All companies that, as a data processing manager, act as part of the group "Doffay Car Rental" (hereinafter referred to as "Doffay Car Rental"), are concerned with the security and protection of your personal data when collecting, processing, using and possibly delivering to third parties and executives in order to process requested services.
Words and expressions not defined herein shall, unless the context otherwise provides, have the same meanings as that set out in the Doffay Car Rental General Terms and Conditions (available at [link]).
INFORMATION COLLECTED FROM YOU
When renting a vehicle or accessing any of our services or products, we may collect:
- Contact information, including, but not limited to; names, addresses, phone numbers and e-mail addresses.
- Driver qualifications and identity verification, including but not limited to; driver's license information, including date of birth, photographs you submit of you and your driver’s licence, insurance information, passport, proof of residence and personal references.
- Transaction information, including but not limited to vehicle rental information, rental and return locations, dates of the rental, type of rental and your vehicle preference; ancillary products purchased; airline and flight number; photographs you submit of receipts through the camera feature available on some of our mobile applications and websites, billing information, charges, payments; and credit/debit card information;
- Information related to details of accidents involving our vehicles, including that of any third parties such as involved individuals, witnesses and police reports;
- Information about relevant health conditions you have that assist in us providing you with adaptive driving devices or related to claims involving injuries;
- Any other option and relevant information such as emergency contract information or any preferences or special requirements you may have; and
- CCTV video recordings and/or photographs of you in public areas of our rental locations.
Your information will only be processed, stored, used or shared as provided for by law or the Terms and Conditions.
Unless required by law or contractual necessity, our websites and online marketing are not directed to, and we do not knowingly collect personal information from, children under the age of 18 or your country's age of minority. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please contact us.
INFORMATION COLLECTED FROM OUR WEBSITES AND MOBILE APPLICATIONS
When accessing our websites or any mobile applications of ours, we may collect:
- Browser information, including but not limited to web logs and geo-location;
- Device information, including but not limited to unique device identifiers, IP address, operating system, location information or device connections.
Location information (where enabled and with your permission) is used for the following purposes:
- Our website uses location information (e.g. country, city, postal code, or geographic area) to provide our services;
- When using your mobile device, location information and device connections may be used to provide you with notifications, offers, confirming rental status information, or to provide other information to enhance your experience.
- Where available, allowing use of location information can enable you to locate the vehicle assigned to you or to expedite your collection and return by allowing access when in proximity to your assigned vehicle.
Permissions to use your device’s camera enables you to upload your photo ID and/or the vehicle’s condition for expedited services (where available).
Permissions to use your device’s precise geolocation information, camera or Bluetooth connection can be turned off at any time by changing the settings in the mobile application or on your device. Some features or service options may not be available when these items are turned off.
COOKIES AND OTHER TRACKING TECHNOLOGIES
INFORMATION COLLECTED FROM THIRD PARTIES
Third parties provide us with additional information about you or your household, including but not limited to:
- Referral sources, such as third-party online booking sites (who provide us general contact information and a booking confirmation number to facilitate the rental), your employer (general contact information), bank/credit unions, and your insurance provider (general contact and policy information);
- Hotel, airline and membership clubs who provide us your general contact information and booking information;
- Third parties who, for fraud prevention purposes, provide us with (if relevant) financial and identity-related verification and document authentication;
- Service providers, such as customer support (customer service-related information and enquiries made by you), security services (footage of you from our CCTV system), and customer survey providers (your response to our customer service surveys);
- Marketing providers who provide information to assist us to better communicate our products and services, including email acquisition services, data hygiene services, data brokers, and market research partners and platforms; and
- Social media content you have made available to the public.
Our vehicles may be equipped with telematics devices such as pre-installed event data recorders, global positioning devices, and other communications systems that may be connected to the Internet or cellular services.
We collect and use vehicle data as follows:
- Fuel information – we use this information to facilitate recording and billing for fuel charges;
- Odometer information – we use this information to facilitate billing for mileage charges (where applicable) and to help us manage our fleet;
- Vehicle diagnostic and performance information – we use such information to help us identify vehicle maintenance needs and manage the fleet.
- Mobile device or app connections to help us issue certain commands to the vehicle to facilitate or expedite your rental;
Location information – collect and use vehicle location information to:
- enable our roadside assistance providers to provide you roadside assistance;
- enable emergency service providers to dispatch emergency services to you;
- assist us in recovering a vehicle we reasonably believe is damaged, lost, stolen or abandoned; and/or
- to facilitate the vehicle return process (where remote return is available) and billing purposes.
- Event data recorders –in certain claims situations we may use this information in connection with accident investigations and claims-related efforts.
- Legally compelled disclosure and emergency circumstances – we may share vehicle information, including location information, where legally compelled or in emergency circumstances.
We retain vehicle information based on retention periods in accordance with our business needs and legal requirements. We may use and store this data after the expiration of our contract with you.
Infotainment Systems and Vehicle Manufacturer Apps
If you pair a mobile device with our vehicles’ navigation or infotainment systems and choose to use Apple CarPlay, Android Auto or other similar third-party software or services on the vehicle or if you choose to use any navigational features on the vehicle’s infotainment systems or other device, your personal information and other data may be transferred and stored on these systems. We cannot guarantee the privacy or confidentiality of such information. You should delete all such personal information and other data from these systems or devices before the vehicle is returned to avoid subsequent occupants of the vehicle accessing this information.
If you download a mobile app made available by a vehicle manufacturer or other third party and register the vehicle in that app, your use of the app may result in the sharing of telematics data and other information (including location information and personal information) with the vehicle manufacturer or other third party. Your use of these apps is strictly governed by the third-party mobile apps’ terms and conditions and privacy policies. Before the vehicle is returned, you should either remove the app from your mobile device or delete the vehicle from the app.
HOW WE USE INFORMAITON ABOUT YOU
We use information we collect from or about you to provide you with our products and services for the following purposes:
Where it is necessary for the performance of a contract which governs the services we provide to you, including, but not limited to –
- assist the transactions that you (or someone on your behalf) request, such as reserving, renting, purchasing, leasing motor vehicles, fleet management services or providing accident management services;
- unless where consent may be required by applicable law, communicate important information regarding your reservation, or rental of a vehicle. These communications are transactional in nature and will be sent to you via email, text or calls;
- provide customer service related to your interactions with us or to respond to your enquiry; and/or
- enroll you in our loyalty programs and send information relating to your ongoing membership of these programs.
Where necessary for us to comply with a legal obligation, including but not limited to –
- to use and share information about your vehicle's location with emergency services in the event that you are involved in a road accident;
- to use and share information with government and regulatory authorities when required by law or in response to legal process, obligation, or request, including checking appropriate sanction lists.
where it is necessary for our legitimate interest and where our interests are not overridden by your data protection rights, including but not limited to –
- communicate important information about your rental and provide you with the best service. These communications, which are transactional in nature, will be sent to you via email, text or calls;
- assist us in providing better products and service such as to evaluate the performance of our staff, to assess the quality of products and services received and to help us improve our websites, facilities and services. Unless where consent may be required by applicable law, your feedback may be requested via email, text or call;
- compile statistics and analysis about our customers' use of our websites, products and services. These statistics are used only to enable us to provide better customer service, products, features and functionality to you and other customers in the future;
- where permissible, to develop a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you;
- protect our legal rights and manage the security of our networks and property, including to protect our websites from spam and abuse such as the use of CCTV to ensure the security of our premises;
- for loss prevention; we maintain a record of individuals whose past interactions with us indicate they may present a non-payment or safety risk;
- for fraud prevention purposes, to verify identity and authenticate identity-related documentation as well as additional points of contact for rental related communications through personal references;
- use and share your information with third parties to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any Rental Agreement or our websites' terms and conditions;
- enable us to use vehicle data systems for purposes listed in the Vehicle Data section above;
- unless where consent may be required by applicable law, to send you certain promotional or targeted marketing communications, opportunities and services that may be of interest to you. These will include invitations to join our loyalty programs, upgrade announcements, communications regarding an incomplete online membership form or reservation, and offers related to other services and products we offer. Some of these offers will be received in advertising on social media, or other digital platforms;
- de-identify or aggregate personal information collected about you and use it for any lawful purpose;
- transfer your data as described herein;
- receive, use and share your information with third parties to prevent, detect, and report fraud and protect our business interests and rights, privacy, safety and property, or that of individuals and the public. We will do this to respond to law enforcement request, collect unpaid bills, to avoid liability for penalties you incur (e.g. traffic citations) and for claims processing purposes.
Where you have given consent, as required by applicable law, including but not limited to –
- assist us in providing you with the most appropriate vehicles, such as those with adaptive driving devices. In some cases, this will require us to infer or explicitly collect information about your health or physical condition;
- where applicable, ask for you feedback by email, text or call, to assist us in providing better products and service such as to evaluate the performance of our staff, to assess the quality of products and services received and to help us improve our websites, facilities and services;
- where applicable, ask if you want to receive by email or text promotional or targeted marketing communications, opportunities and services that may be of interest to you. These will include invitations to join our loyalty programs, upgrade announcements, offers and discounts, online communications regarding an incomplete online membership form or reservation and offers related to other services and products we offer. Some of these offers will be received in advertising on social media or other digital platforms;
- where applicable, use of vehicle information to assist and manage transactions that you have agreed to and to fulfil obligations under the Rental Agreement;
You can choose to withdraw your consent at any time, however, such withdrawal does not affect the lawfulness of processing before your withdrawal.
RETENTION OF PERSONAL INFORMATION
We retain your personal information for as long as we need to fulfil our business purposes, or as required by law, as set out below.
We may keep the data associated to your rental agreement for up to seven (7) years from the date of the rental or in accordance with our business needs, subject to other legal requirements. We may keep records of payments you have made for seven (7) years from the date of the transaction.
We may keep the data associated to claims involving our renters or other individuals for the life of the claim and up seven (7) years from conclusion of our obligation, subject to other legal requirements.
Customer Service-Related Queries
We may keep general queries for one (1) year, unless you make a complaint, in which case, we keep complaint data for seven (7) years.
Marketing and Analytical Purposes
We may keep data linked to cookies and other online identifiers up to three (3) years. We keep other marketing information, such as email subscription and loyalty enrolment data for up to seven (7)years after your last interaction with us.
Disputes & Law Enforcement
If we are involved in litigation or a governmental or regulatory investigation, then we keep data throughout the period of litigation or investigation and for seven (7) years after that. If a settlement means that we must keep data for longer, then we keep data for the period required to administer the settlement. If we provide data to law enforcement agencies, then we keep a record of this for one (1) year beyond the end of the investigation.
WHO WE SHARE INFORMATION WITH
As part of our products and services, or as required by law, we may share your information with third parties.
Service Providers and Business Partners
We may share your contact, driver qualification, health, website and mobile information, transactional, claims information, car rental, financial and personal information with our service providers and business partners, including but not limited to:
- payment, administrative and technical support providers
- our insurance replacement, corporate rental or other customers or partners to facilitate the vehicle repair and rental transactions;
- vehicle recovery agents;
- debt collection providers;
- identity and address verification providers;
- claims processors;
- vehicle manufacturers and their vehicle repair providers and/or roadside assistance providers;
- other providers for vehicle repair and damage assessment purposes; and
- professional advisers.
We may also share your personal information, as outlined above, with Government authorities and statutory bodies.
Sale, Merger or Change of Control
Your personal information may be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of the business. This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your personal information or as otherwise may be required or permitted by law.
We may post customer testimonials on our website which may contain your contact information, but only as necessary and we shall at all times endeavour to maintain, as much as possible, your privacy and anonymity.
Social Media Widgets
SELLING YOUR INFORMATION
We do no sell your personal information to third parties.
Although we do not sell your data, as is common with companies with an online presence, some of our advertising uses information collected by businesses from our digital properties, including IP addresses, digital identifiers, information about your web browsing, and how you interact with our properties and ads, in order to provide you with relevant ads across the Internet and for other analytics purposes. These companies may sell that information to other businesses for advertising and other purposes and we are not liable whatsoever for any claims, losses or damages that may result therefrom.