1.1 PURPOSE

This data privacy statement applies to Gowan Motor Distribution DAC. of 8 Appian Way, Ranelagh, Dublin 6, D06 NV29. The purpose of this statement is to explain how Gowan Motor Distribution DAC (hereinafter referred to as “Gowan Motor Distribution DAC”, “Jeep”, “we” or “us”), collect, process, store and keep secure your personal data in connection with our business in accordance with GDPR Regulation (EU) 2016/679 (the “GDPR”).

It is important that you read this data privacy statement together with any other statement or policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This data privacy statement supplements the other documents and is not intended to override them. Gowan Motor Distribution DAC. of 8 Appian Way, Ranelagh, Dublin 6, D06 NV29 is the company responsible for your personal data known as “controller” under data protection law.

1.2 INFORMATION WE COLLECT

1.2.1 Personal Data

Personal data is information that identifies individuals or can be used to identify individuals and may include details such as a name, address, email address, birth date, marital status, occupation and salary range. We hold basic personal details about our customers and prospective customers. Such details include:

• Customer contact details (so that we can communicate with them if necessary)
• Electronic copies of correspondence sent to or received from our customers, and by our suppliers who work with us.
• As an automotive business, we hold extensive data relating to owners of vehicles purchased from and serviced through a member of the Jeep Dealer Network in Ireland
• Using cookies, our website stores details about your browser, operating system, referral sites, pages that you visit on our website, the date of your visit and your IP address. Please refer to our Cookies Policy for further information.

1.3 HOW WE COLLECT YOUR PERSONAL DATA

Customer and potential customer personal data is normally supplied either by you, the data subject, or by a third party partner (from our Dealer Network or other third party companies, such as breakdown assist partners and warranty providers.)

It is normally collected from visits to our website, by post, by phone, by fax, directly from data subjects or by email correspondence.

We obtain personal information when you register for certain services or purchase a vehicle.

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 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.

We may automatically collect technical information about you when you visit our website, including Internet protocol (IP) addresses (used to connect devices to the Internet), user login details, 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 our website.

1.4 THE PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR INFORMATION

Under data protection law we are only permitted to use your personal data if we have a legal basis for doing so. We rely on the following legal bases to use your 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
We may use your personal information for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). 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.

(d) With your consent
We will only use information to market you by post, text, email or phone where we have your consent to do so. You can withdraw this consent at any time by writing to us Gowan Motor Distribution DAC. of 8 Appian Way, Ranelagh, Dublin 6, D06 NV29 or emailing us at [email protected]

(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. Further details of the purposes and legal bases for the processing we carry out are as follows:

Purpose of Processing	Lawful Basis for processing
Fulfil orders, new vehicle delivery, parts enquiry or vehicle service	processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Booking a test drive or provide requested brochures, ensure follow up through our Dealer Network for sales and aftersales, or to respond to any query you might have.	processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
Manage and respond to any requests you have made to us.	processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
To help us identify you when you contact us.	processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
To manage safety recalls and quality campaigns.	processing is necessary for compliance with a legal obligation to which the controller is subject
To provide you with the most user-friendly online navigation experience.	processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
For general administration, reporting, audit and analysis purposes and to manage our relationship with you.	It is necessary in our legitimate interests and to ensure the effective management of our business.
For market research purposes, customer satisfaction surveys and to carry our mystery shopping exercises. This helps us improve the quality of our products and services we provide.	The data subject has given consent to the processing of his or her personal data for one or more specific purposes
To market to you and, where appropriate, to invite you to any events that we might organise.	the data subject has given consent to the processing of his or her personal data for one or more specific purposes
To comply with legal obligations. If required by any law enforcement agency, court, regulator, government authority or other third party.	processing is necessary for compliance with a legal obligation to which the controller is subject
Pass on to any third party that purchases, or to which we transfer, all or substantially all of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Policy.	processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
To carry out analysis. We may combine and analyse your personal information to help us develop and improve our products and services, understand our customers better; and to manage and improve our relationship with you.	The data subject has given consent to the processing of his or her personal data for one or more specific purposes

1.5 HOW WE PROTECT YOUR PERSONAL DATA

1.5.1 Data storage:
Personal Data is stored securely in electronic form on our IT systems and /or in hard copy form in our offices. We have invested in both technical and organisational security measures and training of employees to safeguard all personal data.

1.5.2 Retention Period:
The length of time we will retain your personal data will depend on the purpose for which we are processing it. The following criteria will be applied:

• We will retain personal data for the minimum period required for the purpose(s) of processing.
• Personal data will be retained for a period of time subject to our data retention policy and/ or legal requirements
• When personal data is no longer required to be retained, it will be anonymized, to remove all personal identifiable information, or deleted in a secure manner in accordance with our technical and organisational procedures.

1.6 SHARING YOUR INFORMATION

1.6.1 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 and market research on our behalf and providers of security and administrative services.

1.6.2 Dealers within our network
We may also share your personal information with a member of our 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.

For example, we may share your personal information with your dealer so that you can be reminded by text message of an upcoming service appointment.

1.6.3 An Garda Síochána, government or quasi-government bodies, courts and tribunals
We may share your personal information with these organisations and bodies, where required to do so by law.

1.6.4 Gowan Group and other Gowan Group entities
We are part of the Gowan Group. 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 Gowan Group and other Gowan Group entities, such as dealers and distributors for analytical and statistical purposes.

1.6.5 Jeep manufacturer and independent auditor
There are circumstances where we may share your information with the manufacturer 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.

1.6.6 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.

1.6.7 Potential sale or merger
If we sell any part of our business and/or integrate it with another organisation, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs, the new owners of the business will only be permitted to use your information in the same or similar way as set out in this data privacy statement.

1.7 MARKETING

If you have consented to marketing from us, we may contact you with information about our products and services through email. All such communications will come from Gowan Motors Distribution DAC or our selected marketing partners.

You have the right at any time to stop us from contacting you for marketing purposes or giving your information to third party marketing companies. You will also be given the opportunity on every email communication that we or our trusted partners send you to indicate that you no longer wish to receive our or their direct marketing material.

1.8 INTERNATIONAL TRANSFERS

We may transfer your information to a country outside the European Economic Area (“EEA”), provided that the country to which the information is transferred ensures an adequate level of protection for your rights and freedoms.

If this country does not offer the same level of data protection as EU and local data protection legislation, we will take adequate measures to ensure that the information is processed in accordance with the applicable legislation relating to data protection.

Such measures include:

• Transferring the personal data to a non-EEA country with privacy laws that give the same protection as those in the EEA.
• Putting in place a contract (in a form approved by the European Commission) with the recipient of the personal information that means they must protect it to the same standards as the EEA.
• Transferring the personal data to organisations that are part of the Privacy Shield. This is a framework that sets privacy standards for data sent between the US and countries in the EEA. It ensures those standards are similar to what is used in the EEA.

1.9 YOUR RIGHTS AS A DATA SUBJECT

• Right to access any personal information we hold about you, the purpose for processing your information and any recipient or categories of recipient to whom your information has been disclosed.
• Right to request a copy of any information which we hold about you.
• Right to rectification of personal information that you consider to be inaccurate.
• Right to update personal information that you consider to be incomplete.
• Right to request that we delete personal information we hold about you.
• Right to request us to restrict the processing of your personal information
• Right to data portability.
• Right to object to the processing of your personal information, subject to certain criteria.
• Right to object to direct marketing.
• Right to have your information transferred where technically feasible.
• Right to withdraw your consent, where processing is based upon consent.
• Right to lodge a complaint with a supervisory authority specifically in the member state where you habitually reside or place of the alleged infringement if you consider we have infringed your data protection rights. For further information please see www.dataprotection.ie.

These rights are in some circumstances limited by data protection legislation. If you wish to exercise any of these rights or if you have any queries about how we use your personal information, please contact us using the contact details at section 1.10 below.

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 period of two months and we will explain why.

We reserve the right to charge a fee to cover our costs where we feel the access request is unfounded or excessive.

1.10 CONTACT INFORMATION

If you have any questions or comments about this privacy statement, you can contact us by email at the following email address: [email protected]

1.11 CHANGES TO THIS PRIVACY STATEMENT

We may update our Privacy Statement from time to time, by communicating material changes to you and publishing the updated Data Privacy Statement on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.