Frank Hogan Ltd. is committed to protecting all personal and special categories of data (also referred to as sensitive personal data) held on you.
Our mission is the managing of the processes related to the sales of cars, parts and accessories, as well as servicing and complementary services, such as roadside assistance, we collect, process and store copious quantities of personal data from our customers on an ongoing basis.
We also want you to be clear as to what rights you can invoke to help you to protect your privacy.
In this regard, it is important that you read this Privacy Statement and understand our use of your personal data.
Please note that we reserve the right to update this Privacy Statement as required.
1.1 Company Information
References to, “us”, “our”, “the Dealer” and “we” mean Frank Hogan’s Ltd. and any associated companies from time to time.
Rest assured that all personal data we gather will be processed in accordance with all applicable data protection laws and principles, the EU General Data Protection Regulation 2018 and the Data Protection Acts 1988 and 2003.
1.3 Queries and Complaints
If you are unhappy with the way we have handled your personal information and wish to complain or if you simply want further information about the way your personal data will be used, please contact us by any of the following options:
John FitzGerald/ Jordana Graham
Frank Hogan Ltd.
Dublin Road Limerick
You have the right to lodge a complaint with the Office of the Data Protection Commissioner. To contact the Office of the Data Protection Commissioner, please use the following details:
Data Protection Commissioner
Telephone: +353 (0)761 104 8000
Telephone: +353 (0)57 868 4800
LoCall Number: 1890 252 231
Fax: +353 57 868 4757
Please note that we will take all appropriate steps to keep your personal data safe. In the unlikely event that we have a security breach, we will notify you without undue delay about the circumstances of the incident in accordance with our legal obligations.
We collect personal data to provide our services to you. This data may be collected directly by our staff, our website, any applications used by us, or indirectly through a third-party service provider on our behalf.
The personal data we collect will be gathered and stored as set out in this Privacy Statement. This will be done directly by our Sales, Administration, Service, Parts and Technical staff. The categories of personal data that we gather are listed in Section 5 ‘Data Collected’ below.
We gather personal data, to market and sell our products and services, servicing facilities to you, our customer.
We mainly use your personal information so that we can provide you with quality car sales and services together with finance and leasing services’ options when requested by you.
We will always give you the option not to receive marketing communications from us. We will never send you unsolicited ‘junk’ email or communications, or share your data with anyone else who might. We do not sell your information to third parties, but we do work closely with selected partners who help us to provide you with the information, products and services that you request from us. For example, the AA who provide roadside assistance on our behalf.
However, more specifically, we may use the personal data we gather for any or all the following purposes):
|Process||Description||Lawful Basis for Processing|
|Purchasing a Vehicle or Part / Booking Vehicle Service||
When a customer books a vehicle service, and / or orders a vehicle or motor part from us, we obtain and enter the relevant personal data into our Dealer Management System (DMS).
These details are not directly stored by us – but order reference number is maintained on the DMS.
|The processing is necessary for the performance of a contract to which the data subject is party.|
|Car Financing / Leasing||We assist customers in obtaining car financing and / or leasing from a variety of third parties such as; VW Bank GMBH, Bank Of Ireland Finance, AIB Finance & Leasing, Ulster Bank Ireland DAC T/A Lombard, Bluestone Finance 1 Ltd, First Auto Finance Ireland Ltd, First Citizen Finance, Leaseplan Ireland||The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract to which the data subject is party.|
|Marketing to Potential Customers||
Information is collected by our Sales, Service and/or Marketing staff when any customer, or potential customer, contacts the dealership.
We record this data in our Customer Relationship Management System and/ or DMS and use the data to market to you.
This data is then sent to third party service providers such as VWGI Hopkins Communication
Where you are a potential customer:
The data subject has given explicit consent to the processing.
Where you are a customer:
The data subject has given explicit consent to the processing.
|Customer Satisfaction Survey||
We send out customer satisfaction surveys based on the personal data which is extracted nightly from our DMS.
This includes customers and potential customers who are inputted into CRM System/DMS.
Additionally, all individuals who interact with us can be surveyed on their experience with us.
Where you are a potential customer: The data subject has given explicit consent to the processing.
Where you are a customer: The processing is in our legitimate interests to ensure the quality of services provided by our staff.
|Quality Improvement / Staff Training||
All phone-calls, written communications and related details stored on our internal server.
Similarly, all communications / queries received through our Web Site are kept on our server.
These communications are stored for both quality improvement and staff training purposes.
|The processing is in our legitimate interests in providing a high standard of services to our customers, by assessing the ongoing development and identifying areas for improvement.|
|CCTV||We operate a CCTV system on our premises to protect the safety and security of our staff and property.||The processing is in our legitimate interests as a private company regarding Safety and Security.|
We use your personal data to comply with anti-money laundering regulations.
In the event of a customer wishing to pay us with personal funds more than €10,000, a regulatory form must be completed containing personal data.
|The processing is necessary for compliance with a legal obligation to which the controller is subject.|
|Change of Ownership Documentation||We process change of ownership documentation (i.e. vehicle registration certificates) for customers through the Revenue Online Service.||The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract to which the data subject is party.|
|Safety Incidents / Product recall||We may use your personal data to contact you regarding an urgent safety measure and / or a product recall.||The processing is necessary for compliance with a legal obligation to which the controller is subject.|
|Staff Data||For data subjects who are Employees of the dealership, we may use your personal data during our operations such as for human resources and payroll purposes.||The processing is in our legitimate interests as a private company as well as necessary for compliance with a legal obligation to which the controller is subject.|
We may also process your data for other purposes in line with our data protection policies http://www.frankhogan.ie/web/privacy-policy/
To enable us to support customers with sales and other enquiries
To support us in understanding customers’ and drivers’ needs
Processing is necessary for product development purposes (for example to improve vehicle quality, performance and safety);
Processing necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
We may process your personal information to comply with our legal requirements (for example to register your car with the (Driver and Vehicle Licensing Agency).
Not Providing Information
If you do not provide us with all the information we require, the resulting action may be that we are not able to fully offer you our services.
Furthermore, some services provided by us require certain categories of information, without which, we may not be able to provide you with the service.
There are various circumstances where we may share personal data with other parties. Generally, this includes your representatives and our representatives, and some pre-advised third parties.
We do not sell your information to third parties. However, we may from time to time disclose your information to the following categories of companies or organisations to which we pass the responsibility to handle services on our behalf:
We take steps to ensure that any third-party partners who handle your information comply with data protection legislation and protect your information just as we do. We only disclose personal information that is necessary for them to provide the service that they are undertaking on our behalf. We will aim to anonymise your information or use aggregated none specific data sets where ever possible.
Sharing within Volkswagen
There are circumstances where we share your information with the manufacturer (or other companies within our Group) to fulfil orders, transactions, handle complaints or provide you with a service or information that you have requested.
Due to the international nature of our business, there may be some instances where your information is processed or stored outside of the EU. In those instances, we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law.
Any party you have given us permission to speak to (such as a relative or friend), your motor insurance company and other people or companies associated with you;
Our employees and employees within Frank Hogan’s Ltd, VWGI, and contractors including companies that provide services in relation to telecommunications and postage, data storage, document production and destruction, IT and IT security, customer loyalty programmes.
Other third parties:
Other motor insurance companies, external advisors (such as solicitors and accountants) and auditors, other VW Group companies, third parties with which we may choose to improve our processes, products or services or to investigate the possibility of new processes, products or services and prospective sellers or buyers if we decide to sell or buy any business or assets; and
State or government departments, bodies or agencies.
The State department (i.e. The Irish Revenue) for the notification of change-of-ownership for a used vehicle, and/or transfer of leasing commitments. The Regulatory Authority, (i.e. the Financial regulator) for Anti-money laundering compliance.
Please feel free to contact us (details in Section 1 'General' above) if you would like more details about the parties with whom we share your information.
Where we choose to have certain services provided by carefully selected third parties, we take precautions regarding the practices employed by the service provider to ensure your personal data is stored and processed legally and securely. We stipulate that such third parties shall have made every possible effort to achieve a state of readiness for GDPR.
We operate as a Data Processor for our partner, VWGI, and as Data Controller, for our non-Volkswagen business operations. We will use every effort to protect your personal data and we will not sell your personal information to any third-party companies.
As a car dealership we need to collect many categories of personal data (about you and other parties) for the purposes set out in this Privacy Notice.
While the type of personal data may change occasionally, we believe it is important you are aware of the types of personal data we gather and use. 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.
Please note that information listed under one category may be used for the performance of a task or in relation to activities under another heading or as outlined under Section 3.
|Purpose||Type of Data|
|Sales of Products / Services||Name, Contact Details, Occupation, Car Details, Lease Operator Information, Bank Details, Service History, Gender|
|Customer Care||Name, Contact Details, Car Details, Phone Calls|
|Finance||Detailed Financial Information|
|Marketing||Name, Contact Details, Occupation, Car Details, Gender, Service History|
We have a comprehensive record retention schedule. The retention periods differ depending on the purpose of the processing and the nature of the information. How long we keep data is primarily determined by how long we need it for the purposes we told you we were going to use it for, time periods set out in law and the period we need to keep it to defend ourselves against legal action.
Generally, we keep information for the periods set out in the table below:
|Type of Information||Retention Period|
|Name and Contact Details||6 Years|
|Vehicle Details||6 Years|
|Finance Applications||Finance proposals are not retained once a finance deal has been paid|
|Service and Repair History||6 Years|
|CCTV Footage||30 Days|
However, in some cases we may need to keep personal data longer than the above periods. Examples of these situations include legal cases and system back-ups required for disaster recovery.
We also retain certain limited details beyond the above time periods to validate and handle any motor insurance claims we receive after the statute of limitations has expired (late claims) and any claims we receive where the claimant was not aware of the injuries until a long time after they were caused (latent claims).
After the periods set out above, we will anonymise or delete the personal data. Anonymisation means that we will delete certain aspects of the information we hold (such as name and street address) so that we can no longer determine who the data relates to.
Please feel free to contact us if you would like more information about data retention periods.
As a data subject, you will have the following rights, as outlined in this section. However, restrictions may apply in certain situations
Where do I send requests?
Please send all your requests to the contact details provided in Section 1, with as much detail as possible about your requirements to allow us to deal with your request efficiently. To answer your request, we may ask you to provide identification for verification purposes.
How long will a request take to complete?
Upon receipt of a request, we will have 30 days to provide a response, with an extension of two further months if required. If we require more time to deal with your request, we will notify you of the delay, and the factors resulting in the delay, within 30 days of the receipt of the request. If we refuse your request, we will notify you within 30 days of the receipt of the request accompanied by the reason for refusal.
We will not charge a fee for any requests, provided we do not consider them to be unjustified or excessive. If we do consider these to be unjustified or excessive, we may charge a reasonable fee (also applicable for multiple copies) or refuse the request.
You are entitled to contact the Office of the Data Protection Commissioner if we refuse your request.
Right of Access
You have a right to know what personal data we hold on you, why we hold the data, and how we are processing the data.
When submitting your request, please provide us with information to help us verify your identity [your name, your contact number or email address, your vehicle registration number] and as much detail as possible to help us identify the information you wish to access (i.e. date range, subject of the request).
Please note that an access request is free of charge, however, where we determine a request to be unjustified or excessive, we may charge you a reasonable fee.
Right to Rectification
You have a right to request that the personal data held in relation to you is up to date and accurate.
Where information is inaccurate or incomplete, we encourage you to contact us to have this information rectified. Upon receipt of request, we will ensure that the personal data is rectified and as up to date as is reasonably possible.
Right to be Forgotten
You have the right to seek the erasure of personal data relating to you in the following circumstances:
However, we will be unable to fulfil an erasure request if the processing of personal data is necessary for the following:
Please be aware that in certain circumstances we may need to retain some information to ensure your preferences are respected in the completion of our duties. For example, we cannot erase all information about you where you have also asked us not to send you marketing material. Otherwise, your preference not to receive marketing material would be erased.
Right to Restriction
You have the right to restrict the extent of personal data processed by us in circumstances where:
When processing is restricted, your personal data will only be processed: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of other people; or for reasons important to public interest.
We will contact you confirm where the request for restriction is fulfilled and will only lift the restriction after we have informed you that we are doing so.
Right to Data Portability
You have the right to the provision of all personal data held in relation to you in a structured, commonly used and machine-readable format where:
You may also request that we send this personal data to another data controller where technically feasible.
Right to Object
You have the right to object to the processing of your personal data. However, the processing must have been undertaken on the basis of legitimate interest by us.
If you wish to object to the processing of data, please contact us with your request. We will then stop the processing of personal data unless it is required for legal proceedings.
Right not to be subject to Automated Decision Making, including Profiling
You have a right not to be subject to a decision based solely on automated processing or profiling, where such decisions would have a legal effect or significant impact on you.
Occasionally we use profiling.
Where we (or one of our third-party processors) use profiling, which produces legal effects for you or otherwise significantly affects you, you will have the right to object to such processing.