BACKGROUND:

John Mulholland Motors Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.johnmulhollandmotors.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

  1. Definitions and Interpretation

    In this Policy the following terms shall have the following meanings:

    “Account”

    means an account required to access and/or use certain areas and features of Our Site;

    “Cookie”

    means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;

    “Cookie Law”

    means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

    “personal data”

    means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and

    “We/Us/Our”

    means John Mulholland Motors Limited, a limited company registered in Northern Ireland under company number NI 03684, whose registered address is 211A Castle Road, Randalstown, County Antrim BT41 2EB.

  2. Information About Us
    1. Our Site is owned and operated by John Mulholland Motors Limited, a limited company registered in Northern Ireland under company number NI 03684, whose registered address is 211A Castle Road, Randalstown, County Antrim BT41 2EB.
    2. Our VAT number is GB 516522170.
    3. Our Data Protection Officer is Ryan Forsythe, and can be contacted by email at ryan.forsythe@johnmulhollandmotors.com, by telephone on 028 9447 3903, or by post at 211A Castle Road, Randalstown, County Antrim BT41 2EB.
    4. John Mulholland Motors Limited is an appointed representative of ITC Compliance Limited which is authorised and regulated by the Financial Conduct Authority.
  3. What Does This Policy Cover?

    This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

  4. Your Rights
    1. As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
      1. The right to be informed about Our collection and use of personal data;
      2. The right of access to the personal data We hold about you (see section 12);
      3. The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
      4. The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
      5. The right to restrict (i.e. prevent) the processing of your personal data;
      6. The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
      7. The right to object to Us using your personal data for particular purposes; and
      8. Rights with respect to automated decision making and profiling.
    2. If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
    3. For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
  5. What Data Do We Collect?

    Depending upon your use of Our Site, We may collect some or all of the following personal data (please also see section 13 on Our use of Cookies and similar technologies:

    1. title;
    2. name;
    3. date of birth;
    4. gender;
    5. address including time at address;
    6. occupation including time employed;
    7. marital status;
    8. housing status;
    9. contact information such as email addresses and telephone numbers;
    10. product information such as make, model and budget;
    11. IP address;
    12. web browser type and version;
    13. operating system;
    14. a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
  6. How Do We Use Your Data?
    1. All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPRat all times. For more details on security see section 7, below.
    2. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
      1. Personalising and tailoring your experience on Our Site;
      2. Personalising and tailoring Our productsfor you;
      3. Replying to emails from you;
      4. Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by following the instructions in the footer of all email correspondence;
      5. Market research;
      6. Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
    3. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone , text messageand/orpost with information, news and offers on Our productsandservices. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
    4. You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
    5. We use the following automated system for carrying out certain kinds of decision-making. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the GDPR gives you the right to do so.
    6. The following automated decision-making method(s) may be used:
      1. Service or vehicle maintenance reminders via email and/or telephone.
    7. We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
      1. Personal data for non-customers will be retained for 1 year;
      2. Personal data for customers will be reviewed every 5 years and retained for no longer than 7 years.
  7. How and Where Do We Store Your Data?
    1. We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
    2. Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under theGDPRby ensuring only highly reputable 3 rd party suppliers are used.
    3. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
    4. Steps We take to secure and protect your data include:
      1. Please see our Data Protection Policy.
  8. Do We Share Your Data?
    1. We may share your data with other companies in our group.
    2. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
    3. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR by ensuring only highly reputable 3 rd party suppliers are used.
    4. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
  9. What Happens If Our Business Changes Hands?
    1. We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
    2. In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
  10. How Can You Control Your Data?
    1. In addition to your rights under the GDPR, set out in section 4, whenyou submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emailsandat the point of providing your details .
    2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
  11. Your Right to Withhold Information
    1. You may access Our Site without providing any data at all.
    2. You may restrict Our use of Cookies. For more information, see section 13.
  12. How Can You Access Your Data?

    You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at info@johnmulhollandmotors.com, or using the contact details below in section 14.

    1. Our Use of Cookies
      1. Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our productsand services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.
      2. All Cookies used by and on Our Site are used in accordance with current Cookie Law.
      3. Before Cookies are placed on your computer or device, you will be shown a Cookie prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
      4. Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.9, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
      5. The following first party Cookies may be placed on your computer or device:

        Name of Cookie

        Purpose

        Strictly Necessary

        _cfduid

        Used by the content network, Cloudflare, to identify trusted web traffic.

        Yes

        jmm_session

        Stores encrypted data about the current user/session

        Yes

        vsid

        Unclassified

        Yes

        XSRF-TOKEN

        Stores an encypted user token used to authenticate ajax and post requests

        Yes

        john-mulholland-motors-cookie-notice

        Stores a single digit value when the user has accepted the cookie notice

        Yes

      6. Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
      7. The analytics service(s) used by Our Site use(s) Cookies to gather the required information.
      8. The analytics service(s) used by Our Site use(s) the following Cookies:

        Name of Cookie

        First / Third Party

        Provider

        Purpose

        _ga

        Third

        googletagmanager.com, providesupport.com

        Registers a unique ID that is used to generate statistical data on how the visitor uses the website

        _gat

        Third

        googletagmanager.com, providesupport.com

        Used by Google Analytics to throttle request rate

        _gid

        Third

        googletagmanager.com, providesupport.com

        Registers a unique ID that is used to generate statistical data on how the visitor uses the website

        ads/ga-audiences

        Third

        googletagmanager.com

        Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites

        fr

        Third

        connect.facebook.net

        Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers

        tr

        Third

        connect.facebook.net

        Unclassified

        p.gif

        Third

        typekit.net

        Pixel tracker for licensing

      9. In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
      10. You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
      11. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
    2. Contacting Us

      If you have any questions about Our Site or this Privacy Policy, please contact Us by email at info@johnmulhollandmotors.com, by telephone on 028 9447 3903, or by post at 211A Castle Road, Randalstown, County Antrim BT41 2EB. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

    3. Changes to Our Privacy Policy

      We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.