This website is not intended for children or minors and we do not knowingly collect data or information relating to children or minors.
This statement describes what type of information we collect from you, how we use the information you provide us with, how this information is shared with others, how long we keep your information for, what your rights are, how you can control the information we hold on you and how you can contact us.
In order to deliver services in relation to your vehicle and the maintenance of that vehicle, we both require and use your information. On occasion, we communicate product information, offers, services and updates, however, you will only receive these if you have given us explicit permission to do so. We will not share your data with anyone else and we do not sell your information to third parties. HCS Direct Limited do work closely with selected partners who assist with the products and services you request from us. You will be suitably notified if your details need to be shared with such partners in order to deliver products and services required/requested.
Our website may include third-party website links and applications. Clicking on these links may enable the third-party to collect and store your data. We are not responsible for these third-party sites and we advise you read privacy policies for any third-party sites you may visit.
HCS Direct, C/O Honda and Volvo Cars Waterford, Butlerstown Roundabout, Cork Road, Waterford.
Consent – Freely given permission or agreement for your personal data to be used by HCS Direct Limited.
Third Party – A generic legal term for any individual, public authority, agency or group of people that are not HCS Direct Limited but are authorised to process data in behalf of HCS Direct Limited.
Recipient – A recipient is any individual, public authority, agency or group of people to whom your personal data is shared with. This includes third-parties.
Processing – Any action, or series of actions, that is performed on personal data (both automated and not) which includes: collecting, recording, sorting, structuring, storing, altering, consultation, use, disclosure, combination, restriction, erasure or deletion.
Restriction of Processing – The action of limiting the processing of an individual’s personal data after the restriction has been put in place.
Data Subject – Any identifiable natural person whose personal data is processed by the HCS Direct Limited group or approved third-parties.
Data – Facts and statistics that are gathered together for reference or analysis.
Personal Data – Any information that relates to an identifiable natural person. An identifiable natural person is anyone who can be directly or indirectly identified.
Anonymised – The process of removing any details that can identify a natural person.
Data Protection Acts 1988 & 2003 – These acts were drawn up to protect an individual’s privacy. The acts also govern how an individual’s personal data is managed by any persons storing and processing such data.
Applications – A client-server computer program which the client runs in a web browser.
IP Address – A unique string of numbers separated by full stops that identifies each computer using the Internet Protocol to communicate over a network.
Warranty – A written guarantee issued to a person that purchases a product, promising to repair or replace said product, if necessary, within a certain allotted time frame.
Data Controller – The person (or collection of people) who determines the purposes and means of processing personal data.
3. Data We Collect
Personal data or personal information is any information gathered and recorded that can identify a person. This does not include information gathered where all identifying data has been removed.
HCS Direct Limited may collect, store, use and transfer your personal data which may include some or all of the below:
1. Full name including title
2. Address (house no., street, town, city, county, country, Eircode)
3. Phone number (mobile and home)
4. Date of birth
5. Email address
6. Additional information may need to be sourced to apply for Motor Finance. These include, but are not limited to, marital status, gender, mother’s maiden name, number of dependent children, residential status and place of birth.
7. Vehicle information (VIN, service history, mileage, warranty information, registration number)
8. Date and times of services
9. Website visits (date, time, location accessed, pages viewed, device used, browser used, IP address, link used to access our website)
11. Transactions between you and us or members of our group/ third party partners.
12. If a business customer, details regarding your employment may be stored. For example, job title, company details, size of the fleet purchased/ hired, contact details etc.
13. Calls may be recorded.
14. Email, live chat and all other forms of correspondence will be stored.
15. Onsite CCTV footage from our dealerships is stored.
16. For finance purposes, banking information, payment methods, working status, financial records and employer information will be collected and stored. Information collected for finance purposes will be forwarded to one or more financial institutions being members of the Irish Finance Houses Association. Credit reference agencies will also be forwarded these details including the Irish Credit Bureau (ICB).
Our websites are powered by Cars Ireland, our third-party web services provider. Cars Ireland are committed to ensuring that all data is processed securely and in accordance with data protection laws.
When visiting one of our websites, Cars Ireland collect and store standard internet information (such as your IP address, browser you are accessing our website from and the device you are accessing the website from) and record details of your visit to our website (link that brought you to our site, pages you click on whilst on our site, the last page you look at before leaving and the time you leave our site).
When entering our online, newspaper, text or email competitions, we may require to request and record your personal data such as full name, address, phone number, gender, email address and photograph. Your personal data will be removed from our system 45days after the closing of the competition, unless otherwise agreed. Should you be the winner of a competition, you will be asked if your photo can be taken, stored and used on our social media pages.
4. What We Use Your Data For
HCS Direct Limited will only process the amount of information required to fulfil the services for which it has been gathered. We will only ever use your personal data when the law permits us to do so.
If all the required information is not provided, some services may not be fully available.
We collect and use your personal data for the following:
· When a customer purchases a vehicle from us. Information is collected for the dealership. All parties require the personal data for the fulfilment of warranty and any other services linked to the purchase. The details are stored locally. The collection of this personal data is necessary due to a contract being drawn up where you, the customer, are party.
· When a customer visits one of our websites and requests a test drive or fills in a form requesting information from HCS Direct Limited, necessary identification and contact details are collected to ensure delivery of the requested material and/or so we can fulfil the service you are requesting from one of our dealerships.
· When a customer registers interest on any of our websites regarding a product or a service, necessary identification and contact details are collected to provide any information required.
· Our Sales and Marketing staff collect information both in the dealership and at events. This information is stored in our local Customer Relationship Management System and the data is used to market to you. When visiting our website, you will be asked for your consent before we use this information to market to you in the future. At any time, you can opt out of such marketing by unsubscribing to our marketing services. HCS Direct Limited use third-party marketing services that include Dealer Marketing Ltd and Mailchimp.
· Follow-up calls are made (and potentially emails sent) after a purchase or service by HCS Direct Limited to check customer satisfaction.
· All written communications, any recorded phone calls and related customer information are stored and may be used for training purposes and for quality improvement.
· CCTV is in operation in all our dealerships. This is for the safety of you (the customer), our staff, all visitors and the property.
· For individuals who work for HCS Direct Limited, personal data is stored and used for Human Resources, health and safety, payroll and legitimate business needs.
5. How Is Your Information Shared?
Where appropriate, your information may be disclosed to approved companies and organisations that are passed the responsibility of handling services in behalf of HCS Direct Limited. For example: roadside assistance and direct marketing.
As HCS Direct Limited is a group of approved dealerships, your personal data will be shared with the franchise company that sells the vehicles.
Third-party companies affiliated with HCS Direct Limited are only provided with the exact personal data required for the service you have requested to be fulfilled. Where possible, your data will be anonymised to prevent identification. Your personal data will not be provided to third-party companies for their own marketing purposes that are not related to HCS Direct Limited.
6. How Long Do We Store Your Information?
The length of time we store your personal information we have collected is dependant on several factors including: purpose the information was gathered for, purpose the information is used for and any legal obligations HCS Direct Limited may have.
Identifiable personal data is not stored for longer than it is necessary. As we may need to found, bring or defend legal claims using your personal data, we retain your personal data for 8 years after the date it is no longer required for any other purposes by HCS Direct Limited.
Exceptions to this are:
· Where you have exercised your right to have your personal data erased from our systems.
· If the law specifically states that we delete your personal data sooner or store it for a longer period.
7. Your Rights
Each individual has rights in relation to their personal information under data protection law. In Ireland, the Data Protection Acts 1988 and 2003 govern these rights. In an instance where you are requesting HCS Direct Limited to search for your personal information, we will require that you confirm your identity. We will endeavour to respond to any requests within 28 working days.
a) Your right to access
You have the right, at any time, to contact HCS Direct Limited and obtain confirmation whether personal data which concerns you is being processed. If personal data regarding you is being processed, you have the right to a free copy of the information stored. Should you wish to exercise this right, please contact our Privacy Manager.
b) Your right to erasure
You have the right to request that HCS Direct Limited erase personal data concerning you without delay. In some instances, we reserve the right to refuse erasure if one, or more, of the following are in question:
· You have a current purchase order/ service request with us.
· You have outstanding debts with us.
· You have a current grievance with us.
· You are currently involved in legal action with HCS Direct Ltd.
· If you have been suspected or found guilty of misusing services provided by us within the last 5 years.
· Your outstanding debts have been sold to a third-party.
· Your finance application has been denied within the last 90 days.
· If you have made a purchase from us, transactional information will not be deleted for accounts and book-keeping purposes.
c) Right to rectification
You have the right to request HCS Direct Limited to rectify inaccurate data stored by us, which concerns you, without delay. You also have the right to have any incomplete data stored by us completed and a copy provided to you for your records. Should you wish to exercise this right, please contact our Privacy Manager.
d) Right to portability
You have the right to request and receive a copy of the personal data HCS Direct Limited stores about you. This can be transferred to you or a third party by means of a well-structured electronic system.
e) Right to restriction
You have the right to request that the processing of your personal data by HCS Direct Limited is restricted under one, or more, of the following circumstances:
· You dispute the accuracy of the information HCS Direct Limited have concerning you, allowing time for us to verify the personal data.
· The processing of the information HCS Direct Limited has gathered is unlawful but you do not wish to request for the data to be erased.
· HCS Direct Limited no longer requires your personal information but are required by you to defend legal claims.
· You object to HCS Direct Limited processing your personal data based on legitimate claims. In such cases, the processing of your personal data will be suspended until legitimate interest can be verified.
f) Right to object
You have the right to object to the processing of any of your personal data at any time, whether it is based on public interest or the legitimate interest of HCS Direct Limited. We will no longer process your personal data in the event of an objection, unless we can demonstrate persuasive legitimate grounds this data which supersedes the rights, interests and freedom of the individual. Founding, exercising or defending legal claims will also be grounds to demonstrate legitimate cause.
HCS Direct Limited process personal data for direct marketing which includes updates regarding offers, sales, new products and dealership news. You have the right, at any time you choose, to object to the processing of your personal data for the use of direct marketing. If you object, HCS Direct Limited will no longer process your personal data for direct marketing means.
g) Right to withdraw consent
You have the right to withdraw your consent to the processing of your personal data at any time. Should you wish to exercise this right, please contact our Privacy Manager.
h) Right to complain
HCS Direct Limited strives to resolve any and all queries, questions, complaints and issues that you may have. Please direct any such concerns to our Privacy Manager. Contact information can be found in section 8 of this policy.
If, for whatever reason, we are unable to resolve any of your concerns or complaints or you are unhappy with the manner in which we did so, you have the right to contact the Data Protection Commissioner’s Office by using the below contact details:
Data Protection Commissioner
Phone: +353 (0)761 104 8000
Phone: +353 (0)57 868 4800
A Cookie – What is it?
Cookies are small text files that can store a small amount of information and are stored on your computer, mobile device or other device when you visit a website. Cookies help us recognise your device the next time you visit our website. They remember settings and preferences you have when using our sites. Cookies don’t run programs on your device and they do not deliver viruses to your device.
What are Cookies used for?
What types of Cookies are used?
HCS Direct Limited use session, analytical and third-party cookies on all our websites.
Session Cookies – Stores information as you navigate through our websites. Your movement is tracked from page to page, so you are not required to input the same information twice in the same visit.
Analytical Cookies – This information is anonymous and collects data about page visits which is used to identify popular pages and content on our websites and recognise possible issues or concerns. The information gathered by these cookies cannot be used to identify who it came from and is used in data reports.
Third-Party Cookies – Used and generated by third-party links and advertisements. The tracking may be anonymous.
If you wish to turn off cookies or change your settings so that you are notified when they are in use, you can use the help menu on your browser. If you disable cookies on your browser, this may affect certain functions on a website, for example, a logging in service. Features that are used to enhance your site experience will also be unavailable.
9. HCS Direct Ltd.
HCS Direct Limited is a private limited registered company in Waterford, consisting of a car dealership group covering the island of Ireland, (Company registration number is 584916 and VAT registration number is 342642PH), whose registered office is Butlerstown Roundabout, Cork Road, Waterford, Ireland.
Any individual may contact our Privacy Manager at any time with any questions or queries concerning data protection. They can be contacted by the address above or by email: firstname.lastname@example.org