Privacy Policy

INTRODUCTION

This Privacy Policy describes how Auto Rent treats the personal data of its customers, as well as job seekers, employees, suppliers. Data privacy is key to Auto Rent's activity.

This privacy policy is governed by compliance with the applicable legislation (Regulation (EU) 2016/679, "RGPD"). It applies to the data collected from our customers through the website, information collected by the reservations department or through agencies and tour operators, as well as the information collected from jobseekers, employees and suppliers.

Please read this policy carefully before using the website or registering for the purchase of our services. By using our website or by contacting us for the use of services you consent to the collection and processing of your data as described in this privacy policy.


DEFINITIONS

Personal Data: Information relating to an identified or identifiable natural person ("data subject"); an identifiable person is considered to be identifiable, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, identifiers by electronic means or by reference to one or more elements specific physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.

Special categories of personal data: Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, as well as genetic data, biometric data to identify a person unambiguously, health or data relating to the sexual life or sexual orientation of a person.

Responsible for processing: A natural or legal person who determines the purposes and means of processing personal data.

Subcontractor: A natural or legal person who treats the data on behalf of the controller (eg a service provider supporting an Information System containing personal data).

Data Holder: The identified or identifiable natural person who is the owner of the information handled or "to whom the information relates or is associated".

Processing of personal data: an operation or set of operations on personal data by automated or non-automated means, such as collection, registration, organization, structuring, preservation, adaptation or alteration, retrieval, use, disclosure by transmission, dissemination or any other form of disclosure, comparison or interconnection, limitation, erasure or destruction.

Data Protection Officer (DPO): Person appointed by the organization that informs and advises on Auto Rent's obligations in the protection of personal data. It also provides advice on impact assessments on data protection and controls its implementation and is also the point of contact with the supervisory authority.


DATA COLLECTION

Auto Rent may collect data directly (directly from the User) or indirectly (through partner entities or third parties). Data is collected only after the consent of the holder. The collection can be done through the following channels:

Direct collection: in person, by e-mail and through the website.

Indirect collection: through partners and official entities.


DATA CATEGORIES

Auto Rent may collect the following categories of data:

Key data: Covers, for example, the name, surname, address (private and / or professional), date of birth, identification document.

Communication data: These include, for example, telephone and / or mobile phone numbers, e-mail address (private and / or professional), and fax number, if applicable.

Contract data: These include, for example, rental information (vehicle category, collection and delivery dates, pick-up and delivery office, reserved extras / services), rental agreement number, reservation number, driving license data , driving license photography, rental vehicle registrations, and customer loyalty information and programs with partners.

Financial data: For example, credit card data, amounts or numerals received, and / or collateral.

Voluntary data: data that we are provided voluntarily, without being explicitly requested, and contain information such as your preferences regarding the equipment and category of the vehicle.

Special data: In the event of an accident, damage to the vehicle, or similar incidents, we process and report data regarding its sequence of events and the damage suffered. These types of data can be provided by customers, passengers, including injured parties. Data processed in these eventualities may include health data, such as data on injuries, blood alcohol levels, driving on the effect of narcotic drugs and the like.

Third party data: In the case of car rental, if you have provided us with personal data of third parties, for example, relatives, second drivers, and / or passengers, we will also process such data.


PURPOSE OF TREATMENT

We collect and process your personal information for the following purposes:

  • Process and Provide the services requested and the benefits you have subscribed;
  • Send email notifications and / or SMS advertising, marketing special promotions, informative content unless you have opted out of receiving such communications;
  • Send you alerts regarding the products purchased;
  • Answer your questions or suggestions;
  • Improve service quality and optimize your visit to Auto Rent;
  • Send you our Newsletter, unless you have chosen not to receive such communications;
  • Elaboration of opinion polls and statistics, in particular to analyze the quality levels of the services provided.


DATA SHARING

Auto Rent may share your Personal Information with partners (third parties) provided you have prior and express consent. Any sharing of data will always be carried out according to the law.

Entities with whom we may share your data:

Third Parties
Purpose
Legal Base
Independent operators / franchisees and network providers in order to fulfill our contract with you and to understand how you use our services and how to improve our business, travel agents
  • Process and confirm your rental reservation;
  • Assist with navigation;
  • Provide customer support;
  • Resolve violations of payment of tolls, traffic or parking;
  • Prosecute any processes related to accidents and / or injuries;
  • Provide travel assistance services.
  • Compliance with the Contract;
  • Legitimate Interests;
  • Legal Obligation;
  • Consent.
Reservation systems in order to fulfill our contract with you whenever you use a reservation system and to understand how you use our services and improve our business
  • Process and confirm your rental reservation;
  • Check the admissibility of using designated accounts and promotional codes;
  • Process payments and returns.
  • Compliance with the Contract;
  • Legitimate Interests.
Credit card issuers in order to receive their payments
  • Process payments and returns;
  • Fraud verification;
  • Debt collection.
  • Compliance with the Contract;
  • Legitimate Interests.
Computer service providers, including computer platform vendors and website analytics services, in order to comply with our contract with you and to understand how you use our services and improve our business
  • Support our systems and computer infrastructures;
  • Ensure maintenance services for our computer systems and infrastructures;
  • Storing data and providing other data processing services;
  • Provide analytical services relating to your use of our website, to identify any technical or user interface issues and / or improvements related to the website.
  • Legitimate Interests
Governments, regulatory authorities and law enforcement authorities, in order to comply with our legal obligations
  • Check your driving license and ensure it meets our criteria for a safe driver;
  • As required by these entities, if disclosure is legally required or permitted;
  • Acting against illegal activities, traffic offenses or non-compliance with the terms of use;
  • Legal obligation;
  • Legitimate Interests
Insurance companies and entities conducting proceedings in respect of any insurance products that you have subscribed in connection with your rental
  • Provide and secure the insurance product you may have requested;
  • Manage any proceedings that may have been triggered under the relevant insurance policy.
  • Compliance with the Contract;
  • Legitimate Interests.


COOKIES

Auto Rent automatically collects information whenever someone visits the Website (www.autorent.pt), obtains information from the user's computer and assigns a "cookie" (small package of information about that user) when someone visits your Website. This data is not provided by the user - it is an automatic collection as a means of facilitating the links to the websites and their use.

We use cookies to facilitate and record in particular which services you use on the websites. These technologies can also be used when sending HTML e-mail messages.

We collect information from your computer in order to evaluate the effectiveness of the content of our websites and their use. This data allows us to improve the use of our websites, or to optimize the navigation of the users in the Websites and to develop programs and contents according to the interests of the users of the Websites.

All browsers allow the user to accept, reject or delete cookies, in particular by selecting the appropriate settings in their browser, so that the user can, at any time, partially or totally disable the cookies used on the Auto Rent website.


MARKETING

If Auto Rent intends to send messages for marketing purposes, whose receipt is independent of the intervention of the recipient, its prior consent is necessary.

Consent is not required in the case of messages sent to legal persons, but the possibility of not receiving them is open.

The recipient must have access to means that allow him at any time to refuse to send these messages, without any burden. Consent should be as easy to withdraw as to give, for example, opt-out / unsubscribe in sent emails.

If the addressee decides to refuse this type of communications, no further communications should be sent for the purposes of that marketing operation.


CCTV

Auto Rent uses video surveillance (CCTV) systems for capturing and recording images with the objective of protecting people and property, under Law 34/2013, of May 16, Article 8.

These systems, however, guarantee the privacy and respect for the fundamental rights of the holders and can not focus on:

  • Public roads or neighboring properties;
  • ATM payment terminals, in order to allow the capture of the access code;
  • Interior areas reserved for clients and / or workers, namely, locker rooms and sanitary facilities;

The image recordings obtained by the video surveillance systems are stored in an encoded record for a period of 30 days counted from the respective capture, at the end of which they are destroyed.

All persons who have access to the recordings performed, due to their functions, are obliged to maintain confidentiality, under penalty of criminal procedure.


CONSERVATION OF DATA

Auto Rent maintains your personal information for a period of time that does not exceed what is reasonably required or legally required. The period of time for which we maintain such information depends on the type of information, its purpose and as long as the holder does not exercise the right of withdrawal or opposition to the treatment of the same.

The criteria we use to determine the retention period for certain categories are as follows:

  • The length of time you are an Auto Rent customer;
  • The frequency with which you rent with us or the date of the last rental;
  • Legal or contractual obligations that oblige us to retain your data for a certain period of time;
  • The existence of legal proceedings in progress that are related to any leases that you have made with us, or that are otherwise related to your relationship with us;
  • The existence of any law, rule or regulation that are applicable and allow a specific retention period;
  • If personal information is considered to be a special category of personal information, a shorter period will generally apply; and
  • The expectation of retention at the time the data is provided to us.


RIGHTS OF THE HOLDER

Under the RGPD, the data subject is guaranteed the exercise of all legally permitted rights, provided that there is a processing of personal data, namely:

Right of access - consists in the right to obtain confirmation of what your personal data are treated and information about them.

Right to rectification - consists of the right to request the rectification of your personal data that are wrong / outdated or request that those incomplete data be completed.

Right to delete data or "right to be forgotten" - consists of the right to obtain the deletion of your personal data, as long as there are no valid and / or legitimate grounds for its conservation.

Right to portability - consists of the right to receive the data you provided in a digital format of current use and automatic reading, or to request the direct transmission of your data to another entity that becomes the new responsible for your personal data.

Right to withdraw consent or right of opposition - is the right to object or withdraw consent at any time to a data processing, provided that there are no valid and / or legitimate grounds for non-acceptance of the exercise of this right.

Right of limitation - consists in the right to request the limitation of the processing of your personal data, in the form of suspension of the treatment or limitation of the scope of the treatment to certain categories of data or purposes of treatment.

Right to complain - consists of the right to complain to the relevant supervisory authority if you consider that there has been an infringement of your rights. In Portugal, this authority is the National Data Protection Commission (CNPD). More information on CNPD is available at www.cnpd.pt


SAFETY IN TREATMENT

Auto Rent will have to implement technical and organizational measures to ensure a level of security appropriate to the risk in order to avoid accidental or unlawful destruction, loss and alteration, unauthorized disclosure or access to personal data.

It is necessary to take into account the potential vulnerabilities of the system and to forecast the impact that these may have on the holders in order to assess the risks and define the most appropriate control measures.

After the impact assessment, the result of this should influence the measures that are adopted depending on what the Rent-a-car understands as appropriate, namely through the following mechanisms:

  • Pseudonymization and encryption of data;
  • The ability to ensure the confidentiality, integrity, availability and ongoing resilience of treatment systems and services;
  • The ability to restore availability and access to personal data in a timely manner in the event of a physical or technical incident;
  • A process to regularly test and evaluate the effectiveness of technical and organizational measures to ensure safe treatment.

Pseudonymisation means the processing of personal data in such a way that it can no longer be allocated to a specific data subject without the use of additional information. This treatment requires that such supplementary information be maintained separately and subject to technical and organizational measures to ensure that personal data can not be attributed to an identified or identifiable natural person. It is a privacy enhancement technique, although it does not exclude the application of other possible data protection measures.


VIOLATION OF DATA

In the event of a breach of data and to the extent that such breach is likely to pose a high risk to the rights and freedoms of the User, Auto Rent undertakes to report the breach of personal data to the User in question within 72 hours from the knowledge of the incident.

Under legal terms, communication to the User is not required in the following cases:

  • If Auto Rent has implemented adequate technical and organizational protection measures and these measures have been applied to personal data affected by the breach of personal data, especially measures that make personal data incomprehensible to any unauthorized person to access them such as encryption;
  • If Auto Rent has taken subsequent action to ensure that the high risk to the rights and freedoms of the User is no longer likely to materialize; or
  • If communication to the User implies a disproportionate effort for Auto Rent. In that case, Auto Rent will make a public communication or take a similar action through which the User will be informed.


DATA PROCESSING RESPONSIBILITY

The person responsible for the processing of Personal Data is Auto Rent-Automóveis de Aluguer, Lda.

In order to deal with issues / issues related to the processing of your personal data, you should contact us through the following means:

Telephone:

(+351) 282 417 171

E-mail address:

dp@autorent.pt

Address:

Auto Rent - Automóveis de Aluguer, Lda.

Av. Tomás Cabreira, Edif Vistamar, Loja I, 8500-802,

Portimao, Portugal