THIS DATA PROTECTION STATEMENT IS EFFECTIVE AS AND FROM 25TH MAY 2018
This statement describes how we process your personal information. Please take the time to read it carefully. 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 on for our legitimate interests and where we process your information for direct marketing.
In this statement we use the terms “we” and “our” to refer to Mitsubishi Motors Ireland. Where this statement refers to the term “dealer”, this means the car dealership authorised to sell or service Mitsubishi vehicles.
1. Who we are and how to contact us.
MMC Commercials Unlimited t/a Mitsubishi Motors Ireland Mitsubishi House, John F Kennedy Drive, Naas Road, Dublin 12 is the company responsible for your personal data known as “controller” under data protection law..
If you have any questions about this data protection statement, including any request to exercise your legal rights, please contact us using the details set out below;
Send an email with to email@example.com
2. The Categories of Personal Data and how we use it
We may collect, use, store and transfer different kinds of personal information about you as follows and use it for a variety of different purposes
Example of how we use it
Name, address, email address, telephone numbers
We use this information to send you information about products and services, to send you information which you have requested such as brochures, to verify orders from our dealers, to contact you about safety, warranty and recall issues and to contact you for the purposes of customer satisfaction surveys, which you have the right to opt out of at any time and for marketing purposes, where you consent.
Information about your vehicle including your vehicle identification number, vehicle registration number, mileage, vehicle model, diagnostic information, work carried out on your vehicle
We use this information for warranty, safety, service, repair and recall issues.
Trade in vehicle type, gender, a predicted age-range, information which you manifestly make public for example through social media and the products and services in which you are interested in or have purchased.
We use this information on an aggregate basis for market research purposes to help understand our customer base.
Interactions with our staff and officers, including notes of your calls with our staff on our database.
We use this information to keep a record of your interactions with us, to monitor and train our staff
We may receive financial information about your finance agreement with your bank or finance provider in respect of your vehicle, where we are under an obligation with the bank or finance house to source a dealer to buy back your vehicle at the end of your finance arrangement.
Information about your experience with the dealer collected through customer satisfaction surveys carried out by us, or through audits that we carry out on our dealer.
We use this information to monitor our dealer performance and send aggregate data to Mitsubishi Motors Japan.
Your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access any website operated by us, information about how you use our websites .
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. To monitor the effectiveness of our website.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not data that directly or indirectly reveals your identity. For example, we may aggregate your usage data of our website to calculate the percentage of users accessing a specific website feature and we may aggregate the age profile of people who purchase particular vehicle types. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this data protection statement.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How we obtain your information
We may collect your information from a dealer from whom you purchase a vehicle or from who you obtain other services such as service, warranty work or repair or with whom you make an enquiry. We may obtain this information directly from a dealer or the dealer management platform or in the course of carrying out an audit on the dealer.
We may also collect your information though our website or where you provide it to us, such as where you enter competitions with us, fill out forms, request a service from us such as a brochure or booking a test drive or contact us. We may also collect information from you at events and brand displays, such as at shopping centres etc.
We may also obtain your information from your finance provider or bank for reconciliation purposes at the end of your finance agreement.
We may also collect your information where we carry out customer satisfaction surveys of your customer experience with our dealers.
We may also collect information about you from publically available sources, such as social media, where you have manifestly made that information publically available. We may combine this with other personal information we hold about you.
We operate CCTV in our premises to protect the safety and security of our staff, as such we may collect your personal information through CCTV, in our legitimate interest.
4. The purpose and legal basis for processing your information.
We collect your information for a number of purposes and rely on a number of different legal bases to use your personal information.
a) To enter into and perform a contract with you:
We may process your information in order to enter into a contract with you or to provide you with a service which you have requested from us.
For example we need to process your personal information in order to manage the warranty which we have provided in respect of your vehicle or to provide you with a brochure or information about a product where you have requested it
b) To comply with our legal obligations
We are required to process your personal information to comply with certain legal and regulatory obligations to which we are subject. For example we are required to obtain certain business records in accordance with company and revenue law which may include your personal information.
c) For our legitimate business interests
Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.
We may use your personal information to manage our everyday business needs, including accounting, internal reporting needs, and market research, to progress and respond to legal claims, security of our premises and staff through use of CCTV, to process rebate claims, to ensure appropriate IT security and to prevent fraud, to monitor and audit warranty claims, to update you on our service and dealer network in our legitimate interest. Our legitimate interest is the effective management of our business.
We may use your personal information to monitor the performance of our dealers and verify dealer orders, including the carrying out of audits on our dealers and contacting you for customer satisfaction surveys by post, email or phone, in our legitimate interest. Our legitimate interest is ensuring that our dealers are complying with our high standards when selling vehicles and servicing Mitsubishi vehicles.
We may use your personal information to send you warranty or service reminders or vehicle health check reminders, in our legitimate interest. Our legitimate interest is connecting with our customers.
We may use your personal information in an aggregate form to classify our customers and to acquire an aggregated overview of our customer base in our legitimate interest. Such processing does not assess individual characteristics. Our legitimate interest is to grow our business, understand our customer base and provide products and services of interest to our customer base as a whole.
We may use your information which we collect, including personal information we obtain from publically available sources such as social media, to help us understand our customers and provide products or services which may be of interest to them, in our legitimate interest. You have the right to object to this at any time.
We may also contact you in the event of the closure of your local Sales or Aftersales Dealer, to give you the details of all other authorised dealers and repairers available to you in the Mitsubishi network, who can carry our warranty work or provide you with information on Mitsubishi products. We do this in our legitimate interest in order to keep our customers updated of changes within our dealer network.
We may obtain information about your finance arrangements in respect of your vehicle from your finance provider in order to arrange buy back of the vehicle. We do this in our business legitimate interest of arranging the reconciliation of finance agreements.
d) With your consent
We will only use your information to market to you by post, text, email or phone where we have your consent to do so. You can withdraw this consent at any time by contacting us at the details set out above.
e) To protect your vital interests
We may in certain circumstances use your personal information to protect your vital interests, for example we may contact you in the event of a recall or safety issue with your vehicle.
5. Your information and Third Parties
Third Party Service Providers: We may share your personal information with third party service providers that perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, debt collection agencies, valuers, lawyers and other business advisors, marketing companies who carry out marketing campaigns, market research and customer satisfaction surveys on our behalf and providers of security and administrative services.
Dealers within our Network: we may also share your personal information with a member of a dealer network in order to provide you with a product or service which you have requested, such as a test drive or to deal with warranty, repair or service issues and to assist the dealer with diagnostic issues or to arrange the repurchase of your vehicle at the end of any finance agreement you have with a finance provider.
An Garda Síochána, government bodies, or other government officials: we may share your personal information with an Gardaí, or other government bodies or agencies, where required to do so by law.
Mitsubishi Motors Europe BV and other Mitsubishi Motor Entities: Where we convert your information, such as information you provide in the course of a customer satisfaction survey, into statistical or aggregate data in such a way as to ensure that you are not identified or indefinable from it, we may pass this information on to Mitsubishi Motors Europe BV and other Mitsubishi motor entities, such as dealers and distributors for analytical and statistical purposes.
Mitsubishi Motors Corporation and entities with the Mitsubishi Motors Global Network: There are circumstances where we may share your information with the manufacture and any independent auditor appointed by the manufacturer, in order to fulfil orders and transactions, to provide you with a service or information which you have requested.
Finance Provider: We may share your personal information with your finance provider in order to arrange the repurchase of your vehicle at the end of your finance agreement.
Potential Sale of the Company: We may share your information with any potential purchaser of our business.
6. Storage Periods
We will retain your personal information for the purpose of satisfying any legal, accounting or reporting requirements. We may hold your personal information by reference to the statute of limitations or for a longer period if we are legally required to do so.
7. Transfers outside the European Economic Area
We may transfer your personal data outside the European Economic Area. These countries do not always afford an equivalent level of privacy protection and in such circumstances we take specific steps, in accordance with data protection law and 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 protection approved by the European Commission.
8. How we use Automated Processing
We may analyse your personal information by automated means for the purposes of market research, analysing our customer database and for our marketing activities. You have the right to object to this at any time.
9. If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a test drive). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
You have several rights under data protection law in relation to how we use your personal information. You have the right free of charge to;
- 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);
- have any inaccurate personal data which we hold about you updated or corrected;
- erase personal information we hold about you;
- 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;
- withdraw your consent at any time where our processing is based on your consent
- 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 grounds for the continued processing of this information; and
- 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 form. 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 period of two months and we will explain why.
You also have the right to lodge a complaint to the Office of the Data Protection Commission. For further information please see www.dataprotection.ie
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We will update this data protection statement from time to time. Any updates will be made available on our website at www.mitsubishi-motors.ie and, where appropriate notified to you.