Privacy Policy

Overview

 

When visiting Digital Odyssey Limited T/A CarsIreland.ie (a wholly owned subsidiary of Mediahuis Ireland)  a company incorporated in Ireland with registered number 410097 whose registered office is at Independent House, 27-32 Talbot St, Dublin 1, Ireland or using one of our services, you’re trusting us with your information. We know that this is a big responsibility and we work hard to protect your information and put you in control.

 

At CarsIreland.ie, we seek to maintain the privacy, accuracy, and confidentiality of all data (including your personal data) that we collect and use as part of our services. We will use your personal data only for the purposes described below and in full compliance with the GDPR Data Protection Legislation.

 

The purpose of this privacy statement is to explain how CarsIreland.ie, in our capacity as a data controller, collect and use your personal information.

As Ireland’s largest media company, Mediahuis Ireland reaches millions of people each week across print and online. Mediahuis Ireland is a group of companies that has a number of online sites and services. Information about the companies in our group can be found here .

 

This Privacy Statement applies to https://www.carsireland.ie

 

CarsIreland.ie provides a range of services through this site. We describe these in detail in this statement but basically, we provide services under the following broad headings.

 

Content: 

We provide two types of content:

1. Cars for Sale. The images and description of the cars for sale are uploaded by the seller, which usually consists of a car dealer but can consist of a private seller.
2. Car Reviews.  We fund the creation of this car review content by allowing advertisers to present you with relevant ads. You may choose to opt out of these personalised advertising services by means which we describe in the advertising section.

 

Site Function:  We use analytics providers in order for us to understand our audience, the content that appeals to them and how well our site is working. We also provide tools from the major social networks (Twitter, Facebook etc.) to allow you to share content from our site.

 

Mobile Apps and other channels: We also provide our content through a variety of other channels including apps, Twitter, Facebook etc. The services and content that we offer through these channels may differ and we provide details of how best to manage them. Platforms such as Facebook have their own privacy controls and you should frequently review your privacy settings there.

By using this Site and by disclosing your Data to us, you consent to the collection, storage, processing, use and disclosure of your Data by us as described in this Privacy Statement.

When you visit our sites or use our services in any way we may collect and process different types of information about you. We have set out below the different types of data that we process, why and how we process it.

 

 

Advertising

Third-party vendors, including Google, display advertising on our site and services. Some of the ads you see are targeted based on interests that have been inferred from the type of content you view when visiting our site and other sites. This type of behavioural advertising is targeted towards groups of users in an aggregated manner. Such online advertising helps support the content, products and services we provide.

 

Our cookie policy provides links to manage your settings with these ad providers.

 

 

 

Ad Blocking

Since advertising plays a key role in supporting our journalism, our websites use ad block detection technology to detect the use of ad blocking software in your browser. It does not collect, store or process any personal information but asks you to turn the blocking software off.

 

 

 

User Details

Registered users of CarsIreland will provide personal details of part of the sign-up process. As detailed below we have taken steps to minimise the personal details stored within our own databases in favour of securely storing data via our trusted partners as appropriate.

 

What we process:

If you register for an account we process your name, email address, and password. We will only store your email address and a userID allowing us to identify you in AWS Cognito where your name and password details will be stored. In the case of private sellers we will use your email to communicate with you where we notice issues or areas of incompleteness associated with ads we see you are trying to create. These emails will provide helpful info and contact details should you need to engage with our Customer support team for extra assistance in placing your ad.

 

Why we process this data:

The legal basis for processing this data is legitimate interest. The data is processed to enable cross device management of ads by the user. (Initially this will only refer to the desktop and mobile web versions of the CarsIreland site – mobile app capability will be added a later stage)

 

Email comms will be used to encourage the publishing of complete ads to aid you in the sale of your vehicle via the Cars Ireland site inclusive of reminders where your ad is left in a draft status for example.

 

 

Who has access:

This data will only be processed by both CarsIreland.ie employees and systems associated with AWS Cognito.

 

 

 

Deletion:

If you wish to delete your account with us CarsIreland.ie, please email [email protected] and request that your account be removed from our system, by filling in a form on our Secure Privacy Portal or by writing a letter to Auto Records Ltd, Independent House, 27-32 Talbot Street, Dublin 1, D01 X2E1.

 

 

Image Upload

 

What we process

On upload of shared images some meta data around location and device usage will be stored in anonymised fashion to allow us assess site performance and image processing.

 

 

Car Enquiries

 

What we process:

If you fill in the enquiry form, we process your name, email, contact number and any question you have. The data is stored in our database and also emailed to the seller. At that point the seller can communicate directly with you.

 

Why we process this data:

The legal basis for processing this data is legitimate interest. The data is processed to start a conversation between the buyer and the seller.

 

Who has access:

This data will only be processed by both CarsIreland.ie employees and systems and by the given seller of the car.

 

Deletion:

If you wish to delete any enquires that you have made on CarsIreland.ie, please email [email protected] and request that you wish to have your entries deleted. If you wish to delete any enquiry data in the possession of a seller, you must contact them directly.

 

 

 

 

 

Finance Enquiries

 

What we process:

It is possible to apply for Car Finance for certain cars on CarsIreland.ie. The form is clearly marked. If you choose to apply for Finance, we process your name, email, contact number and any questions you have. The data is not stored in our database. It is sent directly to the Finance company and then to the seller.

 

Why we process this data:

The legal basis for processing this data is legitimate interest. The data is processed to start a conversation between the buyer and the seller, and also to start the process for getting Finance for the car.

 

Who has access:

This data will only be processed by CarsIreland.ie systems, the given seller of the car and by the Finance company’s systems, their employees and subcontractors

 

Deletion:

CarsIreland do not store any information on your Finance enquiry. If you wish to delete any enquiry data in the possession of a seller or a Finance provider, you must contact them directly.

 

 

 

Telephone Records

 

What we process:

Certain telephone numbers displayed on the site have simple record i.e. we facilitate a call being made to number on site. This is done so CarsIreland can measure performance of the site. The telephony system is managed by a subcontractor who process the caller ID, the dialled number, timestamp and the duration of the call.

 

Why we process this data:

The legal basis for processing this data is legitimate interest. We process this data so we can measure the performance of advertising.

 

Who has access:

This data will only be processed by both CarsIreland.ie employees and systems. The data is also processed by the telephony subcontractor.

 

Deletion:

If you wish to delete any enquires that you have made on CarsIreland.ie, please email [email protected]  and request that you wish to have your entries deleted.

 

 

 

 

Quizzes, Surveys and Polls

When you enter a quiz or answer a poll or survey on CarsIreland we collect data about you and your response.

 

What we process:

• Identity data- online identifier such as IP address
• Quiz, Poll & Survey Data- data you provide in your response to the poll or survey

 

Why we process this data:

 

The legal basis for processing this data is your consent for us to process your response to the poll or survey that you have entered.

 

This data is required to enable CarsIreland to display the results of the poll or survey. No poll data is ever associated with your email or other personal identifier.

 

We do record whether you have interacted with the poll or survey to ensure that duplicate entries are not counted but this is linked to your browser or device and never contains information on your poll response.

 

Who has access:

 

This data will only be processed by both CarsIreland.ie employees and systems, sub contracted service providers for the sole purpose of managing the quiz, survey or poll.

 

The only exception to this is where a 3rd party is running or sponsoring the quiz, survey or poll. This will be made clear to you, along with what happens to your data before submitting your entry to ensure that you have full control of who sees your data.

 

Delete my quiz, survey or poll entries: 

If you wish to delete any quiz, survey or poll entries that you have made on CarsIreland.ie, please email [email protected]  and request that you wish to have your entries deleted.

 

 

Site Function

We use analytics providers in order for us to understand our audience, the content that appeals to them and how well our site is working. We also provide tools from the major social networks (Twitter, Facebook etc.) to allow you to share content from our site.

 

Analytics

Analytics tools allow us to understand how our audience interacts with our site and our content and enables us to provide a better service to our site visitors. We do not collect or process any personal information in our analytics platform.

 

What we process: 

• Your IP address: in order to track your activity on our site we process your IP address
• Anonymous data about your device:  your operating system (e.g. iOS11), device type (e.g. tablet)
• Anonymous aggregated demographics:  for example your current city and other anonymous data.
• Anonymous data about your browsing: - stories you read, types of content consumed and browsing patterns.
• Why we process this data: The legal basis for processing this data is the legitimate interests of INM to manage and optimise the running of our site and its content.

 

This data helps us optimise the way the site is structured and how content is arranged on the site. It also allows us to show interested parties how many people access the different parts of our site and on average how often they visit. This allows understanding of how many people look at our content at different times of the day etc. These statistics are always calculated on an aggregated basis – never individually. We use the data for future marketing and personalised advertisement:

(https://support.google.com/analytics/answer/2700409?hl=en-GB&utm_id=ad).

 

Who has access: Anonymised versions of the data are hosted on Google Analytics. At no point do we have access to personally identifiable information through Google Analytics. Anonymous aggregated reports about the general behaviour of our audience may be made available to the public or others.

 

Stop being tracked:  These analytics tools run on most sites across the web. If you wish to opt out of analytics tracking you must do so on these 3rd party sites or by changing your browser settings. Click on a link below to see the privacy policy and manage your consent across the web for each cookie type:

Google Analytics

 

Further information can be found in our cookie policy .

 

 

Social Sharing 

 

Our website and mobile applications use interfaces with social media sites such as Facebook, LinkedIn, Twitter and others.

 

If you choose to like or share information from our sites through these services, you should review the privacy statement of that service. If you are a member of a social media site and logged in, the interfaces configured on our Services allow the social media site to connect your site visit and browsing behaviour to the personal data held on your social media site. CarsIreland.ie can use this information on an aggregate basis to place ads that are based on your interests on these social media sites. These practices are governed by the privacy statements of these social networking sites and you are advised to review these separately.

Where links are provided on the site to other websites, CarsIreland bears no responsibility for such sites. These sites are not under our control and we are not responsible in any way for any of their contents. 

Where links are provided to websites that process your data. CarsIreland will not be privy to any processing that occurs and accepts no responsibility in relation to the processing of your data by these third parties. 

 

 

Mobile Apps

The following sections refer exclusively to content on Mobile Apps.

 

Mobile App Analytics

We do not collect process or store any personal information on our apps. However, we do collect anonymous browsing and analytics data.

 

What we process:

• IP addresses- Adobe Analytics uses your IP address to recognise you as an individual.
• Anonymous data about your device – your operating system (e.g. iOS11), device type (e.g. tablet), city and other anonymous demographic data.
• Anonymous data about your browsing- stories you read, types of content consumed and browsing patterns.

 

Why we process this data:

 

The legal basis for processing this data is the legitimate interests of CarsIreland.ie namely to manage and optimise the running of our site and apps and their content.

 

IP addresses are used solely to distinguish between individuals visiting our site. IP addresses are never used to personally identify an individual and never combined with other registration data.

 

This analytics data helps us optimise the way our content is structured and how content is arranged on our sites and apps to provide a better service to you.

 

 

Who has access:

Anonymised versions of your browsing data are hosted on Google Analytics. Only CarsIreland.ie employees or our analytics partners have access to this information.

 

 

Affiliate Links

There have a number of affiliate or partner links contained within the site as outlined below. While many of these links are part of the wider Mediahuis group entities others are present due to an affiliate partnership these include but are not limited to:

• Mediahuis entities: Cartell, Irish Independent, Mediahuis Ireland
• Affiliates: NMR, Liberty Insurance, CarTow

 

 

 

 

Your Rights

 

Your Rights Under Data Protection Law

You have several rights under data-protection law in relation to the personal information that CarsIreland.ie holds about you. If you choose to exercise any of these rights, we will ask you to verify your identity. We will consider your request and provide a response within one month. These rights are described in detail on the Data Commissioner’s Website and summarised below:

 

• Right of Access: You are entitled to have access to your personal data which we hold (this is more commonly known as submitting a “data subject access request”). Typically, there is no fee for this, however, we have the right to apply a reasonable fee in exceptional circumstances.
• Right of Portability: You can request a copy of the personal information we hold about you in a structured, commonly used and machine-readable format and if technically feasible, have your personal information transmitted to another data controller in a machine-readable format.
• Right to rectify: If it is found that personal data is inaccurate, you are entitled to have the inaccurate data removed, corrected or completed, as appropriate.
• Right to withdraw consent: You have the right to withdraw your consent to any future processing for which you have previously given that consent.
• Right to Erasure: Subject to certain conditions, you are entitled, on certain grounds, to have your personal data erased (also known as the “right to be forgotten”).
• Right to Restriction: Restrict processing of your personal information in certain circumstances
• Right to object to processing: You are entitled to object to our use of your personal information for our legitimate interests, for profiling and for direct marketing purposes.
• Rights relating to automated decision making including profiling: You are entitled to not be subject to a decision which is based solely on automated processing where that decision produces a legal effect on you or otherwise significantly affects you. We do not make automated decisions of this nature
• Right to complain: You are entitled to lodge a complaint with the Data Protection Commissioner if you have concerns about how we process your personal data.

 

You can complain directly to the Office of the Data Protection Commissioner at Canal House, Station Road, Portarlington, Co. Laois by telephone at 1890 25 2231 and/or by email to [email protected].

 

You can also make a complaint directly to the relevant data protection authorities in the country where you are ordinarily resident. For example, in the UK you can also complain directly to the ICO at https://ico.org.uk/make-a-complaint/ or or call their helpline on 0303 123 1113. 

 

 

 

How To Exercise Your Rights

Requests for information or to exercise these rights should be made in writing to the INM Data Protection Office:

•             by email to [email protected] 

•             by post to the Mediashuis Ireland Data Protection Office, INM, 27-32 Talbot St, Dublin 1, Ireland.

If possible, you should specify the type of information you would like to see to ensure that we meet your expectations. We must be able to verify your identity in order to ensure the safety of your data. Your request may not affect the rights and freedoms of others, e.g. privacy and confidentiality rights of other individuals and/or businesses.

 

 

Limitations To These Rights   

These rights are in some circumstances limited by data-protection legislation. You may have various rights under Data Protection Legislation. However, in certain circumstances, these rights may be restricted (Article 23 of the General Data Protection Regulation, which is transposed into Irish law by section 54 of the Data Protection Bill 2018, sets out the circumstances in which your rights may be restricted). 

 

In particular, your rights may be restricted where this is necessary:

• for the prevention, detection, investigation and prosecution of criminal offences, and/or
• in compliance with a legal obligation such as a court order and/or
• in contemplation of or for the establishment, exercise or defence of a legal claim or legal proceedings (whether before a court, tribunal, statutory body or an administrative or out-of-court procedure).

 

Your Data

The following sections describe how we manage, secure and control access to your data and under what circumstances we disclose data to others.

 

Retention Of Your Data

To make sure we meet our legal data protection and privacy obligations, we will retain your information for at least as long as your account is active, as needed to provide you services or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

If you ask for your account to be closed, we will do this as soon as is reasonably possible subject to any applicable terms and conditions relating to the account. Personal information from closed accounts is retained in order to comply with any/all legal or contractual obligations.

 

As a matter of course, we will delete personal data associated with accounts that have been inactive for at least 6 years.

We will have written contracts with them which provide assurances regarding the protections that they will give to your Data and their compliance with our data security standards and international transfer restrictions.

 

How Is Your Data Secured

CarsIreland.ie operate and use appropriate technical and physical security measures to protect your personal data.

 

We have in particular taken appropriate security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. In addition, our service providers are also selected carefully and required to use appropriate protective measures.

 

 

Where Do We Store Your Data?

In most cases, CarsIreland.ie stores your data securely within the European Economic Area (EEA) using GDPR compliant service providers.

 

In some cases, CarsIreland.ie may have to transfer or store your data to countries outside the EEA, for example, when one of our service providers use employees or equipment based outside the EEA.

 

For transfers of your personal data to third parties outside of the EEA, we take additional steps in line with Data Protection Legislation. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU commission’s model clauses.

 

 

Disclosure Of Your Data

Your Data is private and confidential. Your Personal data may only be shared within CarsIreland.ie, for any of the purposes set out in this Privacy Statement.

From time to time, we may access and/or disclose your Data if required to do so by law or in good faith and belief that such action is necessary to:

• conform with the law or comply with legal process served on us;
• protect and defend our rights or property including, without limitation the security and integrity of our network and systems; or
• act under exigent circumstances to protect the personal safety of users of our services or members of the public

 

Acceptance of this Privacy Statement

By using this Site and by disclosing your Data to us, you consent to the collection, storage, processing, use and disclosure of your Data by us as described in this Privacy Statement. If you do not agree with or are not comfortable with any aspect of this Privacy Statement, your only remedy is to discontinue using our Site. We reserve the right to modify this Privacy Statement at any time. Your continued use of any part of our Site following notification or posting of such changes will constitute your acceptance of those changes.

 

Contact the Data Protection Office

Mediahuis Ireland has a data protection function including a data protection officer. If you wish to invoke you rights or have any questions please contact the Mediahuis Ireland Data Protection Office.

Mediahuis Ireland Data Protection Office

Independent House

27-32 Talbot Street

Dublin 1

Email: [email protected]