Your Privacy
Dualway Coaches Ltd is committed to protecting the privacy of our potential and existing customers. Dualway Coaches Ltd privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other channels online and offline as further described below (collectively the “Gray Line Ireland Products”).

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information, goods or services you have requested.

Dualway Coaches Ltd that is the controller for the processing of your Personal Data as set out in this Privacy Policy will depend on which Gray Line Ireland product(s) you are interested in or have engaged with. Being the controller means that this company is responsible for ensuring that your personal data is processed in compliance with applicable privacy and data protection legislation.

Personal Data

“Personal Data” is information or pieces of information that could allow you to be identified, such as for example:

• Name and contact details (e.g. postal and email address, telephone number)
• Account information (e.g. user name, profile picture or social media account ID)
• Country of residence
• Birth date
• Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data
• Preferences (e.g. shopping habits, preferred city tours)
• Billing information (Credit- debit card number, ID)

How do we collect Personal Data?
We collect Personal Data in a variety of ways:

• Directly from you:Information is collected directly from you, either by you providing the information directly to us or you acting in a manner that provides us with the information, for example:
  • Offline:We collect Personal Data from you offline, for example when you contact customer service, provide information to us in writing or when in contact with one of our employees (e.g. Drivers, Promoters, Management Teams or Shop staff)
  • Online:We collect your Personal Data through the Gray Line Ireland products, for example when you sign up for a newsletter or enter a competition, enrol in a product or service.

We also collect Personal Data:

• Through cookies.Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most
• browsers that allows you to decline the use of cookies. To learn more about cookies, please visit http://www.allaboutcookies.org/. For detailed information about the cookies we use and the purposes for which we use them, please see our cookie policy.
• Through your use of a mobile application.When you download and use one of our mobile applications, and to the extent allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the mobile application on your device accessing our servers and what information and files have been downloaded to the mobile application based on your device number.
• Through your device.Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content.

• From our corporate affiliates, business partners, assistance providers or claim handlers.
  We may receive Personal Data from other parties in conjunction with your travel experience, including:
  • Our corporate affiliates, such as Dublin Visitor Centre, Irish City Tours Ltd, Online Tour Operators, partners selling our products and other companies that promotes the sales of our services & offers customer service and provides us with the Personal Data that is needed to come to an agreement with you on your order.
  • Business partners, such as local sales agents that promote the sales of our services
  • Claims handlers who receive information about your insurance claims in case of an insurance situation.
  • Legal departments in countries. Statutory, regulatory bodies and law enforcement authorities. These include the Data Protection Commission, An Garda Síochána/police authorities’/enforcement agencies, Revenue Commissioners, Criminal Assets Bureau, US, EU and other designated authorities in connection with combating cyber and other serious crimes as well as fraud prevention agencies.
• From other sources.
  We may receive your Personal Data from other sources, such as public databases; joint marketing partners such as marketing agencies or providers of software and services for digital marketing automation and analytics; social media platforms, including but not limited to; Fleet Connect, TripAdvisor, Facebook, Instagram, Snapchat, LinkedIn, Twitter, YouTube and messenger services such as WhatsApp, WeChat or Facebook Messenger; from people with whom you are friends or otherwise connected with on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to our Gray Line Ireland products, such Personal Data that you have registered in your profile, such as your email address, phone number, postal address, date of birth, name and user name will be shared with us. Furthermore, we use cookies to track members of social media networks as further explained in our cookie policy.
• If you browse our sites
  We may also collect information about your use of our services through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the Gray Line Ireland Products you are showing interest in. These data are only stored and used together with other Personal Data that you have submitted if you have given your consent to do so. You can read more about collection of your IP address and other browsing data in our cookie policy.

How do we use Personal Data?

• Your Personal Data will be processed by Dualway Coaches Ltd for the purposes of completing your booking, providing you with the products and services that you have ordered, for customer service, administrative services, operational service or as otherwise necessary to perform the contract between you and us or as further described in this policy. We may contact you via email, phone call, text message, letter or automated phone calls or text messages.

We may also use Personal Data:

• For statistical purposes, calculating usage levels, and helping diagnose server problems with the Gray Line Ireland products as well as to ensure that the products function properly.
  • To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the Gray Line Ireland product experience and content based on your past activities on the Gray Line Ireland products. For example, depending on what product you have searched for on our website, or in previous browsing, the offer presented to you on the Gray Line Ireland social media platforms may be recorded and re-marketed.
  • To market our products and services, including special promotions based on your interests, for example through email marketing solutions such as marketing management software systems which maintains mailing lists and schedules and modifies email messages based on what recipients read, click-on or forward. All such email communication will include a clear unsubscribe link.
  • Co-branded offers with any third parties we work with. It will be clear by the sender whose privacy policy applies.

How do we share Personal Data?

• We share your Personal Data with our corporate affiliates, business partners and service providers both within and outside the EEA/Switzerland:
  • Our corporate affiliates are for example Dublin Visitor Centres, Dualway Coaches and third party partners that promotes the sales of our services and offer customer service
  • Business partners are for example local sales agents that promote the sales of our transportation or accommodation providers or other contractors for management of any of our tours.
  • Service providers, such as providers of IT systems, for example for managing customer relations or payments, providers of software and services for digital marketing automation and analytics.
• We have put appropriate safeguards in place for transfers of your Personal Data outside the EEA/Switzerland, including the standard data protection clauses adopted by the European Commission, available at http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32004D0915and http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087. For more information on standard data protection clauses in place, please see the contact section below.
• We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

On what do we base our right to collect and use Personal Data?

We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services that you have ordered from us, or when there is a legitimate interest for us (i.e. the service provider) to use your Personal Data, such as for the marketing of products or services similar to the one(s) you have already purchased from that same legal entity.

To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can for example be information about health, ethnicity or religious beliefs, read more under “Sensitive data”.

To the extent that we use your Personal Data to send you offers beyond what is considered to be within our legitimate interest, such as marketing of products and services provided by an Irish City Tour Ltd third party partner, we base this on your specific consent.

Security

We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the accidental loss, destruction or damage of the Personal Data.

Unsubscribe

If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.

Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable.

Third Party Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the Dualway Coaches Ltd contain a link. The inclusion of a link on Gray Line Ireland products does not imply endorsement of the linked site by us or by our affiliates.

Any information that you provide through the use of a social media is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.

How long do we store personal data?

We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been communicated.

We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent, but in no event for longer than 12 months after your last completed service or delivery of product.

Sensitive Data

We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union membership. In certain situations, this might however be necessary for any candidate applying for an employment in Dualway Coaches Ltd. See our Candidate privacy policy for further details.

Updates to This Privacy Policy

We will update this Data Protection Policy from time to time. We will not significantly reduce your rights under this Privacy Policy without informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a more prominent notice. Where required by law, we will seek your prior consent to any change.

Processing your information outside Europe

Some of our service providers, for example IT, telecommunication, custodians and providers of administration services, analytical agents and contractors may be based outside of the EEA. Where we authorise the processing or transfer of your personal information outside of the EEA, we require your personal information to be protected to at least Irish standards and include the following data protection transfer mechanisms: Adherence to the EU/US Privacy Shield. You can find more information on the EU/US Privacy Shield at www.privacyshield.gov including a list of all organisations that have signed up to the EU/US Privacy Shield framework.

If you utilize our Services from a country other than the country where our servers are located, your communications with us may result in transferring your personal data across international borders. Also, when you call us or initiate a chat, provide you with service from The Republic of Ireland. In these cases, your personal data is handled according to this Privacy Policy.

Your Rights
You have a right to, once per calendar year, contact us and without cost find out which information about you that is being used. You have a right to receive your Personal Data in a machine readable format and you have a right to transfer your personal to another data controller.

You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing purposes and you may at any time request that the use of your Personal Data is restricted or that we shall delete your Personal Data. Note however that a restriction or deletion could mean that we are not able to provide you with information, services or products as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect, incomplete or misleading.

You can contact the Office of the Data Protection Commissioner at: https://www.dataprotection.ie/docs/Contact-us/b/11.html

Telephone: +353 (0)761 104 800 or Lo Call Number 1890 252 231
eMail: info@dataprotection.ie
Data Protection Commission,
Canal House, Station Road,
Portarlington, R32 AP23, Co. Laois.

Contact Us
If you have any questions about how your personal data is gathered, stored, shared or used, or if you wish to exercise any of your data rights, please contact our Data Protection Officer at:
Telephone: +353 (0)1 531 3762
eMail: compliance@dualway.com

Dualway Coaches Ltd
Keatings Park
Rathcoole
Co Dublin, Ireland