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www.eurolink-m3.ie
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DATA PROTECTION NOTICE

BY USING THE MOTORWAY AND TOLL PLAZAS YOU ARE CONSENTING TO EUROLINK PROCESSING YOUR PERSONAL DATA IN THE WAYS THAT WE EXPLAIN IN THIS NOTICE AND ANY FUTURE VERSIONS OF IT.

HOW EUROLINK USE YOUR INFORMATION
In this notice Eurolink explain how we collect information about you, how we use it and how you can interact with Eurolink about it.

WHO WE ARE
In this notice Eurolink refers to Eurolink Motorway Operations (M3) Limited and Eurolink Motorway Operation Limited. Eurolink are part of a Public Private Partnership contract with Transport Infrastructure Ireland (TII) which permits Eurolink to operate, collect tolls and maintain the M3 and M4 motorway and toll plazas.

HOW WE COLLECT INFORMATION ABOUT YOU AND YOUR CONSENT
In order for Eurolink to successfully operate and maintain a safe and secure motorway and toll plaza/s and to enable Eurolink to establish and manage the relationship with users of the motorway and toll plazas, Eurolink have a legitimate business reason to process personal data.

Eurolink process personal information, for example, when you use the motorway and the toll plazas, when you apply to Eurolink to set up a tag account, when you contact Eurolink to make a query in respect of a toll transit, when you use a card to make payment, when you contact Eurolink to make a Subject Access Request, when you apply for an exemption card.

Eurolink use vehicle plate recognition software and take still images of your motor vehicle at the toll plazas as a method of identification of the motor vehicles using the toll plazas. Eurolink also process CCTV to improve security, health and safety and for enforcement and to resolve any issues raised by you with Eurolink at a later stage. Please note that Eurolink cannot always guarantee the quality of the CCTV so it might not always be possible to identify any personal data or data subjects from our CCTV. No facial recognition software is used by Eurolink.

Eurolink also process information from other toll concessionaries or tag providers that you may have a tag account with to allow road users uninterrupted use of all the toll plazas in Ireland with one tag and so to perform the contract you have in place with your tag provider.

Eurolink do not have a database of all registered owners of motor vehicles in Ireland but in the event that you cause damage to the motorway and do not stop to report the incident to our employees or you do not pay the toll fee as required by law, Eurolink may collect personal data from local and national authorities, the MIBI and An Garda Síochána in respect of ownership of motor vehicles and motor insurance details in order to assist Eurolink with enforcement.

Sensitive Personal Data
In order to avail of exemptions for the toll charges for certain categories of drivers contained in the local Toll Bye Laws, road users may provide sensitive personal data to Eurolink. Eurolink will only process sensitive personal data where they are absolutely required to do so and only with your written consent.

HOW WE KEEP YOUR INFORMATION SAFE
We know that you care about how information about you is processed. We appreciate your trust in Eurolink to do that. To protect your information, our IT Department work very hard to ensure that Eurolink use security measures that comply with Irish law and meet international standards. This includes computer safeguards, secure files and secure buildings.

WHAT WE USE YOUR INFORMATION FOR

Data Analytics- Using Information in our business to improve our business
Eurolink analyse the information that we collect through your usage of the toll plazas. This helps us understand patterns of usage of the toll plazas. Our analysis helps Eurolink ensure that you are afforded a fast and uninterrupted journey through the toll plazas.

Litigation
If you make a claim against Eurolink we will use personal data to investigate the matter and attempt to defend the claim.

If Eurolink wish to make a claim against you for non-payment of a toll journey or for damage caused to the motorway or at the toll plazas, Eurolink will use your personal data to investigate the matter and to form the basis of the claim, to seek judgment and for enforcement.

Payment
When you use a card to make a payment Eurolink use a post payment card system. If the payment is declined, for example, due to insufficient funds or due to being blocked because the card was stolen and therefore the use is unauthorised, Eurolink process the information so that the next time the card is used at the toll plazas that it will be immediately rejected.

Encryption is used to keep your card information safe. In addition to this Eurolink have Data Protection Agreements in place with the companies used to process your payment through your bank to keep your information safe.

Query Resolution
If you make a query in respect of your transit Eurolink will have to process your personal information to resolve the query for you.

Our Legal Obligations
Eurolink have legal obligations, for example:
1) to assist law enforcement agencies when they are investigating criminal activity;
2) to operate the motorway and toll plazas in compliance with the local Bye Laws and with legislation;
3) to operate and maintain the motorway in compliance with our contract with TII;
4) to co-operate with third parties in respect of interoperability contracts between tag providers and other toll concessionaries within Ireland.

Eurolink may disclose personal data if under a duty to disclose or share customer data in order to comply with legal obligations or in order to protect rights, property or the safety of the staff of Eurolink, its customers or others.

Eurolink will also disclose personal data if the disclosure is required in order to comply with an applicable law, summon, search warrant, a court or regulatory order, or other valid legal process which would include in the main but not limited to Section 8 of the Data Protection Act, 1988.

Often Eurolink have to share information with other tag providers and toll concessionaries within Ireland through a centralised portal in order to deal with contractual requirements to resolve the queries of motorway users. This ensures that you are in a position to use one tag on all the motorways throughout Ireland.

Where we suspect criminal activity Eurolink will record this and report to the relevant enforcement agencies, which may be within or outside Ireland because we are legally obliged to do so.

RETENTION
Eurolink will only retain personal data for as long as is required to conduct our business and satisfy our legal obligations.

YOUR INFORMATION AND THIRD PARTIES
We sometimes use other companies and individuals to work on our behalf to collect monies or to give us advice to help us make decisions, for example to:
- Analyse data
- Collect toll charges at the toll plazas
- Collect unpaid toll charges and debts
- Collect unpaid repairs for damage caused on the motorway
- Litigation purposes

We have a contract and GDPR agreement in place with all third parties to whom we give your information to or to whom have access to your information for these purposes to keep your information confidential and to respect the laws on Data Protection.

Eurolink might require technical support from companies outside Ireland. These companies are in the EEA so this would not involve processing data outside the EEA. In all such cases this activity is supported by a contract which includes data protection clauses.

ACCESSING AND MANAGING YOUR INFORMATION
You have a right to make a request under s. 3 and s. 4 of the Data Protection Acts in respect of your personal data.

To make a data access request please click here.

You can access guidance to assist you with this request at the following link which can be copied and pasted into your browser:
https://www.dataprotection.ie/docs/Accessing-Your-Personal-Information/r/14.htm

Once we are satisfied that you are the data subject we will reply to you within 30 days. This is not to frustrate you but Eurolink do not want your personal data to end up in the hands of the wrong person.

Please also note that if you request the reply of communication via your email address, you are held solely responsible for the security and integrity of your own email account. Unfortunately, the transmission of information via the internet is not completely secure. Consequently, while Eurolink will take all reasonable security measures, Eurolink cannot guarantee the privacy or confidentiality of information relating to you being passed via the Internet; any transmission is entirely at your own risk.

Eurolink try to make sure that the information that we have about you is accurate and up to date. If your information changes or you believe that we have information that is not accurate or not up to date, please write to Eurolink at the following address and Eurolink will update your information immediately;

Data Protection Officer,
Eurolink Motorway Operations ( M3) Limited
Blackbull Toll Plaza,
Dunboyne,
Co Meath
Email: dpo@eurolink-m3.ie

RIGHT TO COMPLAIN
You also have a right to complain to the Data Protection Commissioner. You can contact the Office of the Data Protection Commissioner at:

Telephone +353 (0)761 104 800 or Lo Call Number 1890 252 231
Fax +353 57 868 4757
Email info@dataprotection.ie
Postal Address: Data Protection Commission, Canal House, Station Road, Portarlington, R32 AP23, Co. Laois

UPDATES
Eurolink will update their Data Protection Notice from time to time. Any updates will be made available on this website or if you are a tag account holder, will be notified to you by post or email.

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