1. General

TRADELINK, a trading division of the Volkswagen Group Ireland Limited ("we"/"us"), are committed to protecting and respecting any personal information you share with us.

This statement describes what types of information we collect from you, how it is used by us, how we share it with others, how long we keep your information for, your rights, how you can manage the information we hold and how you can contact us.

We require and use your information in order to fulfil and deliver services associated to your vehicle and its maintenance. As a business we sometimes communicate product information, offers and services; however, we will only do this if you have already given us the appropriate permission. We will not send you unsolicited 'junk' email or communications, or share your data with anyone else. We do not sell your information to third parties, but we do work with closely selected partners who help us to provide you with the information, products and services that you request from us. For example, Allianz Worldwide Partners who provide roadside assistance on our behalf.

The contents of this statement may change from time to time so you may wish to check the latest statement page occasionally to ensure you are still happy to share your information with us. The latest version can be found on our website http://www.TradeLink.ie/privacy.

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2. Definitions

The data protection declaration of TRADELINK is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this data protection declaration, we use, among others, the following terms:

1. Personal data: Personal data means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. Data subject: Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing (i.e. You, the customer; an employee [in relation to the company as the employer]).
3. Processing: Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
4. Restriction of processing: Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
5. Profiling: Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
6. Pseudonymisation: Pseudonymisation is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
7. Controller or controller responsible for the processing: Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
8. Processor: Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
9. Recipient: Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
10. Third party: Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
11. Consent: Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

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3. What Information do we collect?

We collect information in the following ways:

Information you give us, about you and your vehicle when you engage with our main office, a member of our authorised dealer and repairer network, or via our websites and applications. We only collect information which is necessary, relevant and adequate for the purpose you are providing it for.

Information we get from your use of our services or service providers. We collect information about you or your vehicle when you use our website, applications and contact our customer care centres. We also obtain information about you or your vehicle from our authorised dealers and repairers. Some of this information does not identify you personally, but provides us with information about how you use our services and engage with us (we use this information to improve our services and make them more useful to you).

The information we collect includes some or all of the following:

1. Name (including title);
2. Address including Eircode;
3. Phone number;
4. Date of birth (only where and if strictly necessary);
5. Email address;
6. Vehicle information (including registration number, VIN, service reminders, mileage and warranty-covered repair information);
7. The date and time you used our services;
8. The pages you visited on our website and how long you visited us for;
9. Your IP address;
10. Your GPS location (where you have permitted access to this and only if relevant);
11. The internet browser and devices you are using;
12. Cookie, Pixels or Beacon information (for more information please see our Cookies policy);
13. The website from which you accessed our website;
14. Details of any transactions between you and us or members of our authorised dealer network;
15. Where you engage with us in a business context, we may collect your job title, company contact details (including email addresses), fleet size and company details;
16. Voice recordings of calls you make to our customer service centres;
17. "Live chat" records;
18. Any information within correspondence you send to us;
19. CCTV in our premises.

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4. How do we use this information?

TRADELINK will only process information that is necessary for the purpose for which it has been collected. If you do not provide us with the information we require, relevant and appropriate to the reason for which we request it, this may prevent you from fully availing of our services.

We may use the personal data we gather for any or all of the following purposes:

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5. How do we share this information?

We may, where applicable and if relevant, disclose your information to companies or organisations to which we pass the responsibility to handle services on our behalf such as roadside assistance, customer contact centres, direct marketing communications, market research or market analytics.

We will also share your information with our authorised dealers and repairers in situations where we need to pass your information to them to manage any request you have made of us. For example, where you have requested a test drive, we will need to share your personal information with your authorised dealers so that they can contact you to arrange for the test drive to take place.

We 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.

Your data will not be passed to any third-party for their own independent marketing purposes.

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.

There are circumstances where we share your information with our parent (or other companies within our Group) in order to fulfil orders, transactions or provide you with a service or information that you have requested. For example, the Manufacturer, VWGI AG/SA in COUNTRY, who is ultimately responsible for the warranty over the vehicles.

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6. How long do we keep your information for?

When we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws.

We do not retain personal information in an identifiable format for longer than is necessary.

We may need your information to establish, bring or defend legal claims. In these cases, we will always retain your personal information for 6 years after the date it is no longer needed by us for any other purposes listed under "How do we use your personal information".

The only exceptions to this are where:

• the law requires us to hold your personal information for a longer period, or delete it sooner;
• you exercise your right to have the information erased (where applicable as per section 6.d) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further How can I manage the information we hold about you).

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7. What are your rights?

You have a number of rights in relation to your personal information under data protection law. In relation to most rights, we will ask you for information to confirm your identity and, where applicable, to help us search for your personal information. Except in rare cases, we will respond to you within one month after we have received any request.

1. Right of confirmation

   You have the right to obtain from the controller the confirmation as to whether or not personal data which concerns you is being processed. Should you wish to avail of this right of confirmation, you may, at any time, contact our Privacy Officer

2. Right of access

   You have the right to obtain from the controller free information about your personal data stored at any time and a copy of such information. Should you wish to avail of this right of access, you may, at any time, contact our Privacy Officer

3. Right of rectification

   You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data which concerns you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Should you wish to exercise this right to rectification, you may, at any time, contact our Privacy Officer

4. Right to erasure (Right to be forgotten)

   You have the right to request from the controller the erasure of personal data which concerns you without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

   • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
   • The customer withdraws consent to which the processing is based and where there is no other legal ground for the processing
   • The customer objects to the processing and there are no overriding legitimate grounds for the processing
   • The personal data has been unlawfully processed
   • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject

   If one of the aforesaid reasons applies, and you wish to request the erasure of personal data stored by TRADELINK, you may, at any time, contact our Privacy Officer, who shall promptly ensure that the erasure request is complied with immediately.

5. Right of restriction of processing

   You have the right to request from the controller restriction of processing where one of the following applies:

   • The accuracy of the personal data is contested by the customer, for a period enabling the controller to verify the accuracy of the personal data
   • The processing is unlawful and the customer opposes the erasure of the personal data and requests instead the restriction of their use instead
   • The controller no longer needs the personal data for the purposes of the processing, but they are required by the customer for the establishment, exercise or defence of legal claims
   • The customer has objected to processing, pending the verification whether the legitimate grounds of the controller override those of the customer

   If one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by the TRADELINK, you may at any time contact our Privacy Officer, who will arrange the restriction of the processing.

6. Right to data portability

   You have the right to obtain from the controller the confirmation as to whether or not personal data which concerns you is being processed. Should you wish to avail of this right of confirmation, you may, at any time, contact our Privacy Officer

7. Right to object

   You have the right to object, on grounds relating to your particular situation, at any time, to processing of personal data which concerns you, which is based on public interest or in the legitimate interest of the Controller. This also applies to profiling based on these provisions.

   TRADELINK shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the customer, or for the establishment, exercise or defence of legal claims.

   If TRADELINK processes personal data for direct marketing purposes, you have the right to object at any time to processing of personal data which concerns you for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If you object to TRADELINK to the processing for direct marketing purposes, TRADELINK will no longer process the personal data for these purposes.

   In addition, you have the right, on grounds relating to your particular situation, to object to processing of personal data which concerns you by TRADELINK for scientific or historical research purposes, or for statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest. In order to exercise the right to object, you may directly contact our Privacy Officer

   Furthermore, you are free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use your right to object by automated means using technical specifications.

8. Automated individual decision-making, including profiling

   As a responsible company, we do not use automatic decision-making or profiling. Each customer shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the customer and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the customer's rights and freedoms and legitimate interests, or (3) is not based on the customer's explicit consent.

   If the decision (1) is necessary for entering into, or the performance of, a contract between the customer and a data controller, or (2) it is based on the customer's explicit consent, TRADELINK shall implement suitable measures to safeguard the customer's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

   If the customer wishes to exercise the rights concerning automated individual decision-making, he or she may at any time directly contact our Privacy Officer

9. Right to withdraw data protection consent

   You have the right to withdraw your consent to the processing of your personal data at any time. Should you wish to exercise the right to withdraw the consent, you may at any time directly contact our Privacy Officer

10. Right to lodge a complaint

    TRADELINK aims to resolve all queries or complaints that you may have. If you have any specific data protection concerns or a complaint, you can address it to our Data Protection Team at privacy@vwgi.ie or contact us at the address and telephone numbers in section 8 below.

If we cannot resolve your query, you have the right to contact the Office of the Data Protection Commissioner Office by using the details below:

Data Protection Commissioner
Canal House
Station Road
Portarlington
R32 AP23 Co. Laois
Telephone: +353 (0)761 104 8000
Telephone: +353 (0)57 868 4800
Email: info@dataprotection.ie
LoCall Number: 1890 252 231
Fax: +353 57 868 4757

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8. Information about TRADELINK

TRADELINK is a trading division of Volkswagen Group Ireland Limited (company registration number 436954, VAT registration number IE9654536U), whose registered office is at Block C, Liffey Valley Office Campus, Dublin 22 - D22 CF60.

Name and Address of the controller
The Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

TRADELINK
Block C
Liffey Valley Office Campus
Dublin 22
D22 CF60
Phone: + 1800 812 761
Email: customer care or service@VWGI.ie
Website: http://www.TradeLink.ie

Name and Address of the Privacy Officer
Any data subject may, at any time, contact our Privacy Officer directly with all questions and suggestions concerning data protection. TRADELINK is not required to appoint a Data Protection Officer.

All enquiries on data protection matters should be directed to our Privacy Officer, who can be contacted at the address above or by emailing:

Email: privacy@VWGI.ie

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