This privacy policy is issued by ETrawler Unlimited Company, trading as CarTrawler, and is the full owner of www.cartrawler.com (the “Website”). CarTrawler is the controller of your personal information when you visit the Website and when you apply for a role (“we”, “us” or “our”).
Who this policy applies to
This privacy policy applies to all visitors on the website and candidates for employment (each “you” or “your”). We respect your privacy and are committed to protecting it. We recognise your need for appropriate protection and management of the personal information we learn about you while you visit our site or while considering a role with CarTrawler. This privacy policy lets you know how we will use and protect that information. The information that we receive depends on what you do during your visit to our Website, and what service(s) are requested.
Collection and Use of Personal Information
Non-Identifying Information
We may collect information about your visit to and use of our Website, including sales data, traffic data and related site information. This information helps us evaluate and improve our site and may also be used for investment analysis purposes. We may share this information with reputable third parties, but only in an aggregate statistical form that includes no personally identifying information.
Device Information
We may collect information about your device, including your hardware model, operating system and version, unique device identifier, country and language settings, mobile network information, and information about the device’s interaction with our services.
Personal Information
Throughout this Website, you may have an opportunity to send us information relating to you, such as through the area where you may manage your booking, send emails, engage in chat, submit your CV, request newsletters or provide feedback. If you choose to apply for a role, you will be providing us with some level of personal information relating to you, including but not limited to contact details, passport number or driver licence number (for identification purposes), previous employment, salary expectations and your entitlement to work in Ireland. We may also process personal data that is provided to us on your behalf by recruiters, information you provide to us in interviews or through job boards and information that is provided by your referees. We may also use publicly available information to notify you of employment opportunities we think you would be suitable for.
Failure to provide us with the required information will result in us not being able to perform the processing activity.
Purposes of Processing and Legal Basis
This information will only be used by CarTrawler for the purposes for which it was obtained for, which may include allowing you to participate in interactive features of our services and notifying you about changes to our service. We may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information.
For the management of bookings, we process your data on the basis that it is necessary for a contract you have entered into.
In some circumstances we rely on consent for processing your data, this will include signing up to our newsletter, when applying directly for a role advertised in CarTrawler and when a third party is applying on your behalf. Where we process your personal data on the basis of your consent, you are free to withdraw that consent at any time. You can withdraw your consent by contacting us using the contact details at the bottom of this statement. If your consent relates to receiving our newsletter, you can use the unsubscribe link in the email to opt out of this consent. Please note that if you withdraw your consent, we may not be able to continue to provide the related service to you.
In some cases, we need to process data to ensure that we are complying with our legal obligations. For example, it is mandatory to check a successful applicant’s eligibility to work in Ireland before employment starts.
We rely on legitimate interest for reaching out to potential candidates for relevant roles, taking interview notes and checking references. Where we use this as a legal ground for processing, we consider that our processing is in line with candidate expectations and that there is a balance between our interests, and those of candidates. Candidates may object to any processing undertaken on the grounds of legitimate interest at any time.
Disclosure of Personal Information
We may disclose your personal information to these parties for one or more of the lawful purposes referred to above:
- Our agents;
- Service providers to help us provide our services and communicate with you ;
- Technical support providers, for example, companies assisting with our IT systems, companies providing hosting services;
- Recruitment and consulting agencies;
- Pre-employment screening services;
- Candidate assessment services;
- Professional advisers;
- Any member of the CarTrawler group of companies and corporate affiliates for the purposes outlined above;
- Third parties in connection with the sale or acquisition of any business or assets in which we are involved. For example, to third parties to whom we may choose to sell, transfer or merge any parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy;
- Other third parties who act as data processors on our behalf, as may reasonably be required in connection with the purposes referred to in this privacy policy or as otherwise required or permitted by applicable law.
We require all third parties that we share your data with, in order to fulfil the purpose it was obtained for, to protect the personal information they are provided with by implementing appropriate security measures and to meet the same standards of data protection as our own. They are prohibited from using the information for their own purposes.
If you are a successful job candidate, you should note that we engage a third party employee screening service provider to verify the details you provide on your employment history, and/or details about personal referees in order to conduct pre-employment reference checks.
We may also share your personal information for legal and safety reasons. We may retain, preserve or share your information if we have a good-faith belief that it is reasonably necessary to: (a) respond, based on applicable law, to a legal request; (b) detect, investigate, prevent and address fraud and other illegal activity, security or technical issues; (c) protect our rights, property or safety; (d) enforce our terms and conditions or any other contracts we have with you; or (e) prevent physical injury or other harm to any person or entity, including you and members of the public.
Data Security
We have put in place appropriate technical and organisational measures to protect against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal information. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breaches and we will notify you and any regulatory authorities of a breach where we are legally required to do so.
Data Transfers
The disclosures of your personal information described in this privacy policy involve the transfer of your personal data to a country outside of the European Economic Area (“EEA”). In these cases, we will ensure that appropriate measures are in place to protect your personal data and to comply with our obligations under EU data protection law. If you are based in the EEA, when your personal information is moved from your home country to a third country outside the EEA, some of these countries may not have the same data protection safeguards as your home country.
Some of our third party processors are based outside the EEA so their processing of your personal information will involve a transfer outside of the EEA. If we transfer your personal information out of the EEA, we will ensure a similar degree of protection is afforded to it.
Where your personal information is transferred to the US, we enter into Standard Contractual Clauses (in the form approved by the European Commission) with the recipients of your personal information. You can request a copy of our Standard Contractual Clauses by emailing [email protected].
When we transfer your personal information to recipients in the UK, we rely on the European Commission’s adequacy decision on data transfers to the UK. You can find further information in relation to this adequacy decision at: European Commission Adequacy Decision on transfers to the UK.
By providing us with your personal information, you agree to such transfers of your personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Third Party Links
Our Website may include links to websites, services, plug-ins and applications that are managed and controlled by third parties. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their data protection policies. Please note that this privacy policy does not apply in those cases. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
Retention
We retain your personal data in accordance with our record retention policy. The record retention policy operates on the principle that we keep personal data for no longer than is necessary for the purpose for which we collected it, and in accordance with any requirements that are imposed on us by law. This means that the retention period for your personal data will vary depending on the type and sensitivity of the personal data, the purposes for which we process your personal information and the applicable legal requirements. For example:
- Email Marketing – We will keep a copy of personal data that is required in order to send you marketing messages for as long as necessary to facilitate your marketing preferences. As part of this we will also retain certain information in relation to your transactions in order to allow us to customise our marketing messages.
- Candidate Data – We will retain your data on file for a period of 12 months in the event you are unsuccessful, so we can contact you should future suitable positions become available. We also retain your personal information for that period so we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.
Direct Marketing
We will only send you marketing communications where we have obtained consent to do so. If you opt in to receiving electronic marketing communications from us, you will find a link in the email on how to opt-out of receiving such marketing communications in future.
Use of “Cookies”
Cookies are small text files stored on your web browser that allow websites to identify you. The use of cookies is a common practice on many websites. For more detailed information on the cookies we use and the purpose for which we use them, see our Cookie Policy, which is available here.
Your Rights
You have the following rights, in certain circumstances, in relation to your personal data:
- Right to access the data – You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
- Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
- Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
- Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
- Right to data portability – You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine- readable format.
In order to exercise any of the rights set out above, please contact us using the contact details at the bottom of this statement. In limited circumstances, there are some restrictions to fulfilling data subject rights requests. This includes but is not limited to the prevention or detection of crime or breaches of ethics for regulated professions, important objectives of public interest matters, protection of judicial proceedings, protection of the data subject or rights and freedoms of others and enforcement of civil law claims.
Changes to our Privacy Statement
We keep our privacy statement under regular review and we will place any updates on this web page.
Questions and Complaints
If you have any queries or complaints in connection with our processing of your personal data, you can get in touch with us using the following contact details:
By post: Data Protection Officer, CarTrawler, Classon House, Dundrum Business Park, Dundrum, Dublin 14, Ireland
By email: [email protected]
You also have the right to lodge a complaint with the Irish Data Protection Commission if you are unhappy with any processing of your personal data by CarTrawler. Details of how to lodge a complaint can be found at (https://www.dataprotection.ie/docs/Raise-a-Concern/1716.htm) or you can call the Data Protection Commission at 353 (0)761 104 800.
