Privacy. Data Protection Policy. | YUKÕ
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YUKÕ PRIVACY AND DATA PROTECTION POLICY

YUKO is owned and operated by Carclick Limited (YUKO). Carclick is a limited liability company registered in Ireland and a member of the Toyota Ireland group of companies. 

YUKO respects your privacy.  Whether you deal with YUKO as an applicant, an active member or someone who signed up and never used the service before you are entitled to the protection of your personal data.

In this Yuko Privacy and Data Protection Policy (“this Policy”) we describe how we collect your Personal Data and why we collect it, what we do with your Personal Data, with whom we share it, how we protect it, and the choices you can make about your Personal Data.

Your personal data refers to any information that would allow us to identify you either directly or indirectly.

This Policy applies to the processing of your Personal Data in the framework of various services, tools, applications, websites, portals, promotions, marketing actions, social media platforms, etc. that are provided or operated by us or on our behalf.

This Policy applies to all your Personal Data collected by (or on behalf of) YUKO, referred to in this Policy as “YUKO”, “YUKO Toyota Car Club”, “Carclick Ltd”, “we”, “us” and “our”.

If you accept the provisions of this Policy, you are agreeing to us processing your Personal Data in the ways that are set out in this Policy.

At the end of this Policy, you will find some definitions of certain key concepts used in this Policy and which are capitalised (for example, Personal Data, Processing, Data Controller…).

1. Who is responsible for the processing of your personal data?

The entity which is responsible for the processing of your Personal Data is: Carclick Limited (trading as YUKO), Lexus House, Killeen Road, Dublin, D12AW94.

2. Purpose of the Processing

Through our mobile applications YUKO provides you with car sharing/rental services.

a.      The creation of your YUKO account

The purpose of processing YUKO members’ personal data is to enable members of the public to become approved YUKO members who would then be eligible to hire and drive cars on the YUKO fleet.

We must process and hold the members’ personal data for identification purposes, to confirm they have an appropriate and legitimate driving licence and for the purposes of ensuring that they meet certain insurance criteria to enable them to legally drive any car from the YUKO fleet. The data is also required for the approved member to be able to book a vehicle, to process the payment of the car hire cost and potentially any fines if necessary. For the duration of your commercial relationship with YUKO, your credit/debit card information will need to be retained to facilitate booking related payments.

b.     Improvement of YUKO services on the basis of:

Survey data, feedback and correspondence is used for training purposes and to improve the user design of our application and products and essentially the experience.  

c.      The processing of your booking:

To confirm your booking with YUKO; to amend/cancel your booking with YUKO; to communicate with you in relation to to your upcoming booking i.e. reminder; to manage your invoices, to manage the payment of arrears; to manage potential claims, to manage the recovery of potential damages to YUKO vehicles; to manage insurance; to manage fines so that they are transferred to the relevant driver who has committed the traffic violation/offence.

Member booking data is also used to gain insight into utilisation rates of vehicles which gives us knowledge of supply vs demand in busy/quieter locations. This information enables us to add/move vehicles from specific locations to meet the needs of the approved members in that community.

d.     The use of connected devices in YUKO vehicles:

As YUKO is a fully digital and automated way of renting, each vehicle is equipped with connected devices. These devices collects data to monitor the state, performance and the functionality of YUKO vehicles. We can verify that vehicles are fit for purpose and safe to drive by approved YUKO members. For example, if the fuel tank is sufficiently full for the next member, the battery level is appropriate, there is no damage to the vehicle that would put the next driver in danger, the vehicle has been returned to the designated station and that drivers can be charged the appropriate amount for kilometres exceeding the 50km per day limit. This processing is aimed at protecting the integrity of YUKO Toyota Car Club’s fleet.

YUKO vehicles are also monitored by geolocation systems and telematics (crash detection). Geolocation systems and telematics have been embedded in our fleet to;

  • Ensure vehicles are situated in their designated station and are available for bookings, thus providing approved YUKO members with a better customer experience;
  • To prevent fraud/damaging action against YUKO vehicles;
  • To locate YUKO vehicles in the event of theft/suspected theft;
  • To locate YUKO vehicle in the event of a suspected accident in order to provide assistance or emergency services;
  • To ensure damage is brought to our attention immediately so that vehicles can be maintained and in a safe condition to drive;
  • To ensure our YUKO members are driving in a safe manner and are not causing danger to other road users or themselves;
  • For potential insurance claims.

 

e.      The management of a watchlist of YUKO members presenting certain contractual risks:

As part of our legitimate business interest, we may identify specific customers who meet a number of criteria and for whom future bookings may be curtailed.  Such criteria can include:

  • Payment incidents which have given rise to legal proceedings;
  • Vehicle accidents or repeated damaged caused by a YUKO member;
  • Use of YUKO’s vehicles in breach of our terms and conditions;
  • Fraudulent licences, use of fuel cards, vehicles etc.

 

f.       Improvement of YUKO services on the basis of:

Survey data, feedback and correspondence is used for training purposes and to improve the user design of our application and products and essentially the experience. 

g.      Promotional & marketing activities, upon your consent:

We may use your personal data and profiling information to analyse your use of our services and to identify specific products or services that may be of interest to you.  We may segment customer data based on a number of criteria such as frequency of booking or duration of booking.  This segmentation information is then used to communicate marketing material to our members where they have given us consent.

h.     The processing of personal data for the purpose of law enforcement

Please note that in accordance with applicable data protection law, your Personal Data can be processed if:

  • you have given us your consent for the purposes of the Processing (as described in this notice). For the avoidance of doubt, you will always have the right to withdraw your consent at any time; or 
  • it is necessary for the performance of a contract to which you are a party; or
  • with such Processing, we pursue a legitimate interest that is not outbalanced by your privacy rights. Such legitimate interest will be duly communicated to you in the privacy notice related to that particular processing. 
  • it is required by law.  

Please note that Yuko will share personal data with an Garda Siochana where requested to do so under Section 41 of the 2018 Data Protection Act.  Such information can include that listed in Section 5 of this document. 

The legal basis on which we process your data will be one of the bases set out above, depending on the type of personal data is being processed and the purpose for the processing.

 

3. Who can you contact in case you have questions or requests on your data?

We have organised a Data Protection Coordinator who will handle your questions or requests relating to this Policy, any specific privacy notice or your Personal Data (and its processing).

For any questions, requests or complaints concerning the application of this Policy or to exercise your rights, as described in this Policy, you may contact our Data Protection Coordinator at:

gdpr@yuko.toyota.ie

Data Protection Coordinator, Yuko Ireland, Killeen Road, Dublin, D12AW94.

 

4. Key Principles

We value your Personal Data that you have entrusted to us, and we are committed to processing your Personal Data in a fair, transparent and secure way. The key principles Yuko apply are as follows:

Lawfulness: we will only collect your Personal Data in a fair, lawful and transparent manner.

Data minimisation: we will limit the collection of your Personal Data to what is directly relevant and necessary for the purposes for which they have been collected.

Purpose limitation: we will only collect your Personal Data for specified, explicit and legitimate purposes and not process your Personal Data further in a way incompatible with those purposes.

Accuracy: we will keep your Personal Data accurate and up to date.

Data security and protection: we will implement technical and organisational measures to ensure an appropriate level of data security and protection considering, among others, the nature of your Personal Data to be protected. Such measures provide for the prevention of any unauthorised disclosure or access, accidental or unlawful destruction or accidental loss, or alteration and any other unlawful form of Processing.

Access and rectification: we will process your Personal Data in line with your legal rights.

Retention limitation: we will retain your Personal Data in a manner consistent with the applicable data protection laws and regulations and for no longer than is necessary for the purposes for which they have been collected.

Protection for international transfers: we will ensure that any of your Personal Data transferred outside the EEA is adequately protected.

Safeguards towards third parties: we will ensure that Personal Data access by (and transfers to) third parties are carried out in accordance with applicable law and with suitable contractual safeguards.

Lawfulness of direct marketing and cookies: when we send you promotional materials or place cookies on your computer, we will ensure that we do so in accordance with applicable law.

5. Categories of Personal Data Concerned

Following signing up as a YUKO member, YUKO may collect and store all or some of the following member data:

  • Identity Data including first name, maiden name, last name, username or similar identifier, title, copy of your driving licence, date of birth, nationality and gender;
  • Contact Data including residential address, email address and telephone number(s);
  • Financial Data including bank account details, credit or debit card details;
  • Location Data including vehicle collection and drop off points - all of our vehicles are fitted with GPS tracking technology and this information is retained for a period after your booking has been completed.  This information shows the locations that you travelled to, the time of your journeys and can also include information in relation to your driving style (speed, acceleration and braking).  This data is collected to ensure the security of our vehicles;
  • Transaction Data including details about payments to and from you and other details of products and services you have purchased from us;
  • Technical Data including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
  • Usage Data including information about how you use our website, products, and services;
  • Marketing and Communications Data including your preferences in receiving marketing from us and our partners.
  • We may also monitor, and record telephone calls made to and from us to assist in improving customer services, to evidence instructions or to prevent or resolve disputes.  
  • As part of our insurance questionnaire completed at the time of applying to join Yuko, a number of additional types of data are requested and retained:

o   Sensitive personal data relating to your health;

o   Details of criminal offences or road traffic offences (if any).

6. Use of social media

YUKO social media accounts have their own terms of use which you need to consider when active on our social media accounts. We remind you that publication on social media may have certain consequences, including for your privacy or for the privacy of persons whose Personal Data you share, such as, for example, the impossibility to withdraw a publication within a short term. You are fully responsible for your publications. YUKO will not have any responsibility and liability in this regard.

7. Retention Period

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. The member’s personal data is kept on the YUKO database for a maximum period of the duration of the member’s membership and for a certain period afterwards to comply with any applicable legal and insurance cover obligations.

YUKO member’s personal data is retained for different periods of time depending on the purposes of processing.

The member’s personal data is kept on the database for a maximum of 7 years if they have never used the service.  If a member has used the service at least once, we may hold personal data for a period afterwards, to comply with any applicable legal and insurance cover obligations.

If you apply for a job in YUKO, we will retain your personal data in this instance for as long as the recruitment process is underway and will delete it when this process has been completed.

8. Keeping your Personal Data accurate and up to date

It is important for us to maintain accurate and up to date records of your Personal Data. Please inform us of any changes to or errors in your Personal Data as soon as possible by contacting us at support@yuko.toyota.ie.  We will take all reasonable steps to make sure that any inaccurate or outdated Personal Data is deleted or adjusted accordingly.

9. Use of cookies

We use cookies on our website. This helps us to provide you with a better experience when you browse our website and allows us to make improvements to our site.

For further information about our use of cookies and on how to avoid them, please consult our cookie policy, available at https://www.yuko.ie/.

10. Your choices and your rights

We want to be as transparent as possible with you, so that you can make meaningful choices about how you want us to use your Personal Data.

How you contact us and how you will be contacted

To unsubscribe from communications please follow the unsubscribe instructions included in the communication you received or contact us at Support@YUKO.Toyota.ie.

Please note that by default, YUKO may communicate with you electronically and you will receive our communications at the normal frequency of the publication involved.

Your Personal Data

You may always contact us to find out what Personal Data we have concerning you. Under certain conditions, you have the right to receive your Personal Data, which you have provided to us, in a commonly used, structured machine-readable format and to transmit your Personal Data to any third party of your choice.

Your corrections

If you find any mistake in your Personal Data or if you find it incomplete or incorrect, you may also require from us that we correct or complete it.

Your restrictions

You have the right to request a restriction on the Processing of your Personal Data (for example, while the accuracy of your Personal Data is being checked).

Your objections

You may also object to the use of your Personal Data for direct marketing purpose by unsubscribing or to the sharing of your Personal Data with third party for the same purpose.

You may withdraw your consent at any time to the continued Processing of the Personal Data that you have provided to us by contacting the Data Protection Coordinator.

Moreover, you may require us to erase any data concerning you (except in some cases, for example, to prove a transaction, for insurance purposes or when required by law).

Please note that these rights are in some circumstances limited by data protection legislation.

Finally, please note that you have the right to file a complaint against the Data Controller with the Data Protection Commissioner.

12. Legal Information

The requirements of this Policy supplement, and do not replace, any other requirements existing under applicable data protection law. In case of contradiction between what is written in this Policy and requirements in applicable data protection law, applicable data protection law will have priority.

YUKO may amend this Policy at any point in time. Where this happens, we will alert you of any changes and we will then ask you to re-read the most recent version of our Policy and to confirm your acceptance thereof.

13. Disclosure of Personal Data

Depending on the purposes for which we collect your Personal Data, we may disclose it to the following categories of recipients, which will then process your Personal Data only within the framework of these purposes:

a) Within our organisations and our brand environment:

Our authorised staff members;

Our affiliate companies;

b) Third party business partners:

Business partners: trusted companies that may use your Personal Data to provide you with the services and/or the products you requested and/or that may provide you with marketing materials (if you have consented to receiving such marketing materials). We ask such companies to always act in compliance with applicable laws and this Policy and to pay high attention to the confidentiality of your personal information.  These partners may include

  • Software and hardware providers:  member’s personal data, usage data, geo-location data and transactional data stored on this system.
  • CRM system providers: members personal data, usage data and transactional data is stored on this CRM system.
  • Advertising, marketing, and promotional agencies: to help us deliver and analyse the effectiveness of our advertising campaigns and promotions. 

c) Other third parties:

When required by law or as lawfully necessary to protect YUKO:

  • To comply with the law, requests from authorities (including Data Protection related requests under Section 41 of the Data Protection Act 2018 from an Garda Siochana), court orders, legal procedures, obligations related to the reporting and filing of information with authorities, etc.
  • To verify or enforce compliance with YUKO policies and agreements; and
  • To protect the rights, property or safety of YUKO and/or its customers;  

In connection with corporate transactions: in the context of a transfer or divestiture of all or a portion of its business, or otherwise in connection with a merger, consolidation, change in control, reorganisation or liquidation of all or part of YUKO Toyota Car Club business.

13. Definitions

In this Policy, the following terms have the following meanings:

(a) Data Controller means the organisation which determines the purposes for which, and the way, your Personal Data is processed.  Unless we inform you otherwise, the Data Controller is YUKO, Lexus House, Killeen Road, Dublin, D12AW94, Ireland. Further information may be provided to you through a separate privacy notice which will, for example, be included in specific services (including communication services), electronic newsletters, reminders, surveys, offers, invitations for events, etc.

(b) Data Processor means the person or organisation which processes your Personal Data on behalf of the Data Controller.

(c) Data Protection Coordinator means the contact point where you can address to your questions or requests regarding this Policy and/or (the Processing of) your Personal Data and which will handle such questions and requests. Unless we inform you otherwise.

(d) EEA means the European Economic Area (= member states of the European Union + Iceland, Norway, and Liechtenstein).

(e) Personal Data is any information that may relate to, including but not limited to, your name, telephone number, email address but also to other data, such as your Vehicle Identification Number (VIN), registration number, geo-location, nationality, Date of Birth, driving licence details, home address etc and telephone call records.

(f) Processing means the collection, accessing and all forms of use of your Personal Data.

 

Updated on 27 January 2023