Last Updated: March 17, 2025

Privacy Policy

Your privacy is critically important to us. This policy explains how Etoil collects, uses, and protects your personal information in compliance with GDPR and Irish data protection laws.

1. Introduction

Etoil Limited ("we," "our," or "us") operates the M50 eToll and tag management service. We are registered in Ireland with company number 1234567 and have our registered office at 1A Ballymount Rd Lower, Walkinstown, Dublin, D12 PC56, Ireland.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our M50 eToll and tag management services, including our website, mobile applications, and related services (collectively, the "Services").

We are committed to protecting your privacy and complying with applicable data protection laws, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

Key Principle: We only collect data necessary to provide our M50 eToll services. We never sell your personal information to third parties for marketing purposes. You have control over your data at all times.

2. Information We Collect

We collect several types of information to provide and improve our M50 eToll services:

2.1 Personal Information You Provide

When you register for an Etoil account, we collect:

  • Contact Information: Full name, email address, phone number, residential address
  • Vehicle Information: Vehicle registration number, make, model, color
  • Payment Information: Credit/debit card details, billing address (processed securely by our payment providers)
  • Account Information: Username, password, security questions
  • Communication Data: Records of your correspondence with us

2.2 Information Collected Automatically

When you use our Services, we automatically collect:

  • Technical Data: IP address, browser type and version, time zone setting, browser plug-in types, operating system
  • Usage Data: Information about how you use our website, products, and services
  • Toll Transaction Data: Date, time, location, and amount of M50 toll transactions
  • Device Information: Device type, unique device identifiers, mobile network information

2.3 Data Collection Summary

Data Category Specific Data Purpose Legal Basis
Identity & Contact Name, email, phone, address Account creation, communication Contract performance
Vehicle Information Registration, make, model Toll processing, tag management Contract performance
Financial Payment card information Processing toll payments Contract performance
Technical IP address, device information Security, analytics, improvements Legitimate interests
Usage Website interactions, toll patterns Service optimization, analytics Legitimate interests

3. How We Use Your Information

We use the information we collect for the following purposes:

  • Service Provision: To create and manage your account, process M50 toll payments, and provide tag management services
  • Customer Support: To respond to your inquiries, troubleshoot issues, and provide technical support
  • Billing and Payments: To process transactions, send invoices, and manage your payment methods
  • Service Improvements: To analyze usage patterns and improve our Services, including developing new features
  • Communication: To send you important updates about our Services, including changes to terms or policies
  • Security: To monitor and protect the security of our Services and prevent fraud
  • Compliance: To comply with legal obligations, including toll regulations and financial reporting requirements
  • Marketing: To send you marketing communications (only with your explicit consent)

5. Data Sharing and Disclosure

We respect your privacy and do not sell your personal information to third parties. We may share your information in the following limited circumstances:

5.1 Service Providers

We engage trusted third-party service providers to assist with:

  • Payment Processing: Stripe, PayPal (for secure payment processing)
  • Cloud Hosting: Amazon Web Services, Google Cloud (for data storage and processing)
  • Communication: Twilio, SendGrid (for SMS and email notifications)
  • Analytics: Google Analytics (for website usage analysis)
  • Customer Support: Zendesk (for customer service management)

All service providers are contractually obligated to protect your data and use it only for the services they provide to us.

5.2 Legal Requirements

We may disclose your information if required by law, such as to:

  • Comply with legal processes or governmental requests
  • Protect our rights, privacy, safety, or property
  • Enforce our terms and conditions
  • Prevent fraud or security issues

5.3 M50 Toll Authorities

We share necessary vehicle and toll transaction data with official M50 toll authorities (e.g., Transport Infrastructure Ireland) as required for toll processing and compliance with Irish transportation regulations.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred to the new entity, subject to the same privacy protections.

6. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption: All sensitive data is encrypted in transit (TLS 1.2+) and at rest (AES-256)
  • Access Controls: Strict access controls and authentication mechanisms
  • Security Assessments: Regular security assessments and penetration testing
  • Secure Development: Secure development practices and code review
  • Employee Training: Comprehensive employee training on data protection and privacy
  • PCI DSS Compliance: Compliance with Payment Card Industry Data Security Standards

Security Commitment: We use bank-level encryption for all sensitive data and undergo regular security audits. While we implement robust security measures, no method of transmission over the Internet or electronic storage is 100% secure.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

7.1 Retention Periods

Data Type Retention Period Reason
Account Information While account is active + 3 years Customer service, legal protection
Toll Transaction Data 7 years Legal requirement (revenue records)
Financial Records 7 years Legal requirement (tax purposes)
Marketing Data 3 years after last contact Business development
Website Analytics 26 months Service improvement

7.2 Data Deletion

Upon account closure, we will:

  • Anonymize your personal data within 30 days
  • Retain anonymized transaction data for legal requirements
  • Permanently delete identifiable personal data from our active systems
  • Remove your data from backup systems within 90 days

8. Your Rights (GDPR)

Under GDPR and Irish data protection laws, you have the following rights regarding your personal data:

8.1 Right to Access

You can request a copy of your personal data in a structured, commonly used format.

8.2 Right to Rectification

You can update or correct inaccurate or incomplete personal data through your account settings or by contacting us.

8.3 Right to Erasure

You can request deletion of your personal data, subject to certain legal obligations we may have to retain certain information.

8.4 Right to Restriction

You can request restriction of processing in certain circumstances.

8.5 Right to Object

You can object to certain types of processing, including direct marketing.

8.6 Right to Data Portability

You can request transfer of your data to another service provider.

8.7 Right to Withdraw Consent

You can withdraw consent at any time where we rely on consent for processing.

8.8 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information in the "Contact Us" section. We will respond within 30 days and may request verification of your identity.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience with our Services. These technologies help us:

  • Remember your preferences and settings
  • Understand how you use our Services
  • Provide personalized content and features
  • Analyze and improve our Services
  • Prevent fraud and enhance security

You can control cookies through your browser settings or our cookie preference center. However, disabling essential cookies may affect your ability to use certain features of our Services.

For more detailed information, please see our comprehensive Cookie Policy.

10. International Data Transfers

Etoil is based in Ireland, and we store and process data primarily within the European Economic Area (EEA). In some cases, we may transfer data to service providers outside the EEA. When we do, we ensure appropriate safeguards are in place, such as:

  • Adequacy decisions by the European Commission
  • Standard Contractual Clauses approved by the European Commission
  • Binding Corporate Rules
  • Privacy Shield certification (for transfers to the US, where applicable)

11. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without verification of parental consent, we will take steps to remove that information from our servers.

If you believe we might have any information from or about a child under 18, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will notify you of any material changes by:

  • Posting the updated policy on our website with a new "Last Updated" date
  • Sending you an email notification (for significant changes)
  • Displaying a prominent notice in our Services

We encourage you to review this Privacy Policy periodically to stay informed about our information practices. Continued use of our Services after changes constitutes acceptance of the modified policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Etoil Limited

1A Ballymount Rd Lower, Walkinstown, Dublin, D12 PC56, Ireland

Email: privacy@eflowe.pro

Phone: +353 1 551 9721

Data Protection Officer: dpo@eflowe.pro

Supervisory Authority: If you have concerns about our data practices, you have the right to lodge a complaint with the Data Protection Commission Ireland.