PRIVACY POLICY

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, accesses cards/co-tags, fobs, audio-visual or audio recordings of a person, details about an individual's location or any other detail(s) specific to that individual such in certain cases special category data such as (Biometric).

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, payroll and marketing or recruitment 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 the JLRI websites and for the provision of our products and services.

We may collect, use, store and transfer different 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 and postal address.
• 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 and our 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 notice.

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.

We use different methods to collect data from and about you including through:

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 vehicle service)
• rent or subscribe to a vehicle
• subscribe to our service or publications;
• request marketing to be sent to you;
• provide feedback; or completing a survey with a retailer;
• apply for a job with the Business;
• enter competitions;
• attend a brand events;
• visit our site and CCTV imagery is obtained;
• manage your personal data preference

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(s) 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 or warranty work or service or an audit of the Retailer
• the Manufacturer of your vehicle
• 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

JLRI is not responsible for the privacy practices of any external websites, manufacturers, retailers, 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 users should review them for further information.

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 JLRI:

1. 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 Hotjar, a technology service provider 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. Other cookies through the use of Google Analytics enable us to identify traffic to our website including pages visited, visitor numbers and traffic paths taken.
   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 COOKIES | Land Rover Ireland
2. If you subscribe to receive digital marketing communications, JLRI may 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 or communication 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.
3. JLRI uses click to open rate (CTOR) and Click Through Rate (CTOR) technology. This will record which users opened a communication and clicked on embedded links in communications sent by JLRI. We engage this activity to measure a campaign’s effectiveness and discern a subscriber’s interests. Your consent will be requested for this activity, and you can withdraw your consent at any stage by unsubscribing within a relevant communication or by contacting dco@ohm.ie
4. We may collect your personal data from Contact Forms, (such as booking a test drive, booking a service or vehicle enquiry) this enables us to deal with your request in a timely manner.
5. 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.
6. Social Media Pages: Content such as messages and photographs, that are posted on social media pages on which JLRI has 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 JLRI 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.
7. We may use advertising networks to help present advertisements or other content on our website and other websites that display JLRI 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.

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:

  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 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.

  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.

When you purchase a vehicle through one of our retailers, we will contact you regarding the warranty position on your vehicle. We do this in our legitimate interest in order to keep you informed on the warranty of the vehicle and any changes to same.

If you are a business customer or prospective business customer of JLRI, 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 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 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 may also contact you in the event of updates about our business such as opening hours, change in address, updates about our site 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 websites to other OHM organizations and our Retailer Network;

• Land Rover Retailer Network: FIND A RETAILER | Land Rover Ireland

We do this in our legitimate interest to keep our customers supported by directing their requests or interests to their preferential vehicle retailer and/or service and parts centre.

JLRI uses vehicle tracking in all our fleet vehicles and courtesy cars. 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 to object any of the above processing scenarios by contacting us on dco@ohm.ie

  d) 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.

Your consent will also be requested for the use of click to open rate (CTOR) and Click Through Rate (CTOR) technology that is used in our digital communications

Where you are a consumer prosect, we will request your consent for all digital direct 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.

e) 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 safety issue with your vehicle.

Below is a summary of these purposes and the lawful justifications that support them:

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 warranty or where requested, 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.

JLRI will not provide any personal information to third parties or partners for direct marketing purposes unless the users have consented to JLRI giving their Personal Data to third parties or partners for that purpose. If a user opts-out from receiving communications from third parties or partners, JLRI will no longer share that user’s contact details with our partners or third parties. However, users will still need to directly opt-out from communications from the partners to whom we have already given their 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.

Retailers Within Our Network: We may also share your personal information with members of our retailer network 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 retailer with diagnostic issues. For further information on our dealer network and how they may process your data please review the following link; FIND A RETAILER | Land Rover Ireland

Insurance Companies: We may pass your information to insurance companies and/or any motor assessor appointed by you or an insurance company, where any portion of the cost of the repairs or work being carried out on your vehicle is being covered under an insurance policy. We may disclose personal data to our insurance providers in connection, with legal claims and prospective legal claims or proceedings.

Jaguar Land Rover Limited and entities within Jaguar Land Rover: There are circumstances where we may share your information with the manufacturer and any independent auditor appointed by the manufacturer, to fulfil orders and transactions, to provide you with a service or information which you have requested. For further information on how Jaguar Land Rover Limited process your data please review the following links.

Please also note that Jaguar Land Rover is required by EU law to collect and disclose certain data relating to vehicles registered on or after 1 January 2021. The vehicle VIN along with the fuel and energy consumption data is required to be shared with the European Commission as part of EU Regulation 2021/392. Data being shared is related to fuel consumed, for PHEVs electric energy data and distance travelled. For more information please refer to the regulation published on the EU web site . You can opt-out of your specific vehicle data being shared with the Commission. Please contact us if you wish to opt out by providing the VIN of your vehicle and registration number. Finance companies, leasing companies/ brokers: 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.

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.

As a vehicle distributor 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.

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.

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.

We may analyse your personal information by automated means for the purposes of market research, analysing our customer database and for our marketing activities.

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 JLRI 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 JLRI 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

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.

An 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 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. JLRI has in place a Breach Notification Policy.

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 JLRI.

(a) Any individual has a right to make an access request, 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 http://www.dataprotection.ie/

This policy [“version 6”] was updated and deemed effective on the 30th of September 2023. We will update this data protection statement from time to time. Any updates will be made available on our website at PRIVACY POLICY Landrover and, we would ask that you check regularly.