Autotowing Ltd., / Bob Sweeney Privacy Notice


Privacy Notice

Autotowing Ltd., / Bob Sweeney are committed to safeguarding the privacy of your personal data. Please read the following privacy notice to understand how we collect and use your personal data, for example when you contact us, visit our website, or seek to avail of our services. The Data Controller is Autotowing Ltd., / Bob Sweeney, we can be contacted through bob@autotowing.ie or through our registered office, which is located at Autotowing Ltd., / Bob Sweeney, Coolready, Castlecolnnell, Co. Limerick, Ireland V94 A3FI. Please note that whenever you provide us with your personal data, you are consenting to its collection, recording, organising, structuring, storing, adaptation, alteration, retrieving, consulting, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. What Personal data do we collect?


Autotowing Ltd., / Bob Sweeney may collect personal data such as your name, and e-mail address through our website interface on www.autotowing.ie and www.bobsweeney.ie or through any e-mail communication, or any other contact that we may have or received from you.


How we use your personal data

If you provide personal data to us, we will collect that information and use it for the purposes outlined hereunder and in accordance with the terms and references within this privacy notice.


Personal Data Processed, Purpose for Processing and Personal Data

# Personal Data Purpose for Processing
1 Your name Required for the purpose of contact, record of financial transactions as applicable, identification of persons removing items from vehicle or collection of vehicles as well as proof of ownership where applicable as well as identification of liaising contact
2 E-mail address Required for the purpose of forwarding communication, transactions, clarification or invoicing.
3 Phone Number Required for purpose of general communication in relation to services provided.
4 Address Required for the purpose ofcallout, delivery or and communication / invoicing.
5 Vehicle Registration Number Required for the purpose of Identification of vehicle and record of financial transactions as applicable
6 Proof of Identity Required for the purpose of identifying persons removing items from vehicle or collection of vehicles as well as proof of ownership where applicable.
7 Photo Identification Required for the purpose of identifying persons removing items from vehicle or collection of vehicles as well as proof of ownership where applicable.
8 Insurance Policy Number Required for the purpose of identifying the vehicle insurance details.
9 Signature Required for the purpose of identification and verification of individuals.
10 Eircode Required for the purpose of callout, delivery or and communication / invoicing.
11 Recording All telephone to / from Autotowing Ltd., / Bob Sweeney landlines are recorded for training, verification, contractual purposes.

Obligation to provide personal data

You are not obliged to provide your personal data to Autotowing Ltd., / Bob Sweeney, you may provide your name or companies details as applicable and e-mail address as a point of contact. The purpose of collecting your personal data is to create a personal point of contact with you, your company or enterprise and for the delivery of our products and services etc., to the person or point of contact availing of our products or services. Failure to provide contact details or e-mail address will create difficulties in delivering products or services. The provision of personal data and e-mail address is not required for any statutory or contractual requirements.


Explanation as to how the personal data could not possibly be processed by any other means.

Failure to provide contact details or e-mail address will create difficulties in delivering our products or services. We will have no other means of processing your request and ensuring that our product or service are delivered to the person who has requested it.


Sharing your personal data

As a global company, we have international users all over the world. When you provide Autotowing Ltd., / Bob Sweeney with your personal data, that data will be used, processed or stored in our head office in Ireland. Autotowing Ltd., / Bob Sweeney will not share or pass on your personal data to any resellers, third parties, third countries or international organisations unless you specifically request this.


In the event that we receive requests from government departments, agencies or other official bodies, we will only disclose your information, if and to the extent that we believe we are legally required to do so (for example, but without limitation, upon receipt of a court order, warrant, subpoena or equivalent). Except as set out above, we will not disclose your personal data save where we need to do so in order to enforce our rights.


If we are compelled to share your personal data, we take all reasonable steps to ensure that it is treated securely and in accordance with this privacy notice.


Recipients or categories of Personal Data

Autotowing Ltd., / Bob Sweeneydoes not share any category of personal data with any third-party recipients.


Transfer to third countryAutotowing Ltd., / Bob Sweeney does not transfer any personal data to any third country or international organisation.


Period of retention of personal data

Personal data provided to Autotowing Ltd., / Bob Sweeney will be retained for a period of time depending on the purpose of providing such details

1. In the event that personal data is provided in relation to the provision of our products and services we are required to retain the personal data for a period of 7 years in accordance with revenue regulations.

2. In the event that personal data is provided for the purpose of identifying persons removing items from vehicle or collection of vehicles as well as proof of ownership whereapplicable the period of retention will be three years to the statute of limitations.


Product and service related data

If you purchase or use our services, we may collect the following types of information:

(i) product type, product version, product features and operating systems being used;

(ii) processing times;

(iii) customer identification and company name,


We may use such information for purposes which include but are not limited to:

In order to continuously improve products and services levels in the Autotowing Ltd., / Bob Sweeney, products and services, it may be necessary for us to collect and process certain information relating to you and to users connected to your account. You acknowledge and agree that the information we collect may include confidential and/or personal data, including without limitation

(i) Contact names and email addresses;

We are committed to safeguarding the privacy of your personal data and will never share this outside Autotowing Ltd., / Bob Sweeney business and services.


Notice of Data Subject Rights

Right of Access

The data subject has the rights to obtain from Autotowing Ltd., / Bob Sweeney(Controller) confirmation as to whether or not personal data concerning him or her is being processed and where such personal data is being processed, he / she will have the right to access their personal data and ascertain the purpose of any processing, the categories of personal data concerned, the recipients or categories of recipient to whom the personal data has been or will be disclosed, in particular any recipients in third countries or international organisations, the period for which the personal data will be retained or stored or if not possible the criterial used to determine that period, the right to request from the controller rectification or erasure of their personal data or restriction of processing of personal data concerning the data subject or their right to object to such processing, the right to lodge a complaint to the supervisory authority (Data Protection Commissioner), in the event that the personal data was not collected from the data subject any available information as to their source and the existence of any automated decision-making profiling and at least in such events meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject. In the event of personal data being transferred to a third country or to an international organisation the data subject has the right to be informed of the appropriate safeguards relating to the transfer. The data subject also has the right to obtain a copy of the personal data undergoing processing from the controller.


Right to Rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.


Right to erasure (‘right to be forgotten’)

The data subject has the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall be obliged to erase their personal data without undue delay where one of the following grounds applies:


(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) the data subject withdraws consent to the processing of his or her personal data for one or more specific purposes, or where the European Union or Member State law prohibit the consenting by data subjects to the processing of special categories of personal data and where there is no other legal ground for the processing;

(c) the data subject objects to the processing on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her based on the grounds that processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child (except where processing is carried out by public authorities in the performance of their tasks) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing of their personal data for direct marketing purposes including profiling for direct marketing purposes .

(d) the personal data has been unlawfully processed;

(e) the personal data has to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

(f) the personal data has been collected in relation to the offer of information society services from a child under the age of 16 years of age and the consent for the processing of that child’s personal information has not been given or authorised by the holder of parental responsibility over the child .

The above requirements in relation to the right to erasure shall not apply to the extent that processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(c) when processing personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation is for reasons of public interest in the area of public health or where such data is processed by or under the responsibility of a professional subject to the obligation of professional secrecy under Union or Member State law or rules established by national competent bodies or by another person also subject to an obligation of secrecy under Union or Member State law or rules established by national competent bodies .

(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subjected to the appropriate safeguards being put in place in accordance with this regulation, protecting the rights and freedoms of the data subject by the putting in place technical and organisational measures to ensure respect for the principle of data minimisation, which may include pseudonymisation; provided such purposes can be fulfilled in that manner or where further purposes for processing of such data does not permit or no longer permits the identification of data subjects, then those purposes shall be fulfilled in that manner so as to render impossible or seriously impair the achievements of the objectives of that processing or

(e) for the establishment, exercise or defence of legal claims.


Right to restriction of processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;


(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

(d) the data subject has objected to processing on grounds relating to his or her particular situation, to processing of personal data concerning him or her which is based on the fact that processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or where processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child, with the exception of processing carried out by public authorities in the performance of their tasks; pending the verification whether the legitimate grounds of the controller override those of the data subject .


Where processing has been restricted under the above conditions, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. A data subject who has obtained restriction of processing pursuant to the above-mentioned conditions shall be informed by the controller before the restriction of processing is lifted. Right to notification obligation regarding rectification or erasure of personal data or restriction of processing.The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with their right to rectification, erasure, and restriction of processing to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.


Right to data portability

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:


(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes or the data subject has given explicit consent to the processing of personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition the processing of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation may not be lifted by the data subject; if the data subject has given explicit consent to the processing of those personal data for one or more specified purposes, except where Union or Member State law provide that the prohibition referred to above may not be lifted by the data subject or on a contract where the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract ; and

(b) the processing is carried out by automated means.

2. In exercising his or her right to data portability, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3. The exercise of the right to data portability shall be without prejudice to the data subject’s right to erasure Article 17. which shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4. provided that the right of data portability of a data subject shall not adversely affect the rights and freedoms of others.


Right to object

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller ; or where processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child or (processing carried out by public authorities in the performance of their tasks) including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.


2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.


3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.


4. This right to object should be brought to the notice of the data subject at the very first communication and shall be presented clearly and separately from any other information.


5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.


6. Where personal data are processed for scientific or historical research purposes or statistical purposes Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.


Right to withdraw consent

Where the processing is based on the data subject having given consent to the processing of his or her personal data for one or more specific purposes except where Union or Member State law provide that the prohibition the right to withdraw his or her consent may not be lifted by the data subject; or where consent to processing of his or her personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation the data subject has the right to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;


Time frame to respond to requests If you exercise any of your rights under the General Data Protection Regulations such as access to and rectification or erasure of personal data or the exercise of the right to object, Autotowing Ltd., / Bob Sweeney, (the Controller) is obliged to respond to requests without undue delay and at the latest within one month and if Autotowing Ltd., / Bob Sweeney, failed to comply with your requests Autotowing Ltd., / Bob Sweeney, must give you reasons why.


Mechanisms for their right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability.


How a Data Subjects may verify the accuracy or request to amend their personal data? A data subject may verify that their personal data submitted to Autotowing Ltd., / Bob Sweeney, is accurate by double checking their data entry before submitting the details to Autotowing Ltd., / Bob Sweeney In the event of any inaccuracy being discovered in any e-mails or other communications the data subject may send an e-mail to Autotowing Ltd., / Bob Sweeney, at bob@autotowing.ie informing us of the inaccuracy and the relevant corrections required. Protectorate Solutions will rectify any inaccurate data highlighted.


How a Data Subjects may request to have their data deleted? Similarly, if a data subject wishes to request their personal data deleted, the data subject may e-mail Autotowing Ltd., / Bob Sweeney, at bob@autotowing.ie and request their right to have their personal data deleted.


The controller is obliged to be responded to a data subject request without undue delay and in any event within one month and where the controller does not comply with the request the controller is required to give reasons for such non-compliance.


How a Data Subject may request the portability of their personal data? If a data subject wishes to request the portability of their personal data the data subject may e-mail Autotowing Ltd., / Bob Sweeney, at bob@autotowing.ie and request the portability of their personal data.


The controller is obliged to be responded to a data subject request without undue delay and in any event within one month and where the controller does not comply with the request the controller is required to give reasons for such non-compliance.


How a Data Subject may request access to their personal data? . If a data subject wishes to access their personal data the data subject may e-mail Autotowing Ltd., / Bob Sweeney, at bob@autotowing.ie and request access to their personal data.


The controller is obliged to be responded to a data subject request without undue delay and in any event within one month and where the controller does not comply with the request the controller is required to give reasons for such non-compliance.


How a Data Subject may request to restrict the processing of a data subject’s personal data?If a data subject wishes to restrict the processing of their personal data the data subject may e-mail Autotowing Ltd., / Bob Sweeney, at bob@autotowing.ie and request to have the processing of their personal data restricted.


The controller is obliged to be responded to a data subject request without undue delay and in any event within one month and where the controller does not comply with the request the controller is required to give reasons for such non-compliance.


How a Data Subject may request to withdraw their consent for the processing of their personal data. If a data subject wishes to withdraw their consent to the processing of their personal data the data subject may e-mail Autotowing Ltd., / Bob Sweeney, at bob@autotowing.ie and request to have their consent withdrawn for the processing of their personal data. If the data subject consented to more than one form of processing, the data subject should clarify it the withdrawal is in respect of all processing of their personal data or in respect of one or more purposes of processing their personal data.


The controller is obliged to be responded to a data subject request without undue delay and in any event within one month and where the controller does not comply with the request the controller is required to give reasons for such non-compliance.


Right of Data Subject to lodge a complaint with the Supervisory Authority

The data subject has the right to lodge a complaint with the supervisory if he or she feel that any of their rights under the General Data Protection Regulations have been infringed and the data subject also has a right to seek judicial remedy to any such infringement.


Security of Personal Data

We endeavour to hold all personal data securely in accordance with our internal security procedures and applicable law. Autotowing Ltd., / Bob Sweeneywill encrypt all personal data received to ensure the protection of your personal data and to prevent any unauthorised access to your personal data or the unauthorised use of your personal data.


All personal data stored on any computer used by Autotowing Ltd., / Bob Sweeney will be stored in our ProtectorApp encryption program, thus ensuring the encryption of such data and requiring a designated password to access it.


Unfortunately, no data transmission over the Internet or any other network can be guaranteed as 100% secure. As a result, while we strive to protect your personal data, we cannot ensure and do not warrant the security of any information you transmit to us, and this information is transmitted at your own risk.


Risks & Safeguard

The greatest risk to personal data is that of it unlawful access. Autotowing Ltd., / Bob Sweeneyhas addressed and mitigated such potential risk by encryption of all personal data it processes through its ProtectorApp Encryption Programs as a safeguard.


Rules in relation to the processing of personal data

The rules of processing of personal data that is processed by Autotowing Ltd., / Bob Sweeney is that all personal data will be stored in encrypted format when it is not used.


Contact Details of Autotowing Ltd., / Bob Sweeney

Autotowing Ltd., / Bob Sweeney is a company registered in Ireland under company number 8284229Q, whose registered office is at Coolready, Castleconnell, Co. Limerick and whose VAT registration number is IE 8284229Q. Website address is www.autotowing.ie


If you want to request any information about your personal data or believe that we are holding incorrect personal data on you, please contact bob@autotowing.ie It is also possible to obtain a copy of the information that we hold on you if you so wish.


Provision of the contents of Privacy Notice Orally

If a data subject wishes to receive the information contained in this privacy notice orally, this will be provided by arranging the sending of an e-mail to bob@autotowing.ie requesting same and providing a contact phone number and a suitable time for the delivery of the information contained within this document to the intended recipient. Arrangements will be made for a member of Autotowing Ltd., / Bob Sweeney to phone the intended recipient and provide all the contents of Autotowing Ltd., / Bob SweeneyPrivacy notice to him or her and ascertain if the recipient understood the information that has been provided orally to him or her.


Browsing Autotowing Ltd., / Bob Sweeney Ltd., Website

Every time you connect to our website, Google Analytics stores a log of your visit which informs us what has been looked at, whether the page request was successful or not. The purpose of collecting and recording this data is to use it for statistical purposes as well as to help customise the user experience as you browse the website and interact with Autotowing Ltd., / Bob Sweeney Ltd. This helps us to understand which areas of the website are of particular interest, which pages are not being requested, and how many people are visiting the website in total. It also helps us to determine which product and services may be of specific interest to visitors. No personal data is recorded for Autotowing Ltd., / Bob Sweeney Ltd. during this processing of information.


Cookies

Autotowing Ltd., / Bob Sweeney use Cookies for the purpose of improving your online experience through analytics, specifically we use Cookies on the site for the following purpose:


We use Cookies to analyze user activity in order to improve the Site. We look at aggregate patterns, like the average number of page clicks that users perform so we can see what information is most sought-after, for example - We also use such analysis to gain insights about how to improve the functionality and user experience of the Site.


Managing cookies in your browser

Use the tools and options in your web browser if you do not wish to receive a cookie. You can easily delete and manage any cookies that have been installed in the cookie folder of your browser by following the instructions provided by your particular browsermanufacturer.


Consult the documentation that your particular browser manufacturer provides. You may also consult your mobile device documentation for information on how to disable cookies on your mobile device.


To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on, to enable you to opt-out of Google’s programs.


*(A cookie is a piece of text that gets entered into the memory of your browser by a website, allowing the website to store information on your machine and later retrieve it. Cookies can also enable the tracking and targeting of the interests of users to enhance the onsite experience).


Automated Decision Making (Profiling)

Autotowing Ltd., / Bob Sweeney does not use any automated decision-making tools or processes in its processing of any personal data.


If you supply personal data, you have the right not t be subjected to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affecting you, however, this shall not apply if a decision is necessary for entering into or performance of a contract between you and the data controller, or is authorised by European Union or Member State law or where you have given explicit consent for such processing.


If your personal data was subjected to automated decision-making, including profiling you are entitled to be notified of the existence of such processing and information about he logic involved as well as any significance and the envisaged consequences of such processing for you.


Account management

If you obtain products or services from us, we may use your contact details

i. providing training, customer support and account management, ii. order processing and billing, iii. verifying the usage of the products and services in accordance with the terms and conditions of your agreement with us, iv. maintaining our company accounts and records.

Market research and surveys

If you participate in surveys, we may use your personal data for our internal business and training purposes in order to improve our understanding of our users’ demographics, interests and behaviour, and to measure and increase customer satisfaction.


Marketing and promotions

We may contact you from time to time in order to provide you with information about products and services that may be of interest to you. All marketing emails that we send to you will follow the email guidelines described below. You have the right to ask us not to process your personal data for marketing purposes, but if you do so, we may need to share your contact information with third parties for the limited purpose of ensuring that you do not receive marketing communications from them on our behalf.


Email communications

We adhere to the following guidelines in relation to our email communications:

If you receive an email which claims to come from us but does not, use these domains, or if you are suspicious that an email may not be approved by us, then please send a copy of the email to bob@autotowing.iebob@autotowing.ie so we can investigate.


Links

This privacy notice applies to personal data collected by Autotowing Ltd., / Bob Sweeney. If an email or website contains links to a third-party site, please be aware that we are not responsible for the content or privacy practices of such site. We encourage our users to be aware when they leave our Site, and to read the privacy notice of other sites that collect personal data.


Notification of changes

This privacy notice was last updated on 15th May 2018. We reserve the right to amend or vary this notice at any time and the revised notice will apply from the date posted on the Site. Autotowing Ltd., / Bob Sweeney Ltd. will provide a link to our privacy notice on all electronic correspondences in order to keep you abreast of the contents of this notice.


Reviews of Protectorate Solutions compliance with the GDPR

Reviews of Autotowing Ltd., / Bob SweeneyLtd. compliance with the General Data Protection Regulations will be conducted every year period in Juneof each commencing in June 2019 following the introduction of the GDPR on the 25/5/2018.