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PRIVACY POLICY (ECI)


This privacy policy is composed of 2 parts:

-        one for processing activities performed by the parent company, Europcar International S.A.S.U.

-        one for processing activities performed by the franchisee

Europcar® is the European leader of car rental and light commercial vehicle rental and operates in over 140 countries, via fully owned subsidiaries as well as franchisees and agents. A Europcar branded vehicle hire station can be operated by a company member of Europcar Mobility Group or by one of our franchisee (i.e. a separate legal entity from the Group).

When renting a car at Europcar, your Personal Data would be processed by Europcar International S.A.S.U. in particular for management of your online account and booking and by our franchisee, which deliver the service locally.

Part 1 - Processing activities performed by Europcar International S.A.S.U

As the parent company of Europcar Mobility Group, Europcar International S.A.S.U. whose registered office is at 13 ter Boulevard Berthier, 75017, Paris (hereinafter referred to as “we”, “us” or “our(s)”) is the "Data Controller" of your Personal Data collected and processed via this website and our mobile applications for the purposes defined below.

When you communicate your Personal Data to us or when we collect Personal Data about you, we undertake to use it in accordance with this information notice.

1. What Personal Data do we collect about you?

As Europcar Mobility Group parent company, Europcar International S.A.S.U. collects and processes various categories of Personal Data in connection with this website and our mobile applications in order to allow you to benefit from the products and services provided by our franchisees.

By Personal Data, we mean not only data that identifies you directly, but also data that identifies you indirectly like your Driver ID or the Vehicle Identification Number (VIN) attached to your rental vehicle.

The categories of Personal Data that we collect include the following:

-Your identification data: surname, first name, email address, telephone number, postal address, date of birth, account identifier

-If applicable, identification data of additional driver(s): surname, first name, email address, telephone number, postal address

-Your driver's licence and that of any additional driver(s);

-Payment data: account numbers, card numbers etc;

-Information on your vehicle reservation, in particular for the management of any loyalty programs;

-Data relating to your navigation on our website or our mobile applications;

-Data relating to your satisfaction surveys.

2. For what purposes do we process your Personal Data?

We collect and process your Personal Data for various purposes and on the following legal bases:

Purposes of the processing

Legal basis of the processing

Creating and managing your online customer account on our website or mobile applications.

This processing activity is based on the acceptance of the terms and conditions of use of our website or our mobile applications.

Managing your reservation and rental contract through a central booking engine, in particular to:

- collect the data necessary to organise your reservation

- communicate this data to the concerned franchisee operating the service

- manage your payment

These processing activities is based on our legitimate interest to ensure the execution of the rental services contract that you enter into with our franchisee.

You can choose to register your credit card for your future bookings.

Sending you emails about special offers and promotions to promote our products and services.

This processing activity is subject to your consent.

Sending you an email in order to collect your feedback on your rental.

This processing is based on our legitimate interest to have a better knowledge of its customers' needs and to improve its services and customer service.

Managing your loyalty program and third party partnership loyalty program

This processing is based on the execution of the loyalty program terms and conditions.

 

3. Who are the recipients of your Personal Data?

3.1. Categories of recipients

Your personal data may be communicated to our employees, our authorized representatives, other companies within our Group and our franchisee network, our agents and intermediaries mandated to provide you with our products and services and if necessary :

a. to the relevant franchisee that delivers your service, in particular for the purposes described below (see Part 2);

b. to our subcontractors, in particular our IT service providers for hosting, maintenance or development purposes, who assist us in providing you with our products and services. These may be entities that are members of our Group or external service providers;

c. marketing agencies to help us collect and analyse your customer satisfaction;

d. to our partners or those of our Group, in particular to enable you to collect loyalty points when you are a member of their program. The list of our partners is available online [https://www.europcar.lv/en/partners/airline-partners].

 

We may also disclose your personal data in accordance with applicable laws and regulations to the relevant authorities.

3.2. International transfers

In order to provide you with our products and services, we may use service providers located outside the European Union. In the event that the vehicle is booked abroad, data transfers will be carried out in the country in question in order to provide you with our mobility solutions.

Depending on the assumptions, some recipients may be located in countries recognized by the European Commission as providing an adequate level of protection of personal data or in countries that have not been recognized by the European Commission as providing such a level of protection. In any case, we have implemented appropriate protection measures to protect your personal data in accordance with data protection regulations.

4. How long do we keep your Personal Data?

Your personal data are kept for different periods of time, depending on the purposes of the processing concerned:

Purposes of the processing

Legal basis of the processing

Creating and managing your online customer account on our website or mobile application.

5 years from the end of the commercial relation

Managing your reservation and rental contract through a central booking engine, in particular to:

- collect the data necessary to organise your reservation

- communicate this data to the concerned franchisee operating the service

- manage your payment

5 years from the end of the rental

Sending you emails about special offers and promotions to promote our products and services.

- If you are a Europcar customer, 3 years from the end of the business relationship with EC.

- If you are not a Europcar customer, 3 years from the collection of your personal data OR from the last time you requested information from us

Sending you an email in order to collect your feedback on your rental.

12 months from the data collection

Managing your loyalty program and third party partnership loyalty program

For the time of your membership in the loyalty program and then until 4 years from the end of the validity of your loyalty points

 

5. What rights can you exercise regarding the processing of your Personal Data?

Within the limits and conditions allowed by the regulations in force, you can:

- access to your Personal Data and obtain further information on the characteristics of the processing we carry out;

- have your Personal Data corrected, updated and deleted, it being specified that deletion can only be carried out when (i) the data is no longer necessary in relation to the purposes for which it was processed, (ii) you withdraw your consent and there is no other legal basis for the processing, (iii) you object to the processing of your personal data and there is no compelling legitimate reason for the processing (iv) it has been established that your personal data has been processed unlawfully, (v) the personal data must be deleted in order to comply with one of our legal obligations

- you object to the processing of your Personal Data based on legitimate interest, which you can check by taking a look the table shown in the part “For what purposes do we process your Personal Data” and in particular the column “Legal basis of the processing”

- you object to the processing of your Personal Data for commercial prospecting purposes

- receive the personal data you have provided us with or request us to pass them on to a third party when the processing of your personal data (i) has been carried out by automated means and (ii) is based on your consent or on the execution of a contract binding us

- request the limitation of the processing of your Personal Data, which means that we will not be able to use your Personal Data for a defined period of time. You can exercise this right when:

a) you dispute the accuracy of your personal data for a period of time that allows us to verify the accuracy of your personal data;

b) the processing of personal data is unlawful and you object to the deletion of your personal data and instead demand that its use be restricted;

c) we no longer need your Personal Data but they are still required for the establishment, exercise or defence of legal claims;

d) you object to the processing for reasons relating to your particular situation, while we are checking whether the legitimate reasons pursued by us take precedence over your own.

- withdrawing your consent to treatment based on your consent

- submit a complaint to a Supervisory Authority. In France, you can contact the Commission nationale de l'informatique et des libertés (CNIL) at cnil.fr.

6. How do you exercise your rights?

If you would like to know more about the provisions of this information notice or to contact our Data Protection Officer, you can also write to us at the following address : 13 ter Boulevard Berthier, 75017, Paris , or by e-mail to: dpo@europcar.com

To exercise your rights, you must prove your identity by clearly indicating your surname, first names, driver ID and any useful information enabling us to identify you (such as the place and date of your last vehicle rental). You must also give us the e-mail address or the physical address to which you would like the reply to be sent to you.

7. How do we protect your Personal Data?

Europcar International S.A.S.U is committed to protecting the information it collects through our website and mobile applications. In particular, Europcar International S.A.S.U uses appropriate physical, technical and organizational security measures to prevent unauthorized or unlawful processing, accidental loss of or destruction of or damage to your personal data.

8. What rules apply to the processing of your Personal Data when you click on links placed on our website, redirecting to our partner's or other sites?

On this site you will find various links to the websites of our partners (e.g. for travel services). We would like to draw your attention to the fact that this information notice does not apply to the processing of your Personal Data by our partners or other third parties, which may occur when you visit their websites, and that we are not responsible for such data processing. If you would like information on how these partners and third parties process your personal data, we invite you to consult their Privacy Policies.

9. Changes to this information notice

This information notice regarding the Processing Activities performed by Europcar International was last updated on 29.12.2021.

Part 2 - Processing Activities performed by the franchisee

When delivering your Services, the franchisee collects and processes your Personal Data. 


1.     Who processes your personal data collected through this website?

Mobility Latvija SIA whose registered office is located at Lielirbes street 1, Riga, Latvia, LV1046 (hereinafter referred to as "ECI") is responsible for the processing of your personal data (i.e. any information that would allow to identify you, either directly or indirectly) collected through this website.


2.     For what purposes does ECI collect your personal data?


ECI processes personal data that you voluntarily provide to ECI through this website for the following purposes:

a)     Your registration as ECI member, creation of your account and providing you with a ECI ID.

This processing is necessary to identify you and to prepare and facilitate your future booking / rental agreements with ECI.

b)     Your booking:

               i.          to confirm and guarantee your booking;

               ii.          to modify or cancel your booking; 

               iii.          to exchange with you in relation to your booking (e.g. to provide you with information on your booking, to send you reminder notice before your check-in / check-out, to respond to your questions or suggestions);

               iv.          to manage your invoices if you decide to pay in advance, and handle any arrears;

               v.          to manage potential claims

This processing is necessary for the management of your booking and the preparation of the rental agreement concluded with an entity of Europcar group or network. 

c)     If you decide to pay in advance, your payment for ECI products / services.

This processing is necessary for the performance of the purchase of ECI products / services. For your full information, ECI can only retain your credit card information, subject to your express consent in order to facilitate future payments.

d)     The improvement of Europcar products / services on the basis of customer surveys you have completed.

This processing, aiming at having a better understanding of ECI members' needs and offering you customized functions to enhance your experience of Europcar products / services, is based on ECI "legitimate interest".

e)     The operation of ECI live web chat to provide you with preliminary online assistance.

This processing, aiming at creating more proximity and establishing a closer relationship with you by notably answering more quickly your queries, is based on ECI "legitimate interest".

f)      Promotional and marketing activities, namely:

               i.          the sending of email and SMS notifications for special promotions / deals;

               ii.          the recording of your rental history to suggest you preferred products / services when looking for new booking / rentals;

               iii.          the recording of your rental history:

- to send you commercial messages,

- to send you special offers; and/or

- to make you benefiting from special advantages;

depending on the volume, amounts, frequency of your orders, duration of your rentals and your activity on our website (e.g., number of visits);

               iv.          the sending of emails about a booking you did not complete or send you a summary about a booking enquiry;

               v.          the management of your loyalty program and membership card;

               vi.          the organization of promotional contests / sweepstakes;

               vii.          the management and update of Europcar customers / prospects database

               viii.          the publication of your ratings on Europcar products / services.

Direct marketing processing activities (prospection directe), i.e. any commercial message from ECI aiming at promoting Europcar products / services, are subject to your express consent.

By exception, if you are already an ECI existing customer and that the message concerns products / services similar to those you have already purchased, the underlying processing aiming at promoting these products / services will not be based on your consent but on ECI "legitimate interest".

In addition, EC also uses third party websites like social networks to display targeted advertising to which you might be exposed when visiting these third party websites.

The underlying processing aiming at promoting our products / services is based on ECI "legitimate interest".

These advertising are displayed by and are under the control of the third party operating the relevant website. Furthermore, ECI will have no direct access to your personal information. You can exercise your data protection rights, including the right to object to such processing, directly with the third party operating the website on which the targeted advertising is displayed. We encourage you to review the third party websites privacy and cookies policies to further understand the rules applicable to the targeted advertising operations and the adequate processes to exercise your rights.

g)     The management of fines, in particular:

               i.          to transfer to the Agence Nationale de Traitement Automatisé des Infractions the identity of the driver (or potential driver);

               ii.          to satisfy fines collection procedure to which ECI may be subject

This processing is required by law.

Claims on social networks and protecting Europcar’s reputation

h)     The management and update of a watch list of customers presenting certain contractual risks based on:  

               i.          payment incidents which have given rise to legal proceedings;

               ii.          vehicle accidents or repeated damages caused by Europcar customers

               iii.          accidents or damages caused voluntarily by Europcar customer;

               iv.          use of Europcar vehicles in breach of the general terms and conditions for rental of vehicles. 

This processing, aiming at reducing Europcar entities risks exposure in the performance of the rental agreements, is based on ECI "legitimate interest" as head of Europcar group / network. Should you appear on ECI watch list, your booking / rental request will be rejected. As the case may be, you will be entitled to contest such decision by contacting ECI or the local Europcar entity where you wish to rent.

For your full information, ECI carries out certain processing of your personal information through "cookies" and other tracers collected every time you visit ECI website. These processing are governed by ECI Cookies Policy, which we encourage you to review. You can accept or reject these cookies and other tracers by following the instructions provided in ECI Cookies Policy.


3.     Who are the data recipients of the personal information we collect about you?


3.1 Categories of recipients

Your personal data will be disclosed, as necessary / relevant, to:

a)     to the authorised personnel of ECI and of entities of the same group, entities of ECI franchise network and agent / sales intermediary appointed by ECI, for the purposes described in this privacy policy;

b)     third party IT service providers for technical purposes in order to help ECI in providing you with access to this website and to Europcar products / services. The main IT service providers are:

                 i.          Cap Gemini, for business applications development and maintenance;

               ii.          Sopra Steria, for data center maintenance and user support services;

             iii.          Unisys, for hardware implementation and maintenance;

              iv.          SalesForce, for marketing services;

               v.          Google Inc., in particular for hosting services and business applications.

c)     regarding the information processed for the payment of fines, to the Agence Nationale de Traitement Automatisé des Infractions;

d)     regarding the information processed for the purpose of the management and update of a watch list of customers presenting certain contractual risks to the vehicle rental agencies branch of the Conseil national des professions de l'automobile to the benefit of their members;

e)      marketing agencies for the preparation and conduct of marketing campaigns;

f)      external consultants for various missions in the course of ECI business activities.

ECI can also disclose your personal data to the extent required by law and/or by competent authorities.


3.2 International transfers

As necessary to provide you with ECI services, ECI will, to the extent necessary for the purposes set forth herein, transfer your personal data outside the EU to the abovementioned third parties.

Depending on the case, certain recipients may be located in countries which have been recognized by the European Commission as ensuring an adequate level of data protection or in countries which has not been recognized as ensuring such a level of protection. In any case, ECI has put in place appropriate safeguards to protect your personal data, in compliance with the EU regulation no.2016/679.

To find more information regarding the countries where your personal data can be transferred and their level of data protection by ECI, please refer to the contact information provided at the end of this Policy.

To have more information about the transfer of your personal data outside the European union, please refer to the contact information provided at the end of this Policy.


4.     For what period will ECI retain your personal data?


Your personal data are retained for different period, depending on the purposes of the processing:

Purpose

Retention period

▪        Your registration as Europcar member, the creation of your account and the provision of your with Europcar ID

▪        Your booking

For the duration of the commercial relationship.

However, information that may evidence a right or a rental agreement, or that must be kept in compliance with a legal requirement, may be subject to an intermediate archiving policy for a period of time that does not exceed the time that is necessary for the purposes for which it is kept, in accordance with applicable legal provisions.

▪        Payment – Payment card information

Upon effective completion of the payment.

However, payment card information (excluding the visual cryptogram):

▪        that may evidence a payment (i.e. card number and date of validity) is subject to an intermediate archiving policy for a period of time of 13 months after the effective payment for a credit card and 15 months for a deferred debit card, to be used only if the transaction is disputed;

▪        can be retained for a longer period, subject to your express consent to facilitate future payments.

In any case, when the payment card is expired, related information will be deleted.

▪        Promotional and marketing activities

▪        For ECI customers, 3 years as from the end of the relationship with ECI.

▪        For prospects – who are not Europcar customers – 3 years as from the collection of your personal information OR as from the last request for information you made.

▪        Cookies

▪        Please check ECI Cookies Policy.

▪        Operation of ECI live web chat

3 years as from the end of the relationship with ECI.

 

▪        Improvement of ECI services depending on your preferences

3 years as from the end of the relationship with ECI.

▪        Payment of fines

For the time necessary to identify the driver (or the potential driver) liable for the infraction leading to the fine, which cannot exceed 45 days after receipt of the fine. However, relevant information can be kept for a longer period of up to 12 months after receipt of the fine, subject to an intermediate archiving policy.

Requests from Agence Nationale de Traitement Automatisé des infractions including personal information are deleted once these requests have been proceeded by ECI.

▪        The management and update of a blacklist of customers presenting certain contractual risks namely: 

                 i.          payment incidents which have given rise to legal proceedings

               ii.          vehicle accidents or repeated damages caused by Europcar customers

             iii.          accidents or damages caused voluntarily

3 years as from the occurrence of the relevant event

             iv.          the use of Europcar vehicles in breach general terms and conditions for rental of vehicles

5 years as from the occurrence of this event


5.     What rights can you exercise with respect to the processing of your personal data?


At any time, you can view and/or update your personal profile, which includes member registration, driver information and car rental preferences information, through the "My Europcar" link, accessible through the main navigation bar of ECI website. You will be able to change your password, secret question, update or correct phone number, address, email, and driving licence information and update your car rental and travel preferences including insurance, means of payment and frequent traveler membership.

As per EU regulation no.2016/679, you can also benefit from the following rights:

a)     right of "access": right to obtain confirmation as to whether or not your personal data are being processed by ECI, and, where that is the case, to access to these personal data and to obtain further information on the characteristics of our processing[1];

b)     right "to rectification": right to obtain the rectification of inaccurate personal data or the right to have incomplete personal data completed, including by means of providing a supplementary statement;

e)     right to "erasure" (or the so-called "right to be forgotten"): right to obtain the deletion of your personal data in certain circumstances[2]; right to "object": at any time, a right to object to the processing of your personal data to prevent ECI from continuing to carry out such processing:

                    i.          where your data are processed for direct marketing purposes;

                   ii.          where your personal data are processed on the basis of ECI's legitimate interest. In that case, your request will be satisfied only if you provide ECI with a description of the particular situation legitimating your request and save if ECI can demonstrate overriding legitimate grounds in light of your particular situation.

f)      right to "withdraw your consent": where the processing of your personal data is based on your consent, a right to withdraw your consent to the processing of your personal data at any time and to prevent ECI from continuing to carry out such processing;

g)     right to "data portability": where the processing of your personal data is based on your consent and carried out by automated means, the right to receive your personal data provided to ECI, in a Excel spreadsheet[3] and to transmit those data to a designated third party.

h)     right of a "deceased person": right to define guidelines regarding the processing of your personal information after your death.

If you wish to exercise any of these rights, please contact ieva.smite@europcar.lv as set out below in section 6.

To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections

As per article 77 of the EU regulation no. 2016/679, you can lodge a complaint about the processing of your personal data with the body regulating data protection in your country[4] if you consider that the processing of your personal data infringes the said EU regulation no. 2016/679.


6.     Who to contact when you have a query regarding the processing of your personal data?


Depending on the purpose of your query, you will find below

a)     To exercise your rights (access, rectification, erasure, restriction, etc.) contact ieva.smite@europcar.lv

b)     For general query regarding the processing of personal data carried out by ECI:       eis-dpo@europcar.com.


7.     How does ECI protect your personal data?


ECI is committed to protecting the information it collects through this website.

In particular, ECI uses appropriate physical, technical and organizational security measures to prevent unauthorized or unlawful processing, accidental loss of or destruction of or damage to your personal data.

ECI's systems are configured with data encryption, or scrambling technologies, and industry-standard firewalls. When you send personal information to a ECI website over the Internet, your data is protected by "Transport Layer Security" (TLS) technology to ensure safe transmission.

Any credit card transaction you make through ECI websites is done through our Secure Server Technology. This technology notably:

a)     assures your browser that your data is being sent to the correct computer server, and that the server is secure;

b)     encodes the data, so that it cannot be read by anyone other than the secure server;

c)     checks the data being transferred to ensure it has not been altered.


8.     What rules apply to the processing of your personal data when clicking on links placed on ECI website redirecting to ECI partner's websites or other websites?


You may find various links to ECI's partners websites or other third party websites (e.g. for travel services) on this website. ECI would like to draw your attention to the fact that this privacy policy does not apply to the processing of your personal data carried out by our partners or other third parties when visiting their respective websites and that ECI is not responsible for these kind of processing. We encourage you to review the privacy policies of ECI's partners and other third parties to further understand the rules applicable to the processing of your personal data carried out by the same.


9.     Changes to this Privacy Policy


This privacy policy was published on May 25th, 2018. In case of changes to this privacy policy implemented by ECI, such changes will be identified by ECI on this webpage.

When a change materially impacts a processing carried out on the basis of your consent, ECI will contact you to obtain a new consent.

 



[1] Regarding the purposes of the processing, the categories of personal data concerned, the categories of recipients, whether these data are transferred to third countries and appropriate safeguards put in place (if any), the storage period, the existence of any automated decision-making based on these data, the right to lodge a complaint with the relevant data protection authority, the existence of other data subjects' rights (rectification, erasure, restriction).

[2] Where (i) data are no longer necessary in relation to the purposes for which they are processed, (ii) you withdraw your consent and there is no other legal ground for the processing, (iii) you object to the processing of your personal data and there are no overriding legitimate grounds, (iv) it is demonstrated that your personal data have been unlawfully processed, to comply with a legal obligation.

[3] Or any other commonly used and machine-readable format.

[4] The country where you have your habitual residence, place of work or place of the alleged infringement.

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