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Privacy & Cookies

1. Introduction

1.1         This eFlow website is operated by Turas Mobility Services Ltd. (“Turas”) on behalf of Transport Infrastructure Ireland (“TII”). Turas and TII fully respect your right to privacy and treat all data collected through this website in accordance with applicable data protection laws.

1.2         TII was established following the statutory merger of the National Roads Authority and the Railway Procurement Agency under the Roads Act 2015. TII is the controller in respect of data which is collected and processed via this eFlow website and its main address is Parkgate Business Centre, Parkgate Street, Dublin 8, D08 DK10, Ireland.

1.3       Turas is an Irish company that processes personal data on behalf of TII in order to operate the barrier-free tolling system on Dublin’s M50 motorway and provide electronic tags for use on all toll roads in the Republic of Ireland related to eFlow toll services.

Turas can be contacted:

 

1.4         Please read the terms of this privacy statement carefully as it provides details on the personal data which may be collected via this website and the purposes for which the data may be used.  If you are not happy with this website privacy statement you should not use this website. You may also wish to review our Data Protection Notice.

2. Collection and use of personal information

2.1         We will collect no personally identifying information about you when you visit this website unless you choose to provide that information to us. The information we collect depends on options selected when visiting this website.

2.2         If you visit this website to browse, read or download we automatically collect and store your IP address, browser type and length of user sessions. We use this information to help us make this website more useful to visitors, to learn about the number of visitors to this website and the type of technology that our visitors use. We do not track or record information about individuals on their visits. We may compile and report aggregate statistics about our users in terms of numbers, traffic patterns and related site information. Any such statistic will not include any personally identifying information.

2.3         You may choose to provide us with personal data associated with some of the services provided on the website, for example, register and manage your eFlow account, make a payment or contact us with your enquiry.

2.4         If you open an account, we ask you to provide us with your full name, email/postal address, contact telephone number, licence plate number, and credit card, debit card or direct debit details. We use this data for the purposes of processing your toll payment(s) and managing your eFlow account. We do not collect any more personal data than is necessary for these purposes. In circumstances where you apply to be a registered eFlow customer in respect of eFlow fleet and business accounts (including where 5 or more tags will be linked to one account), TII may also process your personal data for credit check and credit card validation purposes.

2.5         M50 users, who do not wish to register with eFlow, have an option to make a payment on this website by using the ‘Pay a Toll’, ‘Pay a Penalty’ facility. For this purpose, we ask you to provide us with the licence plate number, journey reference number and credit or debit card details. If you require a receipt, we will request your email or postal address from you.

2.6         The M50 users who are registered with another tag provider, but have received an eFlow penalty letter, can appeal the penalty on this website by using the ‘Appeal a Penalty’ option. We will ask you to complete the form requesting the journey reference number, your licence plate number, the tag provider and your tag number.

2.7         Whenever you use a ‘contact us’ form to communicate with us you may choose to provide us with the following:

  • Full Name, email/postal address, phone number;
  • Account number/Vehicle registration number;
  • Attached documentation (proof of payments, etc.).

2.8         Information which you provide to use using a ‘contact us’ form is used solely for dealing with your query.

2.9         Your personal data is stored securely and kept for no longer than is necessary.

2.10       From time to time, we may contact you by phone, email or SMS in relation to Customer Satisfaction Surveys. You can opt-out from such contact by emailing us at dataprotection@eflow.ie or by writing to us at the address set out at Section 1.3 above.  You will also be afforded the right to opt-out of receiving Customer Satisfaction Surveys in any calls or emails to you about such surveys.

2.11       We may also send you occasional emails about service disruption on the M50.  You can opt-out from such service disruption emails by emailing us at dataprotection@eflow.ie or by writing to us at the address set out at Section 1.3 above. 

You will also be afforded the right to opt-out of receiving further service disruption emails in any emails we send to you about service disruption.

 

3. Purpose of Processing and Legal Basis

3.1         We process personal data relating to you in order to:

(a)          ensure that payment is obtained from all road users using eFlow services in accordance with TII’s statutory obligations;

(b)          receive services from third party service providers;

(c)           respond to queries and complaints from members of the public, and

(d)          comply with TII’s other statutory obligations.

3.2         TII’s legal basis for collecting and using this information is that such processing is necessary to comply with TII’s legal and regulatory obligations and to carry out its tasks in the public interest and/or in the exercise of official authority vested in TII. In certain limited circumstances processing your personal data may be on the basis of your consent – where this is the case you will be asked to give a positive indication of that consent.

3.3         The legal basis on which we collect, process and transfer special categories of data relating to you (e.g. data relating to health) in the manner described above are that:

(a)          this is necessary for reasons of substantial public interest; or

(b)          you have given your explicit consent to such processing.

4. Disclosure of Personal Data

4.1         We may disclose your personal data to other organisations in connection with the above purposes, in the following circumstances:

(a)          We may share personal data with our agents, contractors and service providers who assist us with the operation of aspects of our services and functions, such as our payment card processor, banking and printing/postal correspondence contractors, the eFlow enforcement service provider(s), Foreign Vehicle Licensing Authorities and law enforcement agencies.

(b)          Where TII appoints a new operator of eFlow, we may share personal data with this new operator in order to facilitate successful transition to the new operator and ensure continuity of service for eFlow customers during any transition period.

(c)           Where we are under a duty to disclose or share personal data in order to comply with any legal obligation, or to protect the rights, property or safety of eFlow, our customers, or others. We may also share information about the way you conduct your account with credit reference agencies.

(d)          Where required or permitted by law, we may share your personal data with other public authorities and bodies, such as the Gardaí or other law enforcement authorities for the purposes of the prevention, investigation or detection of crime.

(e)          In connection with the provision of interoperable toll transactions in Ireland, we may disclose your personal data to a relevant compatible operator.

(f)           We may share toll passage data with key stakeholders, e.g. the Department of Transport, for the purposes of research and statistical analysis.

(g)          For the purpose of operating competitions on behalf of TII, we may disclose, subject to your consent, your name, email address and marketing preferences provided to us by you.

(h)          Where we are otherwise permitted by law.

5. Cookies

5.1   This website uses cookies. Cookies are small text files which provide us with information about how often someone visits our website, and what website activity is carried out during those visits.

5.2   The eFlow website uses two separate domains, eflow.ie and secure.eflow.ie. Consent for all non necessary cookies will be required for both domains i.e. the user will be asked to consent to non necessary cookies twice as each domain requires separate consent, even where the cookies are the same.

5.3   There are two main types of cookies as follows :

Session cookies – a simple text file that a website installs on its visitor’s device for temporary use. It helps track real-time changes of a user’s activity while on a website. Most websites have session cookies enabled by default as it helps the web pages load faster and makes navigation easy for the user. A session cookie is only active during each browsing session and is programmed to be automatically deleted at the end of each browsing session when the user exits the web browser.

Persistent cookies – cookies stored on a user’s device to hold usage information, settings, personalisations, or sign-on credentials. The primary purpose of persistent cookies is to provide users with an immersive and seamless browsing experience by auto-filling information that the user may have already provided.

All persistent cookies have a specific expiration date assigned by the webserver. The expiration date is helpful as it allows users to continue having a smooth browsing experience even after closing the browser window and reopening it.

5.4   Consent given for non necessary cookies is only valid for a maximum of six months, after which time re-consent will be requested

5.5  For more information about the way this website uses cookies and your options for accepting and rejecting cookies, please see below list of cookies.

6. Transfers Abroad

6.1         We may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognised by the European Commission as providing an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with its obligations under applicable law governing such transfers, which may include entering into a contract governing the transfer which contains the ‘standard contractual clauses’ approved for this purpose by the European Commission. Further details of the measures that have been taken in this regard are available from the eFlow Data Protection Officer using the contact details in Section 1.3 above.

7. Security

7.1         For website security purposes and to ensure that this website remains available to all users, our computer system employs software programs to monitor network traffic in order to identify unauthorised attempts to upload or change information or otherwise cause damage. Unauthorised attempts to upload information or change information on this website are strictly prohibited and may be punishable by law.

7.2         Your personal data which you provide to us will be held on secure servers hosted by Turas. The nature of the internet is such that we cannot guarantee the security of any information you transmit to us online. However, we take all reasonable steps (including appropriate technical and organisational security measures) to protect your personal data.

8. Your Rights

8.1         You have the following rights, in certain circumstances, in relation to your personal data:

  • the right to access your personal data;
  • the right to request the rectification and/or erasure of your personal data;
  • the right to restrict the use of your personal data;
  • the right to object to the processing of your personal data;
  • the right to receive your personal data, which you provided to us, in a structured, commonly used and machine readable format or to require us to transmit that data to another data controller, and
  • where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.

8.2         In order to exercise any of the rights set out above, please contact us using the contact details in Section 1.3 above.

9. Retention

9.1         We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

9.2         Our retention periods differ depending on the type of categories of personal data held. 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 unauthorised 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.

10. Changes to this Privacy Statement

10.1       From time to time we may decide to change our privacy statement, but any changes will be posted on this page to keep you up to date on how we collect, use and disclose information. If at any time we decide to use personal data in a manner significantly different from that stated in this privacy statement, or otherwise disclosed to you at the time it was collected, we will notify you, and you will have the choice as to whether or not we use your information in the new manner.

11. Questions and Complaints

11.1       If you have any questions or complaints about our use of your personal data, please contact us using the contact details in Section 1.3 above.  Alternatively, TII’s Data Protection Officer may be contacted as follows:

  • by post: Data Protection Officer, Transport Infrastructure Ireland, Parkgate Business Centre, Parkgate Street, Dublin 8, D08 DK10
  • by phone: +353 1 646 3600
  • by email: dataprotection@tii.ie

11.2       Further information about data protection can be found on the Data Protection Commission’s website: www.dataprotection.ie.

11.3       You also have the right to lodge a complaint with the Data Protection Commission if you are not happy with the way we have used your information or addressed your rights.  Details of how to lodge a complaint can be found on the Data Protection Commission’s website

12. Cookie Declaration

The categories of cookies used on the eFlow website are as follows :

Necessary cookies – help make the website usable by enabling basic functions. The website cannot function properly without these cookies. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site and therefore consent is not required. Consent is required for all other categories of cookies.

Webchat Services cookies – help to improve your experience of our website and help us improve our information and services to you. Cookies used for the webchat function on the eFlow website enable us to understand how visitors interact with the webchat functionality by collecting and reporting information anonymously.

N.B. You must consent to webchat cookies in order to avail of the webchat function. If you have not consented to webchat cookies at the start of your session, but want to avail of webchat, click on the webchat widget (on every page) and you will be presented with the consent option.

 Statistic cookies – help eFlow to understand how visitors interact with our website by collecting and reporting information anonymously.

eFlow uses Google Analytics 4 (GA4) to collect, analyse and report on website use data with the aim of identifying and employing improvements in the website user experience. Data collected by GA4 is processed and hosted by Google’s US based data centres. This data is retained for two months. If you wish to submit a data deletion request relating to this data, please submit your request using the contact methods outlined in section one of this document

Marketing cookies – are used to track visitors across websites. They allow eFlow to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Unclassified cookies – when new functions are added to the eflow website, new cookies may be detected by the cookie management tool. Occasionally this tool will be unable to classify these cookies and they will be place in this category. The list of cookies on both domains will be manually reviewed on a monthly basis and any unclassified cookies will be assessed and categorised correctly i.e. added to one of the other cookie categories

You can also manage and clear cookies by visiting your browser settings.

Learn more about who we are, our website cookies and how we process personal data by contacting us – see contact details above (section 1.3). Additional information re third party cookies on the eflow website is available at the following links :

  1. Cookiebot (cookie management tool) – com/en/privacy-policy
  2. Google / Youtube – google.com/privacy
  3. Hotjar – hotjar.com/legal/policies/privacy
  4. Akamai – akamai.com/cloudlets/docs/cookie
  5. Genysis-mypurecloud.com/articles/genesys-cloud-and-gdpr-compliance/

Please state your consent ID and date when you contact us regarding your consent.