Privacy Policy

General

Frank Keane MG is committed to protecting all personal and special categories of data (also referred to as sensitive personal data) held on you.

Our mission is the managing 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.

Changes to this Privacy Policy:

We may modify or update this privacy policy from time to time. Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have under local law (e.g. to object to the processing).

How Do We Collect Your Personal Information.

These are the main ways we collect your information:

• If you contact us directly via our websites or via our customer hotlines to request information about our products and services
• If you buy a product or service directly from us (e.g. Lifestyle shops)
• If you reply to our direct marketing campaigns (e.g. filling out a response card)
• If with your permission, your contact details are transferred from the vehicle manufacturer or other third parties
• If your vehicle data (incl. vehicle identification number) is transferred to the vehicle manufacturer while you’re having your vehicle serviced or repaired
• If with your permission, other legal entities or business partners transfer your personal data to us
• If we acquired your personal data from other sources with your permission
• When you apply for finance

If you give information on behalf of someone else you must ensure that they have been provided with this Privacy Policy before doing so.

If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian to do so.

Please help us to keep your information up to date by informing us of any changes to your contact details or preferences.

What Information May Be Collected About You.

The following types of personal information about you may be collected:

Contact Details

• Name
• Address
• Phone numbers
• Email address

Interests

• Information you provide us about your interests
• Including the type of vehicles you are interested in

Website and Communication Usage

• How you use our website and whether you open or forward our communications, including information collected through cookies and other tracking technologies

Sales and Services Information

• Relating to purchases and services, including complaints and claims

Credit and Anti-Fraud Information

• 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
• Fraud, offences, suspicious transactions, politically exposed person and sanctions lists where your details are included

Device and Service Usage

• How you use your device (mobile or vehicle) and services offered on the device

Vehicle Configuration Details

• Information about the features and current settings of your vehicle (identified by the Vehicle Identification Number)

Vehicle Technical Information

• About how the engine and systems within the vehicle perform

Vehicle / Device Location Information

• Your vehicle or mobile device’s location

How Your Personal Information May Be Used.

Use of personal information under EU data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy.

The main uses of your information are:

Customer Support and Marketing – to respond to enquiries and to bring you news and offers.

Frank Keane use your personal data for customer care and for personalised communication of product and service information, where necessary with your consent. For these purposes, Frank Keane may transmit this data to their manufacturing partner companies.

In order to ensure that you receive relevant and personalised communications, we will use your data to create an individual customer profile and we may share your personal data between manufacturing partner companies and other suppliers of licenced vehicle branded products and services where relevant. This may include data you have provided to us, or which is generated by your use the products, for example contact details, preferences, customer history, vehicle data, app usage and online behaviour.

Vehicle Sales & Service – to process your sale, configure and service your vehicle

Frank Keane will obtain Contact Details, Vehicle Configuration Details, Vehicle Technical Information and Sales and Services Information when you purchase, service or repair a vehicle from or with them as part of the sale or service and will use it to provide the services you request and notify you of issues in relation to your vehicle. This information may be accessed by the brand manufacturing partner to troubleshoot technical or other issues relating to the delivery of these services.

The above mentioned controllers may also receive limited Vehicle Location Information during the repair process which will be used only in accordance with Location Information Safeguards.

Quality Assurance, Research and Development – to improve our products and services.

The brand manufacturing partner may use any of the information that it receives through the provision of services, centres (including Location Information) for product and service quality assurance and development purposes. Before any such use is undertaken your information will be de-personalised so it cannot be directly linked back to you.

Compliance with legal requests for your information – to comply with our legal obligations to law enforcement, regulators and the court service.

We may be legally required to provide your information to law enforcement agencies, regulators and courts and third party litigants in connection with proceedings or investigations anywhere in the world. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Legal grounds for processing of your personal information.

The use of your information set out above is permitted under EU data protection law on the basis of these principal legal grounds:

• where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time
• by contacting Frank Keane on 01 240 5666
• or sending an email to info@frankkeane.ie
• or by writing to us
• where necessary to enter into or perform our contract with you
• 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 Frank Keane business and tailoring news and offers to your profile, research and development of vehicle related products and services, assessing your creditworthiness, detecting fraud and criminal activities)
• where necessary for us to defend, prosecute or make a claim against you, us or a third-party

There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavour to identify the ground and communicate it to you as soon as possible after becoming aware of the new basis.

Transfer to third parties.

Personal information which we collected may be transferred to third parties on your behalf, only with your consent.

This is only 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.

The types of third parties apart from the companies already stated, including Frank Keane Group companies are:

• Marketing agencies who run and manage marketing campaigns on our behalf.
• Event companies who run and manage sponsored events on our behalf.

How Do 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 information.

Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. Our main security measures are:

• tightly restricted personal access to your data on a ‘need to know’ basis and for the communicated purpose only
• transferred collected data only in encrypted form
• firewalled IT systems to prohibit unauthorised access e.g. from hackers
• permanently monitored access to IT systems to detect and stop misuse of personal data

If you have a personal password which enables you to access certain parts of our websites or any other portal, app or service we operate, do not forget your responsibility for keeping this password confidential. We ask you not to share your password with anyone.

How Long We Keep Your Personal Information For.

We retain your information only as long as is necessary for the purpose for which we obtained them and any other permitted linked purposes. If information is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.

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 and your information that is no longer needed is either irreversibly anonymised or destroyed securely.

Use for marketing:

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 point.

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.

ConnectedDrive and Connected App:

We set out how long we retain Vehicle Location Information [and Device Information] in relation to each service in the relevant service descriptions.

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.

Who May We Share Your Information With.

Your personal information may be accessed by our staff, agents or contractors from a country outside the European Economic Area (EEA) for any of the purposes set out, in which data protection laws may be of a lower standard than in the EEA. We will ensure that any of your information that is accessible outside the EEA is handled subject to appropriate safeguards.

Certain countries outside the EEA, such as Canada and Switzerland, have been approved by the European Commission as providing essentially equivalent protection to EEA data protection laws and therefore no additional legal safeguards are required. In countries which have not had such approval, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.

How To Change Your Privacy Preferences.

You can change your preferences, or withdraw your consent in relation to how Frank Keane use your personal information in one of the following ways:

• You can make individual changes directly in your App account, where applicable
• You are also able to request information about your data stored at Frank Keane as well as request the correction, deletion or restriction of your personal data for analytics and/or marketing use
• By contacting Frank Keane on 01 96 33 258
• Or by sending an email to info@frankkeanemg.ie
• Or by writing to us

Contacting Frank Keane About This Privacy Policy.

If you have any questions in relation to our use of your information you should first contact Frank Keane MG in one of the following ways:

• Call 01 963 3250 – Frank Keane MG
• Or by sending an email to info@frankkeanemg.ie
• Or by writing to us

Under certain conditions you have the right to require us to:

• Provide you with further detail on the use we make of your information
• Provide you with a copy of your information
• Update any inaccuracies in the information we hold about you
• Delete any information about you that we no longer have a lawful ground to use
• Remove you from any direct marketing lists when you object or withdraw your consent
• Provide you with your personal information in a usable electronic format and transmit it to a third party (right to data portability)
• Restrict our use of your personal information
• Cease carrying out certain processing activities based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights

Your exercise of these rights is subject to certain exemptions to 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.

© Frank Keane 2021.