We use the information we collect from you or about you to provide you with our services and for the following purposes:
Where it is necessary for the performance of a contract which governs the services we provide to you, including
- 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, to communicate important information regarding your reservation, rental, lease or purchase of a vehicle. These communications are transactional in nature and will be sent to you via email, text or calls;
- To provide customer service related to your interactions with us or to respond to your enquiry;
- To enroll you in our loyalty programs and send information relating to your ongoing membership of these programs;
- To enroll you in our CarShare and Car Club business, and to send information relating to your ongoing membership of these business.
Where necessary for us to comply with a legal obligation, including
- 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, traffic regulation, or in response to legal process, obligation, or request, including checking appropriate sanction lists or for maintaining public security.
Where it is necessary for our legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, including
- To communicate important information about your rental and provide you great service. These communications, which are transactional in nature, will be sent to you via email, text or calls;
- To assist us in providing better products and services: for example, 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;
- To 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. To enhance your advertising experience, we use cross-device tracking. This means we may collect and combine data from your various devices to show you ads that are relevant to your interests;
- To protect our legal rights and manage the security of our networks and property, including to protect our websites from spam and abuse. For example, we will use 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;
- To 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;
- To enable us to use vehicle data systems for purposes listed in the Vehicle Data section above, such as assisting in recovering a vehicle we reasonably believe is stolen or abandonded; and to facilitate the vehicle return process (where remote return is available) and billing purposes;
- Unless where consent may be required by applicable law, we may use personal information for marketing and promotional purposes to show you advertisements for products and/or services tailored to your interests on social media and other websites.
- To de-identify or aggregate personal information collected about you and use it for any lawful purpose;
- To transfer your data as described in the “Global Data Transfers and Processing” section; and
- To 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 your country’s applicable law, including
- 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;
- To send one-time use security tokens via text;
- Where applicable, to ask for you feedback by email, text or call, to assist us in providing better products and services: for example, 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 to 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. To improve your advertising experience we use cross-device tracking to show you ads that are relevant to your interests. Some of these offers will be received in advertising on non-Enterprise sites, including on social media, or other digital platforms;
- Where applicable, to 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.
We retain your personal information for as long as we need to fulfil our business purposes, as set out below:
We may keep the data associated to your rental agreement for up to seven years from the date of the rental or in accordance with our business needs, subject to other local legal requirements. We keep records of payments you have made for two years from the date of the transaction (depending on the location of the rental).
We keep the data associated to the sale of a vehicle for up to ten years from the date of sale, subject to other local legal requirements.
We keep the data associated to claims involving our renters or other individuals for the life of the claim and up to ten years from conclusion of our obligation, subject to other legal requirements
Customer service-related queries
We keep general queries for three years, unless you make a complaint, in which case, we keep complaint data for seven years.
Marketing and analytical purposes
We keep data linked to cookies and other online identifiers up to three years. We keep other marketing information, such as email subscription and loyalty enrollment data for up to seven 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 five 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 year beyond the end of the investigation.