Vantastic Privacy Statement – Last updated May 2018

1. Introduction
Protecting our customer’s personal data is important to Vantastic. This Privacy Statement sets out how we collect, use, store, share and protect your personal data in compliance with Data Protection legislation.

1.1 Company Information. Vantastic is the trading name of Vantastic Company Limited By Guarantee, a company registered in Ireland with company number 323056 and having its registered office at Chase House, City Junction Business Park, Northern Cross, Dublin 17. Further information can be found at https://www.vantastic.ie

1.2 Contact us. If you have questions as to the manner in which your personal data is being handled or if you require any further information you can contact the Data Protection Officer at info@vantastic.ie(Subject: Data Protection) or by writing to the :

Data Protection Officer, Vantastic, Chase House, City Junction Business Park, Northern Cross, Dublin 17.

1.3 Statement Review. This Statement will be regularly reviewed to ensure we continue to meet our obligations in processing your personal data and protecting your privacy. In order to do so, we reserve the right to update, modify and amend this Statement at any time as required. We would recommend that you check back regularly to keep informed of any updates. We will not make any significant changes to the Statement without informing you.

1.4 Protecting your Information. We are committed to protecting your personal data and to implement appropriate technical and organisational security measures to protect it from any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.

2. Data we Collect In order to provide Accessible Transport products and services and provide you with information on these products and services we need to collect a number of categories of personal data through a number of channels including from you, third parties and other transport providers. We obtain this personal data during the registration process, marketing or through our on-going management of your account. We cannot offer and/or provide you with transport products or services which best suit your requirements unless we have the necessary information.

These personal data categories include:
Name, address, contact details such as telephone number, mobile phone number, email address, date of birth, gender, mobility restrictions, home address, records of payments and any arrears, marketing preferences, emergency contact, driver licence details (rental car service only) and contact notes.

In certain circumstances, we may collect special categories of personal data for the customer care register including any disabilities or special needs information necessary to support the provision of service to you.

3. How we use your Information

We will use your personal data to provide you with Accessible Transport products and services and to allow us to better manage your customer account. In particular, we may use your personal data for the following purposes:

3.1 Account Management. In order to set up and administer your account and manage your customer journey and contact us, we are required to process your personal data. This involves processing personal data for the purpose of account set up, monitoring, identity verification and managing your account including billing purposes and processing payments.

Legal Basis: The processing is necessary for the performance of the Minibus Trip / Rental Agreement which you are party to or in order to take specific steps prior to you entering into a Minibus Trip / Rental Agreement.
Legal Basis: The processing is necessary to comply with our legal obligations.
Legal Basis: The processing is necessary for our legitimate interests or those of a third party. It is within Vantastic’s legitimate interest to use certain personal data to establish, maintain and review an account to allow Vantastic to better manage customers’ accounts, enforce rights set out in the terms & conditions of supply, and to ensure customers are provided with the most appropriate transport products and services.

3.2 Customer Support. In order to respond to queries and manage and investigate any complaints, we are required to process your personal data. If you contact our customer service team or if we contact you we will use personal data such as account information and contact history. We may monitor and record such communications, email and other electronic communication to help investigate any complaints and for training purposes.

3.3 Marketing. In accordance with your marketing preferences, from time to time we may provide you with information on our transport products and services/promotional efforts and those of carefully selected third parties (whose products and services may be unrelated to ours) which we feel may be of interest to you. Again depending on your marketing preferences, we may also contact you after you have ended your account with us to make you aware of our products, services and any available offers.

Depending on your marketing preferences and as otherwise permitted by law we may contact you by:
(a) Non-electronic means, including by post or in person; and
(b) Electronic means including live telephone calls, email, SMS (texts), multimedia messaging or social media (e.g. Facebook and Google).

Legal Basis: The processing is based on your consent for the specific purpose (e.g. by opting in and receiving certain marketing communications on sign up or otherwise).
Legal Basis: The processing is necessary for our legitimate interests or those of a third party. It is within Vantastic’s legitimate interest to provide you with information on Vantastic products and services including information that we have tailored to your interests.

If you wish to change your marketing preferences you can do so at any time by writing to us at the address provided above, emailing us at info@vantastic.ie or by calling customer services on Freephone1800 242 703

3.4 Improving our Products & Services. In order to improve our products, services and customer interaction we carry out customer surveys and market research which involves the processing of personal data.

Legal Basis: The processing is necessary for our legitimate interests or those of a third party. It is within Vantastic’s legitimate interest to provide you with the best customer experience by ensuring that we continually improve our processes and offerings.

3.5 Debt Management. In order to allow Vantastic to appropriately manage any debt issues if they were to occur.

Legal Basis: The processing is necessary for the performance of the Minibus trip/Rental Agreement to which you are a party or in order to take specific steps prior to entering into a Minibus trip/Rental Agreement.
Legal Basis: The processing is necessary for our legitimate interests of the controller or those of a third party. It is within Vantastic’s legitimate interest to use certain personal data to help manage a debt issue and enforce rights set out in the terms & conditions of supply with respect to a Minibus trip/Rental Agreement.

3.8 Funding, Regulatory & Licence. In order to meet our funding, regulatory and licence requirements Vantastic is required to process personal data and provide information to the Regulatory Authorities and government departments.

Legal Basis: The processing is necessary to comply with a legal obligation to which we are subject under our Statutory Funding Contract & Licence requirements.

3.9 Website (http://www.vantatsic.ie)

Online Payments

Credit card payments made through the Vantastic website are managed using a secure payment system called Stripe. Stripe is certified to PCI Service Provider Level 1, the most stringent level of certification available in the payments industry. All credit card data provided is processed securely by Stripe – the only data sent to Vantastic are your contact details and the amount of the payment.

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Legal Basis: The processing is necessary for our legitimate interests or those of a third party. It is within Vantastic’s legitimate interest to provide you with the best customer website experience by ensuring that we continually improve our processes and website.

3.10 Assessment of Customer Preferences and Account History. Our systems assess customer profiles such as payment preferences, online account preferences, payment history, services delivered, contact history, sign up behaviour/channel etc. in order to assess customer loyalty for marketing and to determine what services or special offers or, where available, customer rewards, may be of interest to certain customers. Profiling may result in customers being offered different customer rewards or rewards of different value or may result in customers being specifically contacted (in accordance with any consents given) to be informed of our service offerings. Any customer may contact our Customer Service Teams at any time to inquire about our latest offers.

3.11 Recruitment. If you submit a job application online, we will use your personal data for recruitment-related purposes, which may include contacting you via email, telephone, SMS or post.

Legal Basis: The consent of the individual.
Legal Basis: The processing is necessary to comply with legal obligations to which we are subject under our employment law.

3.12 Special Categories of Personal Data. In order to support customers requiring additional account management support (e.g. customers with poor eyesight or blindness requiring bills to be provided in braille or assisting customers in ill health with debt or payment management plans), we may from time to time obtain data concerning a customer (or previous customer’s) health such as a vulnerable customer checklist.

Legal Basis: The explicit consent of the individual.
Legal Basis: Where required to protect the vital interests of the individual where the individual is physically or legally incapable of giving consent to such processing.
Legal Basis: The processing is necessary to comply with legal and regulatory obligations to which we are subject under our Licence requirements.

4. Sharing your Information

There are a number of circumstances in which we may share your personal data with other parties. Below is a list of such potential recipients or categories of recipients with whom we may share information.

In order to meet our Statutory Funding requirements, we are required to share certain personal data with the POBAL who Manage the Vantastic Statutory Funding (provided under the Community Services Programme) on behalf of the Department of Rural and Community Development.
For debt management purposes we may in certain cases be required to share personal data with debt collection agencies.
We may disclose information when required by law or legal process for the administration of justice, to protect your vital interest, for investigations by law enforcement or regulatory bodies, to protect and defend Vantastic’s property and legal rights or by order of a valid order from a court or law enforcement agency.
Organisations who act as service providers to Vantastic such as providers of telecommunications, postal services, records storage, data storage, document production and destruction, IT services and security, fraud detection, customer loyalty programmes, marketing and market research, and making and receiving financial payments.

We may pass personal data to our agents and service providers when relevant for these purposes, including the use of cloud providers. This may involve passing your personal data outside of the European Economic Area and any such recipients will be bound to comply with the European Commission standard contractual clauses for the transfers of data outside the EEA. Further information is available from homeenquiries@energia.ie.

5. Retention of your information

We will retain your personal data only for as long as is necessary for the purposes for which it was collected and in order to meet the legal and business requirements of managing your customer account and experience with us. In particular:

We will retain personal data that is necessary for us to provide you with a product or service that you have requested or purchased for as long as it takes us to provide that product or service;
We will retain your contact details for marketing purposes for as long as we have your permission to send you marketing information or for as long as we are permitted to do so, subject to your right to object at any stage;
We will retain records of any transactions you enter into with us or products or services you receive for up to seven years after the date of the transaction. This is so that we can respond to any complaints or disputes that arise in that period;
We will retain any financial transaction information for seven years after the date of those transactions; and
We will retain other personal data necessary for us to do so to comply with our regulatory and legal requirements.

6. Your rights
The General Data Protection Regulation provides you with a number of rights under the legislation as a data subject. We will respond to your requests within one month of the receipt of your request or inform you in circumstances where an extension may be required.

6.1 Right of access. You have the right to be provided with details of the processing of your personal data and to obtain a copy of the personal data we hold about you, subject to applicable exemptions. To help us better deal with your request please provide us with the information necessary to identify you (name, address, account number) and to identify the personal data you require.
In order to make an access request please email info@vantastic.ie or send your request in writing to (Data Protection Officer, Vantastic, Chase House, City Junction Business Park, Northern Cross, Dublin 17.

6.2 Right to rectification. If the personal data we hold on you is inaccurate or incomplete you have the right to rectify such personal data and we would encourage you to ensure the personal data we hold on you is kept as up to date and accurate as possible.

6.3 Right to Erasure. In certain circumstances, you have the right to request the deletion of your personal data where there is no compelling reason for us to continue processing it.

6.4 Right to restrict processing. In certain circumstances you can request the restriction of the processing of your personal data where you contest the accuracy of the information; where you object to processing which is based on legitimate interests; where the processing is unlawful and you wish to restrict the processing rather than seek erasure; or where we no longer require to retain your personal data but you wish the personal data to be held while you establish, exercise or defend a legal claim.

6.5 Right to data portability. You can request to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller.

6.6 Right to withdraw consent. If we are processing your personal data on the legal basis of consent you have the right to withdraw your consent at any time. If you withdraw your consent we will no longer be able to carry out processing based on your consent. However, by withdrawing your consent it does not invalidate any processing which was undertaken prior to the withdrawal of your consent.

6.7 Right to object to processing. You have the right to object to processing based on legitimate interests and to direct marketing (including profiling for the purpose of direct marketing).

Where we have indicated that we are processing your personal data based on the legitimate interest you are entitled to object to such processing on grounds relating to your particular situation. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which overrides your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defence of legal claims.

If you wish to object to receiving direct marketing please use the provided opt-outs or contact us to do so.

6.8 Automated decision making including profiling. You have the right not to be subject to automated individual decision making, including profiling, which produces legal effects concerning you or similarly significantly affects you unless it is necessary for the entry into or performance of a contract, authorised by EU or member state law, or based on your explicit consent.

6.9 Right to lodge a complaint with Data Protection Commissioner. You have the right to lodge a complaint with the:

(ROI customers) Data Protection Commissioner by emailing info@dataprotection.ie or writing to the Data Protection Commissioner, Canal House, Station Road, Portarlington, R32 AP23 Co. Laois.