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PRIVACY POLICY


Preamble


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 www.europcar.com.pl/en/partners/airlines

 

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 26.01.2022.

 

Part 2 - Processing Activities performed by the franchisee


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

Personal data processing activities performed by Inter Best 97 Polska Sp. z o.o. Sp. k.

 

Inter Best 97 Polska Sp. z o.o. Sp. k. is the franchisee of Europcar International S.A.S. U. that has the exclusive right to use Europcar’s trademark in Poland. Inter Best 97 Polska Sp. z o.o. Sp. k. has 12 car rental stations across the country. As Inter Best 97 Polska Sp. z o.o. Sp.k. whose registered office is in Warsaw, ul. Komitetu Obrony Robotników 48, is the Data Controller of your personal data collected and processed for the purposes of a car rental. 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 Inter Best 97 Polska Sp. z o. o. Sp.k. collects and processes various categories of Personal Data for car rental purposes within Europcar International S.A.S.U. 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, phone number, postal address, ID/passport number;

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

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

- location data of the vehicle’s GPS system.

 

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

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

- collect the data necessary to organise your reservation and rental process 

These processing activities are based on the necessity to fulfill the contract to which the Hirer is party and to perform activities prior to the contract conclusion under Article 6(1)(b) of the General Data Protection Regulation in order to provide electronic services and vehicle rental services. 

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

This processing activity is subject to your prior consent under Article 6(1)(a) of the General Data Protection Regulation.

Bringing claims of civil-law character or protection against them, in particular:

  1. claiming payment due under the car rental contract
  2. protection of property on loan, in particular to localize the rented vehicle in case of its loss, misappropriation or theft and to verify the proper performance of the contract by the Hirer.

This processing activity is based on our legitimate interest under Article 6(1)(f) of the General Data Protection Regulation.

 

Automated decision-making, including profiling.

We don’t perform it.

 

3. Who are the recipients of your Personal Data?

3.1. Categories of recipients


Your personal data may be communicated to our employees, employees of the service network, other companies within our franchisee network, that are authorized to provide the car rental service and if necessary:

  • to our subcontractors, in particular our IT service providers for hosting, maintenance or development purposes, providers of accounting, debt recovery services or legal services
  • marketing agencies to help us prepare commercial promotional camapigns
  • 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.com.pl/partners/airlines
  • We may also disclose your data to the relevant legal authorities appointed to impose and enforce charges for using public roads in accordance with the content of the Act of March 21, 1985 on public roads (Dz. U. Nr 14 poz. 60) or to enforce penalties imposed in accordance with the content of the Act of May 20, 1971 - Criminal Offenses (Dz. U. Nr 12 poz. 114) and on the basis of the decree of the Prime Minister from November 24, 2003 on the amount of punitive fines imposed for selected types of offenses (Dz. U. Nr 208, poz. 2023). 

3.2. International transfers


Inter Best 97 Polska Sp. z o.o. Sp. k. is the franchisee of Europcar International S.A.S. U. Under the franchise agreement, in order to provide you with our services, we share your personal data with Europcar International S.A.S. U. We may also 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. In such a case, Europcar International S.A.S. U. is responsible for your personal data. It has 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

Data retention period

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

- collect the data necessary to organise your reservation and rental process 

5 years counting from the end of the calendar year in which the tax payment date for the rental invoice expired

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

3 years from the date of consent or 3 years from the last marketing contact on our part, subject to consent

Bringing claims of civil-law character or protection against them, in particular:

  1. claiming payment due under the car rental contract
  1. protection of property on loan, in particular to localize the rented vehicle in case of its loss, misappropriation or theft and to verify the proper performance of the contract by the Hirer.

6 years from the date the service was provided

 

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:

  • the data is no longer necessary in relation to the purposes for which it was processed,
  • you withdraw your consent and there is no other legal basis for the processing,
  • you object to the processing of your personal data and there is no compelling legitimate reason for the processing,
  • it has been established that your personal data has been processed unlawfully,
  • 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 (‘right to be forgotten’)

- request us to pass your personal data on to a third party when the processing of your personal data  has been carried out by automated means and or 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:

  •  you dispute the accuracy of your personal data for a period of time that allows us to verify the accuracy of your personal data;
  • 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;
  • we no longer need your Personal Data but they are still required for the establishment, exercise or defense of legal claims;
  • 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, i.e. the President of the Personal Data Protection Office (Urząd Ochrony Danych Osobowych) with whom you can contact via this website:
https://epuap.gov.pl/wps/portal/strefa-klienta/katalog-spraw/sprawy-ogolne/ogolne-sprawy-urzedowe-2/pismo-ogolne-do-podmiotu-publicznego-nowe or in writing: Urząd Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warszawa.

 

6. How do you exercise your rights?


If you would like to know more about the provisions of this information notice or to contact us, you can write to us at: Inter Best 97 Polska Sp. z ograniczoną odpowiedzialnością Sp. K., ul. Komitetu Obrony Robotników 48,02-146 Warszawa or via e-mail: ado@europcar.pl. 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?


Inter Best 97 Polska Sp. z .o.o Sp. K. is committed to protecting the information it collects through our website and mobile applications. In particular, Inter Best 97 Polska Sp. z .o.o Sp. K. 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. Changes to this information notice


This information notice regarding the Processing Activities performed by Europcar International was last updated on 02.01.2022.

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