Privacy and Data Protection Policy
Drift Away Campers Ltd. Privacy and Data Protection Policy
Drift Away Campers Ltd. respects your privacy and will always ensure that Personal Data is protected.
The Personal Data that we hold may relate to your name, telephone number, email address but also to other data, such as your driving licence and proof of address. This information is held by us before, during and after your hire period to fulfil the requirements of our Self-Drive Hire Insurance providers and also as security to ensure that our VW Campervans are returned to us in the same condition that they leave our premises and to ensure all driving fines, parking fines and tolls are paid and to avoid driver fraud.
In this 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, (online) sales promotions, marketing actions, sponsored social media platforms, etc. that are provided or operated by us or on our behalf.
This Policy applies to all your Personal Data collected by (or on behalf of) Drift Away Campers Ltd., referred to in this Policy as “we”, “us” and ”our”.
If you accept the provisions of this Policy, you are agreeing to us processing your Personal Data in the ways that are set out in this Policy.
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?
The entity which is responsible for the processing of your Personal Data is:
Drift Away Campers Ltd., The Railway Cottage, Mullanboys, Inver, Co. Donegal, F94 R3P9.
3. Who can you contact in case you have questions or requests ? The Data Protection Contact Point
If you have any questions or requests concerning the application of this Policy or to exercise your rights, as described in this Policy, you may contact us as: firstname.lastname@example.org
or at: Drift Away Campers Ltd., The Railway Cottage, Mullanboys, Inver, Co. Donegal, F94 R3P9.
4. Key Principles
We value your Personal Data entrusted to us and we are committed to processing your Personal Data in a fair, transparent and secure way. The key principles we apply are as follows:
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 la
5. Processing of your Personal Data: Which personal data do we collect and on which Legal Grounds
Whenever we require your Personal Data, we will always clearly inform you which of your Personal Data we collect.
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
We will only process your Personal Data for specified, explicit and legitimate purposes and we will not process your Personal Data further in a way that is incompatible with those purposes.
Such purpose can be the execution of a hire period for one of our VW Campervans which you have placed, the improvement of your visit on one of our websites, the improvement of our products and services more generally, the offering of services or applications, marketing communications and actions, etc.
As part of our marketing activities, we may use your personal information (including, where permitted by you) to analyse your suitability for hire of our VW Campervans in accordance with the requirements of our Insurers. We may do this by phone, post, email, text or through other digital media. Where we do so we rely on the lawful processing ground of legitimate interest and our legitimate interest is to develop relationships with our existing customers and to assess our performance and standards.
When you hire a VW Campervan we will ensure your suitability for insurance as required by our Insurers and as required by law. This may include verification of penalty points or endorsements on driving licences or records of past claims.
We may also use your personal information to manage our everyday business needs, including accounting and to prevent fraud. Where we do so we rely on the lawful processing ground of legitimate interest and our legitimate interest is in the effective management of our business.
As we are reliant on our Insurers consent to permit you to avail of our Self-Drive Insurance Policy, we manage personal data in line with their recommendations, requirements and terms and conditions.
7. Keeping your Personal Data accurate and up-to-date
It is important for us to maintain accurate and up-to-date records of your Personal Data for the purposes of hiring our VW Campervans. Please inform us of any changes to or errors in your Personal Data as soon as possible by contacting us at the Data Protection Contact Point (see section 3 “Who can you contact in case you have questions or requests?”). We will take reasonable steps to make sure that any inaccurate or outdated Personal Data is deleted or adjusted accordingly.
8. Access to your Personal Data
You have the right to access your Personal Data which we are processing free of charge and, if your Personal Data is inaccurate or incomplete, to request the rectification or erasure of your Personal Data. If you require further information in relation to your privacy rights or would like to exercise any of these rights, please contact us at the Data Protection Contact Point (see section 3 “Who can you contact in case you have questions or requests?”).
We will endeavour to respond to your request within a month. If we are unable to deal with your request within a month we may extend this period by a further two months and we will explain why.
9. How long do we Keep your personal data
We may hold your personal information for a period of 7 years from the date of completion of a contract. We may hold this data for a longer period if we are legally required to do so. We reserve the right to hold the €1000 Security Deposit for a period of 14 days after the return of a hired vehicle to ensure all tolls, parking and speeding fines are paid.
10. Protecting your Personal Data
We have a set of technical and organisational security measures in place to protect your Personal Data against unlawful or unauthorised access or use, as well as against accidental loss or damage to their integrity. They have been designed taking into account our IT infrastructure, the potential impact on your privacy and the costs involved and in accordance with current industry standards and practice.
Your Personal Data will only be processed by a third party Data Processor if that Data Processor agrees to comply with those technical and organisational data security measures.
Maintaining data security means protecting the confidentiality, integrity and availability of your Personal Data:
a). Confidentiality: we will protect your Personal Data from unwanted disclosure to third parties.
b). Integrity: we will protect your Personal Data from being modified by unauthorised third parties.
c). Availability: we will ensure that authorized parties are able to access your Personal Data when needed.
Our data security procedures include: access security, backup systems, monitoring, review and maintenance, management of security incidents and continuity, etc.
12. Disclosure of Personal Data
Depending on the purposes for which we collect your Personal Data, we may disclose it to the following categories of recipients, which will then process your Personal Data only within the framework of these purposes:
a). Third Party Service Providers: We may share your personal information with third party service provides that perform services and functions at our direction and on our behalf such as our accountants, IT service providers, printers, legal advisers and other business advisors, marketing companies who carry out marketing campaigns on our behalf and providers of security and administration services. We may also share your information with third party service providers who provide services to you such as insurance companies and car rental companies.
b). Insurance Companies and Motor Assessors: We may pass your information to insurance companies and/or motor assessors appointed by us, you, a third party or an insurance company.
c). An Garda Siochana, Government Bodies or officials: We may share your personal information with an Gardai or other government bodies or agencies where required to do so by law.
Please be aware that third party recipients listed above – especially service providers who may offer products and services to you through – 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. 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.
Your choices on how you want to be contacted
In this context, you can make a variety of choices about how you want to be contacted by us, through which channel (for example, email, mail, social media, phone…), for which purpose and how frequently by following the unsubscribe instructions included in the communication or contacting us at email@example.com
Your Personal Data
You may always contact us at the Data Protection Contact Point (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.
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.
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).
You may also object to the use of your Personal Data for direct marketing purpose or to the sharing of your Personal Data with third party for the same purpose.
You may withdraw your consent at any time to the continued Processing of the Personal Data that you have provided to us by contacting us at the Data Protection Contact Point (see section 3 “Who can you contact in case you have questions or requests?”). 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).
Please note that these rights are in some circumstances limited by data protection legislation. Finally, please note that you have the right to file a complaint with the Data Protection Commissioner.
14. Marketing from Drift Away Campers Ltd.
If you do not wish to hear from us about special offers and promotions by way of post, email, phone, text or digital media please let us know by contacting us at firstname.lastname@example.org
15. Legal information
The requirements of this Policy supplement, and do not replace, any other requirements existing under applicable data protection law. In case of contradiction between what is written in this Policy and requirements in applicable data protection law, applicable data protection law will have priority.
Drift Away Campers Ltd. may amend this Policy at any point in time. Where this happens we will alert you of any changes and we will then ask you to re-read the most recent version of our Policy and to confirm your acceptance thereof. You can also check this Policy periodically on www.driftawayvwcampers.com to inform yourself of any changes.
In this Policy, the following terms have the following meanings:
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 Drift Away Campers Ltd. 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 to the 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). Personal Data is any information that may relate to your name, telephone number, email address but also to other data, such as your driving licence, driving claims history, proof of address, (geo-)location, etc.
e). Processing means the collection, accessing and all forms of use of your Personal Data.
Updated Policy: 5/1/2022