Apollo Upolstery respects your privacy. Whether you deal with Apollo Upolstery as a customer, a consumer, a member of the general public, etc., you are entitled to the protection of your Personal Data.
This data may relate to your name, telephone number, email address but also to other data, such as your Vehicle Identification Number (VIN), registration number, geo-location, etc. In addition, we may hold data pertaining to your vehicle during the time of your ownership. Finally, we will also hold information in relation to contacts made between you and MS Consulting Group Ireland. We may also monitor and record telephone calls made to and from us to assist in improving customer services, to evidence instructions or to prevent or resolve disputes.
In this General Apollo Upolstery Privacy and Data Protection Policy (“this Policy”) we describe how we collect your Personal Data and why we collect it, what we do with your Personal Data, with whom we share it, how we protect it, and the choices you can make about your Personal Data.
This Policy applies to the processing of your Personal Data in the framework of various services, tools, applications, websites, portals, promotions, marketing actions, social media platforms, etc. that are provided or operated by us or on our behalf.
This Policy contains general rules and explanations. It is complemented with separate specific privacy notices relating to particular services. These privacy notices will be communicated to you whenever your Personal Data is needed in the framework of the activities mentioned above (for example, via websites, portals, individual communication services, newsletters, reminders, surveys, offers, events, etc.).
This Policy applies to all your Personal Data collected by (or on behalf of) MS Consulting Group Ireland, referred to in this Policy as “MS Consulting Group”, “we”, “us” and ”our”.
At the end of this Policy, you will find some definitions of certain key concepts used in this Policy and which are capitalised (for example, Personal Data, Processing, Data Controller…).
2. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
MS Consulting Group Ireland, Killeen Road, Dublin, D12 AW94, Ireland
3. WHO CAN YOU CONTACT IN CASE YOU HAVE QUESTIONS OR REQUESTS? THE DATA PROTECTION CONTACT POINT
- Data Protection Coordinator, Customer Relations Department, Apollo Upholstery
4. KEY PRINCIPLES
- Lawfulness: we will only collect your Personal Data in a fair,
lawful and transparent manner.
- Data minimisation: we will limit the collection of your Personal
Data to what is directly relevant and necessary for the
purposes for which they have been collected.
- Purpose limitation: we will only collect your Personal Data
for specified, explicit and legitimate purposes and not process your Personal
Data further in a way incompatible with those purposes.
- Accuracy: we will keep your Personal Data accurate and up to date.
- Data security and protection: we will implement technical and organisational measures to ensure an appropriate level of data security and protection considering, among others, the nature of your Personal Data to be protected. Such measures provide for the prevention of any unauthorised disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of Processing.
- Access and rectification: we will process your Personal Data in line with your legal rights.
- Retention limitation: we will retain your Personal Data in a manner
consistent with the applicable data protection laws and
regulations and no longer than is necessary for the
purposes for which they have been collected.
- Protection for international transfers: we will ensure that any of your Personal Data
transferred outside the EEA is adequately protected.
- Safeguards towards third parties: we will ensure that Personal Data access
by (and transfers to) third parties are carried out in accordance
with applicable law and with suitable contractual safeguards.
- Lawfulness of direct marketing and cookies: when we send you promotional materials
or place cookies on your computer, we will ensure that we do so in accordance with applicable law.
5. PROCESSING OF YOUR PERSONAL DATA: WHICH PERSONAL DATA DO WE COLLECT AND ON WHICH LEGAL GROUNDS
inform you which of your Personal Data we collect.
This information will be provided to you through a separate privacy notice which may,
for example, be included in specific services (including communication services),
electronic newsletters, reminders, surveys, offers, invitations for events, etc.
Please note that in accordance with applicable data protection law, your Personal Data can be processed if:
- you have given us your consent for the purposes of the Processing (as described in the privacy notice related to that particular Processing). For the avoidance of doubt, you will always have the right to withdraw your consent at any time; or
- it is necessary for the performance of a contract to which you are a party; or
- with such Processing, we pursue a legitimate interest that is not outbalanced by your privacy rights. Such legitimate interest will be duly communicated to you in the privacy notice related to that particular Processing.
- it is required by law.
6. FOR WHICH PURPOSES WE PROCESS YOUR PERSONAL DATA
7. KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE
8. ACCESS TO YOUR PERSONAL DATA
9. HOW LONG DO WE KEEP YOUR PERSONAL DATA
10. PROTECTING YOUR PERSONAL DATA
12. DISCLOSURE OF PERSONAL DATA
- a) Within our organisations and our brand environment:
- Our authorised staff members;
- Our affiliates and subsidiary companies;
- Members of our Authorised Retailers and Authorised Repairers network which you have indicated as preferred Authorised Retailers or Authorised Repairers or which are located near you (based on your postcode, address) or which you have been in contact with;
- MS Consulting Group Financial Services Ireland (to verify and administer your finance agreement with MS Consulting Group Financial Services);
- MS Consulting Group Motor Europe (to assist in administering warranty/service product details, customer relations queries and any other TME provided services)
- MS Consulting Group Motor Corporation (to assist with warranty, technical or customer relations matters)
- b) Third party business partners:
- Advertising, marketing and promotional agencies: to help us deliver and analyse the effectiveness of our advertising campaigns and promotions;
- Business partners: for example, trusted companies that may use your Personal Data to provide you with the services and/or the products you requested and/or that may provide you with marketing materials (provided that you have consented to receiving such marketing materials). We ask such companies to always act in compliance with applicable laws and this Policy and to pay high attention to the confidentiality of your personal information;
- Service providers of MS Consulting Group: companies that provide services for or on behalf of MS Consulting Group, for the purposes of providing such services (for example, MS Consulting Group may share your Personal Data with external providers of IT related services or fulfilment companies);
- c) Other third parties:
- – when required by law or as lawfully necessary to protect MS Consulting Group:
- to comply with the law, requests from authorities, court orders, legal procedures, obligations related to the
reporting and filing of information with authorities, etc.;
- to verify or enforce compliance with MS Consulting Group policies and agreements; and
- to protect the rights, property or safety of MS Consulting Group and/or its customers;
- – in connection with corporate transactions: in the context of a transfer or divestiture of all or a portion of its business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or part of MS Consulting Group business.
- Please be aware that third party recipients listed under points b) and c) above –especially service providers who may offer products and services to you through MS Consulting Group services or applications or via their own channels– may separately collect Personal Data from you. In such case, these third parties are solely responsible for the control of such Personal Data and your dealings with them will fall under their terms and conditions.
13. SPECIFIC CONTACT WITH OUR AUTHORISED RETAILERS AND REPAIRERS
- If you purchase a car or another product or service from one of our Authorised Retailers or Authorised Repairers or if you give them your personal information, you will have a separate relationship with this Authorised Retailer or Authorised Repairer. In this case, they become the data controller of your Personal Data, possibly together with us. For all questions or requests about the collection and use of your Personal Data by one of the Authorised Retailers or Authorised Repairers, please contact them directly.
The preferred Authorised Retailer or Authorised Repairer is (1) the Authorised Retailer or Authorised Repairer that you have selected as your preferred one via a sales or service experience survey or (2) in case you did not make such selection, we will identify an Authorised Retailer or Authorised Repairer based on the history of your contacts with our network.
14. USE OF SOCIAL MEDIA
- If you use on a MS Consulting Group tool (website, portal, App) a specific login from a social media (for example, your Facebook account), MS Consulting Group will record your Personal Data available on this social media and your use of such social media means that you have explicitly allowed the communication of your Personal Data recorded by MS Consulting Group through its tool.The preferred Authorised Retailer or Authorised Repairer is (1) the Authorised Retailer or Authorised Repairer that you have selected as your preferred one via a sales or service experience survey or (2) in case you did not make such selection, we will identify an Authorised Retailer or Authorised Repairer based on the history of your contacts with our network.
15. TRANSFERS OUTSIDE THE EEA
- Your Personal Data may be transferred to recipients which may be outside the EEA, and may be processed by us and these recipients outside the EEA. An example of this would be the sharing of personal data with the MS Consulting Group Motor Corporation in Japan.
- In connection with any transfer of your Personal Data to countries outside the EEA that do not generally offer the same level of data protection as in the EEA, MS Consulting Group will implement appropriate specific measures to ensure an adequate level of protection of your Personal Data. These measures can for instance consist in agreeing with recipients on binding contractual clauses guaranteeing such adequate level of protection.
16. YOUR CHOICES AND YOUR RIGHTS
- We want to be as transparent as possible with you, so that you can make meaningful choices about how you want us to use your Personal Data.
- How you contact us and how you will be contacted
Please note that by default, MS Consulting Group may communicate with you electronically and you will receive our communications at the normal frequency of the publication involved.
- Your Personal Data
You may always contact the Data Protection Coordinator (see section 3 “Who can you contact in case you have questions or requests?”) to find out what Personal Data we have concerning you. Under certain conditions, you have the right to receive your Personal Data, which you have provided to us, in a commonly used, structured machine readable format and to transmit your Personal Data to any third party of your choice..
- Your corrections
If you find any mistake in your Personal Data or if you find it incomplete or incorrect, you may also require from us that we correct or complete it.
- Your restrictions
You have the right to request a restriction on the Processing of your Personal Data (for example, while the accuracy of your Personal Data is being checked).
- Your objections
You may also object to the use of your Personal Data for direct marketing purpose by unsubscribing or to the sharing of your Personal Data with third party for the same purpose.
Moreover, you may require us to erase any data concerning you (except in some cases, for example, to prove a transaction or when required by law).
17. LEGAL INFORMATION
- (a) Data Controller means the organisation which determines the purposes for which, and the manner in which, your Personal Data is processed. Unless we inform you otherwise, the Data Controller is MS Consulting Group Ireland, Killeen Road, Dublin, D12AW94, Ireland. Further information may be provided to you through a separate privacy notice which will, for example, be included in specific services (including communication services), electronic newsletters, reminders, surveys, offers, invitations for events, etc.
- (b) Data Processor means the person or organisation which processes your Personal Data on behalf of the Data Controller.
- (c) Data Protection Contact Point means the contact point where you can address your questions or requests regarding this Policy and/or (the Processing of) your Personal Data and which will handle such questions and requests. Unless we inform you otherwise, the Data Protection Contact Point can be reached as described in section 3 “Who can you contact in case you have questions or requests?”).
- (d) EEA means the European Economic Area (= member states of the European Union + Iceland, Norway, and Liechtenstein).
- (e) Personal Data is any information that may relate to your name, telephone number, email address but also to other data, such as your Vehicle Identification Number (VIN), registration number, (geo-)location, etc. In addition, we may hold data pertaining to your vehicle during the time of your ownership. We will also hold information in relation to contacts made between you and MS Consulting Group Ireland and to surveys completed by you. We may also monitor and record telephone calls made to and from us to assist in improving customer services, to evidence instructions or to prevent or resolve disputes..