Personal data

“Personal data” or “Personal information” means any information identifying a person or information from which a person can be identified.

Any personal information you provide to us, whether through our contact form or any other form will not be released, sold, or rented to any entities or individuals outside of Wheels We Deliver other than as provided for in this Privacy Policy.

Purpose of this Privacy Statement

This Privacy Statement explains the kinds of information we may obtain from or about you or other individuals, whether as a visitor to our website or as a user of our services or by submitting forms or providing other information or feedback to us; how we may use that information (together with information provided offline or via other means); and who we may share that information with.

Wheels We Deliver respects an individual’s right to privacy and we are committed to complying in a transparent manner with applicable laws including the Data Protection Acts 1988 to 2018 and General Data Protection Regulation (GDPR) as well as being clear with our customers (and their customers and clients) and job applicants (whether current or former) and other users of our website about what we do with their personal information. We will only collect, handle and store personal information as described in this policy. Any personal information provided to us and/or which we obtain will be kept secure and confidential using appropriate technical measures.

Customers Personal Data

We may collect and process personal data relating to our customers (and their customers and clients), suppliers and job applicants through our website (including but not limited to comment boxes, forms, links and website usage) and/or in your offline interactions with us (whether via phone, email, post or surveys) and we may combine the data provided through the various sources.

Processing of personal data includes collecting, recording, storing, altering, disclosing, destroying, and restricting of personal data.

As part of the services that we provide to customers, we may need to obtain and process certain data. If we do not receive certain information, we may not be able to provide the service. By way of example, personal data such as names, addresses and phone numbers are required to transport goods from one location to another. Likewise, unless we obtain and retain certain data, we may not be able to comply with our legal obligations.

Accuracy of Personal Data

It is important that the personal data we hold about you is accurate and current. You agree to notify us without delay in the event of any change in the personal data that we hold about you, to enable us to comply with our obligations, including to keep information up to date. You agree that any data you provide to us will be true, complete and accurate in all respects.

Contact Details

15, Belvedere Pl, Mountjoy, Dublin 1, D01 V045
Phone: (01) 855 0100
GDPR@Wheelswedeliver.com

Purpose & Legal basis for processing your data

Why we collect and use your data

We collect and use your personal information when the law allows us to. Most commonly, we collect and use your personal information in the following circumstances:

  1. Where we need to perform a contract we have entered into with you.
  2. Where we need to comply with a legal obligation.
  3. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We will only collect personal information from or about you which is necessary to:

  • Provide this website to you;
  • To personalise your experience of our website where you have consented to non-essential cookies;
  • Provide courier and delivery services to you;
  • Set up and administer your account with us;
  • Maintain our relationship with you and investigate any queries, complaints, disputes or accidents;
  • Contact you for direct marketing purposes, to the extent only that same is permissible under applicable law;
  • Provide you with information relating to our services, to the extent only that same is permissible under applicable law;
  • To communicate with you, including to respond to information requests /enquiries submitted and/or to the extent that same is permissible under applicable law, to obtain your feedback on our products and services;
  • To notify you about changes to contracted services relevant to you;
  • To obtain credit references, credit checks and for debt collection, fraud detection and prevention and risk management purposes.
  • To obtain your feedback on services
  • To comply with all relevant law
  • To manage your safety and security while you are on our premises
  • To investigate, exercise or defend legal claims or other claims of a similar nature.

Change of Purpose

We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Legal basis for holding your data

Consent

Where you have explicitly agreed to us processing your information for a specific reason such as marketing using the soft opt-in per ePrivacy directive for all electronic marketing or explicit consent for us to process any special category of data about you.

In the context of the sale of our services to a customer, we rely on Regulation 13(11) of the ePrivacy Regulations, which allows the use of opt-out marketing for similar services.

Where consent is relied upon as a basis for processing of any personal data, you will be presented with an option to agree or disagree with the collection, use or disclosure of personal data and to withdraw your consent at any time.

Where we process special categories of information relating to your racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, biometric data or sexual orientation, we will always obtain your explicit consent to process such data unless this is not required by law or the information is required to protect your health in an emergency.

Where lawful basis is a statutory or contractual requirement, if the individual is obliged to provide the personal data, failure to provide this information may result in us being unable to provide our services.

Contract

Where you have entered into a contract with us and agreed to our Terms and Conditions or such other terms as you agree to and the processing is necessary to perform this service or in order to take steps at the request of the customer prior to entering into a contract;

Where lawful basis is a statutory or contractual requirement, if individual is obliged to provide the personal data, failure to provide this information may result in us being unable to provide our services.

Compliance

Processing your personal data may be necessary so that we can comply with any legal obligation we have such as keeping records for Revenue or tax purposes or providing information to a public body or law enforcement agency. We may also be required by law to process that data in order to ensure we meet our fraud prevention and anti-corruption obligations. The processing may also be necessary for the establishment, exercise or defence of legal claims.

Legitimate Interest

Processing may be necessary for the purposes of a legitimate interest pursued by us to safeguard the safety and security of Wheels We Deliver’s employees, property, customers, buildings, information located or stored on the premises and assets, and those of its service providers, consultants, and advisors that assist Wheels We Deliver in carrying out its functions. It may also be necessary:

  • to provide our services to you or your customers (and their customers and clients) and other third parties;
  • to ensure that our services are well-managed;
  • to ensure that complaints are managed effectively;
  • to prevent fraud, to enhance our service offerings;
  • to keep you and your customers informed about the service we are currently providing;
  • to inform recruitment decisions taken about appointments and new hires; and
  • to operate our business generally and manage and administer our services to clients, suppliers and potential candidates and drivers.
  • From time to time we may conduct customer satisfaction surveys. Where we do so we rely on the lawful processing of legitimate interest to enhance our service delivery. A withdrawal option will be provided in all survey communication thereafter.

 

Personal Data we may collect

We may collect the following personal data:

  • Names
  • Business and/or home addresses
  • Eircode/Postcode
  • Telephone number (personal or work number)
  • Fax numbers
  • Email address
  • IP addresses
  • Vat number
  • Usernames and passwords
  • CCTV footage in our Head office
  • Bank details to process the financial transaction

While we may require credit or debit card details for payment, we do not store these details on our systems.

We also hold any other personal information that you choose to provide to us when you complete our online contact forms or otherwise make contact with us.

We may also receive your data indirectly from our customers who provided your name, address & phone number to enable us to deliver a consignment to your address as instructed by our customer.

All processing is conducted in a secure manner via a third party portal. 

 

Potiential Candidates/Drivers

Using email to communicate

Any information you send to us via email is sent via an unsecured email link. Due to the nature of the internet, there is a possibility that unsecured (unencrypted) email could be intercepted and read by third parties. Wheels We Deliver accepts no responsibility for any interception of confidential information (including information in a CV) that you send in an unsecured (unencrypted) email message.

Right to Hire

Any employment agency, person or entity that submits an unsolicited CV to us, does so on the understanding that we have the right to hire that applicant without any hiring fee owed.

Unsolicited Applications

If you are interested in being considered for employment/driver by Wheels We Deliver you may provide us with your CV. We will then match your qualifications and experience to the position you applied for, or any other current job opportunity. If your profile corresponds to our requirements, we may contact you.

The personal data you provide us will be used for the purposes described above and retained as described below.

Deletion and Rectification of your personal data

Personal data arising from unsolicited job applications, where the job applicant is not offered a job, will be deleted within 3 months. Unsuccessful candidate’s personal data for solicited jobs will be held for a maximum of 13 months.

Verification checks may be required for specific roles and if so required, this fact will be identified in the job advertisement. Verification checks include the following:

  • Reference checks
  • Proof of Identity
  • Proof of Activity
  • Proof of Residency
  • Proof of the Right to Work
  • Proof of Penalty Points
  • Proof of Loss of Licence

Wheels We Deliver may carry out pre-contract medicals as part of the recruitment process.

Upon commencement of employment, we may process the following personal data, depending on specific roles:

  • GPS trackers during work hours only
  • Body size for company uniforms
  • Photographic Driver ID
  • CCTV in a limited number of specialised vehicles

 

Who we share your data with

Your personal information may also be processed by other organisations on our behalf for the purposes outlined in this Privacy Policy. We may disclose your information to our Auditors, Bankers, Clients, Government bodies, Health and Safety consultants, Human Resources consultants, Insurance providers, IT providers, Law Enforcement Agencies, Legal Advisers, Pension Brokers, Revenue, Service Providers, Social Welfare, Subcontractors, and to possible successors to all or part of our business.

Processing your information outside the EEA

Some of third parties we share your data with may reside outside the European Economic Area (which currently comprises the Member states of the European Union plus Norway, Iceland and Liechtenstein).  If we do this,  your information will be treated to the same standards adopted in Ireland and include the following data protection transfer mechanisms:

  • Model Clauses (also known as Standard Contractual Clauses) are standard clauses in our contracts with our service providers to ensure that any personal data leaving the EEA will be transferred in compliance with EU data protection law. Copies of our current Model Clauses are available on request.
  • Transfers to countries outside the EEA which have an adequate level of protection as approved by the European Commission (such as the United Kingdom).
  • Transfers are permitted in specific situations where a derogation applies as set out in Article 49 of the GDPR. For example, where it is necessary to transfer information to a non-EEA country to perform our contract with you.

 

Safeguarding your Personal Data

We have implemented appropriate technology and organisational standards to safeguard your data including

  • transparent data collection procedures
  • training employees in data protection and security measures
  • encryption where feasible
  • data minimisation as the default
  • data protection risk management embedded
  • integrating data privacy into IT policies and operational policies

We operate role-based access, secure back up procedures and regular testing to protect your data against any unauthorised or illegal processing by internal or external parties.

 

Retention of Data

We have implemented appropriate technical and organisational standards to safeguard your data including

  • transparent data collection procedures
  • training employees in data protection and security measures
  • encryption where feasible
  • data minimisation as the default
  • data protection risk management embedded
  • integrating data privacy into IT policies and operational policies

We operate role-based access, secure backup procedures and regular testing to protect your data against any unauthorised or illegal processing by internal or external parties.

 

Where Wheels We deliver is the Data processor

Where you, as a data controller, engage the services of Wheels We Deliver, we will act as data processors on your behalf. In doing so, we will:

  • Only process personal data under a Contract in accordance with your reasonable written instructions and in accordance with applicable Data Protection Legislation.
  • Adopt appropriate technical and organisational measures against accidental disclosure, loss or destruction of personal data;
  • Inform you promptly in the event of unauthorised disclosure, loss or destruction of any personal data processed on your behalf.
  • Refer to you any requests, notices or other communication from data subjects, the Office of the Data Protection Commission or any other law enforcement agency relating to personal data processed on your behalf.
  • Ensure that all Wheels We Deliver personnel processing personal data are under an obligation of confidentiality;
  • Make available reasonable information necessary to demonstrate compliance with our data protection obligations.
  • Make available such information and assistance as are reasonably necessary to you to comply with your obligations to respond to requests for exercising the data subject’s rights, to report personal data breaches and to conduct Data Protection Impact Assessments and prior consultation with data protection authorities.
  • Comply with our obligations to you in respect of sub-processing and third-country transfers
  • Delete or return all personal data processed on your behalf, upon the termination of any services provided by us to you.

 

Your Rights

About Your Rights

Under data protection law you have the right to access, erase or correct information held about you in certain circumstances, and to have some of that data (if held by Wheels We Deliver) provided to you in a portable form. You have the right to request a copy of any personal information we hold about you. We will endeavour to comply with such requests within one month, but where any such request is unusually onerous, we may extend that time by a further two months. In fulfilling such a request, we may request a copy of ID to confirm your identity. To make such a request, please write by sending an email to GDPR@Wheelswedeliver.com. See below for full details of your rights.

Right of access to Personal data we hold about you

When do I have the right to access my personal data from Wheels We Deliver

You have a right to request confirmation of whether we are processing your personal data. Where we process any personal data relating to you, you have the right to obtain confirmation of same from us, and to have access to your data.

What information will Wheels We Deliver provide me

If we are processing your personal data you are entitled to access a copy of all such personal data processed by us. We will also provide the following information:

  • why we are processing your personal data
  • the types of personal data processed
  • the third parties or categories of third parties to whom the personal data have been or will be disclosed. We will inform you if any of the third parties are outside the European Economic Area (EEA) or international organisations
  • how your personal data is safeguarded where we provide your personal data outside the European Economic Area or to an international organisation
  • the length of time we will hold your data or if not possible, the criteria used to determine that period
  • your right to lodge a complaint with the Data Protection Commission - info@dataprotection.ie
  • where we have collected your personal data from a third party, we will provide you with the information as to our source of your personal data
  • any automated decision-making, including profiling which includes your personal data. We will provide you with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.
How long wil it take to receive my personal data

We will provide you with a copy of the personal data we are currently processing within one month of request. In rare situations, if we are unable to provide you with the data within one month we will notify you within one month of your request explaining the reason for the delay and will commit to delivery within a further two months.

How much will it cost me to receive my personal data

We will not charge for providing your personal data unless we believe the request is excessive and the cost of providing your data is disproportionate to your request.

Can I receive my persoanl data electronically

You can request your personal data by electronic means and we will provide your personal data in a commonly used electronic form if technically feasible.

What will Wheels We Deliver do if another persons personal data is shared with my personal data

If the information you request reveals details, directly or indirectly, about another person, we may have to seek consent from that person before we can let you see that information. In certain circumstances, where disclosure would adversely affect the rights and freedoms of others, we may not be able to disclose the information to you, in which case you will be informed within one month of receipt of your request and given full reasons for that decision. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.

Contact Us at GDPR@Wheelswedeliver.com

Right of Rectification

Where you indicate that data we hold about you is inaccurate, we will rectify any such inaccuracies without undue delay and provide confirmation of same.

Where we have disclosed inaccurate personal data to third parties, we will inform them and request confirmation that rectification has occurred unless this proves impossible or involves a disproportionate effort. We will also provide you with details of the third parties to whom such personal data has been disclosed if you so request.

Contact us at GDPR@Wheelswedeliver.com

Right to Erasure (Right to be forgotten)

When have I the right to all my personal data being deleted

You have the right to have your personal data deleted if:

  • The personal data is no longer necessary in relation to the purpose(s) for which it was collected/processed
  • You are withdrawing consent and there is no other legal ground for the processing
  • You object to the processing and there are no overriding legitimate grounds for the processing
  • The personal data has been unlawfully processed
  • The personal data has to be erased so that we are in compliance with a legal obligation
  • The personal data has been collected in relation to the offer of information society services.
When do I not have the right to all my personal data being deleted

We will not be obliged to erase your personal data or to inform other third parties of your request were processing your personal data is necessary:

  • for exercising the right of freedom of expression and information;
  • for compliance with a legal obligation that requires processing by EU law or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;
  • for reasons of public interest in the area of public health;
  • for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in so far as your right to erasure is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
  • for the establishment, exercise or defence of legal claims, 

in which case you will be informed within one month of receipt of your request and given the reason for our decision. We will also inform you of your right to lodge a complaint with the relevant supervisory authority and seek a judicial remedy.

What hapens if Wheels We Deliver have made my personal data public 

If we have made your personal data public, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform those who are processing your personal data that you have requested the erasure but you appreciate we cannot guarantee erasure by such third parties.

What happens is Wheels We Deliver has disclosed my personal data to third parties

Where we have disclosed your personal data in question to third parties, we will inform them of your request for erasure where possible. We will also confirm to you details of relevant third parties to whom the data has been disclosed where appropriate.

Contact us at GDPR@Wheelswedeliver.com

Right to Restriction of Processing

When can I restrict processing

You may have processing of your personal data restricted:

  • While we are verifying the accuracy of your personal data which you have contested
  • If you choose restricted processing over erasure where processing is unlawful
  • If we no longer need the personal data for its original purpose but are required to hold the personal data for the establishment, exercise or defence of legal claims
  • Where you have objected to the processing (where it was necessary for the performance of a public interest task or for the purpose of legitimate interests), and we are considering whether our legitimate grounds override.
What happens if Wheels We Deliver has disclosed my personal data to third parties

Where we have disclosed your personal data in question to third parties, we will inform them about the restriction on the processing, unless it is impossible or involves disproportionate effort to do so.

How will I know if the restriction is lifted

We will inform on an individual basis when a restriction on processing has been lifted.

Please note that where processing of your personal data has been restricted, such personal data, with the exception of storage, will only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the right of another natural or legal person or for reasons of important public interest of the EU or of a Member State.

Contact us at GDPR@Wheelswedeliver.com

Right to Data Portability

When can I receive my personal data in machine readable format

You will receive your personal data concerning you in a structured, commonly used and machine-readable format that supports reuse if:

  • processing is based on consent
  • processing is carried out by automated means.
Would Wheels We Deliver transfer the personal data to another service provider if I requested this

We can transfer this data to another company selected by you on your written instruction where it is technically feasible taking account of the available technology and the feasible cost of transfer proportionate to the service we provide to you.

Under what circumstances can Wheels We Deliver refuse

You will not be able to obtain or have transferred in machine-readable format, your personal data if we are processing this data in the public interest or in the exercise of official authority vested in us.

Will Wheels We Deliver provide me with my personal data if the file contains the persoanl data of others

We will only provide you with your personal data, ensuring we protect the rights and freedoms of others. Where personal data of another person may be on the same files as yours, we will redact the full details of the other person.

Please also note that we are not obliged to retain personal data for longer than is otherwise necessary in order to service any potential data portability request that you may make. We also reserve the right not to comply with your request where to do so would adversely affect the rights and freedoms of others in which case you will be informed within one month of receipt of your request and given full reasons for that decision. We will also inform you of your right to lodge a complaint with the relevant supervisory authority and seek a judicial remedy.

Contact us at GDPR@Wheelswedeliver.com

Right not to be evaluated on the basis of Automated Porcessing including Profiling

We do not have any automated decision-making processes. Where any such processes are introduced, we will provide you with the relevant information as required by law.

Right to Object

Have I already been informed about my right to object

We have informed you of your right to object prior to us collecting any of your personal data as stated in this Privacy Policy. You can object on grounds relating to your particular situation but it may prevent us supplying any services to you.

When can I object to Wheels We Deliver processing my personal data 

You can request us to stop processing your personal data unless:

  • we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms; or
  • the processing is for the establishment, exercise or defence of a legal right.

Please note that this right only applies where the basis for our processing is either:

  • for the performance of a task carried out in the public interest or in the exercise of an official authority vested in us
  • our legitimate interest or that of a third party

You have the right to object at any time to processing of personal data concerning you for direct marketing purposes.

Where you so object, we will no longer process this data for such purposes.

You may also object to the processing of your personal data for scientific, historical or statistical purposes unless the processing is necessary for the performance of a task carried out for reasons of Public interest.

Contact us at GDPR@Wheelswedeliver.com

Right to withdraw Consent

When can I withdraw consent

You can withdraw consent if we are processing your personal data based on your consent. Any processing based on your consent will cease upon the withdrawal of that consent. Your withdrawal will not affect any processing of personal data prior to your withdrawal of consent, or any processing which is not based on your consent.

Contact us at GDPR@Wheelswedeliver.com

Right to lodge a complaint

Can I lodge a complaint with the Data Protection Commission

You can lodge a complaint with the Data Protection Commission in respect of any processing by or on behalf of us of personal data relating to you.

How do I lodge a complaint

Making a complaint is simple and free. All you need to do is write to the Data Protection Commission giving details about the matter. You should clearly identify the organisation or individual you are complaining about. You should also outline the steps you have taken to have your concerns dealt with by the organisation, and what sort of response you received from them. Please also provide copies of any letters between you and the organisation, as well as supporting evidence/material. The Data Protection Commission will then take the matter up with us for you.

 

WWD -Po- 0021- REV0003 08 April 2022