WHAT FRANK KEANE BMW COMPANIES ARE COVERED BY THIS POLICY.

All companies as members of the Frank Keane Group are covered by this policy in Ireland. Relevant to this website these include:

Frank Keane BMW Naas Road, registered at this address:

John F Kennedy Drive
Naas Road
Dublin 12
D12 Y985

Frank Keane MINI Naas Road, registered at this address:

John F Kennedy Drive
Naas Road
Dublin 12
D12 Y985

What Frank Keane does:

• Operate using the BMW and MINI brand under license to sell and/or service.
• They provide services to customers and support for technical issues.

Changes to this Privacy Policy:

We may modify or update this privacy policy from time to time.

Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have under local law (e.g. to object to the processing).

HOW DO WE COLLECT YOUR PERSONAL INFORMATION.

These are the main ways we collect your information:

• If you contact us directly via our websites or via our customer hotlines to request information about our products and services.
• If you buy a product or service directly from us (e.g. Lifestyle shops).
• If you reply to our direct marketing campaigns (e.g. filling out a response card).
• If with your permission, your contact details are transferred from BMW Ireland or other third parties.
• If your vehicle data (incl. vehicle identification number) is transferred to BMW AG while you’re having your vehicle serviced or repaired.
• If with your permission, other BMW Group legal entities or business partners transfer your personal data to us.
• If we acquired your personal data from other sources with your permission.
• When you apply for finance from BMW FS.

If you give information on behalf of someone else you must ensure that they have been provided with this Privacy Policy before doing so.

If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian to do so.

Please help us to keep your information up to date by informing us of any changes to your contact details or preferences.

WHAT INFORMATION MAY BE COLLECTED ABOUT YOU.

The following types of personal information about you may be collected:

Contact Details

• Name
• Address
• Phone numbers
• Email address

Interests

• Information you provide us about your interests
• Including the type of vehicles you are interested in.

Website and Communication Usage

• How you use our website and whether you open or forward our communications, including information collected through cookies and other tracking technologies

Sales and Services Information

• Relating to purchases and services, including complaints and claims.

Credit and Anti-Fraud Information

• Which establishes your identity, such as driving licences, passports and utility bills
• Information about transactions, requests for credit and non-payment of debts with us and third parties and credit ratings from credit reference agencies
• Fraud, offences, suspicious transactions, politically exposed person and sanctions lists where your details are included.

Device and Service Usage

• How you use your device (mobile or vehicle) and services offered on the device.

Vehicle Configuration Details

• Information about the features and current settings of your vehicle (identified by the Vehicle Identification Number).

Vehicle Technical Information

• About how the engine and systems within the vehicle perform.

Vehicle / Device Location Information

• Your vehicle’s or mobile device’s location

HOW YOUR PERSONAL INFORMATION MAY BE USED.

Use of personal information under EU data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy.
The main uses of your information are:

Customer Support and Marketing - to respond to enquiries and to bring you news and offers.

Frank Keane BMW Naas Road use your personal data for customer care and for personalised communication of BMW Group product and service information, where necessary with your consent. For these purposes, Frank Keane BMW Naas Road may transmit this data to other BMW Group companies.

In order to ensure that you receive relevant and personalised communications, we will use your data to create an individual customer profile and we may share your personal data between BMW Group companies and other suppliers of BMW or MINI branded products and services where relevant. This may include data you have provided to us, or which is generated by your use of BMW or MINI products, for example contact details, preferences, customer history, vehicle data, app usage and online behaviour.

Vehicle Sales & Service – to process your sale, configure and service your vehicle

Frank Keane BMW Naas Road will obtain Contact Details, Vehicle Configuration Details, Vehicle Technical Information and Sales and Services Information when you purchase, service or repair a vehicle from or with them as part of the sale or service and will use it to provide the services you request and notify you of issues in relation to your vehicle. This information may be accessed by BMW UK and BMW AG to troubleshoot technical or other issues relating to the delivery of these services.

The above mentioned controllers may also receive limited Vehicle Location Information during the repair process which will be used only in accordance with Location Information Safeguards.

Quality Assurance, Research and Development – to improve our products and services.

BMW AG may use any of the information that it receives through the provision of services to BMW UK, centres (including Location Information) for product and service quality assurance and development purposes. Before any such use is undertaken your information will be de-personalised so it cannot be directly linked back to you.

Compliance with legal requests for your information – to comply with our legal obligations to law enforcement, regulators and the court service.

We may be legally required to provide your information to law enforcement agencies, regulators and courts and third party litigants in connection with proceedings or investigations anywhere in the world. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Legal grounds for processing of your personal information.

The use of your information set out above is permitted under EU data protection law on the basis of these principal legal grounds:

• where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time

o by contacting Frank Keane BMW Naas Road on 01 240 5666

o or sending an email to [email protected]

o or by writing to us at:
Frank Keane BMW
John F Kennedy Drive
Naas Road
Dublin 12
D12 Y985

• where necessary to enter into or perform our contract with you
• where we need to use it to comply with our legal obligations
• where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include promoting the Frank Keane BMW Naas Road business and tailoring news and offers to your profile, research and development of vehicle related products and services, assessing your credit-worthiness, detecting fraud and criminal activities)
• where necessary for us to defend, prosecute or make a claim against you, us or a third party

There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it you as soon as possible after becoming aware of the new basis.

Transfer to third parties.

Personal information which we collected may be transferred to third parties on your behalf, only with your consent.

This is only shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.

The types of third parties apart from the BMW companies already stated are:

• Marketing agencies who run and manage marketing campaigns on our behalf
• Event companies who run and manage sponsored events on our behalf

Frank Keane use cookies to help improve our websites and make your browsing experience more useful, more relevant and tailored to you. In order to comply with the most recent legislation and in the interests of transparency, we have updated our privacy policy to give you clearer information on the way we use technology such as cookies and how they affect your privacy.

Cookies are small text files, placed on your hard disk by a web page server. They are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.

We will use encrypted information gathered from the cookies to improve your online experience with Frank Keane.

None of the cookies on our web site collect or store personal data, we only store standard internet log data for our internal reporting purposes. We do this to find out things such as the number of visitors to the various parts of the Frank Keane web site. We collect this information in a way which does not identify anyone, keeping your privacy as well as allowing us to improve the web site wherever possible.

The Frank Keane website does collect some personal / identifiable information but this is always done through asking you the user to enter details such as your email address. We will never capture personal information without making you aware first.

You still have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Frank Keane services or web site.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/. Alternatively, you can search the internet for other independent information on cookies.

Some of the cookies we use will expire after you close the browser window. These are called session cookies. Some cookies last longer than this, because they are used to identify return visits to the website.

After browsing our website, you may receive personalised banner advertisements whilst browsing other reputable websites. We are committed to providing you with information on products and offers which are relevant to you. Any banner advertisements you receive will relate to products which have been viewed whilst browsing this website on your computer or other device. This service is provided by Frank Keane via a reputable third party specialist provider, through the use of cookies placed on your device. All cookies listed below will be enabled while you use our website and they will operate as established below. Please note that cookies do not harm your computer or any software you may have.

Our legal basis for the use of cookies is Art. 6 (1) b) GDPR and Art. 6 (1) f) GDPR. Our legitimate interest is e.g. the optimization of our advertising to increase our sales.

What cookies we use and why:

·              Session cookies are deleted when you leave our websites. They help keep track of your progress so you don't have to enter the same information more than once.

·              Persistent cookies stay on your device after your browsing session has ended. They will remember settings, preferences and details for the next time you use the websites.

·              First party cookies are set by the website owner, i.e. Frank Keane BMW.

·              Third party cookies are set by other parties, such as Google, Facebook and Twitter.

·              Necessary cookies are required for the operation of our website.

·              Performance or analytical cookies allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

·              Functionality cookies are used to recognise you when you return to our website. This enables us to personalise our content for you, for example, remember your preferences (for example, location, etc.).

This section is a table which explains why we use certain cookies and what they do.

Google Analytics:

We use Google Analytics, a web analytics service provided by Google Inc. ("Google"), on all websites. Google Analytics uses its own "cookies" (see above). On behalf of Frank Keane, Google uses this information to evaluate every use of our websites, to compile reports on website activity in general, and to provide other services related to website activity and internet usage to Frank Keane. The IP address provided by Google Analytics as part of Google Analytics will not be merged with other Google data. Google is an American company that uses servers in the United States and has been licensed by us to transfer personal information worldwide, including to non-EEA countries. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymisation on our websites, your IP address will be shortened by Google beforehand within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there. By setting this in your browser, you can prevent the installation of cookies. In addition, you may prevent the collection by Google of the data generated by the cookie and related to your use of the website (including your IP address) as well as the processing of this data by Google by downloading the browser plug-in available under the following link and install: Browser Add On to disable Google Analytics. Our legal basis for the use of Google Analytics is Art. 6 (1) b) GDPR and Art. 6 (1) f) GDPR. Our legitimate interest is e. g. the optimization of our advertising to increase our sales.

Google AdWords:

Our website uses Google Conversion Tracking. If you have reached our website via an advertisement sent by Google, Google Adwords will set a cookie on your computer. The conversion tracking cookie is set when a user clicks on a Google-served ad. These cookies lose their validity after 30 days and are not used for personal identification. If the user visits certain pages on our website and the cookie has not expired, we and Google may recognize that the user clicked on the ad and was redirected to this page. Each Google AdWords customer receives a different cookie. Cookies can not be tracked through AdWords advertisers' websites. The information obtained from the conversion cookie is used to generate conversion statistics for advertisers. Customers will be told the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag ("clicks"), the number of times their ad was shown ("impressions"), and the number and type of ads Actions users take after clicking an ad on the linked web page ("Conversions"). However, they do not receive information that personally identifies users. Google is an American company that uses servers in the United States and has been licensed by us to transfer personal information worldwide, including to non-EEA countries. If you do not want to participate in the tracking process, you can refuse the required setting of a cookie - for example via a browser setting that generally deactivates the automatic setting of cookies or sets your browser to block cookies from the domain "googleleadservices.com". Please note that you can not delete the opt-out cookies as long as you do not want to record measurement data. If you have deleted all your cookies in the browser, you must set the respective opt-out cookie again. Our legal basis for the use of Google AdWords is Art. 6 (1) b) GDPR and Art. 6 (1) f) GDPR. Our legitimate interest is e. g. the optimization of our advertising to increase our sales.

To find out even more about cookies, visit: http://www.aboutcookies.org

The additional cookies that run during your session will collect information about your computer in the form of server logs, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions. Disabling cookies ensures that your IP address will not be recorded.

Frank Keane BMW recommend that you accept cookies, as we use them to:

·              Customise elements of our website’s layout and content, and test different designs of our websites to improve your experience.

·              Recognise when a user has visited before, meaning we can see how many unique visits we receive. We can then make sure the websites are easy to use and have enough capacity.

·              Remember your preferences and settings, such as text size and language.

·              Recognise your device so you don't have to provide the same information during your visit, or on subsequent visits.

·              Help us identify errors and resolve them effectively.

·              Establish what information is relevant to you while you are browsing our websites.

·              Collect statistical, anonymous information about how our visitors use/interact with our digital services so we can improve them.

·              Learn which parts of our websites are most popular and improve them.

·              See how effective our online messages are.

However, you can choose to decline cookies by changing your browser settings.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

The Website may offer you the opportunity to share or follow information about us (or the website or our services) using third party social networking functionality (such as through "share this", "like" or "follow" buttons).

We offer this functionality in order to generate interest in us, the website and our services among the members of your social networks, and to permit you to share and follow opinions, news and recommendations about us with your friends. However, you should be aware that sharing personal or non-personal information with a social network may result in that information being collected by the social network provider or result in that information being made publicly-available, including through Internet search engines.

Please note that we do not exercise any endorse or control the policies or practices of any third party social network whose functionality you may access through the website. You should always read the privacy policy of any social network through which you share information carefully in order to understand their specific privacy and information usage practices.

HOW DO WE KEEP YOUR PERSONAL INFORMATION SAFE.

We use a variety of security measures, including encryption and authentication tools, to help protect and maintain security, integrity and availability of your information.

Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. Our main security measures are:

• tightly restricted personal access to your data on a 'need to know' basis and for the communicated purpose only
• transferred collected data only in encrypted form
• firewalled IT systems to prohibit unauthorised access e.g. from hackers
• permanently monitored access to IT systems to detect and stop misuse of personal data.

If you have a personal password which enables you to access certain parts of our websites or any other portal, app or service we operate, do not forget your responsibility for keeping this password confidential. We ask you not to share your password with anyone.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR.

We retain your information only as long as is necessary for the purpose for which we obtained them and any other permitted linked purposes. If information is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.

We restrict access to your information to only those persons who need to use it for the relevant purpose.

Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised or destroyed securely.

Use for marketing:
We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for. You retain the right to remove this consent at any point.

Use to perform a contract:
In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus one year to deal with any queries or claims thereafter.

ConnectedDrive and Connected App:
We set out how long we retain Vehicle Location Information [and Device Information] in relation to each service in the relevant service descriptions.

Where claims are contemplated:
In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.

WHO MAY WE SHARE YOUR INFORMATION WITH.

BMW is a global company. Your personal information may be accessed by our staff, agents or contractors from a country outside the European Economic Area (EEA) for any of the purposes set out, in which data protection laws may be of a lower standard than in the EEA. We will ensure that any of your information that is accessible outside the EEA is handled subject to appropriate safeguards.

Certain countries outside the EEA, such as Canada and Switzerland, have been approved by the European Commission as providing essentially equivalent protection to EEA data protection laws and therefore no additional legal safeguards are required. In countries which have not had such approval, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.
 

HOW TO CHANGE YOUR PRIVACY PREFERENCES.

You can change your preferences, or withdraw your consent in relation to how Frank Keane BMW Naas Road use your personal information in one of the following ways:

• You can make individual changes directly in your ConnectedDrive account or the Connected App, where applicable.
• You are also able to request information about your data stored at Frank Keane BMW Naas Road as well as request the correction, deletion or restriction of your personal data for analytics and/or marketing use.
• By contacting Frank Keane BMW Naas Road on 01 240 5666
• Or by sending an email to [email protected]
• Or by writing to us at:
  Frank Keane BMW Naas Road
  John F Kennedy Drive
  Naas Road
  Dublin 12
  D12 Y985

CONTACTING FRANK KEANE BMW NAAS ROAD ABOUT THIS PRIVACY POLICY.

If you have any questions in relation to our use of your information you should first contact Frank Keane BMW Naas Road in one of the following ways:

• Call 01 240 5666.
• Or by sending an email to [email protected]
• Or by writing to us at:
  Frank Keane BMW Naas Road
  John F Kennedy Drive
  Naas Road
  Dublin 12
  D12 Y985

Under certain conditions you have the right to require us to:

• Provide you with further detail on the use we make of your information
• Provide you with a copy of your information
• Update any inaccuracies in the information we hold about you
• Delete any information about you that we no longer have a lawful ground to use
• Remove you from any direct marketing lists when you object or withdraw your consent
• Provide you with your personal information in a usable electronic format and transmit it to a third party (right to data portability)
• Restrict our use of your personal information
• Cease carrying out certain processing activities based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and the rights of third parties.

We endeavour to only send you information that’s relevant to you. As a Frank Kean e customer, please be assured that your information and online security is of the utmost importance to us.

Changes to our Privacy Policy

Any changes we may make to our privacy & cookies policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

This policy was last updated: 24th May 2018.