Privacy Policy

ALPHERA Financial Services understands that its use of your information requires your trust. ALPHERA Financial Services is committed to the highest standards of data privacy and will only use your information for clearly described purposes and in accordance with your data protection rights.

Which companies are covered by this policy This policy covers BMW Financial Services (Ireland) DAC, trading as ALPHERA Financial Services.

References in this policy to “ALPHERA”, “we” or “us” are references to BMW Financial Services (Ireland) DAC, trading as ALPHERA Financial Services which is registered at:

• Swift Square
• Santry Demesne
• Santry
• Dublin
• D09 R802

What ALPHERA does: ALPHERA provides services through:

• ALPHERA
  ALPHERA provides regulated and unregulated motor finance products, services, and associated general insurance products to customers in Ireland through its Partners which are motor dealerships and independent credit intermediaries. BMW Financial Services (Ireland) DAC trading as ALPHERA Financial Services regulated by the Central Bank of Ireland.


• Partners
  • Unless stated otherwise, are independent businesses and not part of ALPHERA or other BMW Group companies;
  • They undertake credit intermediary and insurance mediation activities; and
  • They are not covered by this policy and are referenced here to provide additional clarity regarding your personal information.

ALPHERA as Data Controller and our responsibilities: ALPHERA is responsible for, and is the Data Controller of your personal information that it receives through its websites (www.alphera.ie).

ALPHERA is also the Data Controller of the information which is used to grant and provide finance to you.

Ultimately, BMW AG is the parent company of BMW Group Ireland and provides much of the IT infrastructure through the above mentioned companies. BMW AG is generally a service provider or Data Processor to ALPHERA.

Partners

Although this Privacy Policy describes some of the uses of your information made by our Partners, they may collect other information relating to you. Each Partner is a Data Controller in relation to the information it processes for its own purposes. Their privacy policies will set out how they use your information. If you have any queries regarding the use of your information by a Partner please contact them directly or visit the privacy policy on their website.

Changes to this Privacy Policy:

We may modify or update this privacy policy from time to time.

If we change this privacy policy, we will notify you of the changes by publishing an updated policy on this website. Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have (e.g. to object to the processing).

How do we collect your personal information These are the main ways we collect your information.

• If you contact us directly via our websites or via our customer hotlines to request information about our products and services.
• If you buy a product or service directly from us.
• If you reply to our direct marketing campaigns (e.g. filling out a response card).
• If your contact details are transferred from authorised centres or other third parties.
• If other BMW legal entities or business partners transfer your personal data to us.
• If we acquired your personal data from other sources, for example social media sites.
• When you apply for finance from ALPHERA or from the Partners.

If you give information on behalf of someone else you must ensure that you have their permission and that they have been provided with this Privacy Policy before doing so.

If you are under 16 please do not provide us with any of your information unless you have the permission of your parent or guardian.

Please help us to keep your information up to date by informing us of any changes to your contact details or privacy preferences. You may change or review your preferences, please see section Contacting ALPHERA about this privacy policy.

What information may be collected about you The following types of personal information about you may be collected:

• Contact Details
  • Name
  • Address
  • Phone numbers
  • Email address


• Website and Communication Usage
  • How you use our website and whether you open or forward our communications, including information collected through cookies and other tracking technologies (see our Cookie Policy below).


• Sales and Services Information
  • Relating to purchases and services, including complaints and claims.


• Credit and Anti-Fraud Information
  • Which establishes your identity, such as driving licences, passports and utility bills
  • Information about transactions, requests for credit and non-payment of debts with us and third parties and credit ratings from credit reference agencies
  • Fraud, offences, suspicious transactions, politically exposed person and sanctions lists where your details are included.
  • Employment history
  • Bank details
  • ALPHERA may also ask you to provide information about your health if it becomes aware of a condition that might affect your ability to repay the finance without difficulty.

How your personal information may be used Use of personal information under Irish data protection laws must be justified under one of a number of legal grounds and we are required to set out the grounds in respect of each use in this policy. An explanation of the scope of the grounds available can be found below.

The main uses of your information are:

Customer Support and Marketing - to respond to enquiries and complaints and to bring you news and offers.


Vehicle Sales & Service – to process your sale, configure and service your vehicle


Vehicle Finance – to assess your eligibility for finance to comply with legal obligations and for legitimate interests. For example to ensure that ALPHERA offers the most appropriate offers of finance to you, to ensure that the services function correctly, to prevent fraud and money laundering and to ensure that your records are accurate and up to date

When you apply for finance from ALPHERA you must provide certain personal information. ALPHERA may share the information with Credit Reference Agencies (for example the Irish Credit Bureau) to help them decide whether to offer you finance. Using information about you in this way is necessary for ALPHERA to make this decision and if you do not provide it to ALPHERA they may not be able to offer you finance. Your information will be used by ALPHERA and these agencies as follows:

• ALPHERA will check records about you and others held by them and by Credit Reference agencies, for example to assess your application for credit and verify identities to prevent and detect crime and money laundering.
• If you give ALPHERA false or inaccurate information or BMW FS Ireland suspect or identifies fraud, they will record this and may also pass on the information to organisations involved in crime prevention. Law enforcement agencies may also access and use this information. If fraud is detected, you could be refused certain services, finance or employment.
• Your data may also be used for other purposes for which you give your permission or, in limited circumstances, when required by law or where permitted under the terms of relevant data protection and privacy law.
  
  Please review Irish Credit Bureau’s Fair Processing Notice which is available at http://www.icb.ie/policy_privacy.php. It documents who they are, what they do, details of their Data Protection Officer, how they get the data, why they take it, what personal data they hold, what they do with it, how long they retain it, who they share it with, what entitles them to process the data (legitimate interests), what happens if your data is inaccurate and your rights i.e. right to information, right of access, right to complain, right to object, right to restrict, right to request erasure and right to request correction of your personal information.
  
  ALPHERA uses automated decision-making tools to help it to decide whether to offer you finance. Based on the information you provide us, we will compare this against different metrics to determine whether you meet the eligibility criteria for finance or to determine whether you will be able to make repayments on a vehicle without difficulty. If your application for finance is rejected using automated means alone, you will be given the opportunity to ask for the decision to be reviewed manually. This does not mean that the decision will be changed.
  
  ALPHERA does not share credit and anti-fraud information with Partners or other BMW Group Companies.
  
  ALPHERA will also use your personal information to manage its contractual obligations and to enforce its rights under the finance agreement. For example, if you fall into arrears or break any other term of the agreement, ALPHERA may pass on your details to a debt collection agency for the purpose of collecting the debt or to a vehicle recovery agent to repossess the vehicle or to solicitors to issue court proceedings against you. ALPHERA may also activate your GPS tracker or review publicly available information to trace your whereabouts. For full details of how ALPHERA processes your personal information please refer to the “Use of Your Information” clause in your finance agreement.

Compliance with legal requests for your information – to comply with our legal obligations to law enforcement, regulators and the court service

We may be legally required to provide your information to law enforcement agencies, regulators, courts and third party litigants in connection with civil or criminal proceedings or investigations anywhere in the world. Where permitted, we will direct any such request to you or we may notify you before responding unless to do so would prejudice the prevention or detection of a crime.

Legal grounds for processing of your personal information The use of your information set out above is permitted under Irish data protection law on the basis of these principal legal grounds:

• Where you have consented to the use (you will have been presented with a consent form in relation to any such use and may withdraw your consent at any time through the ALPHERA Customer Service
  • on 0186 28275
  • or sending an email to alphera customerservices@alphera.ie
  • or by writing to us at:
  
  

  ALPHERA Customer Service
  FAO – Customer Service Manager
  Swift Square
  Santry Demesne
  Dublin 9
  D09 R802



• Where necessary to enter into or perform our contract with you
• Where we need to use it to comply with our legal obligations
• Where we use it to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights (our legitimate interests include promoting the ALPHERA business and tailoring news and offers to your profile, research and development of vehicle related products and services, assessing your credit-worthiness, detecting fraud and criminal activities).

There may be uses that are permitted on the basis of other grounds; where this is the case we will use reasonable endeavours to identify the ground and communicate it you as soon as possible after becoming aware of the new basis.

Third parties to whom we may transfer your data Personal information which we collect may be transferred to or accessed by third parties on our behalf, with your consent where necessary.

The types of third parties apart from ALPHERA the other BMW Group companies already stated are:

• Marketing and research companies who run and manage marketing and research campaigns
• Event companies who run and manage sponsored events
• ALPHERA’s Customer Interaction Centre who provide customer support
• Partners who provide services to you
• IT providers who provide us systems and services for customer support
• Card Payment Services providers who operate payment platforms
• Logistics and courier companies who transport our products to you
• Companies who provide transport to you or offer you mobility services (e.g. chauffeurs)
• Law firms who provide legal advice to us (e.g. where there is a customer dispute).
• BMW (UK) Limited who provide systems and support to help us deliver service of sales and technical support
• BMW Financial Services (GB) Limited who provide systems to support the delivery of our services

This is only shared in a secure manner, using a consistent security protocol. When we share with other parties we ensure that they only use your personal data for the purpose it was collected and do not allow them to abuse this agreement.

ALPHERA may also transfer your personal information to a third party without your consent if it is in its legitimate interest or if there is a contractual obligation to do so. For example, ALPHERA may pass on your personal details to a third party debt recovery agent if you fail to make the payments due under your finance agreement or to a vehicle recovery agent to collect the vehicle at the end of your finance agreement. For full details of how ALPHERA uses and shares your personal information please refer to the “Use of Your Information” clause in the finance agreement.

How do we keep your personal information safe We use technical and organisational security measures including encryption and authentication tools to protect your personal information, against manipulation, loss, destruction, and access by third parties.

Although data transmission over the Internet or website cannot be guaranteed to be secure, we and our business partners work hard to maintain physical, electronic and procedural safeguards to protect your information in accordance with applicable data protection requirements. Our main security measures are:

• Tightly restricted access to your data on a “need to know” basis and for the communicated purpose only
• Transferred collected data only in encrypted form
• Highly confidential data stored only in encrypted form - e.g. credit card information
• Firewalled IT systems to prohibit unauthorised access e.g. from hackers
• Permanently monitored access to IT systems to detect and stop misuse of personal data.

If you have a personal password which enables you to access certain parts of our websites or any other portal, app or service we operate, do not forget your responsibility for keeping this password confidential. We ask you not to share your password with anyone.

How long we keep your personal information for We retain your information only as long as is necessary and only for the purpose for which we obtained them. We restrict access to your information to only those persons who need to use it for the relevant purpose.

Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised or destroyed securely.

Use for marketing:

• We retain your personal information for as long as is necessary, but only for the relevant purpose that we collected it for. For example, if you have obtained finance for the purchase of a vehicle through ALPHERA, we will retain your personal data for the life of your finance product, so that towards the end of that period we can get in touch with you about your options at the end of the finance term.

Use to perform a contract:

• In relation to your information used to perform any contractual obligation with you we may retain that data whilst the contract remains in force plus seven years to deal with any queries or claims thereafter.

Where claims are contemplated:

• In relation to any information where we reasonably believe it will be necessary to defend or prosecute or make a claim against you, us or a third party, we may retain that data for as long as that claim could be pursued.

Data sharing with third parties ALPHERA is part of BMW Group which is a global group of companies. Your personal information may be accessed by our staff, agents or contractors from a country outside the European Economic Area (EEA) for any of the purposes set out in this policy. These countries may have in place data protection laws which may be of a lower standard than in the EEA. We will ensure that any of your information that is accessible outside the EEA is handled subject to appropriate safeguards.

Certain countries outside the EEA, such as Canada and Switzerland, have been approved by the European Commission as providing essentially equivalent protection to EEA data protection laws and therefore no additional legal safeguards are required. In countries which have not had such approval, we will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.

ALPHERA will not share your contract information with other Group Companies other than as specifically mentioned in this Privacy Policy or the Use of Information clause on the finance agreement.

Please contact us if you would like to see a copy of the specific safeguards applied to the export of your information.

Contacting ALPHERA about this privacy policy If you have any questions in relation to our use of your information you should first contact the BMW Customer Service in one of the following ways:

• Call ALPHERA Customer Service on 0186 28275
• Or by sending an email to alphera customerservices@alphera.ie
• Or by writing to us at:
  
  

  ALPHERA Customer Service
  FAO: Customer Service Manager
  Swift Square
  Santry Demesne
  Dublin 9
  D09 R802

In addition you may contact our data privacy officer under the above contact details.

Under certain conditions you have the right to require us to:

• Provide you with further detail on the use we make of your information
• Provide you with a copy of your information
• Update any inaccuracies in the information we hold about you
• Delete any information about you that we no longer have a lawful ground to use
• Remove you from any direct marketing lists when you object or withdraw your consent
• Provide you with your personal information in a usable electronic format and transmit it to a third party (right to data portability)
• Restrict our use of your personal information
• Cease carrying out certain processing activities based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights (Please see section Legal grounds for processing of your personal information).

Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and the rights of third parties.

If you are dissatisfied with our use of your information or our response to any exercise of these rights you have the right to complain to the Office of the Data Protection Commissioner which regulates the processing of personal data in Ireland.

ALPHERA COOKIE POLICY 1 What is a cookie?

A cookie is a small text file that stores Internet settings. Almost every website uses cookie technology. The cookie is downloaded by your Internet browser the first time you visit a website. The next time you visit this website from the same device, the cookie and the information in it are either sent back to the originating website (first-party cookies) or to another website to which it belongs (third-party cookies). By that, the website can detect that it has already been opened using this browser, and in some cases it will then vary the content it shows.

Some cookies are extremely useful because they can improve your user experience when you return to a website you have already visited. This assumes that you are using the same device and the same browser as before; if so, cookies will remember your preferences, will know how you use the website, and will adapt the content you are shown so that it is more relevant to your personal interests and needs.

2 Categories of cookies.

Based on what function cookies have and the purpose for which cookies are used, there are four categories of cookie: strictly necessary cookies, performance cookies, functional cookies and marketing cookies.

Strictly necessary cookies
Are essential in order to enable you to move around the website and use its features. Without these cookies, some services cannot be provided – for example, remembering previous actions (e.g. entered text and vehicle configurations) when navigating back to a page in the same session.

Performance cookies
Gather information about how a website is used – for example, which pages a visitor opens most often, and whether the user receives error messages from some pages. These cookies do not save information that would allow the user to be identified. The collected information is aggregated, and therefore anonymous. These cookies are used exclusively to improve the performance of the website, and with it the user experience.

Functional cookies
Enable a website to save information which has already been entered (such as user names, languages choices, and your location), so that it can offer you improved and more personalised functions. For example, a website can offer you local, price-relevant tax information if it uses a cookie to remember the region in which you are currently located. Functional cookies are also used to enable features you request such as playing videos. These cookies collect anonymous information and cannot track your movements on other websites.

Targeting cookies
Are used to deliver adverts and other communications more relevant to you and your interests. They are also used to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns. They remember whether you have visited a website or not, and this information can be shared with other organisations such as advertisers. Cookies for improving group targeting and advertising will often be linked to site functionality provided by other organisations.

3 Your cookie settings on this website.

Cookies on this website that do not require approval.
Cookies that are essential, also known as ‘strictly necessary’ cookies, enable features without which you would not be able to use the website as intended. These cookies are used exclusively by ALPHERA and are therefore known as first-party cookies. They are only saved on your computer while you are actually browsing the website. An example of why strictly necessary cookies are used is so that when you open the car configurator, you receive a version of it which corresponds to the data volume which your current Internet connection can handle.

Another example of what these cookies do is facilitate a switch from http to https when you change pages, so that the security of data transmitted is maintained. Furthermore, a cookie of this kind is used to store your decision about the use of cookies on our website. Your consent is not required for the use of strictly necessary cookies.

Strictly necessary cookies cannot be disabled using the features of this website.

It is important to note that if you change your settings and block certain cookies, you will not be able to take full advantage of some features of our site, and we might not be able to provide some features you have previously chosen to use.

Disabling/Enabling all cookies.

You can accept or decline cookies by modifying the settings in your browser. However, you will not be able to use all the interactive features of the site if cookies are disabled. Most recent web browsers allow control over the cookies saved through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit:

www.allaboutcookies.org