Platinum RAC Privacy Policy – Platinum Rent A Car

PRIVACY POLICY
This policy was last updated on February 1, 2019
At Platinum Rent A Car, Inc., we respect your privacy. We have implemented this privacy policy (“Privacy Policy”) and cookie policy (“Cookie Policy”) to explain our data collection and use practices. You can learn more in the sections below.
What Information We Collect
Information Collected About You
You may provide us with certain information in connection with a transaction or in your interactions with our websites and at our locations. We collect the following types of personal information from you:
• Your name, contact information, date of birth, driver’s license number and expiration date and emergency contact information;
• Vehicle rental information, including the location of where the vehicle is rented, date of rental, type of rental and your preferences;
• Your credit card details and passport information;
• Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;
• Photographs you submit of you and your driver’s license;
• Information about relevant health conditions you have that assist us in providing you with adaptive driving devices; and
• Financial information that is necessary to facilitate the purchase or lease of a vehicle from a Car Sales or Fleet Management location
Third parties provide us with additional information about you, including:
• 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), and your insurance provider (general contact and policy information).
• Credit reporting agencies, who, for fraud prevention purposes, provide us with identity-related information.
• Service Providers, such as customer support (customer service-related information and enquiries made by you), customer survey providers (your response to our customer service surveys) and marketing providers (information to assist us to better communicate our products and services).
With your consent, we will access location-based information or collect location markers from your mobile device or based on your IP address. We will use this information to provide you with notifications related to our locations, return information, local offers or other information that we think will be helpful in providing you with better services. We do not use
this information to specifically locate you for any reason other than to provide you the service. With your consent, our application will utilize your device’s camera. If you have allowed us to utilize your location information or your device’s camera in the past and wish to revoke the permissions, please change the settings on your device.
Vehicle Operation and Location Data
Our vehicles may be equipped with a vehicle telematics system (“Telematics System”). Some or all Telematics System functionality will be active during rental periods. Telematics Systems provide us with use of, disclosure of or access to (1) location information, (2) crash notification and related crash data, (3) operational condition, mileage, diagnostic and performance reporting of vehicles and (4) driver behavioral information (“Telematics Data”), as permitted by law.
Use of the Telematics System is subject to the terms and conditions and privacy policy posted by the applicable Telematics Systems provider and/or vehicle manufacturer (in the case of OnStar, information is available at www.onstar.com), which may include system and service limitations, warranty exclusions, limitations of liability, wireless service provider terms, privacy practices, descriptions of use and sharing of information and user responsibilities.
We are not responsible for any data that is left in the vehicle as a result of your use. We cannot guarantee the privacy or confidentiality of such information and you must wipe it before you return the vehicle to us.
Telematics Data will be shared with emergency service providers, others who assist in responding to an accident, telematics service operators or those with whom we have a legal or contractual obligation to provide such data.
Children’s Privacy
Our websites and online marketing are not directed to, and we do not knowingly collect personal information from, children under the age of 18. 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.
How We Use Information About You
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 us to enter into a contract with you and provide services to you for the duration of the contract, including
o To assist the transactions that you request, such as reserving, renting, purchasing or leasing motor vehicles.
o To provide customer service related to your interactions with us or to respond to your enquiry.
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• Where it is necessary for us to comply with a legal obligation, including
o To share information about your vehicle’s location with emergency services in the event that you are involved in a road accident.
o To share information with government and regulatory authorities when required by law or in response to legal process, obligation, or request.
• Where it is necessary for our legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, including
o To communicate important information about your rental, such as arrival and return alerts. These communications, which are transactional in nature, will be sent to you via email or SMS.
o 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.
o 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.
o 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.
o To protect our legal rights and manage the security of our networks and property. For example, we will use CCTV to ensure the security of our premises and we maintain Do Not Rent lists of customers that are non-payment or safety risks.
o To share your information with third parties in order to prevent fraud and protect our business interests and rights, privacy, safety and property, or that of the public. We will do this to collect unpaid bills, to avoid liability for penalties you incur (e.g. traffic citations) and for claims processing purposes.
o To share your information with third parties in order 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. We will also disclose your information to third parties if the rights of another individual may be violated.
o To enable us to use telematics (e.g., for the purposes of tracking mileage and location in the event of theft and to alert us if the telematics systems has been removed or tampered with).
• Where you have given consent, including
o 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.
o 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, electronic newsletters and communications regarding an incomplete online membership form or reservation. Some of these offers will be received in advertising on non-Platinum Rent A Car, Inc. sites, including on social media.
o To send you text messages in order to provide you with time sensitive communications related to your transaction (e.g., construction delay at airport branch), extended rental opportunities, customer experience surveys, marketing
promotions such as coupons, discounts, last-minute specials or loyalty and rewards information.
Retention of Your Personal Information
We retain your personal information for as long as we need to fulfil our business purposes, as set out below:
• Marketing 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 7 years after your last interaction with us.
• Rental transactions: We keep the data associated to your rental agreement for up to 7 years from the date of the rental, subject to other local legal requirements. We keep records of payments you have made for 2 years from the date of the transaction (depending on the location of the rental).
• Customer service related queries: We keep general queries for 3 years, unless you make a complaint, in which case, we keep complaints data for 7 years.
• 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 5 years after that. If a settlement means that we have to 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.
Who We Share Information With
Our employees in our IT, marketing, operations and customer service divisions will use your information, as described in this Privacy Policy, including, if required by applicable law, to send you information about products and services or respond to your inquiry.
Our Service Providers And Business Partners
We will share your information with third parties, such as (1) payment, administrative and technical support providers or our insurance replacement, corporate rental or other customers or partners to facilitate the rental transaction (2) companies who conduct customer research or satisfaction surveys on our behalf, (3) communication providers which send email and other marketing and service-related communications to you on our behalf, (4)debt collection providers, (5) claims processors.
Government Authorities
Your personal information may also be shared with government authorities as outlined above.
Sale, Merger or Change in Control
Your information may also be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of Platinum Rent A Car, Inc’s businesses or assets. 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.
Your Rights
Other rights you have may include: 1) asking for a copy of your personal information, 2) to correct it, 3) to erase certain categories or types of information, 4) to restrict certain processing, 5) to obtain the information you provide in a structured, machine readable format and 6) to transfer some of this information to other organizations.
You have the right to object to processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process information, you have the right to withdraw this consent at any time.
You can exercise these rights by Contacting Us. We will respond to your request within 30 days or as required by local law.
You have the right to lodge a complaint with a supervisory authority regarding our processing of your personal information and/or how we have responded to or handled any concern you have raised with us.
We reserve the right not to allow access to your information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent.
Changes To These Policies
As necessary, we will update our Privacy Policy and Cookie Policy to reflect changes in our privacy practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site or as otherwise may be required or permitted by law, prior to the change becoming effective. We encourage you to periodically review this site for the latest information on our privacy practices