Privacy Policy

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 DS Automobiles 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.

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.

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 at Gowan Motor Distribution Limited, 2007 Orchard Avenue, Citywest Business Campus, Dublin 24, D24 RW52, or emailing us at ds-customercare@dsautomobiles.ie

(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.

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.

1.6.1 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 DS Automobiles 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.

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 Motor Distribution Ltd 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.

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.

• 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.