N6 Privacy Statement

WHO WE ARE

N6 (Concession) Limited (“N6″) was awarded a “PPP” (Public Private Partnership) contract by Transport Infrastructure Ireland (“TII”) (formerly the National Roads Authority, NRA). Under the contract N6 is contracted to design, finance and construct 53km of motorway from Ballinasloe to East to Galway. Upon completion, N6 will collect tolls, operate and maintain the N6 motorway.

COMMITMENT

At N6, we are committed to maintaining the trust and confidence of visitors to this web site and the users of the N6 motorway. We want you to know that N6 under no circumstance will be selling, renting or trading your data with other companies and businesses for marketing purposes.

At N6 we value respect and protect your right to privacy in relation to your interactions with this website and when using the N6 motorway. We are committed to safeguarding your personal information and to protecting its confidentiality. Any personal information which you volunteer to us via this website or otherwise will be treated in accordance with the terms of the General Data Protection Regulation (GDPR) (EU) 2016/679 legislation and/or such amending or replacement legislation as may be adopted in Ireland from time to time.

COOKIES

The website uses cookies, which are small data files generated on the user’s computer. We will not place cookies on any user’s computer where the user has not opted-in to their use, save where the use of cookies is strictly necessary to provide a service specifically requested by the user. For more information, please consult our N6 Cookie Policy

YOUR PERSONAL INFORMATION – TYPES OF PERSONAL DATA THAT WE PROCESS

N6 will process the personal data which you provide to us, and which will include the following:

Name and contact details
Encrypted Credit or debit card details (where you pay using this method)
Vehicle registration details
Vehicle class
CCTV footage
Still images
Tag numbers associated with your vehicle registration number

YOUR PERSONAL INFORMATION – PURPOSE AND LEGAL BASIS FOR PROCESSING

Purpose(s) for Processing	Legal Basis
To provide the road user with customer service, to ensure that payment of the toll may be taken and processed, and to respond to any queries or complaints from road users in connection with our service	· To perform our contract with you
To manage our relationship with you and provide our services	· To perform our contract with you. · To comply with our legal obligations. · To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights – you have the right to object at any time.
To ensure that automated vehicle classification when you pass through the toll is effective	· To support our legitimate interests in managing our business and ensuring that vehicles are properly classified for the purpose of tolling, provided such interests are not overridden by your interests and rights – you have the right to object at any time.
To ensure that any ‘tag customers’ who wish use our service are able to do effectively and automatically, and to ensure vehicle classification for such customers can operate correctly	· To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights – you have the right to object at any time.
To ensure that we can provide our service to customers who are purchasing ‘trip cards’, including taking payment for the trip card and providing the trip card to the user	· To perform our contract with trip card customers
For the prevention and detection of criminal activity or for the purpose of responding to a binding request from a public authority or court	· To comply with legal and regulatory obligations
To assert, protect and defend our legal rights, including via legal proceedings or other legal claims (for example, where damage is caused to the motorway)	· To comply with our legal obligations. · To support our legitimate interests in managing our business and protecting our legal rights and interests provided such interests are not overridden by your interests and rights – you have the right to object at any time.
Managing and operating our website – to keep it updated and relevant, to develop our business and to inform our marketing strategy	· To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights – you have the right to object at any time.
Processing of job applications	· To perform or enter into a contract with the data subject · To support our legitimate interests in managing and providing services to our clients provided such interests are not overridden by the rights and interests of the data subjects concerned.
Transferring information to third parties, including to our own service providers	· To support our legitimate interests in managing our business provided such interests are not overridden by your interests and rights – you have the right to object at any time · To comply with our legal obligations

In the event that you cause damage to the motorway and do not stop and/or report the incident to, or you do not pay the toll as required by law, N6 may receive personal data from local and national authorities, the MIBI and An Garda Síochána in respect of ownership of motor vehicles in order to assist N6 with enforcement. This processing is to support our legitimate interests in establishing, maintaining or defending claims concerning our legal rights.

We do not consider that the legitimate interests referenced above would prejudice your rights or fundamental freedoms as a data subject. For more information on our legitimate interests and the balancing exercise, please contact our Data Protection Officer using the details below.

Where processing is based on our legitimate interests, you have the right to object to such processing.

We do not collect any information personally identifying you when you visit our website. We automatically collect and store statistical and other analytical information collected on an aggregate and anonymised (non-individual) basis of all browsers who visit the site.

SPECIAL CATEGORIES OF DATA

In the event of an accident or similar incident on the N6 motorway, we may process special categories of your personal data (namely data concerning your health). This processing is based on our legitimate interest, with such processing being necessary for the establishment, exercise or defence of legal claims which N6 may become involved in.

RECIPIENTS OF PERSONAL DATA

To the extent required by the performance of our contract with you, any legal obligations which are imposed on us, or otherwise in our legitimate business interests, N6 will disclose your personal data to other recipients and third parties.

These third parties or other recipients include:

Other ‘car tag’ providers and toll concessionaries in Ireland, to ensure co-operation across the industry in upholding our obligations under interoperability contracts, and to maintain a centralised portal to ensure queries and complaints from national motorway users are properly resolved;
Statutory or regulatory bodies to whom N6 is obliged to disclose information, for example the Revenue Commissioners, an Garda Siochána and other law enforcement or regulatory authorities.

RETENTION

N6 will only retain CCTV footage it collects for a period of 90 days. All other personal data will be retained by N6 for as long as is required to conduct our business and satisfy any legal obligations requiring the retention of such personal data.

WHERE YOU DO NOT PROVIDE US WITH YOUR PERSONAL DATA

If you do not provide us with your personal data, you may not be able to access or use our services, which may also impact on your ability to travel along the N6 motorway, or our ability to provide you with effective customer service.

DATA SUBJECT RIGHTS

In certain circumstances, you have the right to:

Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below);
Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes;
Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
Request the transfer of your personal information to another party.

If you wish to make a Data Subject Access Request, please complete our Subject Access Request Form by clicking here Subject Access Request Form and email your request to our Data Protection Officer, at the email address below. You can also post it to us at the address below. We will respond to your request in writing, or orally if requested, as soon as practicable and in any event not more than within one month after of receipt of your request. In exceptional cases, we may extend this period by two months and we will tell you why. We may request proof of identification to verify your request. For more details in relation to your rights, including how to exercise them, please see contact us using the contact details below.

N6 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 N6 at the following address and N6 will update your information immediately;

Postal Address: N6 (Concession) Ltd, Toll Plaza Building, Cappataggle, Ballinasloe, Co. Galway, Ireland H53 N672

E-mail: dpo@n6concession.com

LINKS TO THIRD PARTY WEBSITES

Our website may contain links that permit you to link to other websites. When you click on one of those links you are connecting to another website. N6 has no responsibility or liability for, or control over, those other websites or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites before you submit any personal information to them.

CHANGES TO OUR PRIVACY STATEMENT

N6 reserves the right at any time without notice to revise and make changes to this Privacy Statement. Any changes to the Privacy Statement will be posted on the company’s website and by continuing to use this website following any such change you signify that you agree to be bound by the revised Privacy Statement.

CONTACT

If you have any questions, concerns or complaints about this Privacy Statement please contact our Data Protection Officer by email at: dpo@n6concession.com

Please remember that email sent over the Internet is not secure. If you send an email directly to us from your own email account, the contents will not be encrypted. We strongly recommend that you do not send sensitive information (like a credit card number) to us via unencrypted email. N6 is not responsible for any transmission by you of any personal information over the Internet.

We will respond to your request or investigate your concern as quickly as we can within the legal periods established in the related regulations.

RIGHT TO COMPLAIN

You also have a right to complain to the Data Protection Commission. You can contact the Data Protection Commission 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