PERSONAL DATA PROTECTION

Cedar Motors Limited:

"Personal data" means any information that can be used to identify you either directly (such as your name) or indirectly (e.g. using a unique customer number).

Generally speaking, we undertake to collect only the personal data necessary for each of the purposes for which we process your personal data.

The personal data we collect depends on our interaction with you and may include information about:

• Your identity and contact details (surname, first name, postal address, email address, telephone, etc.),
• Data related to your personal and/or professional situation (family situation, socio-professional category, etc.),
• Your payment and transaction data (payment type, discount granted, etc.),
• Data relating to our commercial relationship, in particular our interactions and contracts (order history, after-sales operations, service agreements, games, interaction with our call centre, etc.),
• Your vehicle identification data (brand, model, registration, VIN number, etc.),
• Your geolocation data (your consent is obtained when required by law),
• Data related to the use of the vehicle (mileage, journey, use of multimedia, etc.) and, where applicable, its battery (charge level, etc.),
• If you have a connected vehicle, data allowing control of the vehicle and, where applicable, its battery (locking/unlocking, pre-conditioning, battery charge programming, etc.), relating to driving mode (use of controls, acceleration, braking, etc.) or to the provision of connected services or on-board applications,
• Data needed to carry out loyalty, direct marketing, market research or survey actions (e.g. your vehicle preferences),
• Data relating to your digital profiles (online accounts),
• Data concerning the use of our websites and mobile apps, as well as our communications (number of visits, page visited, messages opened, etc.).

As such, the data required to respond to your request or meet the needs of a contract or legal obligation is pointed out in the collection forms. If you do not wish to provide the mandatory data, we may not be able to process your request or provide you with the relevant services. The other information is intended to get to know you better, in particular to send you customised advertisements. This information is therefore optional.

We encourage you to keep us regularly informed in writing of any changes to your personal data.

The products and services that we offer are primarily for adults. Therefore, we do not carry out any specific processing on minors.

We will provide you with explanations relating to the context of collection of your personal data, the purposes for which we process them and the duration for which we retain them.

We collect your personal data in particular when:

- You visit one of our websites, which may use cookies or other tracers,
- You contact us via an online form, email, telephone, live chat, visit to a dealership or by any other means,
- You participate in a game or event, or subscribe to one of our newsletters,
- You purchase a vehicle or a service (maintenance, repair, warranty, connected services),
- You use a connected vehicle,
- You respond to one of our studies or satisfaction surveys,
- You create a user account to access our services from your computer or smartphone,
- You interact with us on social media, including through the Facebook, Instagram and X (formerly Twitter) "Like", "Share" or " Tweet" buttons on our webpages, which can lead to collection and exchange of personal data between the social networks and us.

Within the context of our relationship, and in line with the context in which your personal data is collected, we may use your data to:

A - Manage our initial interactions
B - Manage our commercial relationship
C - Manage services provided by your connected vehicle and on-board applications
D - Conduct studies and analyses
E - Manage our marketing operations

We draw your attention to the fact that Facebook carries out activity and statistics reporting in anonymised form from visits to the "fan page" for the purposes of managing the promotion of Renault's activity, and can also use them to improve the Facebook advertising system. You can get more information about how Facebook processes personal data by consulting its privacy policy available at: https://www.facebook.com/about/privacy

When you are in contact with our call centres, our objective is to best meet your demands. To improve the quality of our services and to train and assess our employees, your calls may be recorded. However, you may oppose this at any time and without reason.

Some connected services or on-board applications that you have subscribed to use services offered by Google to provide you with map data or points of interest in your vehicle or on your smartphone. You can obtain more information about how Google processes your personal data by consulting its privacy policy available at: https://policies.google.com/privacy?hl=en-ie

When we send you messages on the screen of your vehicle, our objective is to inform you of the end of one of your service agreements and to suggest that you renew it.

Some connected services and on-board applications may require processing of your location data. Your consent is requested before the data is processed. You can withdraw your consent and suspend this processing at any time through your vehicle on screen settings, by contacting customer relations or through the relevant Renault phone application.

For some electric vehicles, when you connect your phone to your vehicle, your mobile phone number will be requested to send you notifications regarding the charge status of your battery. You can manage notifications preferences in the "My notifications" tab on the Renault application being used to view your battery status.

Information relating to the activation of your services, the sharing of your data and their suspension can be found by contacting your local dealer or by contacting our customer relations team by telephone or by using the appropriate link (see Your Rights section below for details). We are committed to respecting your privacy, but we remind you that it is your responsibility to inform any other user or the buyer of the connected services on the vehicle and the data collection activities that you have consented to. You should suspend any data collection activities from the vehicle (via the vehicle settings or contacting our customer relations team) before selling and/or transferring your vehicle.

Studies and analyses are conducted to measure our performance, assess the quality of our products and services and the level of customer satisfaction, and to continuously improve them.

We analyse the personal data of our customers and prospects, both the data they have provided to us directly (including data related to browsing on our websites and the use of our mobile applications, subject to consent) and data from third parties (subject to consent where necessary), to create algorithms that enable us to assess and/or predict their potential interests and preferences for our products and services (using scores and segmentation).

The use of such tools is defined as profiling by law. We believe it is in our legitimate interests to understand the preferences of our customers and prospects in order to provide them with content that meets their needs or desires. We have weighed up the respective interests and have put in place measures to ensure that your fundamental rights and freedoms are not breached.

The analysis activities are intended to provide you with personalised content, such as specific offers by email, on Renault phone applications, and content on our websites or third-party websites (e.g Facebook). For example, processing of this data may lead us to send you offers relating to the car segment likely to be of interest to you. This also enables us to not send you certain advertising offers if we understand that they will not match your interests.

More information is available on this point on request. If you do not wish us to send you offers based on profiling, you can object to them by referring to the "how to exercise your rights" section.

In accordance with law, we are committed to keeping your personal data only for the time necessary to achieve the purpose pursued, to meet your needs, or to meet our legal obligations.

In determining this time, we take into account, in particular, the following:

• The length of your contract,
• The time required to process your request or complaint,
• The length of time your user account has been open, unless it has been inactive for 3 years,
• Your interest in our brands,
• The need to keep a record of your interactions with us, to effectively manage our business relationship. This period will vary depending, in particular, on whether you have bought a vehicle or a service such as repair, or whether you have only interacted with us without entering into contracts with us, and
• Our legal or regulatory obligations (this is particularly the case for the technical data of our vehicles).

When we no longer need to use your personal data, it is deleted from our systems and records or made anonymous so that we can no longer identify you. However, it may be necessary to archive some of your personal data in order to be able to respond to any legal proceedings, throughout the statute of limitations provided for in the applicable legislation.

Within  Cedar Motors Limited and its network members, we ensure that only those people who are duly authorised for their functions and tasks to process your personal data are given access to your data.

We may share your personal data with our approved dealer network. We may also share your personal data with Renault SAS when you take part in our customer surveys or in relation to your vehicle warranty. We share your personal data with [the Nissan Group] in order to provide aftersales services where applicable. . Your consent will be obtained where consent is required by law. These entities may act as data controller, in accordance with their personal data protection policy, or as processor, to perform tasks according to the instructions we give them.

In order to process all or part of your personal data, we call upon trusted third-party providers, acting as processors, in accordance with our instructions and solely on our behalf, to fulfil the following functions:

For all of this data sharing, we ensure that we only work with trusted companies and secure these relationships (contracts, audits, guarantees and security tests, etc.).

• Hosting, operation or maintenance of our databases, websites and mobile applications,
• Provision of authentication services,
• Credit/debit card payment processors (including WorldPay);
• RAC, AXA, TNS/Kantar, Global Insurance Management or other provider of services directly to you;
• A purchaser or potential purchaser of our business or otherwise in the event of a merger, re-organisation or similar event;
• Customer relations management (call centres, communication tools, etc.);
• Provision of services relating to our marketing, including the sending of commercial offers;
• Organisation of competitions and events;
• Performance of studies and surveys;
• Any motor manufacturer from whom we purchase or hire goods (and their group companies) such as Renault SAS;
• Third party insurance providers;
• Credit reference and fraud prevention agencies to help us make credit decisions and fraud prevention checks (they may also share information about you with us);
• Debt collection agencies;
• Our legal or other professional advisers;
• An Garda Síochána, fraud prevention and identity authentication entities, other law enforcement agencies, government and tax authorities in the Ireland or abroad in order to detect, investigate and prevent crime (please note that fraud prevention agencies may also enable law enforcement agencies to access and use your information to detect, investigate and prevent crime);
• The courts in Ireland or abroad as necessary to comply with a legal requirement, for the administration of justice, to protect vital interests and to protect the security or integrity of our business operations.

For all of this data sharing, we ensure that we only work with trusted companies and secure these relationships (contracts, audits, guarantees and security tests, etc.).

Your data may be shared with social media companies (e.g Facebook) and other advertising partners (e.g Google) to match you on their sites and send you online personalised advertising and offers, this processing is carried out on the basis of our legitimate interest.

In some cases, we may share some of your personal data with partners, who will use it for their own purposes. In such a case, these partners shall act as data controllers and their personal data processing policy shall apply to the data shared. We make sure to ask you for your consent to this sharing when required by law, or at least to enable you to object.

We may also offer you the opportunity to use your social network login data. Please be aware that, in this case, you are sharing your profile information with us. The personal data shared depends on the configuration of the social network platform. Please note that these social networks apply their own privacy policies.

Finally, we may be required to communicate your personal data to third parties in order to comply with a legal obligation (e.g., to recover a traffic fine following a test drive) or an administrative or legal decision.

5.1- Your rights
You have several rights under personal data protection regulations:

A right to object to the processing of your personal data, provided you have grounds connected with your particular situation, and the right to request the limitation of your personal data processing, in some cases as provided for in law.

A right to object to any direct marketing: you can ask at any time not to receive our communications related to our offers, news and events. This right may, in particular, be exercised via the unsubscribe link in each marketing email. You can also object to profiling.

A right to withdraw your consent at any time, for the purposes for which we obtained your consent.

A right to information: you have the right to obtain clear, transparent and understandable information about how we use your personal data and about your rights. This policy is an example of this.

A right of access to your personal data: you have the right to obtain information concerning the processing of your personal data (including the data that is used, for what purposes, etc.) and a copy thereof.

A right of rectification: you have the right to correct your data if it is inaccurate or incomplete, despite our efforts to keep it up to date, enabling us to comply with our obligation to have up-to-date data about you.

A right of restriction of processing: you have the right to obtain restriction of the processing in certain circumstances.

A right to the portability of your data, i.e., under certain conditions, the right to receive the personal data you have provided to us, in a structured, commonly used computerised format, and for it to be transmitted to a third party if technically possible.

A right to erasure (or right to be forgotten): you have the right to have your data erased or deleted. This right may be limited in light of our contractual or legal obligations (contract in progress) (prevention of legal action in particular).

Finally, you have the right to lodge a complaint with the Data Protection Commission) or your local supervisory authority about the processing of your personal data. We encourage you to contact us prior to any claim, so that we may attempt to resolve your problem together.

5.2- How do I exercise them?

To exercise any of your rights, call our customer relations team on 1800 771 771 or email data.privacy@cedarmotors.ie. You can unsubscribe from receiving our mailings at any time in the future by using the link that appears in the footer of every email that we send to you, or by post to:

Cedar Motor Limited
Cedar House, Joyce Way
Park West Business Park
Dublin 12
D12 RW59        

We may request certain information or documents (identity document, vehicle registration document) if we fail to identify you or to identify your vehicle data. 

Your personal data is stored on secure servers. We put in place, and require from our processors and partners, appropriate data security and data protection measures in line with the latest technologies.

When personal data processing involves transferring data, we ensure that this transfer is carried out under appropriate conditions that ensure an adequate level of protection, security and confidentiality.

When a digital account is created, entering a password that respects our security standards is mandatory and is part of our privacy policy. It is your responsibility to keep it secret.

Whenever possible, your data is processed in the European Economic Area (EEA). However, as some of our service providers or their processors are located in countries outside of the EEA, your personal data may be processed in those countries. Some of these countries may have different personal data laws from those of the EEA. In such a case, (i) we pay particular attention to ensuring that this transfer is carried out in accordance with applicable law and (ii) we put in place safeguards ensuring an adequate level of protection of your privacy and fundamental rights (in particular by using the European Commission's standard contractual clauses). Upon simple request sent to the address indicated in the "What are your rights?" section, we can provide you with more information on such transfers (in particular the European Commission’s standard contractual clauses).

We may change this information from time to time. We will inform you and/or seek your consent whenever necessary or required. We therefore recommend that you consult this policy each time you visit our website in order to review the latest version.

Last updated 10/11/2023