Fleet

This is the supplemental Privacy Statement of Spirit Motor Group Limited (“SMG”) t/a Spirit Rent who’s registered office is C/O, OHM Group, Clonlara Rd, Baldonnell Business Park, Dublin, D22 WIH9. In this statement we use the terms “we,” “our” and “us” to refer to SMG.

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 for the purpose of the Spirit Rent Service (“Spirit Rent”). This Privacy Statement can be read in conjunction with the Spirit Motor Group Privacy Statement which is available here Spirit Motor Group

SMG respects the privacy of all those individuals whose Personal Data it encounters, which in particular includes the following:

All users of Sprit Rent APP, SMG Website or Social Media Pages,
Customers or prospective customers of Sprit Rent;
All subscribers to SMG marketing and digital communications
Members of the public and visitors to our site

This Data Protection Statement will explain why and how we use the Personal Data we collect when you engage with Spirit Rent . We will ensure that we keep all Personal Data provided in accordance with our obligations under applicable data protection laws. We will update this Statement from time to time to reflect any material changes in technology, legislation or our data use practices which may materially affect the way in which we process Personal Data.

1. Who we are and how to contact us?

SMG is made up of different legal entities, as follows; Spirit Motor Group Ltd, Spirit Rent, Spirit Volvo, Spirit Jaguar, Spirit Land Rover, Spirit Burton, and other companies within the brand, Spirit Skoda Ltd, Spirit Foster, Spirit Premium, Spirit Seat, Spirit Cupra, Spirit Ford Ltd, Spirit Lillis O’Donnell and Spirit Mobility. This privacy statement is issued on behalf of SMG so where we mention “SMG,” “us,” “we” or “our” in this privacy statement, we are referring to the relevant company in SMG responsible for processing your data.

We have in place a Data Compliance Officer [“DCO”] who is responsible for overseeing questions in relation to this privacy statement. If you have any questions about this privacy statement, including any request to exercise your legal right please contact our data compliance manager using the details set out below.

2. 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, driving behaviours, details about an individual's location or any other detail(s) specific to that individual such in certain cases special category data.

Please be aware that it is your responsibility to alert other named drivers and all passengers and people you authorise to use the vehicle about the privacy practices discussed in this Privacy Statement. Any passenger of the vehicle you have authorised to utilise the entertainment system within the vehicle should be made aware that personal data will be collected from the user’s device and shared to the Manufacturer and their 3rd parties where it relates to the personal data that is collected through the entertainment system

3. Categories of personal data and how we use it

We may collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:

identity Data includes first name, last name, username or similar identifier, title, image, and gender.
contact Data includes email address, telephone number and postal address.
technical data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, chosen language, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the APP or SMG website or the subscribed vehicles on-board entertainment system.
profile data includes your interests, preferences, and feedback
usage data includes information about how you use our APP and our website and relevant services
marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences regarding push notifications and messages from the Spirit Rent App

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated 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 privacy statement.

We do not intend to collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we intend to collect any information about criminal convictions and offences. However, if such information is provided it will only be retained within the context of the documentation it was provided in and will be treated with the highest level of confidentiality.

4. How we obtain your information?

We use different methods to collect data from and about you including through:

Direct interactions

You may give us your Identity and Contact Data by filling in forms, registering on the Spirit Rent App or by corresponding with us by email or SMS. This includes personal data you provide when you:

request our services; (your interest in subscribing to the services)
subscribe to our publications;
request marketing to be sent to you;
provide feedback; or completing a survey;
entering competitions;
attendance at brand events;
CCTV (this may be collected when you visit our site to collect your rental car);
manage your personal data preference;
provide a copy of your driver’s license
a selfie image provided within the Spirit Rent App

Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. When you visit our website(s) all cookies apart from strictly necessary cookies will require your consent.

When you download the Spirit Rent App (IOS or Android) certain information will be collected by the App developer at first instance. The App developer uses Software Development Kits (“SDK”) via Google Firebase to support the App’s performance and to manage Crashlytics. The App developer may collect and process this data in its own interest. For further information on what data is collected and processed by the App developer and any third parties please see the following Privacy Statement DashApps

Information may also be collected about you through the use of the vehicles entertainment system .This information is shared to the vehicle Manufacturer and further information about how they use this data, and your rights can be obtained directly from the manufacturer of the vehicle which you are renting.

Third parties or publicly available sources

We may receive personal data about you from various third parties such as;

advertising networks which we utilise and to which you might engage with
interactions with Social Media sites to where we have a presence and where you may have availed of easy signup through Facebook to the Spirit Rent web portal

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

5. What Personal Data does SMG collect and use Online

We collect various types of Personal Data when a person uses our website, APP, or social media platforms. The following are examples of Personal Data collected by SMG:

Spirit Rent App: When a person registers to use the App, the following information is processed; communication preferences, full name, address, phone number, email address, Eircode, profile picture (selfie), gender, Date of Birth, signature, I.P address, location data, IOS, device details, drivers’ licence, driving fines, or penalties.
If you visit our website, please note we use 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 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 do not deploy un-necessary cookies on our website, such as analytics, marketing, targeting, or profiling cookies without your consent. Please see our Cookie Policy for further details Spirit Cookie Statement
We may collect your personal data from Contact Forms, (such as an expression of interests in our services) this enables us to deal with your request in a timely manner.
Competitions: When a person enters a competition, we may collect and use the entrant’s name and contact details (including postal address, email address, telephone number) in connection with the competition (including mobile competitions). Where we operate competitions in conjunction with a third-party commercial partner, subject to the competition rules and notices, that partner may collect and use the data.
Social Media Pages: Content such as messages and photographs, which are posted on social media pages on which SMG has a presence 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). If inappropriate content is posted to our social media platform and is deemed to be in breach of this supplemental Privacy Statement or the policies operated by such websites or social media platforms, such content may be removed by or at the request of SMG or the operators of those social media platforms. If such inappropriate content is posted to a social media page that we control, you can report it at the following address dco@ohm.ie and we will endeavour to ensure that appropriate action is taken in accordance with our policies and the policies of the relevant social media platforms.
We may use advertising networks to help present advertisements or other content on our website and other websites that display SMG 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.

6. The purpose and legal basis for processing yourinformation.

We collect and process the Personal Data described below for a variety of purposes. Below is a summary of these purposes and the lawful justifications that support them:

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 the service which you have requested from us. For example, we need to process your personal information in order to enable you to subscribe to a vehicle or to provide you with a brochure or information about a product or service where you have requested it

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 business records in accordance with company and revenue law which may include your personal information.

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 are a customer or prospective business customer of SMG, we may use your information to send you communications on products and services that may interest you and that you would reasonably expect to receive. You have the right to object to this at any time by unsubscribing via the link that will be provided in the communication.

We may also contact you via email or SMS regarding any changes in your rental vehicle, such a vehicle model changes, collection and return times.

We may contact you post rental with regards to any driving offences or fines that were obtained by you during the course of your vehicle rental.

We may use your personal information to manage our everyday business needs, including accounting, internal reporting needs, and market research (surveys) to progress and respond to legal claims, notifications to you on any driving violations you obtained during the rental period, security of our premises and staff through use of CCTV, to process 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 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 as a whole.

We may use your information which we collect, including personal information we obtain from publicly available sources such as social media, 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 site etc. We do this in our legitimate interest in order to keep our customers updated on changes within our organisation.

Some of our vehicles contain built in tracking technology. Where such tracking technology is in place the information that is collected from the vehicle may indicate the location of the vehicle. Spirit Rent does not intentionally track rental vehicles in the normal course of business. However, it may have the ability to access to such data should it be deemed appropriate to do so, for example in the event of an traffic accident or vehicle theft.

You may have the right to object to any of the above processing scenarios by contacting us on dco@ohm.ie

With your consent

We will request your consent for the deployment of push notifications and/or message via the Spirit Rent App.

We will request your consent for the use of all cookies on our websites outside of strictly necessary. You can withdraw this consent at any time by clicking “cookie settings” at the bottom of our webpage, see our cookie policy for further information.

Where you are a consumer and not an existing customer of our business (prospect) we will request your consent for all digital direct marketing communications.

You can revoke your consent at any time by contacting dco@ohm.ie or by using the un-subscribe option in the marketing communication.

To protect your vital interests

We will in certain circumstances use your personal information to protect your vital interests, for example we may contact you in the event of a recall or safety issue with your subscribed vehicle.

Purpose	Description	Lawful Basis for Processing
Renting a Vehicle	Name, contact details, (include postal address, email address, telephone numbers)image, gender, drivers’ licence, date of birth, number of years of driving experience, bank details, credit/debit card details. Employer details in certain circumstances. We may also retain records of any driving violations provided by An Gardai Siochana which you obtained during the rental period. Such notifications of driving violations and/or fines will be provided to you for remediation and payment. We may retain records with regards to non-payment of toll charges or parking offences. We will contact you regarding these violations for remediation and payment.	When you rent a vehicle ,information is processed to enable the services. (a)The lawful basis for processing is the performance of a contract to which the customer is party. (b)In certain instances we will require your consent to process certain data, such as push notifications and messages. (c)The processing is in our legitimate interests to ensure only those drivers with the relevant prerequisites can partake in Spirit Rent and can avail of the service . (d)In certain instances we will process your data to protect the business assets and financial interests of SMG
Customer Care	Name and Contact details. Interactions with our staff and officers, which includes notes of your calls with our staff on our database. If you require customer support please contact our customer care team on customercare@spiritrent.ie	We use this information for the purpose of identity verification and in order to assist the relevant queries. (a)This processing is necessary for the performance of a contract and to keep a record of your interactions with us. (b)The processing is in our legitimate interests to assist in monitoring and training our staff.
Rented Vehicle Support Services	We may use your personal information to notify you if a service is due on your rented vehicle or; where you have requested Road-Side Assistance where you have been involved in a roadside incident	(a)this processing is necessary for the performance of a contract (b)Necessary to support your vital interests
Marketing to Potential Customers and Existing Customers	Name and Contact details	Where you are a Business-to-Business Prospect or Existing Customer. (a)The processing is in our legitimate interests to develop our business by providing information that is relevant and where you would reasonably expect to receive such information and have not opted out of the processing Where you are a Consumer Prospect. (b)We will rely on your consent to communicate to you, where you have provided such consent to us directly .
Customer Satisfaction Survey	Name and Contact details and rented vehicle details.	We may request your feedback in the form of a survey. (a)We use this information to monitor our performance and for driving service improvements in our legitimate interests.
Vehicle Tracking	Some vehicles contain built in technology that can track the location of the vehicle.	(a)The processing is necessary for our Legitimate Interests in protecting our business assets.
CCTV	Images	We operate a CCTV system on our premises for the safety and security of our staff and visitors. (a)The processing is in our legitimate interests in protecting our customers and our business assets.
Anti-Money Laundering	g We may use your personal data to comply with anti-money -laundering regulations.	(a)The processing is necessary for compliance with a legal obligation to which we are subject.
Safety Incidents / Product recall	We may use your personal data to contact you regarding an urgent safety measure and / or a product recall.	(a)This processing is necessary for the performance of a contract and to keep a record of your interactions with us. (b)The processing is Necessary to support your vital interests
Legal obligation	Name and Contact details and vehicle subscription details	(a)We may use your personal information to comply with various legal obligations to which we are subject such as: Making a payment of VAT or in respect of the sale of a vehicle subscription service
To understand our customer base	Name and Contact details ,current and previous vehicle rental details	We may use your personal information on an aggregate basis for market research purposes to help us understand our customer base. (a)We rely on our legitimate interest in order to understand our customer base.
App and Website Security	I.P Address, device details	To administer and protect our business and this website (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 reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
Website analytics	Interests, consent preferences, IP address, browsing history, device details, location details, language, IOS/browser	(a)With your consent where your data has been collected through our website and/or APP and where you have subscribed to receive direct marketing communications.
On Board Vehicle Entertainment Services	When you use the entertainment system within the vehicle some personal data may be stored on the hardware within the vehicle, such as your name, phone profile and location data including recent trips or saved locations. We would encourage you to delete your phone details from the entertainment system at the end of your rental period.	SMG does not process data associated to the entertainment system of the vehicle; this information is shared directly to the manufacturer of the vehicle via the renter. Limited Data is stored in vehicle on the terminal device however this . is deleted immediately from the vehicle hard drive at the end of the rental period Please note this does not delete data from the Entertainment services or any data that is processed through these services. For further information please contact the vehicle manufacture

7. Who do we share information with?

Third Party Service Providers: We may disclose your Personal Data to third parties in certain circumstances. For example, we use third party service providers for the processing of personal data for a number of purposes, including APP development and maintenance, security services, consultant advisors, I.T. services, printers, debt collection agencies, valuers, marketing companies who carry out marketing campaigns, market research, customer satisfaction surveys on our behalf and providers of security and administrative services. We may also share you information with other organisations who provide services for you to avail of such as Roadside Assistance. SMG will not provide any personal information to third parties or partners for direct marketing purposes unless the users have consented to SMG giving their Personal Data to third parties or partners for that purpose. If a user opts-out from receiving communications from third parties or partners, SMG will no longer share that user’s contact details with our partners or third parties. However, users will still need to directly opt-out from communications from the partners to whom we have already given their information

OHM Group and other OHM Group entities: We are part of the OHM Group, and we may pass your information on to OHM Group entities, for the purpose of administrative efficiencies, for fulfilment of a contract and for storing your data in central IT Systems. https://www.ohm.ie/brands/ .We may also convert your information, such as information you provide during a customer satisfaction survey, into statistical or aggregate data in such a way as to ensure that you are not identified or indefinable from it, we may pass this information on to OHM Group and other OHM Group entities, for analytical and statistical purposes.

Insurance Companies: We will pass your information to insurance companies for the provision of insurance on your rented vehicle. We may also pass your information to any motor assessor appointed by our insurance company, to assess the cost of the repairs or works carried out on your rented vehicle covered under an insurance policy where an incident or damage has been noted on your rented vehicle

We may disclose personal data to our insurance providers in connection with legal claims and prospective legal claims or proceedings.

Vehicle Manufacturer : Personal data may be shared directly to the vehicle Manufacturer through the use of the Vehicle Entertainment system. The Manufacturer is the Controller of this data and information regarding the processing of your data through the use of the entertainment system can be found on the manufacturers website.

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.

8. 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 endeavour 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.

It is our Policy to delete inactive users’ personal data from the APP after a period of 12 months from the last engagement or activity date. Users will be notified of this action prior to deletion.

9. Transfers outside the European EconomicArea

We may transfer, store, or process your personal information in 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. These frameworks make sure those standards are similar to what is used within the EEA.

10. 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.

11. Processing for Security Purposes

We operate closed circuit television cameras ("CCTV") throughout our premises covering buildings, internal spaces, car parks, roads, pathways, and grounds. Our CCTV system is implemented in a proportionate manner as necessary to protect our property against theft or pilferage and for the security of employees, customers, and visitors to our premises. Footage is retained for 60 days, except where incidents or accidents have been identified in which case such footage is retained specifically in the context of an investigation of that issue.

12. 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, we will require a copy of a valid driver’s licence to provide access to vehicle rental). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

13. Information Security

In accordance with applicable laws, we aim to ensure that all Personal Data controlled by us is held securely using appropriate security measures. In the event of a personal data breach, we will comply with applicable reporting and notification obligations under data protection law. SMG has in place a Breach Notification Policy.

14. 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 SMG

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.

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 persona 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 endeavour 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, OHM Group, Clonlara Rd, Baldonnell Business Park, Dublin, D22 WIH9

By Email: dco@ohm.ie

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

15. Updates

This supplemental Privacy Statement [“version 1”] was deemed effective on the 5th of March 2024. We will update this data protection statement from time to time. To view our other Data Protection Statement please visit Spirit Motor Group