We may use your personal information to comply with various legal obligations to which we are subject including make a payment of VAT or VRT in respect of the sale of a new car or where the car is being first registered in the state,	The processing is necessary for compliance with a legal obligation to which the controller is subject
Dealing with sales and other enquiries	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);	To takes steps prior to the entry into a contract with you.
To understand our customer base	We may use your personal information on an aggregate basis for market research purposes to help us understand our customer base	We rely on our legitimate interest in order to understand our customer base.
Business needs	We may also use your personal information to manage our everyday business needs, including accounting, sharing your information within our company group for administrative purposes, and to prevent fraud.	We rely on our legitimate interest in the effective management of our business
Website Security	To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
Website analytics	To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Not Providing Information

If you do not provide us with all the information we require, the resulting action may be that we are not able to provide you with the services you have requested from us. We will advise you if this is the case.

3.WHO DO WE SHARE INFORMATION WITH?

Manufacturer of Your Vehicle & Their Distributor: We pass your personal information on to the manufacturer of the vehicle and/or their appointed distributor in Ireland for the purposes of warranty, recall and service issues and customer satisfaction surveys.If you consent we will also pass your information to the manufacturer and/or the distributor of the vehicle or their appointed distributor in Ireland for marketing activities. You can withdraw this consent at any time.The manufacturer may contact you separately regarding their use of your information.

Insurance Companies and Motor Assessors: We may pass your information to insurance companies and/or any motor assessor appointed by you or an insurance company, where any portion of the cost of the repairs or work being carried out by us on your vehicle is being covered under an insurance policy.

Third Party Service Providers to us: 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, any sub-contractors we engage to carry out repairs to the vehicle or to provide us with parts, and providers of security and administration services.

With our Company Groups: We are part of a larger company group and for administrative efficiencies your information will be stored within our central IT system.

Finance Company: Where you have asked for a quote to include the cost of financing of the vehicle we may pass your personal information to a bank or finance company to obtain such a quote.

Finance companies, leasing companies, insurance companies and other third-party providers: Where you have asked for a quote or to arrange any third-party products such as finance, leasing or any other third-party product, we may pass your personal information to that third party in order to obtain a quotation or that service on your behalf

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

4.WHAT TYPE OF INFORMATION IS COLLECTED?

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.

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.

Purpose	Type of Data
Sales of Products / Services	Name, Contact Details, Occupation, Car Details, Lease Operator Information, Bank Details, Service History, Gender
Customer Care	Name, Contact Details, Car Details, Phone Calls
Finance	Detailed Financial Information
Marketing	Name, Contact Details, Occupation, Car Details, Gender, Service History
Security	CCTV Footage
IT Information	We collect information about your internet activity using technology known as cookies, which can often be controlled through internet browsers. See our cookies policies on our websites for further information.

5.HOW LONG DO WE RETAIN INFORMATION?

The period of time we hold your information depends on the purpose for which we collected it. As a general rule we may hold your personal information for a period of 7 years from the date of completion of a contract with us or the date of expiry 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 may transfer your personal data outside of the European Economic Area (“EEA”). 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.

7.Your 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:

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.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

6.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 order form.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.

We rely on legitimate interest for our marketing activities except where you are not a customer in which case we will obtain your consent. This consent can be withdrawn at any time by contacting us at the details set out above.

You can object to our use of your information for direct marketing purposes at any time by contacting us at the details set out above or following any of the unsubscribe links in our marketing material.