Contact Us
OHM Group
Clonlara Road, Baldonnell Business Park, Baldonnell, Dublin, D22 W1H9
Business: +353 (0) 1 403 4100

OHM Privacy Statement

This is the Privacy Statement of OHM Group (“OHM”) a registered business name of Armalou Holdings Limited under company registration number 450693. In this statement we use the terms “we”, “our” and “us” to refer to OHM.

OHM is a decentralised multi-disciplined organisation, offering key services such as Retail Sale of Automotive Vehicles, Specialist Service and Repair of Automotive Vehicles, Distribution of Automotive Vehicles, Retails Sale of Automotive Vehicle Parts and Peripherals, Retails Sale and Service of Industrial and Domestic Generators, and Lease of Commercial Property. The below table identifies the associated companies within the OHM Group.


Armalou Holdings Limited
Spirit Motor Group Limited
DAF Distributors Ireland LimitedSpirit Ford Limited
MAN Importers IrelandJaguar Land Rover Ireland Limited
DE Power Limited
Spirit Skoda Limited

The purpose of this Privacy Statement is to outline our position concerning the collection, use, retention, disclosure, and transfer of Personal Data which is gathered and processed by us. This Privacy Statement also sets out our information management practices.

At OHM we respect the privacy of all those individuals whose Personal Data we encounter, which includes the following:

  • All users of this Website,Social Media Pages or Apps;
  • Employees and contractors (including applicants for employment with OHM);
  • All members (including former employees) of OHM on sponsored pension schemes;
  • Business contacts and suppliers;
  • Customers and their Employees;
  • All Customers or prospective customer
For each of these categories of individuals, this Privacy Statement will explain why we collect and how we use the Personal Data we collect. We will ensure that we keep all Personal Data provided to it in accordance with our obligations under applicable data protection laws. We may update this Privacy Statement from time to time to reflect any material changes in technology, legislation or the data use practices which may materially affect the way in which we process Personal Data. You will always find the most up to date version on our website /site/privacy-and-legal/

This is not an exhaustive statement of all our data protection practices and we may apply specific policies within certain environments. We might include a separate privacy notice at the point of capturing data on a new service and any specific consents obtained or information provided in this way will apply specifically to that service and will supplement this Statement.

Who we are and how to contact us?

If you have any questions about this data protection statement, including any request to exercise your legal rights, please contact us by writing to our Data Compliance Officer (DCO), OHM, Clonlara Avenue, Baldonnell Business Park ,Baldonnell, Dublin 22, Ireland or via email dco@ohm.ie/ or via our Data Preference Centre /data-preferences/

The below sections of the Privacy Statement set out the type of Personal Data collected by us, the purposes for which such Personal Data is collected and processed and the lawful justifications for such processing in the context of the OHM Website.


1.What/ is Personal Data?

Personal Data is any information relating to a living individual that allows for the identification of that individual. Personal Data can include a name, address, contact details, an identification number, IP address, audio-visual or audio recordings of a person, details about an individual's location or any other detail(s) specific to that individual


2.Categories/ of personal data and how we use it.

We may collect, store, use, and share aggregate data such as statistical or demographic data. Aggregate data is information gathered and expressed in a summary form for purposes such as statistical or demographic analysis.

Aggregate data may be derived from your personal data but is not data that directly or indirectly reveals your identity. For example, we may aggregate your usage data of our website to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregate data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this data protection statement.

We temporarily store IP addresses of visitors to our website for associated performance metrics (i.e., data related to how well our software performs on our site) and to monitor and track application errors. Please note we will never access IP addresses without any operational or security need.


3.How/ we obtain your information?

We may collect your information though our website or social media platforms where you provide it to us, such as filling out forms, requests such as a brochure or contact us communication. We may also collect and store data available to us through our social media platforms, such as age, geo location, gender, interests, page likes.

OHM is not responsible for the privacy practices of any external websites or platforms which may be accessed or used in connection with a person’s use of this website or OHM social media pages. They are subject to their own privacy statements which may materially differ from those of OHM so users should review them for further information.


4.What/ Personal Data does OHM collect and use online?

OHM collects various types of Personal Data when a person uses this website or OHM social media. The following are examples of Personal Data collected by us:

  • Social Media Pages: Content such as messages and photographs, that are posted on social media pages on which OHM has a presence and may be made publicly available and may be used in connection with the operation and promotion of our social media pages, services, and this website. Data such as the name of your internet service provider, the website you visited us from, the parts of our site that you have visited, the date and duration of your visit, and information from the device (e.g., device type, operating system, screen resolution, language, country location, and web browser type) used during your visit. We may process this usage Data to facilitate access to our website (e.g., to adjust our website to the devices that are used).
  • This website uses cookies, web beacons, device identifiers, social plugins, tracking pixels, etc. “Cookies” are small pieces of information stored by your internet browser that collect data such as your browser type, your operating system, web pages visited, time of visits, content viewed, advertisements viewed, and other click stream data. We use cookies to help us tailor our websites and communications to your needs, to deliver a better, more personalised service and to remember certain choices you have made so you do not have to re-enter them. Cookies also enable us to identify traffic to our website including pages visited, visitor numbers and traffic paths taken. We may record which users opened and clicked any embedded links in communications sent by us to measure a campaign or a specific communications effectiveness. OHM does not deploy un-necessary cookies, such as analytics, marketing, targeting, tracking, or profiling cookies without consent.
  • We may use advertising networks to help present advertisements or other content on our website and other websites that display OHM advertisements. Advertising networks use cookies, web beacons, or similar technologies on your computer or mobile or other device to serve you advertisements or content tailored to interests you have shown by building a profile of your internet browsing on this website and other websites you have visited.
  • If content is posted that is deemed to be in breach of this Privacy Statement or the policies operated by such websites or social media platforms, such content may be removed by or at the request of OHM or the operators of those social media websites. If such inappropriate content is posted to a social media page that OHM controls, you can report it at the following address dco@ohm.ie/ and we will endeavor to ensure that appropriate action is taken in accordance with the OHM policies and the policies of the relevant social media platforms.

5.The/ purpose and legal basis for processing your information.

OHM collects and processes the Personal Data described below for a variety of purposes. As required by data protection laws, below is a summary of these purposes and the lawful justifications that support them:

a)To enter into and perform a contract with you.

We may process your information in order to enter into a contract with you or to provide you with a service which you have requested from us. For example, we need to process your personal information to provide you with a brochure or information about a product or service where you have requested it.

b)To comply with our legal obligations

We are required to process your personal information to comply with certain legal and regulatory obligations to which we are subject. For example, we are required to obtain certain records in accordance with Anti-Money Laundering regulation company, and revenue law which may include your personal information.

c)For our legitimate business interests

We may use your personal information for the purposes of carrying out activities that are in our legitimate interests (or those of a third party). Where we process your information for our legitimate interests, we ensure that there is a fair balance between our legitimate interest and your fundamental rights and freedoms.

If you engage with OHM, we may use your information to send you communications via email, post, SMS, or telephone on products and services that may interest you and that you would reasonably expect to receive, you can at any stage easily opt out of these communications by contacting us on dco@ohm.ie/ or by following the unsubscribe/opt-out link in the relevant marketing communication or through our Data Preference Center on this website.

We may use your personal information to manage our everyday business needs, including accounting, internal reporting needs, and market research, to progress and respond to legal claims, to ensure appropriate IT security and to prevent fraud. Our legitimate interest is the effective management of our business.

We may use your personal information to send you notifications or reminders of service appointmentsandto provide customer care. Our legitimate interest is connecting with our customers and keeping them notified of important events.

We may use your personal information in an aggregate form to classify our customers and to acquire an aggregated overview of our customer base in our legitimate interest. Such processing does not assess individual characteristics. Our legitimate interest is to grow our business, understand our customer base and provide products and services of interest to our customer base.

We may use your information which we collect, including personal information we obtain from publicly available sources such as social media, public directories etc. to help us understand our customers and provide products or services which may be of interest to you, in our legitimate interest.

If you are a business contact, we may acquire your contact data from reputable marketing agencies, which may include your personal data with the intention to provide you with information on products or services which may be of interest to you, in our legitimate interest. We will notify you of any such acquisition and you have the right to object to this at any time.

We may also contact you in the event of updates about our business such as opening hours, change in address, updates about our sites etc. We do this in our legitimate interest to keep our customers updated of changes within our organisation.

We may provide your personal information from contact forms collected via our websites to other OHM entities which are listed below. We do this in our legitimate interest to keep our customers supported by directing their requests to their preferred service.

You have the right to object to this and any of the above processing scenarios by contacting us on dco@ohm.ie/ or by visiting our Data Preference Centre /data-preferences/

d)With your consent

We will request your consent for the use of all cookies on our websites outside of strictly necessary and for tracking technologies within OHM marketing communications. You can withdraw your consent at any time by clicking “cookie settings” at the bottom of our webpage or by contacting dco@ohm.ie/ Please see our cookie policy for further information /site/cookies-policy/

Where you are a consumer prospect, we will request your consent for marketing related activities.

When you are applying for Finance on a product or service, we may seek your consent to share your data with the with our Financial Services Providers.

e)To protect your vital interests

We will in certain circumstances use your personal information to protect your vital interests or the interests of another.

Below is a summary of these purposes and the lawful justifications that support them:

Purpose

Description

Lawful Basis for Processing

Purchasing a Product or Service from an OHM Brand

We will process your personal data to provide you with the service you requested

The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract to which the data subject is party.

Application for Finance for an OHM Brand Product/Service

We may assist you in obtaining a Financial Services product or service.

We may seek your consent to share your data when making an application for a financial product

The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract to which the data subject is party.

The Data Subject has provided consent for the processing.

Notifications and Reminders

We may use your personal data to remind you of a scheduled service

We rely on our legitimate interest to connect with our customers.

Marketing to Potential Customers and Customers

Information is collected by our Sales staff, and/or Marketing staff when any customer, or potential customer, contacts us.

Where you are a Business Prospect or Existing OHM Customer

The processing is in our legitimate interests to develop our business by providing information that is relevant and where the data subject has not opted out of the processing.



Where you are a Consumer Prospect

The Data Subject has provided consent for the processing.

Profiling

We may use your personal data that you have provided for profiling purposes which enables us to direct specific products and service that may be of interest to you.

The Data Subject has not objected to the processing



Quality Improvement / Staff Training

All, written communications, and digital communications received through the web are stored by us.

The processing is in our legitimate interests in providing a high standard of services to our customers, by assessing the ongoing development and identifying areas for improvement.

Legal obligation

We may use your personal information to comply with various legal obligations to which we are subject including.

Managing our Revenue obligations

We may use your personal data to comply with anti-money - laundering regulations.

COVID 19 Contact Tracing Logs

COVID 19 Return to work Safely Forms.

The processing is necessary for compliance with a legal obligation to which the controller is subject

Dealing with sales and other enquiries

To respond to correspondence, you send to us and fulfil the requests you make to us (for example further information on OHM Brand services or product or brochure requests.

To takes steps prior to the entry into a contract with you and for our Legitimate Business Interests

To understand our customer base

We may use your personal information on an aggregate basis for market research purposes to help us understand our customer base

We rely on our legitimate interest to understand our customer base.

Business needs

We may use your personal information to manage our everyday business needs, including accounting, sharing your information within our company group for administrative purposes, and to prevent fraud.

We rely on our legitimate interest in the effective management of our business

Processing of OHM Employee Data



Employee data is processed for the following reasons; Payroll, appraisal, and review, monitoring of adherence to OHM policy, employee welfare and health and safety in the workplace employee pension, prospective employee and recruitment, compliance with statutory obligations, contact tracing and return to work safely documentation (Covid 19)

We rely on the following purposes.

(a)Necessary to comply with a legal obligation (to comply with employment law)

(b)The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract to which the data subject is party.

(c)Necessary for our legitimate interests and that of a 3rd party

(d)Where the Data Subject has provided consent (Recruitment)

(e)Necessary in order to protect the vital interests of the data subject or of another natural person.

(f)Necessary for the purpose of establishing, exercising, or defending a legal claim

Website Security

To administer and protect our business and OHM websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

Website analytics

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

With your consent where your data has been collected through our website. We use the data to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and marketing strategy


The following table is a non-exhaustive list and provides an indication of the types of personal data we use to perform our duties.



Purpose

Type of Data

Sale of Product/ Services

Full Name, Postal Address, Email Address, Phone Number, Bank Details, Gender, Vehicle Details

Customer Care

Full Name, Postal Address, Email Address, Phone Number, Bank Details, Gender, Vehicle Details

Financial Services

Full Names, Email Address, I.P, Phone Number, Bank Details, Date of Birth, Home address, Marital Status, Image of Data Subject, Gender, Income & Occupation details, vehicle details, Proof of ID

Marketing

Full Name, Email Address, Phone Number, Occupation, Company Name, Gender, Purchase History, I.P Address, Cookie Preferences, Contact Forms, SMS communications, Social Media details

Security/ IT Information

I.P Address, cookies, cookie preference, device details

OHM Group Employees

Full Names, Home address, Email Address, I.P, Contact Details, PPSN, Bank Details, Date of Birth/Birth Cert (Pension Purposes), Next of Kin, Vehicle details, Membership of a Trade Union, Health Data, Employment History, Educational History, Image of Data Subject, Vehicle Telemetry Data




6.Who/ do we share information with?

Third Party Service Providers

OHM discloses Personal Data to third parties in certain instances. For example, we use third party service providers for the processing of Personal Data for several purposes, including, consultants, advisors, I.T. service providers, printers, debt collection agencies, valuers, marketing companies who carry out marketing campaigns, market research and providers of security and administrative services.

In certain circumstances we may disclose personal data to other external third parties’ examples outlined below;

OHM Group entities We may also provide your personal data onto other OHM Group entities as requested by you for fulfillment of a service request or to meet contractual obligations.

Insurance Companies: We may disclose personal data to our insurance providers in connection, with legal claims and prospective legal claims.



Financial Services: We may pass on your personal data to Insurance Companies or Financial Service Providers to meet our contractual obligations with you and to provide specific services that you have requested. As these are independent Data Controllers their processing activities and decisions regarding the processing of your data may vary to that of OHM, we would suggest that you review their Privacy Statements.

You can request further information on the 3rd parties we share data with by contacting dco@ohm.ie/

Potential sale or merger

If we sell any part of our business and/or integrate it with another organisation, your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs, the new owners of the business will only be permitted to use your information in the same or similar way as set out in this data protection statement.

Garda Síochána, Government or Quasi-Government Bodies, Courts and Tribunals: We may share your personal information with these organisations and bodies, where required to do so by law.

7.Storage/ Periods



The period for which we will keep your personal information will depend on the service you have requested from us. The retention period may be longer than the period for which we are providing services to you where, for example, we have a legitimate interest in retaining such information that is not outweighed by your fundamental rights and freedoms, or where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in the event of a legal claim.

We endeavor to ensure that Personal Data is retained for an appropriate period and no longer than necessary. Retention of data is detailed in our Data Retention Policy.

8.Transfers/ outside the European Economic Area



We may transfer, store, or process your personal information to countries outside the European Economic Area. Where the laws of such countries do not afford an equivalent level of protection of personal information as the laws of Ireland, we take specific steps in accordance with data protection law to protect your personal information.

We will use one of these safeguards:

  • Transfer to a non-EEA country with privacy laws that give the same protection as the EEA
  • Put in place a contract (in a form that is approved by the European Commission) with the recipient of the personal information that means they must protect it to the same standards as the EEA.
  • Transfers to organisations that are part of an EU Framework that sets privacy standards for data sent between countries. Such frameworks ensure those standards offer equal or greater protection as provided under Union law.

9.How/ we use automated processing



We may analyse your personal information by automated means for the purposes of market research, analysing our customer database and for our marketing activities.

10.If/ you fail to provide personal data



Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to Financial Services Product). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

11.Information/ Security

In accordance with applicable laws, OHM ensures that all Personal Data controlled by OHM is held securely using appropriate security measures including the following:

  • Physical measures such as locked filing cabinets and offices containing Personal Data;
  • IT security systems;
  • Restricted access to Personal Data subject to approvals;
  • Time limits on retention of personal data;
  • Provision of targeted data protection training to employees, contractors and other staff who have access to and process Personal Data;
  • Password restrictions on access to Personal Data; and technical measures including:
    • Encryption on OHM laptops/portable devices; and
    • Logging mechanisms to record certain access to Personal Data and alteration and other processing of Personal Data.
    • Secure email services using state of the art encryption technology.

12.Your/ Rights



In certain circumstances, you have the following rights under data protection law in relation to your personal data:

A right to access Personal Data held by OHM.

  • Any individual has a right to make an access request, in writing, under data protection law for a copy of their Personal Data held by us. We may ask for further identification details to confirm your identity before the relevant information is provided.
  • It should be noted that there may be specific exemptions relating to accessing Personal Data. If we utilise any of the exemptions, we will provide you with details and our justification for their use.
  • Where we act in the capacity of a Processor, we will notify you of same and will also notify the Controller of your request.
Other data protection rights

  • Rectification of inaccurate personal data;
  • Erasure of personal data (also known as the "right to be forgotten");
  • Restriction of processing of personal data;
  • Right to data portability;
  • Right to object to processing of personal data.
However, under data protection law, these rights are available only in certain circumstances. If you wish to exercise any of your data protection rights, please contact dco@ohm.ie/ or by us using the contact details below. We will endeavor to respond to your request within a month. If we are unable to deal with your request within a month, we may extend this period by a further period of two months, and we will explain why. Please provide as much detail as possible to enable us to respond to your request and to locate relevant personal data about you.

By Post:DCO, Clonlara Avenue, Baldonnell Business Park, Baldonnell, Dublin 22

By Email: dco@ohm.ie/

By Webform: /data-preferences/

By Phone: + 353 (0) 1 4034100

You also have the right to lodge a complaint to the Office of the Data Protection Commission. For further information please see www.dataprotection.ie/

13.Updates/

This policy [“version 2”] was updated and deemed effective on the 20th of August 2021. We will update this data protection statement from time to time. Any updates will be made available on our website at /site/privacy-and-legal/ and, we would ask that you check regularly.