VAN MONSTER PRIVACY POLICY

Van Monster take data privacy seriously and will only use your information in accordance with the policy below. This means we will adhere to the relevant legislations whilst doing our best to provide you with the best level of service and security.

This policy sets out how and why we store, process and delete your data and gives you information on how to contact us to view, correct or delete that data.

Last revised: May 2018

INTRODUCTION

In this Privacy Policy “we, “us” or “our” means the Van Monster entity that collects or processes your Personal Information (as defined below) and interacts with you (for example, the entity from whom you hire or purchase a vehicle). The relevant Van Monster entities are:

Northgate Vehicle Hire (Ireland) Limited, a company registered at Suite 3, One Earlsfort Centre, Lower Hatch Street, Dublin 2, Ireland, with company number 333586.

In this Privacy Policy, references to “you” or “your” means the individual whose Personal Information (as defined below) we collect, use and process, whether this information is collected on the Site (as defined below), in person, by telephone or otherwise and will apply whether you provide us with the personal data yourself or if it is provided by a third party.

In this Privacy Policy, references to the “Site” means the website at www.northgatevehiclehire.ie or https://www.vanmonster.ie, our app and related technology.

We take our obligations under privacy and data protection law very seriously. This policy sets out how we will use and process the Personal Information that you, or third parties, provide to us or we collect from you.

For the purposes of the Data Protection Acts 1988 and 2003 and from 25 May 2018, the General Data Protection Regulation (EU) 2016/679 (GDPR) and any applicable Irish data protection law (collectively, “Data Protection Law”), we are the data controller in respect of the Personal Information that we collect and process in accordance with this Privacy Policy.

If you are providing Personal Information to us relating to a third party, you confirm that you have the consent of the third party to share such Personal Information with us and that you have made the information in this Privacy Policy available to the third party.

WHAT PERSONAL INFORMATION DO WE COLLECT?

Information you provide to us

The Personal Information we collect and hold about you includes:

information you directly provide to us on registration such as, name, address, username, password, email address, telephone number (including mobile phone) and other contact details;
the information included in any documents you send to us (such as information documents), or when using our Site (including to search for hire vehicles, place orders or report problems with the Site or an order), our app or any online services to which you subscribe;
information you complete in relation to customer satisfaction surveys;
your occupation or the nature of your business (if applicable);
details about the vehicle to be hired or purchased;
information obtained by credit reference agencies;
information provided to us by third parties with whom we are working (such as business partners and brokers, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers and search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information, if different from the purposes set out in this Privacy Policy;
details about your marketing preferences and interests;
debit or credit card details or the bank account details from which direct debits under your vehicle hire will be collected;
information you provide to us through our app or other technology, including device IDs and user location; and
information which we collect about you when you visit our Site:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service.

You may also provide us with additional Personal Information if you contact us, for example, by emailing us.

Certain information, including name, address, username, password, email address and other contact details, identification documents, occupation and the nature of your business, information obtained by credit reference agencies, payment and financial information, device IDs and user location are required to provide the service. The failure to provide this information may impact on our ability to provide the service to you and for you to receive the best service from us.

Other information, including customer satisfaction surveys and marketing preferences are not required for us to provide the service to you, but do assist us in providing the best service to you and to our customers as a whole.

Information sent by our service or other equipment

Personal Information is automatically sent to us when you interact with our services or visit or use our Site on your computer or other device. This Personal Information includes your IP address, browser information, device identifiers, and the web pages that you have requested.

We collect data from our websites, apps and related technologies.

In this Privacy Policy we refer to the information set out above as “Personal Information”.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use any Personal Information provided by you or collected by us in connection with the relevant vehicle hire or sale agreement, via the Site, or otherwise as a result of our dealings with you including for the purposes of:

allowing you to register to use our Site (if applicable), fulfilling our contractual obligations to you (or enforcing our contract terms against you) and providing you with the Site and other services you require, for example, we will use the information you provide to create your account and we may also use the technical information we receive to identify and correct issues;
to customise the Site according to your interests;
to respond to any requests for advice or information and otherwise provide customer support to you;
managing our business;
assessing and evaluating the quality of the vehicle hire or other services we have supplied (including the use of mystery shoppers and satisfaction surveys), complying with legal and regulatory obligations and best practice standards (including carrying out credit reference checks and taking steps to comply with our obligations under anti-money laundering regulations), improving our services and providing us with insights into how our services are used;
for security purposes and fraud prevention purposes – we may use user information to keep our systems, us, our staff, users and members of the public safe;
fulfilling the requirements of our insurance policies (including the requirements of our insurance providers);
to send you information relevant to our Site, such as informing you about changes to this Privacy Policy or maintenance to our Site;
to send you a password reset link if you tell us that you have forgotten your password;
as part of our efforts to keep our site safe and secure;
in case we have any queries concerning any aspect of your use of our Site;
to ensure that content from our Site is presented in the most effective manner for your device;
to allow you to participate in interactive features of our Site when you choose to do so;
to administer our Site and for internal operations, including troubleshooting, data analysis, testing and research; and
to measure or understand the effectiveness of advertising we serve to you and others.

Our legal bases for using your Personal Information are:

where using such information is in our legitimate interests as a business, and our interests are not overridden by your interests, fundamental rights or freedoms;
where using such information is necessary to give effect to our contract with you;
where using such information is necessary for us to comply with a legal obligation; and/or
where we have received your consent to use such information.

We will take a copy of your driving licence if you are the person hiring a vehicle from us (either in your own right or on behalf of an organisation) when the vehicle hire commences. We will also need a copy of the driving licence of all other named drivers. We take and retain a copy of the driving licence for some of the purposes and in reliance on the legal bases set out above in accordance with applicable law.

We and other companies within our group may also use your Personal Information to contact you by email, telephone, post, SMS (in accordance with applicable law) and other electronic means (including social media), with information about services (including service amendments and improvements we have made to our services), industry news, industry relevant legislation changes, promotions and offers that may be of interest to you. We may use your Personal Information in order to establish the services, promotions and offers that are likely to be of interest to you. We will do this marketing in accordance with any preferences you have indicated to us. You can change your preferences around promotional messages at any time, but we reserve the right to contact you in connection to service related issues.

Please see the [link to rights in relation to Personal Information] section for information as to how to change your marketing preferences.

WHERE DO WE STORE AND/OR PROCESS PERSONAL INFORMATION?

We have in place appropriate technical and security measures to prevent unauthorised or unlawful access to or accidental loss of or destruction or damage to your Personal Information. We store your Personal Information on a secure server. We use firewalls on our servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Site, you are responsible for keeping this password confidential. You are responsible for protecting against unauthorised access to your password and to your computer and we ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and in accordance with the appropriate safeguards as required by relevant data protection law. To obtain further details and a copy of the appropriate safeguards please contact dataprotectionroi@northgatevehiclehire.ie.

SHARING WITH THIRD PARTIES

We will not sell, distribute or lease your Personal Information to third parties unless we have your permission or are required by law to do so. We may pass Personal Information to parties who process data for us. We have contracts with these parties and we ensure they are contractually bound to do only what we say they can do with your Personal Information. We may pass details about you to our agents and subcontractors to help us with any of our uses of your data set out in this Privacy Policy; for example, we may use third parties to assist us with providing the administration for running our Site, to analyse data and to provide us with marketing or customer service assistance.

We may also share your Personal Information with:

our affiliates, subsidiaries, and related group companies (all of whom use your Personal Information in accordance with this policy and their statutory obligations);
law enforcement agencies, regulatory bodies and other third parties (including but not limited to the Driver and Vehicle Computer Services Division of the Department of Transport, Tourism and Sport) if: we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation (including but not limited to in connection with a court order); in order to enforce our website terms of use or our terms and conditions of hiring vehicles, or any other agreement we have with you; or to protect the rights, property or safety or us, our customers or others;
our insurers to comply with our insurance obligations;
professional advisors and debt collection agencies to provide us with advice and assist with the recovery of amounts owed to us by you or the organisation you represent under any agreement between you and us;
credit reference agencies (for further information see the Credit Reference Check Policy [insert link]; and
commercial partners and/or possible acquirers or investors (and our and/or their advisors) upon or in anticipation of the sale or acquisition of our company and/or all or part of its assets. This will enable you to enjoy continuity of service.

We may share non-personal information (particularly aggregated data) publicly. For example, for use in sales presentations and in marketing.

HOW LONG DO WE KEEP PERSONAL INFORMATION?

We keep Personal Information for so long as is necessary in light of the purpose for which it was originally collected or lawfully further processed. We generally store your Personal Information for the duration of your account with us, and for a period of seven (7) years after your account with us is closed (whether settled by you, or upon default) or where the account has become inactive or dormant, or longer where required by national law or in order to defend legal claims.

You can deactivate your account at any time by emailing dataprotectionroi@northgatevehiclehire.ie and letting us know your preferences.

We will also allow you to delete your account at any time. To do this, please email dataprotectionroi@northgatevehiclehire.ie and let us know your preferences.

HOW DO WE KEEP PERSONAL INFORMATION SECURE?

We deploy appropriate organisational and technical security measures to keep Personal Information secure. However, the internet is not a 100% secure environment, so we cannot guarantee the security of Personal Information.

We encourage you to play your part in keeping your Personal Information secure by choosing a strong password, only visiting trusted sites and by keeping your login details secret.

WE OCCASIONALLY UPDATE THIS POLICY

We are constantly working to develop new and improved services which we hope that you will enjoy. We may also change our practices over time as our business and technology evolves. Occasionally, this means that we will need provide you with new or additional information about the ways in which collect and use Personal Information. As a result, we may amend this Privacy Policy from time to time.

If we materially change our Privacy Policy we will take steps to inform you of the change in advance. We may do this through an email, SMS, notices on our website, notice in-app, or other means (or a combination of these means). If you are unhappy with the changes that we propose, you are free to close your account with us. Alternatively, you can continue to use our services. If you continue to use or access our services after the date any revised Privacy Policy comes into force, you will be deemed to have consented to the revised Privacy Policies.

THIRD PARTY WEBSITES

Our site may contain links to other websites of interest. However, once you have used these links to leave our Site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Communication, engagement and actions taken through external social media platforms on which we may participate on are subject to the terms, conditions and privacy policies held with each social media platform respectively. We will never ask for Personal Information through social media platforms and we encourage users wishing to discuss sensitive details to contact us through primary communication channels such as by telephone or email. Our site may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised before using such social sharing buttons that you do so at your own discretion and note that the social media platform may track and/or save your request to share a web page through your social media platform account.

RIGHTS IN RELATION TO PERSONAL INFORMATION

We operate in accordance with European and Irish data protection law, including in particular, the rules set out in the Data Protection Law. You may enjoy a number of rights under Data Protection Law. These rights include:

the right to access and, in some circumstances, to amend and delete your Personal Information,
the right to restrict or object to the processing of your Personal Information; and
the right to data portability.

You can access, amend or delete much of your Personal Information, deactivate your account and exercise your rights as a data subject under Data Protection law by emailing dataprotectionroi@northgatevehiclehire.ie and letting us know your preferences.

If you believe that the information we hold about you is inaccurate, you should write to us at Northgate Vehicle Hire (Ireland) Limited at Suite 3, One Earlsfort Centre, Lower Hatch Street, Dublin 2, Ireland.

Under the Data Protection Law, you have the right to access Personal Information we hold about you. If you want to exercise that right you should write to Northgate Vehicle Hire (Ireland) Limited at Suite 3, One Earlsfort Centre, Lower Hatch Street, Dublin 2, Ireland.

If at any time you would like to change the way we market to you, you should contact dataprotectionroi@northgatevehiclehire.ie. You can also choose to stop receiving marketing e-mails or SMS messages from us by clicking on the opt-out link in the SMS or e-mail and following the relevant instructions.

QUERIES

If you have any queries about the way we handle Personal Information please contact Northgate Vehicle Hire (Ireland) Limited at Suite 3, One Earlsfort Centre, Lower Hatch Street, Dublin 2, Ireland.

RIGHT TO LODGE A COMPLAINT WITH A SUPERVISORY AUTHORITY

You have a right to lodge a complaint with a supervisory authority. Further information on your data privacy rights is available on the website of the Irish Data Protection Commissioner at http://www.dataprotection.ie. You may bring any complaints to the attention of the Irish Data Protection Commissioner by emailing info@dataprotection.ie.

CREDIT REFERENCE AGENCIES

If you are applying to open a vehicle hire account with us we may need to carry out certain credit reference checks on you personally or on the organisation you represent. We may use credit reference agencies to help make credit decisions about the applicant. The entities that we use for this purpose are Vision-Net and Creditsafe. We may also use these agencies for identity verification, debtor tracing and anti-money laundering purposes. We may search the files of credit reference agencies (who will record the search) for references to you, the organisation you represent or other individuals within that organisation. We may disclose information about how you or the organisation you represent conducts its account to such agencies and Personal Information provided to us by you or your organisation may be linked to records relating to other individuals living at the same address who are financially linked. Other organisations may use this information to make credit decisions about you and the individuals with whom you are financially associated, as well as for identity verification, fraud prevention, debtor tracing and anti-money laundering purposes.

If you are providing information about third parties, you must be sure that you have the agreement of those third parties.

How to find out more

For further information as to how we use credit reference agencies please click here [insert link to Credit Reference Check Policy].

To find out more about credit reference agencies, please contact the two (2) main credit reference agencies that we use; the information they hold may not be the same so it is worth contacting them both. They may charge a small statutory fee. These organisations are:

Creditsafe Ireland Limited, Unit 1h, Block 71, The Plaza, Parkwest Facilities Complex, Nangor Road, Dublin 12, D12 Y4C0, or call +353 (0)1 898 3200 or log on to https://www.creditsafe.com/ie/en.html

CRIF VisionNet Limited, 22 Northumberland Road, Ballsbridge, Dublin 4, D04 ED73 or call +353 (0)1 664 1111 or log on to https://www.vision-net.ie/.

CREDIT REFERENCE CHECK POLICY

This policy applies if you are hiring a vehicle under an established account or an account is being set up in order to permit you to hire vehicles and in each case if you are not paying in advance for the vehicle hire. In this section “Customer” means the business hiring a vehicle from us.

How we will use your information?

We will search credit reference agencies for information on Customers which may include carrying out a search on you personally. In so doing we will provide current and previous names, addresses and dates of birth, of all parties, so if you are providing information about third parties, you must be sure that you have the agreement of those third parties. If false or inaccurate information is given and we identify fraud, details may be passed to credit reference and fraud prevention agencies.

We will use the information provided to us by credit reference agencies to help make decisions about whether to open an account, to verify identity, for the prevention and detection of fraud and/or money laundering, and to manage accounts (including for debt recovery and cash collection purposes). We may use scoring methods to do this.

When credit reference agencies receive a search from us they will place a search “footprint” on the credit file of the Customer or you (if your individual status is searched) whether or not we decide to open an account. This “footprint” may be seen by other organisations when the Customer or you (if your individual status is searched) apply for credit in the future and may affect the Customer’s or your ability to obtain credit elsewhere in the near future.

Credit reference agencies will supply us with public information such as court judgments and bankruptcies, electoral register information and fraud prevention information on applicants’ (and their known financial associates), current and previous names, addresses and dates of birth.

If the Customer or you is making a joint application now or has ever:

applied for credit with someone else;
held joint account(s); and/or
been financially linked to someone else;

we will check relevant financial associates’ personal accounts as well.

Links between financial associates will remain on your file and the file of your financial associates until such time as you or the relevant financial associate files for a disassociation with the credit reference agencies.

How data will be used by credit reference agencies?

The information which we and other organisations provide to the credit reference agencies about the Customer or you, or any person financially linked to the Customer or you, may be supplied by credit reference agencies to other organisations and used by them to:

prevent crime, fraud and money laundering, for example by checking details provided on applications for credit and credit related or other facilities;
check the operation of credit and credit-related accounts;
verify the identity of the Customer or you, or any person financially linked to the Customer or you when applying for other facilities;
make decisions on credit and credit related services about the Customer or you, or any person financially linked to the Customer or you;
manage the account or credit facility of the Customer or you, or any person financially linked to the Customer or you;
trace whereabouts and recover debts that the Customer or you owe; and
undertake statistical analysis and system testing.

Credit reference agencies can also be fraud prevention agencies.

How to find out more

To find out more about credit reference agencies please contact the two (2) main credit reference agencies that we use; the information they hold may not be the same so it is worth contacting them both. They may charge a small statutory fee. These organisations are:

CRIF VisionNet Limited, 22 Northumberland Road, Ballsbridge, Dublin 4, D04 ED73 or call +353 (0)1 664 1111 or log on to https://www.vision-net.ie/.