In order to protect your privacy and safeguard your personal data, we observe reasonable business processes and procedures to prevent unauthorised access to and misuse of personal information.
We use appropriate, up-to-date business systems and technologies to protect your personal data in a secure manner.
We also restrict access to, and use of, any personal data, using internal security procedures as well as physical and technical means, to prevent access or use. Only authorised personnel under internal supervision are permitted to access personal information in the course of their work.
European Car Rental offers online car rental and related products and services through our own websites and mobile apps and through other online platforms such as partners’ websites. This policy applies to all of these platforms.
2. Responsible Data Controller
3. Data Collection
European Car Rental provides its services through web-based systems. Some personal data is necessary in order to provide our car rental services, including when we complete a booking or save a quote for you.
Personal data. “Personal data” means individually identifiable information that would allow us to determine the actual identity of, and contact, a specific living person. We may collect this information through our website, mobile application or other online “platforms” such as partners’ websites. European Car Rental may also collect data that is non-personal, for example the computer display preferences set by a user’s web browser when visiting our website.
4. Purposes and Legal Bases for Data Processing
We collect and process data you provide for the following purposes:
Enquiries and Bookings: When you request a quote or make a booking on our website or app, we use your personal data to create a quote or to configure and complete your booking transaction, and to forward the necessary details to the car supplier. In the same manner we may use your personal data to complete and administer the booking of any ancillary products or services (such as insurance), and to forward the necessary details to the relevant supplier.
Customer service: We may share your personal data with our customer service staff as necessary to help you when you need it: for example, helping you find a car, or responding to your queries. European Car Rental provides international customer service 24/7 in 6 languages. We operate our own customer service; we do not outsource this important function. Only personnel who are authorised and trained in data privacy protection are permitted to access customers’ personal data in the course of their work.
Customer reviews: To help European Car Rental understand our customers and improve our services, we may use your contact information to send you a short questionnaire about your rental experience.
Marketing communications: We may use your personal data for marketing activities, as permitted by law. For example:
– With your consent, we may use your email address to send you email with European Car Rental news, offers and updates, including details of our, or our partners’, products and services, special offers, discounts or promotions, new products or services, or special events or competitions. If you consent once for us to send you email with news, offers and updates, as described above, we may continue to send these communications to you, until you unsubscribe. At any time, you may opt out of receiving email marketing messages from us by sending us your request via email.
– When you make a booking or request a quote on our website, we may use your email address to invite you to receive information and offers from us, such as price alerts and discount coupons. We only send these marketing emails twice a year, and we base them on your favourite destinations. You will receive these emails only if you have given your consent.
– We may use your email address to send you information about excess cover products that you didn’t include in your car booking. Again, we send these offers only if you have given your consent.
– Based on the information you share with us, you may see tailored offers in mobile apps or on third-party websites, including social media sites.
Other communications: There may be other occasions when we contact you by email or phone, depending on the contact information you have provided to us. Examples of purposes for these other communications include:
– We may need to contact you to respond to and handle your requests.
– If you have not finalised a booking online, we may email you a reminder to do so. We see this as a useful service because it enables you to pick up a booking process where you left off if you are interrupted.
– We may send email to you or contact you by telephone with a price alert or other offer related to your destination.
– We may send you a questionnaire or ask you to evaluate and comment on your experience.
– We may send you other communications related to your booking, such as information on contacting European Car Rental or your car supplier if you need help, or travel tips for your destination, or a summary of your previous bookings.
Fraud detection and prevention: Personal data may be used as part of detecting and preventing fraud and other illegal or unwanted activities.
Improving our services: We use information including personal data in the course of analytics, in order to better understand customer preferences, to understand how to improve our services, to enhance the user experience, and to improve the functionality and quality of our online travel services.
The legal bases we rely on when we collect and process your personal data are founded upon the provisions of the European Union’s General Data Privacy Regulation (2018). Depending on the particular service we are providing to you, the legal grounds for our processing your personal data may be one or more of the following.
Performance of a contract: For example, we need to process your personal data and provide your booking details to the supplier that will provide your rental car, in order to fulfil your booking.
Legitimate interests: We may rely on our legitimate interests in, for example, proper business administration, providing you with information and services, and in promoting and improving our services.
Consent: We may rely on your consent to process your personal data, for example, when you provide your email address so that we may send you newsletters.
5. Provision of your personal data to others
We respect your privacy and we will not provide your personal data to any third party which is not involved in your car rental enquiry.
We also use the latest online secure encoding and encryption technologies to protect any transfer or storage of your private personal data.
We may disclose your personal data to the company that will supply your rental car, which is identified on the booking voucher that we provide to you, insofar as reasonably necessary for purposes of your car rental.
We may disclose your enquiry data to third party suppliers of goods and services identified on our website, for the purpose of enabling them to contact you so that they can offer relevant products or services to you.
We may share your email address and order number to a third party company, for you to be able to evaluate our services in an independent manner and help us improve our services.
We also reserve the right to transfer your data to debt collection agencies and business protection organizations, on the basis of our legitimate business interests.
European Car Rental has offices outside the European Economic Area in Switzerland, as noted in Paragraph 2. The European Commission has made an “adequacy decision” with respect to the data protection laws of Switzerland, and this decision is subject to periodic review under the European Union’s General Data Protection Regulation (GDPR). The adequacy of Swiss data protection law means that any transfers of your personal data to Switzerland are protected in a manner that satisfies GDPR requirements.
6. Data Security and Retention
For processing of all inquiries and bookings, our websites use HTTP Secure (HTTPS, Hypertext Transfer Protocol Secure). This provides bi-directional encryption of communication between your browser and our server, to protect the privacy and integrity of the exchanged data.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We may retain your personal data where such retention is necessary for us to comply with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Enforcement of Rights
Your principal rights with respect to personal data under EU data protection law are in the following areas. These rights are not all absolute, that is, they may apply in some circumstances only :
the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.
In summary, you have the right to access the personal data that we hold about you, and you have the right to request the correction, restriction of the processing, or erasure of this data at any time. To assert these rights, or to inquire about your personal data that we hold, please use one of the contact methods listed in Paragraph 2.
If at any time you don’t want to receive our offers, discount coupons and other newsletters you can unsubscribe here.
8. Right of Appeal at Supervisory Authorities
If you believe your rights in regard to your personal data have been violated, you need to first contact European Car Rental with your complaint. If you are not satisfied with our response, you have the right to file a complaint with the competent supervisory authority.
For EU countries, the contact information of the data protection authority in your country can be found on the website of the EU:http://ec.europa.eu/justice/data-protection/..
Cookies are used by the European Car Rental website. A cookie is a small message sent from our web server to your web browser during your visit to our website. Your browser stores the message as a small text file on your computer. The message is then sent back to the server each time your browser requests a page from our web server.
Browsers are normally set to accept cookies, but you can disable this function in your browser settings. Enabling cookies is not strictly necessary for the website to work, but it will provide you with a better browsing experience.
The primary purpose of cookies is to continue to recognize your computer during a visit to our website and to retain your display preferences when you switch from one of our web pages to another, or leave our website and return later.
The information in cookies is not used to identify you personally. We also do not use techniques that combine information generated by cookies with users’ personal data.
Information collected automatically. When you visit our website or use our application, we automatically collect certain non-personal information from your browser or device. This information could include your IP address, device ID, your browser type and language, display preferences, access times, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address.
Cookies and Use of Cookie Data. We may assign your device one or more cookies to facilitate your use of our website or application and to customise your experience. Through the use of a cookie, we may collect information about your online activity on our site, such as the pages you visit, the time and date of your visits, the links you click, and the searches you perform on our site. If you choose to disable cookies, please note that you may not be able to sign in or use some of the interactive features offered on our website.
Other Technologies.We may use standard Internet technology, such as web beacons, pixel tags, local storage and other technologies that facilitate personalisation to track your use of our site. We also may use these technologies in advertisements or email messages to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customise the services we offer our website visitors, to deliver customised advertisement, and to measure the overall effectiveness and relevance of our online advertising, content, design, website navigation or other aspects of our services.
Information collected by third-parties. We may permit service providers or third parties to display advertisements on our site. These advertisers may use tracking technologies, such as cookies, to collect information about your interaction with their advertisements. This information allows them to deliver targeted advertisements and to evaluate the impact of those advertisements.
10a. Google Analytics
Our website makes use of Google Analytics services. Google Analytics is a web analytics service provided by Google Inc. (“Google”). Cookies are stored on your computer, which allows an analysis of your use of the website.
The cookie holds the information about your use of the website. This information generated by the cookie is usually sent to a Google server in the USA and stored there. The service we use on our website is IP anonymized, i.e. your IP address will be abbreviated beforehand by Google within the member states of the European Union or in other contracting states of the Agreement in the European Economic Area and therefore anonymous. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and abbreviated there. Google will use this information, on our behalf, to evaluate your use of the website, to create reports on website activity and to provide other services related to the website activity and internet usage to us as website operators.
Your IP address obtained from your browser and used by Google Analytics will not be merged, linked or connected with other data held by Google.
You may prevent the collection and use of this, by downloading and installing the browser plug-in available here.
10b. Google, Bing, Yandex and Facebook Advertising
Our website makes use of the advertising and re-marketing tools of Google, Bing, Yandex, or Facebook Advertising to advertise and promote its contents and services and publish ads fitted to the users’ visits. Therefore, some pages of the website may include a code called “re-marketing code”. This code allows us to read and configure browser cookies in order to determine which type of ad to show to the user. This selection is based on the data related to your visit to the website, such as the chosen browser, the actual pages visited or your actions within the page. The anonymized re-marketing lists are created and processed on our behalf by the corresponding advertising platforms.
Some pages of our website may include a conversion tracking code: a statistical service that connects data from the individual ad networks of Google, Bing, Yandex, Facebook Advertising to actions within this website.
– For more information about Google Advertising, click here.
– For more information about Bing Advertising, click here.
– For more information about Yandex Advertising, click here.
– For more information about Facebook Advertising, click here.
Credit: Portions of this document have been created using a template from SEQ Legal (seqlegal.com).