Data Protection Statement
This is the Privacy Statement of Polestar Distributors Ireland Limited who’s registered number is 236154 and with a registered office at OHM Group Clonlara Avenue, Baldonnell Business Park, Baldonnell, D22 W1H9, Dubin, Ireland and Spirit Motor Group T/A Polestar Dublin who’s registered number is 380141 with a trading address at 37 Heather Road, Sandyford Business Park ,D18 EDX4 Dublin, Ireland and who is the authorised retailer.
In this statement we use the terms “we”, “our” and “us” to refer to Polestar Distributors Ireland Limited and Polestar Dublin. For the purposes of data protection Polestar Distributors Ireland Limited and Polestar Dublin are joint controllers of the processing described in this statement.
The purpose of this Privacy Statement is to outline our position concerning the collection, use, retention, disclosure, and transfer of Personal Data which is gathered and processed by us. This Privacy Statement also sets out information management practices.
We respect the privacy of all those individuals whose Personal Data we encounter, which in particular includes the following:
All users of our Website and Social Media Pages
All employees and contractors (including applicants for employment);
Business contacts, retailers, manufacturers, and suppliers;
Customers or prospective customers.
For each of these categories of individuals, this Privacy Statement will explain why we collect and how we use the Personal Data we collect. We will ensure that we keep all Personal Data provided in accordance with our obligations under applicable data protection laws. We will update this Privacy Statement from time to time to reflect any material changes in technology, legislation or our data use practices which may materially affect the way in which we process Personal Data.
This is not an exhaustive statement of all our data protection practices and we may apply specific policies within certain environments. We might include a separate privacy notice at the point of capturing data on a new service and any specific consents obtained or information provided in this way will apply specifically to that service and will supplement this Statement. You will always find the most up to date version on our website.
1. What is Personal Data?
Personal Data is any information relating to a living individual that allows for the identification of that individual. Personal Data can include a name, address, contact details, an identification number, IP address, CCTV footage, etc.
2. Who we are and how to contact us?
In circumstances where we control Personal Data by deciding why and how that Personal Data is processed, we will be a "Data Controller". Any entity that processes Personal Data controlled by us and does so on our behalf and with our instruction, is a "Data Processor". Data Processors may include third party service providers engaged by us (for example communications providers, or marketing agencies). As required by applicable data protection law, when we appoint a Data Processor, we will ensure that appropriate contractual protections are in place.
If you have any questions about this data protection statement, including any request to exercise your legal rights, please contact us by writing to our Data Compliance Officer, OHM Group, Clonlara Rd, Baldonnell Business Park, Dublin, D22 or emailing us at dco@ohm.ie .
The below sections of the Privacy Statement set out the type of Personal Data collected by us, the purposes for which such Personal Data is collected and processed and the lawful justifications for such processing in the context of our websites and for the provision of our products and services when engaging directly with our retailer Polestar Dublin who operates as a joint controller in this instance.
3. Categories of personal data and how we use it.
We collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, username or similar identifier, title, and gender.
· Contact Data includes email address, telephone number(s) and postal address.
· Financial data includes bank details, finance on a vehicle and salary details, employment history and marital status
· Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, chosen language, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
· Profile Data includes your interests, preferences, and feedback.
· Usage Data includes information about how you use our website and services.
· Marketing and Communications Data includes your preferences in receiving marketing from us our retailer , third parties and your communication preferences.
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 considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 privacy statement.
It is not our intention to 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 is it our intention to collect any information about criminal convictions and/or offences. However, if we are required to collect such special category data, we will request your explicit consent to do so.
4. How do we obtain your information?
We use different methods to collect data from and about you through the following methods.
Direct interactions
You may give us your identity and contact data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you
· request our services; (booking a test drive or when you configure a vehicle)
· subscribe to our publications;
· create an account;
· request marketing to be sent to you;
· provide feedback; or complete a survey with a retailer;
· complete a finance application form;
· apply for a job with the business;
· enter competitions;
· attend brand events;
· when you visit our premises CCTV imagery is obtained;
· manage your personal data preferences.
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. When you visit our website all cookies apart from strictly necessary cookies will require your consent.
Third parties or publicly available sources
We may receive personal data about you from various third parties such as;
· the retailer where you purchased your vehicle
· the manufacturer of your vehicle - Polestar Performance AB
· advertising networks which we utilise and to which you might engage with
· interactions with social media sites
· recruitment agencies when you apply for a role within our business
We are not responsible for the privacy practices of any external websites, manufacturer, or platforms which may be accessed or used in connection with a person’s use of our website or social media pages. They are subject to their own privacy statements which may materially differ from those of ours so visitors should review them for further information.
5. What Personal Data do we collect and use Online
We collect various types of Personal Data when a person uses our website or social media platforms and when they engage with our digital marketing communications. The following are examples of Personal Data collected by us;
Our website uses cookies, web beacons, device identifiers, social plugins, tracking pixels, etc. “Cookies” are small pieces of information stored by your internet browser that collect data such as your browser type, your operating system, web pages visited, time of visits, content viewed, advertisements viewed, and other click stream data. We use cookies to help us tailor our websites to your needs, to deliver a better, more personalised service and to remember certain choices you have made so you do not have to re-enter them. We do this through the utilisation of Google Analytics, and other technology service providers that helps us better understand our website visitors experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) this enables us to build and maintain our service with user feedback and to also identify traffic to our website including pages visited, visitor numbers and traffic paths taken. We also use an AI-supported analytics tool developed by our website partner Vyro to better understand customer sentiment and enhance the personalisation of your buying experience. This tool also helps us measure and improve our website’s performance. All data collected is retained on a first-party basis and with your consent. This data is not shared with any third parties or external platforms. Please note we do not deploy un-necessary cookies on our website, such as analytics, marketing, targeting, or profiling/behavioural cookies without your consent. Please see our Cookie Policy for further details on all cookies that are utilised Cookie Policy
If you subscribe to receive digital marketing communications, we utilise technology such as UTM codes which are included via links within the communication and which directs you to our website, this allows us to review what digital campaign you initially engaged with. We utilise this type of aggregate data internally to measure a campaign’s effectiveness, it also supports in designing future campaigns that are relevant to our subscribers.
We will collect your personal data from Contact Forms, (such as booking a test drive, vehicle enquiry and vehicle configuration) this enables us to deal with your request in a timely manner. We will also collect and retain your data when you create an account on our website, the purpose of this processing is to allow you to retain information regarding vehicle configuration, or a vehicle that you have liked and for the purpose of managing your vehicle order and its progress.
We offer an online card payment service on our website to facilitate a deposit or full payment of your chosen vehicle. We use Stripe for payments, analytics, and other business services. Stripe may collect your personal data this will include data via cookies and similar technologies. The personal data Stripe collects may include transactional data and identifying information about devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection, loss prevention, authentication, and analytics related to the performance of its services. You can learn more about Stripe and read its Privacy Statement at https://stripe.com/privacy
We will collect your data when you complete a finance application form through our website. Finance Ireland provides this service. Please note Finance Ireland is a Data Controller and will make decisions regarding your personal data independently from PDIL. For further information on how Finance Ireland will process your data please be sure to read their Privacy Statement
You may choose to trade in your current vehicle against a new Polestar. PDIL provides an online service to which you can obtain details of the trade in value of your vehicle. This service is provided through Tradebid (trade-bid.ie)
Competitions: When a person enters a competition, we may collect and use the entrant’s name and contact details (including postal address, email address, telephone number) in connection with the competition (including mobile competitions). Where we operate competitions in conjunction with a third-party commercial partner, subject to the competition rules and notices, that partner may collect and use the data.
Social Media Pages: Content such as messages and photographs, that are posted on social media pages on which we have a presence may be made publicly available and may be used in connection with the operation and promotion of our social media pages, services, and this website. Data such as the name of your internet service provider, the website you visited us from, the parts of our site that you have visited, the date and duration of your visit, and information from the device (e.g., device type, operating system, screen resolution, language, country location, and web browser type) used during your visit. We may process this usage Data to facilitate access to our website (e.g., to adjust our website to the devices that are used). If inappropriate content is posted to our social media platform and is deemed to be in breach of this Privacy Statement or the policies operated by such websites or social media platforms, such content may be removed by or at the request of PDIL or the operators of those social media platforms. If such inappropriate content is posted to a social media page that we control, you can report it at the following address dco@ohm.ie and we will endeavour to ensure that appropriate action is taken in accordance with our policies and the policies of the relevant social media platforms such as Facebook, Instagram and LinkedIn.
We may use advertising networks to help present advertisements or other content on our website and other websites that display our advertisements. Advertising networks use cookies, web beacons, or similar technologies on your computer or mobile or other device to serve you advertisements or content tailored to interests you have shown by building a profile of your internet browsing on this website and other websites you have visited.
6. The purpose and legal basis for processing your information
We collect and process the Personal Data described below for a variety of purposes. Below is a summary of these purposes and the lawful justifications that support them:
To enter into and perform a contract with you.
We will 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 or our retailer Polestar Dubin. For example, we need to process your personal information in order to enable you to purchase a vehicle or to provide you with a brochure or information about a product or service where you have requested it.
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.
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.
If you are a consumer customer, we may use your information to send you communications on products and service that may interest you and that you would reasonably expect to receive, you can at any stage easily opt out of these communications by contacting us on dco@ohm.ie
If you are a business customer or prospective business customer, we may use your information to send you communications on products and services that may interest you and that you would reasonably expect to receive. You have the right to object to this at any time by unsubscribing via the link that will be provided in the communication.
We use information which we collect, including personal information we obtain from publicly available sources such as social media, to help us understand our customers and provide products or services which may be of interest to you, in our legitimate interest.
If you are a business contact, we may acquire your contact data from reputable marketing agencies, which may include your personal data with the intention to provide you with information on products or services which may be of interest to you, in our legitimate interest. We will notify you of any such acquisition and you have the right to object to this at any time.
We use your personal information to manage our everyday business needs, including accounting, internal reporting needs, and market research (surveys) to progress and respond to legal claims, security of our premises and staff through use of CCTV, to process claims, to ensure appropriate IT security and to prevent fraud, to monitor and audit warranty claims. Our legitimate interest is the effective management of our business.
We 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 also contact you in the event of updates about our business such as ours or our retailers’ opening hours, change in address, updates about our privacy statements and notices etc. We do this in our legitimate interest in order to keep our customers updated of changes within our organisation.
We provide your personal information from contact forms collected via our website to other OHM organisations and to our retailer Polestar Dublin. We do this in our legitimate interest to keep our customers supported by directing their requests or interests to the vehicle retailer.
We use vehicle tracking in all test drive vehicles. The purpose of installing and using telemetric tracking systems is our legitimate interest in the efficient management of our business assets and ensuring the security and safety of employees, the public, and the assets of our business.
You have the right in certain circumstance to object to any of the above processing scenarios please contact us on dco@ohm.ie
With your consent
We will request your consent for the use of all cookies on our websites outside of strictly necessary. You can withdraw this consent at any time by clicking “cookie settings” at the bottom of our webpage, see our cookie policy for further information.
Where you are a consumer prospect we will request your consent for all direct digital marketing communications.
You can revoke your consent at any time by contacting dco@ohm.ie or by using the un-subscribe option in the marketing communication.
To protect your vital interests
We will 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 significant safety issue with your vehicle.
Purpose
Description
Lawful Basis for Processing
Applying for a Job
Name, contact details such as postal address, email address, telephone numbers. CV and its contents (gender, current and former employment, academic details, reference, interests, hobbies)
The processing is in our legitimate interests in the assessment of potential candidates for employment within our business.
Anti-Money Laundering
We may use your personal data to comply with anti-money -laundering regulations
The processing is necessary for compliance with a legal obligation to which we are sub
Business needs
Name and contact details such as postal address, email address, telephone numbers and current vehicle details
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
Customer Care
Interactions with our staff and officers, including personal and vehicle details.
We use this information for the purpose of identity verification and in order to assist the relevant queries.
Customer Satisfaction Survey
Name and Contact details and current vehicle details.
Information about your experience with our retailer collected through customer satisfaction surveys carried out by us, or through audits that we carry out on our retailer.
We use this information to monitor our retailer’s performance and for driving service improvements in our legitimate interests.
CCTV
Images
We operate a CCTV system on our premises for the safety and security of our staff and visitors.
The processing is in our legitimate interests
Lost Lead Management
Name and contact details and vehicle details
We respect your right to change your mind in purchasing a vehicle from us. We will contact you to determine if we could have done anything better to retain you as our customer.
The processing is in our legitimate interests to improve our services and that of our retailer
Legal obligation
Name and contact details such as postal address, email address, telephone numbers and current vehicle details
We may use your personal information to comply with various legal obligations to which we are subject including.
Making a payment of VAT or in respect of the sale of a vehicle or vehicle parts or service.
Marketing to Potential Customers and Existing Customers
Name and Contact details and current vehicle details.
Where you are a Consumer Customer or a Business-to-Business Prospect or Customer. The processing is in our legitimate interests to develop our business by providing information that is relevant and where you would reasonably expect to receive such information and have not opted out of the processing.
Where you are a Consumer Prospect we will rely on your consent to communicate to you.
Online Finance Application Form
Financial information, employment history, marital status
Online Payment Service
Name and contact details such as postal address, email address, telephone numbers, vehicle details, payment amount
We will process data related to your payment transactions through our website.
Purchasing a Vehicle
Name, contact details such as postal address, email address, telephone numbers, gender, current vehicle details.)
When you order a vehicle information is collected by us for processing and is shared to Polestar AB (manufacturer) for the fulfilment of the order, warranty registration roadside assistance and after sales support .
The lawful basis for processing is the performance of a contract to which you are party
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 of our services and to assist in monitoring and training our staff and identifying areas for improvement.
Registering Interest
Name and contact details and current vehicle details
When an individual visits our websites and registers interest in any of our products, contact details are collected in order provide information so we can arrange follow up.
Requesting a Quote/Brochure Booking a Test Drive
Name and contact details such as postal address, email address, telephone numbers and current vehicle details
When you visit our websites and request a quote or brochure or book a test drive or service, personal information is collected in order to satisfy this request. Where applicable these details are sent to the retailer who will fulfil the request.
The processing is in our legitimate interests in developing a relationship with potential customers.
Safety Incidents / Product recall
We may use your personal data to contact you regarding an urgent safety measure and / or a product recall.
(a) Necessary for compliance with a legal obligation to which the controller(s) are subject.
(b) Necessary to support your vital interests.
(c) Necessary for the purpose of our Legitimate Interests that of our customers and the vehicle manufacturer
To understand our customer base
Name and contact details such as postal address, email address, telephone numbers and current vehicle details
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.
Trading in a Vehicle
Name, contact details such as postal address, email address, telephone numbers. Current vehicle details, mileage, vehicle registration , finance details (if applicable)
The processing is the performance of a contract to which the customer is party.
Vehicle Financing
Financial Information.
We may receive financial information about your finance agreement with your bank or finance provider in respect of your current vehicle, where we are under an obligation with the bank or finance house to source a retailer to buy back your vehicle at the end of your finance arrangement.
This processing is necessary for the performance of a contract and to keep a record of your interactions with us.
Vehicle Tracking
We operate vehicle telematics in our test drive vehicles. The vehicle is tracked via GPS and location data is retained and in certain instances the driving behaviour of the vehicle operator may also be recorded.
The processing is necessary for our legitimate interests in protecting our business assets.
Website Security
I.P Address, device details
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
We use data analytics to improve our website, products/services, marketing, customer relationships and experiences. This will include reviewing the behaviours of visitors to our website via Google Analytics and Vyro Insights.
With your consent where your data has been collected through our website.
This type of personal data enables us to define customer types for our products and services, to keep our website updated and relevant, to inform our marketing strategy and to develop our business .
7. Who do we share information with?
Third Party Service Providers:
We may disclose Personal Data to third parties in certain instances. For example,
we use third party service providers for the processing of Personal Data for a number of purposes, including, security service providers, consultant advisors, IT service providers, printers, debt collection agencies, valuers, marketing companies who carry out marketing campaigns, market research or customer satisfaction surveys on our behalf and providers of security and administrative services. We share your information with organisations who provide services for you to avail of roadside assistance. These service providers are subject to a contractual obligation to only process Personal Data obtained from us for purposes to which it was obtained and in accordance with our instructions.
We will not provide any personal information to third parties for direct marketing purposes unless you have consented to giving Personal Data to third parties or partners for that purpose. If you opt-out from receiving communications from third parties or partners, we will no longer share your contact details with our partners or third parties. However, you will still need to directly opt-out from communications from the partners to whom we have already provided your personal information.
OHM Group and other OHM Group entities: We are part of the OHM Group, and we may pass your information on to OHM Group entities, for the purpose of administrative efficiencies, for fulfilment of a contract and for storing your data in central IT Systems. https://www.ohm.ie/brands/ We may also convert your information, such as information you provide during 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 OHM Group and other OHM Group entities, for analytical and statistical purposes.
Website Partner:
We partner with Vyro Pty who support this website and the collection of visitor’s data and customer preferences. Please note Vyro will retain the I.P address of visitors to our website as a Controller of the data for the purposes of security measures and crash analytical reporting. For further information on Vyro Pty please see their Privacy Policy - Vyro
Retailer Within Our Network:
Your personal information is shared with our retailer Sprit Motor Group Limited T/A Polestar Dublin who operates as a Joint Controller with Polestar Distributors Ireland Limited on the activities outlined in this Privacy Statement.
Insurance Companies:
We may disclose personal data to our insurance providers in connection, with legal claims and prospective legal claims or proceedings.
Polestar Performance AB:
We will share your information with the manufacturer of your vehicle to fulfil orders and transactions, for the purpose of warranty registration and for customer care queries and aftermarket support. We will also share your information with any independent auditor appointed by the manufacturer. For further information on how Polestar Performance AB will process your data see below links.
Privacy Policy:
Car Privacy Notice:
Polestar App Notice:
Finance companies, leasing companies/ brokers: We may receive financial information about your finance agreement with your bank or finance provider in respect of your current 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. You may also choose to apply for finance via our website. Please be aware that Finance Ireland provide this service and operate as independent Data Controllers with regards to your data throughout the application process. Please read their Privacy Statement before proceeding with your application Finance Ireland - Privacy Policy - Finance Ireland
Payment Services Provider: You can pay a deposit or the full amount on your chosen vehicle through our website. This service is provided by Privacy Policy (stripe.com) who will process and verify your payment.
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 protection statement.
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.
8. What type of information is collected?
As a vehicle distributor and retailer we need to collect many categories of personal data (about you and other parties) for the purposes set out in this Privacy Statement.
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 Product
Name, Contact Details, (Email/Phone) Gender, Vehicle Details, Bank Details, Service History, Warranty Records
Customer Care
Name, Contact Details, (Email/Phone), Vehicle Details, Phone Calls, Data Preference (Webforms & Surveys)
Finance
Finance Agreements with Lenders, Bank Details, Card Details, Transaction Details
Finance Application Forms
Name, Contact Details, (Email/Phone) Gender, Bank Details, Family Status, Current and Previous Address Details (for up to 3 years), Employment History and Salary
Marketing
Name, Contact Details, (Email/Phone), Occupation, Vehicle Details, Gender, Purchase History, I.P Address, Cookie Preferences, Device Details, Location Data, Browser Type, Interests, Contact Forms, Consent Records, Data Preference (Webforms & Surveys)
Security
CCTV Footage, I.P Address
IT Information
We collect information about your internet activity when engaging on our website using technology known as cookies. Your consent will be required for certain cookie types. See our cookies policies on our websites for further information.
9. Storage Periods
The period for which we will keep your personal information will depend on the service you have requested from us. The retention period may be longer than the period for which we are providing services to you where, for example, we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, or where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in the event of a legal claim.
We endeavour to ensure that Personal Data is retained for an appropriate period and no longer than necessary. Retention of data is detailed in our Data Retention Policy.
10. Transfers outside the European Economic Area
We may transfer, store, or process your personal information in countries outside the European Economic Area. Where the laws of such countries do not afford an equivalent level of protection of personal information as the laws of Ireland. We take specific steps in accordance with data protection law to protect your personal information.
We will use one of these safeguards:
· Transfer to a non-EEA country with privacy laws that give the same protection as the EEA.
· Put in place a contract (in a form that is 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.
· Transfers to organisations that are part of an EU Framework that sets privacy standards for data sent between countries. These frameworks make sure those standards are similar to what is used within the EEA.
11. 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.
12. Processing for Security Purposes
We operate closed circuit television cameras ("CCTV") throughout our premises covering buildings, internal spaces, car parks, roads, pathways, and grounds. Our CCTV system is implemented in a proportionate manner as necessary to protect our property against theft or pilferage and for the security of employees, customers, and visitors to our premises (to protect their vital interests). Whilst CCTV footage is monitored by our, senior management, security staff or contractors, access to recorded footage is strictly limited to authorised personnel.
Footage is retained for 60 days, except where incidents or accidents have been identified in which case such footage is retained specifically in the context of an investigation of that issue. CCTV footage may be used in the context of disciplinary proceedings involving PDIL employees and to detect, establish and/or defend legal proceedings (to protect the vital interests of our, employees and affected individuals). CCTV footage is not disclosed to third parties except where disclosure is required by law (such as for the purpose of preventing, detecting, or investigating alleged offences) and in such instance’s disclosure is based on a valid request. Signage indicating that CCTV is in use is displayed throughout our premises. We operate a CCTV policy, and this can be made available upon request to dco@ohm.ie
13. 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.
14. Information Security
In accordance with applicable laws, we aim to ensure that all Personal Data controlled by us is held securely using appropriate security measures including the following:
· Physical measures such as locked filing cabinets and offices containing Personal Data;
· IT security systems;
· Restricted access to Personal Data subject to approvals;
· Time limits on retention of personal data;
· Provision of targeted data protection training and information security to employees, contractors and other staff who have access to and process Personal Data;
· Password restrictions on access to Personal Data; and technical measures including:
a. Encryption on all laptops/portable devices; and
b. Logging mechanisms to record certain access to Personal Data and alteration and other processing of Personal Data.
c. Encrypted e-mail services
In the event of a personal data breach, we will comply with applicable reporting and notification obligations under data protection law. A Breach Notification Policy is in place.
15. Your Rights
In certain circumstances, you have the following rights under data protection law in relation to your personal data:
A right to access Personal Data held by us
(a) Any individual has a right to make an access request, verbally and/or in writing under data protection law for a copy of their Personal Data held by us. We may ask for further identification details to confirm your identity before the relevant information is provided.
(b) It should be noted that there may be specific exemptions relating to accessing Personal Data. If we utilise any of the exemptions, we will provide you with details and our justification for their use.
Other data protection rights
(a) Rectification of inaccurate personal data;
(b) Erasure of personal data (also known as the "right to be forgotten");
(c) Restriction of processing of persona data;
(d) Right to data portability;
(e) Right to object to processing of personal data.
However, under data protection law, these rights are available only in certain circumstances. If you wish to exercise any of your data protection rights, please contact dco@ohm.ie or by us using the contact details below. 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. Please provide as much detail as possible to enable us to respond to your request and to locate relevant personal data about you.
By Post: DCO, OHM Group, Clonlara Rd, Baldonnell Business Park, Dublin, D22 WIH9
By Email: dco@ohm.ie
By Phone: + 353 (0) 1 4034100
You also have the right to lodge a complaint to the Office of the Data Protection Commission. For further information please see Data Protection Commission
16. Updates
This policy [“version 2”] was updated and deemed effective on the 6th of June 2025. We will update this data protection statement from time to time. Any updates will be made available on our website and we would ask that you check regularly.