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Supplemental Privacy Information

Last Updated: 6 September 2023.

1. APPLICATION

This subpage (“Subpage”) applies if you reside in the EEA or Switzerland and supplements our Privacy Policy. It contains important information we are required to disclose by the General Data Protection Regulation (“GDPR“), including (i) the controller(s) of your personal information, (ii) legal bases, (iii) your legal rights, and (iv) the contact details of the controller and Data Protection Officer.

Car Valet Hero is the Controller for processing data based on legitimate interest. You can request that Car Valet Hero not process your personal information by providing reasons specific to your circumstances. If you object to such processing, Car Valet Hero will review your objection and will no longer process your personal information for these purposes unless we have compelling legitimate grounds for such processing, or where such processing is required for the establishment, exercise or defence of legal claims. We will let you know the outcome of our review. You may exercise your rights to object to such processing by sending us an email.

This Subpage also contains important information about the Payments Controller (defined below) and the information processed in connection with the Payments Services.

Please read this Subpage carefully. If you have any questions, you can contact us using the details below.

2. WHO CONTROLS MY PERSONAL INFORMATION

2.1 Controller

Where this Subpage mentions “Car Valet Hero”, “we”, “us” or “our”, it refers to the Car Valet Hero company that is responsible for your information under this Privacy Policy (the “Controller”).

2.2 Payments Controller

The Privacy Policy also applies to the Payment Services provided to you by Car Valet Hero Payments pursuant to the Payments Terms (“Payments Terms”).

2.3 Contact Us

To contact the Controller or the Payments Controller for Car Valet Hero, click here.

3. PROCESSING OF PAYMENTS INFORMATION

3.1 Information Necessary for Use of Payment Services

The Payments Controller needs to collect the following information necessary for the performance of the contract with you and to comply with applicable laws (such as anti-money laundering regulations). Without it, you will not be able to use Payment Services.

  • Payment Information. When you use the Payment Services, the Payments Controller requires certain financial information (such as your bank account or credit card information) in order to process payments and comply with applicable law.
  • Identity Verification and Other Information. The Payments Controller may require identity verification information (such as images of your government-issued ID document(s), passport, national ID card, tax ID or driving licence) or other authentication information (such as your date of birth, address, email address or phone number) as well as other information in order to verify your identity, provide Payments Services to you and comply with applicable law.

3.2 How the Payments Controller Uses Personal Information Collected

We may use personal information as a part of Payment Services to

  • enable or authorise third parties to use the Payment Services;
  • detect and prevent money laundering, fraud, abuse and security incidents;
  • conduct security investigations and risk assessments;
  • comply with legal obligations (such as anti-money laundering regulations);
  • enforce the Payment Terms and other payment policies;
  • with your consent, send you promotional messages, marketing, advertising and other information that may be of interest to you based on your preferences; and
  • provide and improve the Payments Services.

4. LEGAL BASES FOR PROCESSING PERSONAL INFORMATION

We process personal information for the purposes described in the Privacy Policy in line with the lawful bases set out below. For more information on the processing activities, please refer to the relevant section of the Privacy Policy.

4.1 Processing of Payments Information (Section 3, this Subpage)

SUB-SECTIONLEGAL BASESDATA CATEGORIES USED
How the Payments Controller uses the personal information collected.The Payments Controller processes this personal information according to its legitimate interest in improving the Payment Services and its users’ experience with it, and where it is necessary for the adequate performance of the contract with you and to comply with applicable laws.For these purposes, we use the information described in the following section of this Subpage:

  • “Information Necessary for Use of Payment Services”

4.3 How We Use Information We Collect (Section 3 of the Privacy Policy)

SUBSECTIONLEGAL BASESDATA CATEGORIES USED
Provide, improve and develop the Car Valet Hero Platform.We process this personal information for these purposes according to our legitimate interest in improving Car Valet Hero and our users’ experience with it, and where it is necessary for the adequate performance of the contract with you.For these purposes, we use the information described in the following sections of the Privacy Policy and this Subpage:

  • “Information needed to use the Car Valet Hero Platform”
  • “Information you choose to give us”
  • “Information Automatically Collected by Using the Car Valet Hero Platform and our Payment Services”
  • “Personal Information We Collect from Third Parties”
  • “Information Necessary for Use of Payment Services” and
  • “Information Necessary for Travel Insurance”
Create and maintain a trusted and safer environment.We process this personal information for these purposes, according to our legitimate interest in protecting Car Valet Hero and our users, to verify your identity for safety and security purposes, for further safety and security purposes, run sanctions checks, prevent fraud and conduct background checks (where permitted under applicable law), to measure the adequate performance of our contract with you, to comply with applicable legal obligations, for the protection of your or another person’s vital interests, and for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health.For these purposes, we use the information described in the following sections of the Privacy Policy and this Subpage:

  • “Information needed to use the Car Valet Hero Platform (including Contact Information, Account, Profile Information and Identity Verification and Payment Information)”
  • “Information you choose to give us”
  • “Information Automatically Collected by Using the Car Valet Hero Platform and our Payment Services”
  • “Personal Information We Collect from Third Parties”
  • “Information Necessary for Use of Payment Services” and
  • “Information Necessary for Travel Insurance”
Provide, personalise, measure and improve our advertising and marketing.We will process this personal information with your consent or based on our legitimate interest in undertaking marketing activities to offer you products or services that may be of interest to you.For these purposes, we use the information described in the following sections of the Privacy Policy and this Subpage:

  • “Information needed to use the Car Valet Hero Platform”
  • “Information you choose to give us”
  • “Information Automatically Collected by Using the Car Valet Hero Platform and our Payment Services”
  • “Personal Information We Collect from Third Parties” and
  • “Information Necessary for Use of Payment Services”
Analyse your communications.These activities are carried out based on Car Valet Hero’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety and improving and ensuring the adequate performance of our services.For these purposes, we use the information described in the following sections of the Privacy Policy and this Subpage:

  • “Information needed to use the Car Valet Hero Platform”
  • “Information you choose to give us”
  • “Information Automatically Collected by Using the Car Valet Hero Platform and our Payment Services”
  • “Personal Information We Collect from Third Parties”
  • “Information Necessary for Use of Payment Services” and
  • “Information Necessary for Travel Insurance”
Link third-party accounts, third-party partners and integrations.We process personal information from linked third-party accounts, third-party partners and integrations to the extent necessary to ensure the adequate performance of our contract with you, or to ensure that we comply with applicable laws or with your consent.For these purposes, we use the information described in the following sections of the Privacy Policy and this Subpage:

  • “Information needed to use the Car Valet Hero Platform” “Information you choose to give us”
  • “Information Automatically Collected by Using the Car Valet Hero Platform and our Payment Services”
  • “Personal Information We Collect from Third Parties”
  • “Information Necessary for Use of Payment Services” and
  • “Information Necessary for Travel Insurance”
Provide payments services.Read above in “Processing of Payments Information” for how the Payments Controller processes personal information collected.

4.4 Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting Our Rights (Section 4.5 of the Privacy Policy)

SUBSECTIONLEGAL BASESDATA CATEGORIES USED
Complying with Law, Responding to Legal Requests, Preventing Harm and Protecting our Rights.These disclosures may be necessary to comply with our legal obligations, for the protection of a person’s vital interests, for reasons of public interest in the area of public health (such as protecting against serious cross-border threats to health), for reasons of substantial public interest, or for the purposes of Car Valet Hero’s or a third party’s legitimate interest in keeping Car Valet Hero secure, preventing a breach of the law, harm or crime, enforcing or defending legal rights, claims or obligations, facilitating the collection of taxes and prevention of tax fraud, or preventing loss or damage.For these purposes, we use the information described in the following sections of the Privacy Policy and this Subpage:

  • “Information needed to use the Car Valet Hero Platform”
  • “Information you choose to give us”
  • “Information Automatically Collected by Using the Car Valet Hero Platform and our Payment Services”
  • “Personal Information We Collect from Third Parties”,
  • “Information Necessary for Use of Payment Services”, and
  • “Information Necessary for Travel Insurance”.

As further set out in our Privacy Policy, we are obliged to comply with certain tax laws. In the European Union, the following tax legislation is relevant in the context of the data processing carried out by Car Valet Hero:

APPLICABLE LEGAL OBLIGATIONDATA CATEGORIES DISCLOSEDTHIRD-PARTY RECIPIENT
DAC7 – European Council Directive 2021/514 (link).
  • First and last name
  • Primary address
  • VAT identification number, if relevant
  • Date of birth
  • Car Valet Hero service fees
  • Amounts earned via Car Valet Hero platform per quarter and the number of listings
  • Financial account identifier(s) (i.e., bank account or other payment services account)
  • Name of holder of the account into which payment is made if not the Provider’s account

If you provide us with certain information (such as name and bank account details) relating to non-users who reside in the EU, or who receive income from properties located in the EU, we will be obliged to share this information with the Irish Revenue Commissioners.

The Irish Revenue Commissioners.

The Irish Revenue will share information relating to you with the relevant local tax authority/ies in the EU.

5. YOUR RIGHTS

You benefit from rights pursuant to applicable law. While some of these rights apply generally, certain rights apply only in certain limited cases. We may ask you to verify your identity before taking further action on your request.

5.1 Data Access and Portability

You have the right to request certain copies of your personal information held by us. In certain instances, you also have the right to request copies of personal information that you have provided to us in a structured, commonly used and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

5.2 Rectification

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Car Valet Hero account).

5.3 Erasure

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us, to comply with our legal obligations and as permitted by applicable law.

You have the right to ask us to delete your personal information, subject to certain limitations and restrictions. Please note that if you request the erasure of your personal information:

  • We may retain personal information as necessary for our legitimate business interests, such as the prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Car Valet Hero account for fraud or safety reasons, we may retain information from that Car Valet Hero account to prevent that Member from opening a new Car Valet Hero account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Car Valet Hero and Car Valet Hero Payments may keep your information for tax, legal reporting and auditing obligations.
  • Information you have shared with others (e.g., reviews and forum postings) may continue to be publicly visible on Car Valet Hero, even after your Car Valet Hero account is cancelled.
  • Because we maintain Car Valet Hero to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

5.4 Withdrawing Consent

If we are processing your personal information based on your consent, you can withdraw your consent at any time by changing your account settings or by writing to Car Valet Hero specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

5.5 Restriction of Processing

You have the right to limit the ways in which we use your personal information, in particular, where (i) you contest the accuracy of your personal information, (ii) the processing is unlawful and you oppose the erasure of your personal information, (iii) we no longer need your personal information for the purposes of the processing, but you require the personal information for the establishment, exercise or defence of legal claims, or (iv) you have objected to the processing pursuant to Section 5.6 (below) and pending verification of whether the legitimate grounds of Car Valet Hero override your own.

5.6 Objection to Processing

You have the right to object to the processing of your personal information based on grounds specific to your situation if such processing is for direct marketing or is for a purpose based on a legitimate interest or public interest. If you object to processing based on legitimate or public interests, we will no longer process your personal information for these purposes unless we have compelling legitimate grounds for such processing or where the processing is otherwise required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time, ask Car Valet Hero to cease processing your data for these direct marketing purposes by sending an email to support@carvalethero.ie.

5.7 Lodging Complaints

You have the right to lodge complaints about our data processing activities by filing a complaint with your local supervisory authority or our lead supervisory authority, the Irish Data Protection Commission.

6. RETENTION

We retain personal information for as long as needed or as permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • the length of time we have an ongoing relationship with you, whether you are a Customer or a Provider, and provide Car Valet Hero to you (for example, for as long as you have an account with us or keep using Car Valet Hero);
  • whether there is a legal obligation to which we are subject (for example, certain laws, such as anti-money laundering requirements, require us to keep records of your transactions for a certain period of time before we can delete them); and/or
  • whether retention is advisable in light of our legal position or to protect the safety of individuals (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

7. Means to Ensure an Adequate Level of Data Protection

If Car Valet Hero is the Controller and your information is shared with corporate affiliates or third-party service providers outside the EEA, we have (prior to sharing your information with such corporate affiliates or third-party service providers) established the necessary means to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). We will provide further information on the means to ensure an adequate level of data protection, such as a copy of the EU Model Clauses, on request.

Schedule 1:

YOUR PLACE OF RESIDENCEYOUR ACTIVITY ON THE CAR VALET HERO PLATFORMYOUR CONTROLLERCONTACT ADDRESS
European Economic Area and SwitzerlandPayments Services for all activities.Car Valet Hero2 Retreat Ridge, Athlone, Westmeath N37 PX63
All other activities.Car Valet Hero2 Retreat Ridge, Athlone, Westmeath N37 PX63
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