Top Oil and Irving Oil act as the Joint Controllers of personal data you provide to Top Oil in connection with the Top Oil Fuel to Win competition (the “Competition”) pursuant to a Data Sharing Agreement in place between Top Oil and Irving Oil.

The Joint Controllers respect your right to privacy and will use your personal data only for the purpose as described in the rules of the Competition (the “Competition Rules”) and this Privacy Statement, and in accordance with any other permissions you have provided to them. Aside from those other permissions, personal data collected is used solely by the Joint Controllers to administer the Competition.

The Competition Entities will handle your personal data in accordance with Irving Oil’s Data Protection and Privacy Policy and Top Oil’s Privacy Policy (which can be accessed at https://www.irvingoil.com/en-CA/discover-irving/privacy#:~:text=We%20rarely%20collect%20any%20sensitive,of%20your%20personal%20contact%20details and http://topoilwin.ie/contest/privacy or by contacting the privacy officer at Privacy@irvingoil.com) and in accordance with any other permissions you have provided to them.

Joint Controllers: Tedcastles Oil Products Unlimited Company trading as Top Oil (ie, the Competition Sponsor) and Top Oil’s parent company, Irving Oil Limited, Saint John, New Brunswick, Canada (“Irving Oil”)

Joint Controllers’ Contact Details: Privacy@irvingoil.com

Processor: WSP International Limited, Markham, Ontario, L3R 1H5, Canada (ie, the Administrator)

Competition Entities: The Sponsor, the Participating Retail Service Stations, Irving Oil and the Administrator.

Personal data

The Joint Controllers will process your name, address, phone number, and email address as a Competition entrant to administer the Competition and distribute prizes to you if you are selected as a winner and (subject to your consent) for marketing to you. Your first name, initial of last name and Top Oil location associated with your registration account may be published for publicity purposes and your full name and county or residence will be released upon request, to comply with our obligations under the ASAI Code. No special category or sensitive personal data will be processed.

Use of your personal data and basis of processing

By completing the Competition registration form or submitting one or more No Purchase entries, you consent to the collection and processing of your personal data by the Joint Controllers to conduct the Competition, including, where relevant, validating winning submissions and sending any potential winner and confirmed winner notifications to you. You may specifically request to be completely removed from participation in the Competition by following the process set out in the Competition Rules. This will not opt you out of marketing communications.

Where you have provided your consent to receive future communications from the Joint Controllers by email or SMS, you grant the Joint Controllers permission to send you competition updates and winner notifications, specials, and promotions and / or newsletters or other updates. You can change your mind about receipt of special offers from the Joint Controllers at any time by: a) contacting Top Oil at support@topoilwin.ie; b) by updating your account preferences at www.topoilwin.ie by clicking the unsubscribe button found on the Account page, under View/Edit My Profile; or c) by following the opt-out instructions provided on any communication you receive. Your Competition entries will still be included in the draws, even if you opt out of receipt of special offers.

If you are selected as a winner, your personal data may be used for publicity purposes as set out in the Competition Rules on the basis of the legitimate interests of the Joint Controllers.

Sharing of personal data

None of your personal data will be transferred or sold to any third party except in the following circumstances:
• when you give us permission to do so (eg, where the Joint Controllers market group products and services to you);
• when in good faith we believe the law requires it;
• under limited circumstances specifically described to you when we collect the information, such as in the rules of competitions or other promotions;
• to the Joint Controllers’ agents for data processing purposes, or to their professional advisors and promotional and marketing agencies, provided that such agents, professional advisors, and promotional and marketing agencies are restricted from using your personal data for any purpose other than as described in the Rules.

The Joint Controllers may aggregate your personal data and share it with the other Competition Entities. The Competition Entities may match aggregated, statistical personal data to parameters established by third parties, without releasing any personally identifiable data. The Competition Entities may share aggregate personal data with trading partners, co-branded locations, participating sponsors, and advertisers; however, this aggregated data will not contain personally identifiable information.

International transfers

Your personal data will be processed by the Administrator in Canada. The Sponsor has entered into an agreement with the Administrator under which the Administrator is obliged to keep your personal data secure. The transfer of your personal data to Canada is permitted under the decision of the European Commission relating to transfers of personal data to Canada (Decision 2002/2/EC).

Retention of your personal data

Your personal data will be retained for no longer than is necessary for the purpose for which it was obtained by the Joint Controllers or as required or permitted for legal and legitimate business purposes. In general, the Joint Controllers (or their service providers on its behalf) will hold Competition entry information for a period of 60 days from the Competition end date when you opt-out, and winner details for a period of seven years, unless they are obliged to hold it for a longer period under law or applicable regulations. Information used to contact you for marketing purposes will be retained until the Joint Controllers are notified that marketing consent has been withdrawn.

Your rights in relation to your personal data

You have the right to request any personal data that the Joint Controllers process about you, such as:
• What personal data we hold about you
• The purposes of the processing
• The categories of personal data concerned
• The recipients to whom the personal data has/will be disclosed
• How long we intend to store your personal data for
• If we did not collect the data directly from you, information about the source

You should contact us directly at Privacy@irvingoil.com to inform us of any changes in your personal data. If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and / or complete the information, and we will strive to do so as quickly as possible; if there is a valid reason for not doing so, you will be notified. You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with data protection law. We will update or delete your data in accordance with our obligations under the GDPR and Data Protection Act 2018.

Where you have consented to our use of your personal data (such as for direct marketing), you may at any time withdraw your consent. Where we are relying on our legitimate interests, you may object to any processing by us. Where applicable, you have the right to data portability of your personal data.

Any requests for access to the information that you have supplied, or to update or rectify such information, or to exercise your other data protection rights, should be made in writing by sending a self-addressed envelope with your request to: Top Oil Fuel to Win, P1, East Point Business Park, Dublin3, D03 C825 or by emailing your request to dataprotection@top.ie.

Complaints

You have the right to lodge a complaint with the Data Protection Commission if you consider that processing of your personal data by the Competition Entities is contrary to the GDPR. The contact details of the Data Protection Commission are:

Telephone 1890 252 231

E-mail info@dataprotection.ie

Address Data Protection Commission 21 Fitzwilliam Square South Dublin 2, D02 RD28 Ireland

Complaint form Available here.

Last updated: 29 July, 2024