Introduction
This online privacy policy describes how Globalvia Jons Ltd (hereinafter referred to as ‘Globalvia Jons’, ‘the Company’ or collectively as ‘we’, ‘us’ or ‘our’) collects and process your Personal Data in the course of our business.
Who we are?
Globalvia Jons is an Irish registered company formed in 2013 by three Shareholders – Globalvia Inversiones Ireland and Jons Civil Engineering Ltd to fulfil the MMaRC Network A (“the Network”) Generation 2 Contract for the TII. We are committed to lawfully and fairly processing the Personal Data of data subjects as set out in this document in accordance with applicable data protection laws.
What is Personal Data?
Personal Data can be defined as any information about an individual who visits and uses our website. Such information may include name, email address, IP address or other online identifier. We will need to collect and use your personal information for the purpose of providing you with information you require with regards to our services. Where required, we may need to collect information about you from a third party; however, we will only do this where it is not reasonable or practical for us to collect this information directly from you. Where inaccurate or incomplete information is provided incomplete or inaccurate by you, we may not be able to engage with you as required to meet your specific needs.
Scope
This policy applies when Globalvia Jons collects any Personal Data relating to staff, visitors, contractors, suppliers working on behalf of Globalvia Jons and any third parties or members of the public who visit our website or correspond with us, where their details are legitimately obtained in the course of the Company’s everyday operations.
Purpose
This online privacy notice ensures Globalvia Jons:
- Complies with data protection law and follows best practice.
- Protects the rights of data subject whose Personal Data are collected and processed via this website or through direct engagement with us.
- Demonstrates openness and transparency regarding the end-to-end processing of Personal Data.
Personal Data We May Collect
The following list is non-exhaustive of categories and types of data Globalvia Jons may collect:
|
Personal Data |
This relates to Globalvia Jons employees, visitors, contractors, and suppliers. |
Special Categories of Personal Data |
While it is the not norm to collect health or other related information defined as special categories of Personal Data under data protection law, we may do so in so far as is necessary;
|
Claims Information |
Information necessary for processing insurance claims following an incident may include but not limited to driver name, licence details, address, occupation, medical information (where required), information obtained from the Incident Support Unit including emergency services personnel and third parties at scene of incident, vehicle registration details, insurance details, recovery company information and photographic evidence. |
Image Data |
CCTV, vehicle tracking device data. |
Third Party |
Personal Data supplied or referred by third parties may include but not limited to Motorway Traffic Control Centre (MTCC), M50 Concession Ltd or Local Authorities in the pursuit of information or complaint resolution. This may include name, address, email address, phone number. |
How We Collect Personal Data
We may obtain your personal information in a number of ways. This includes directly from you either in person, over the phone or via the email address provided on our website. With your consent, we will use cookies, and related tracking technology when you use our website in order to optimise your browser experience.
Personal Data Received from Other Sources
We may also need to process your Personal Data shared with us via our partners or external entities (e.g., government agencies or law enforcement). Your contact details may be supplied by Motorway Traffic Control Centre (MTCC), Local Authorities or M50 Concession Ltd in the context of providing responses to enquiries or complaints received from members of the public pertaining to the Network Area of the MMaRC Contract.
How we may use your Personal Data
We will only collect and process personal information from you that is reasonably necessary to assist us in meeting our contractual and legal obligations, as well as address any queries you may have. Outlined below are reasons why your personal data may be processed by us.
Processing Purpose |
To process queries on your behalf. |
|
To process insurance claims for damage on the Network. |
|
|
To ensure the security of data held by the company and for fraud monitoring and prevention. |
|
|
To carry out location checks during weather events. |
|
|
To comply with legal and professional obligations and to cooperate with regulatory bodies. |
|
|
To exercise, defend or protect Globalvia Jons’ legal rights or the rights of our client or third parties. |
|
|
To record a data subject’s site visit for safety requirements. |
|
|
For vital interests where the processing is necessary to protect the interests of the data subject or another natural person. |
|
|
Administrative and internal business purposes. |
Legal Bases for Processing Personal Data
|
Legitimate Interests |
To process payments, respond to queries and/or complaints from customers. |
|
The protection of property, staff, the IT network, and facilities and for the efficient management of the Company’s business and reporting obligations. |
|
Processing and management of job applications. |
|
|
Establish, exercise, or defend legal claims. |
|
Legal Obligation |
Ensuring diligence and reporting obligations, Compliance with the Roads Traffic Acts 1961, General Data Protection Regulation, Data Protection Acts 2018 and other related national or EU laws. In certain circumstances, the GDPR allows Personal Data to be disclosed to competent authorities without the consent of the data subject. Under these circumstances, Globalvia Jons will disclose the data requested. However, we will ensure the request is legitimate, seeking assistance from the company’s legal advisors where necessary. |
Contractual |
Performance of our contractual obligation. |
Disclosure of Your Personal Data
Where appropriate and in accordance with applicable Data Protection Laws, Globalvia Jons may share Personal Data with third parties under the following circumstances:
- with any of our Trusted Service Providers for the uses and purposes outlined under this policy;
- where required, with our clients, intermediaries, advisors, or stakeholders for the purpose of fulfilling our contractual and reporting obligations and efficiently delivering our services;
- with trusted third-party service providers (where required) who perform functions on our behalf such as lawyers, email delivery, IT audit, technical support and IT consultants carrying out testing and development work on our business technology systems;
- In the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business.
[*NOTE: Globalvia Jons does not process Personal Data relating to criminal convictions and offences or related security measures unless under the control of official authority or where processing is authorised by Union or Member State law].
Personal Data Security
Globalvia Jons maintain appropriate technical and organisational security measures to safeguard and protect the security of your Personal Data against loss, misuse, unauthorised access, disclosure, or alteration. These measures are aimed at ensuring the ongoing integrity, confidentiality, availability, and resilience of Personal Data. We evaluate these measures regularly to ensure the security of the processing activities.
The protection of your personal information is a responsibility which we take with utmost seriousness and as such, we are committed to ensuring that your personal information is protected against loss, misuse, unauthorised access, disclosure, or alteration. We have measures in place to guarantee safe and secure keeping of your Personal Data under our care, as well as with third parties who act on our behalf with whom we may share your information. We have put in place a number of technical security precautions in place to mitigate loss, misuse, or unauthorised alteration of your information. Our staff have a moral responsibility and a legal obligation to keep information about you confidential and safe. Our staff have received and will continue to receive appropriate training in data protection, information security and confidentiality in line with our data security policy.
Personal Data Retention
The legal bases define the above for the processing of Personal Data may necessitate retention for defined thresholds. Irrespective of purpose or legal basis for processing, we will not keep your Personal Data for longer than is necessary in accordance with the purpose(s) for which it was first collected. Globalvia Jons has a retention policy in this regard. We may retain aggregated or anonymised data (which is not treated as Personal Data under this privacy notice) for longer.
Rights of Access
You have the right to request the following: to access, review, correct, update, suppress, object to or request deletion or restrict the processing of your Personal Data. For your protection, we may need to verify your identity before facilitating your request. We will respond to your request within one month to either confirm that your request is in place or to offer a legitimate reason why your request cannot be processed at that time. Depending on the nature or the complexity of the request, access response may take another two months to process. We are committed to working with you to obtain a fair resolution of any concern or complaint about your privacy. If, however, you believe that we have not been able to assist with your enquiry satisfactorily, you have the right to make a complaint to the Data Protection Commission at info@dataprotection.ie. For more information, visit www.dataprotection.ie.
Data Destruction
While Globalvia Jons endeavours to permanently erase Personal Data once it reaches the end of its retention period or where we receive a valid request to do so, some data may still exist on our systems, for example if it is waiting to be overwritten or anonymised. In such instances this data has been put beyond use – meaning that, while it still exists on the archive system, it cannot be readily accessed by any of our operational systems, processes, or staff.
Cross Border Transfer
Globalvia Jons does not normally transfer any Personal Data to any country that is not regarded as ensuring an adequate level of protection for Personal Data under European Union law. Should any such transfer be required, Globalvia Jons will take steps to ensure that it is managed carefully in accordance with applicable data protection law.
Changes to our Privacy Policy
We reserve the right to modify this privacy policy at any time and we will provide the most up to date version on our website www.globalviajons.ie . If you would like to be included on a mailing list to receive revised versions, please contact us.
Enquiries and Contact Information
If you have any questions or comments regarding this privacy notice please contact our GDPR Compliance Representative, Globalvia Jons Ltd, Luttrellstown Road, Diswellstown, Castleknock, Dublin 15 or by email at info@globalviajons.ie.