e Car Rental Ireland Privacy Policy



Table of contents

  • 1. Who processes your personal data collected through this website?
  • 2. For what purposes does Executive Trust Limited collect your personal data?
  • 3. Who are the data recipients of the personal information we collect about you?
  • 4. For what period will Executive Trust Limited retain your personal data?
  • 5. What rights can you exercise with respect to the processing of your personal data?
  • 6. Who to contact when you have a query regarding the processing of your personal data?
  • 7. How does Executive Trust Limited protect your personal data?
  • 8. What rules apply to the processing of your personal data when clicking on links placed on Executive Trust. Limited website directing to Executive Trust Limited partner's websites or other websites?
  • 9. Changes to this Privacy Policy


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

Executive Trust Limited trading as e Car Rental Ireland, whose registered office is located at 35 Northwood Court, Northwood Business Park, Santry, Dublin 9 Ireland. e Car Rental Ireland 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 e Car Rental Ireland collect your personal data?

e Car Rental Ireland processes personal data that you voluntarily provide to e Car Rental Ireland through this website for the following purposes:

a) Your registration as e Car Rental Ireland member, creation of your account and providing you with a e Car Rental Ireland ID. This processing is necessary to identify you and to prepare and facilitate your future booking / rental agreements with e Car Rental Ireland.

b) Your booking and your car rental agreement:

i. to confirm and guarantee your booking;

ii. to modify or cancel your booking;

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

iv. to manage your rental (delivery and return of the vehicle);

v. to manage your invoices;

vi. to manage the payment of arrears;

vii. to manage potential claims;

viii. to manage the recovery of potential damages to e Car Rental Ireland vehicle;

ix. to manage your insurance.

This processing is necessary for the booking and the performance of the rental agreement concluded with e Car Rental Ireland.

c) Your payment for e Car Rental Ireland products / services.

This processing is necessary for the performance of the rental agreement. For your full information, e Car Rental Ireland can only retain your credit card information, subject to your express consent in order to facilitate future payments.

d) The improvement of e Car Rental Ireland products / services on the basis of customer surveys you have completed.

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

e) The operation of e Car Rental Ireland 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 e Car Rental Ireland"legitimate interest".

f) Promotional and marketing activities, namely:

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

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

ii. the recording of your rental history to send you special offers and make you benefiting from special advantages depending on your volume and frequency of your orders;

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

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

v. the organization of promotional contests / sweepstakes;

vi. the management and update e Car Rental Ireland's customers / prospects database.

Direct marketing processing activities, i.e. any commercial message from e Car Rental Ireland aiming at promoting e Car Rental Ireland products / services, are subject to your express consent.

By exception, if you are already an e Car Rental Ireland 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 e Car Rental Ireland "legitimate interest".

g) The management of fines, in particular:

i. to transfer to the Transport Infrastructure Ireland or it's nominated servants or agents in respect of tolls, An Garda Siochana in relation to driving offences or Council Authorities in respect of parking violations the identity of the driver (or potential driver);

ii. to satisfy fines collection procedure to which e Car Rental Ireland may be subject.

This processing is required by law.

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 e Car Rental Ireland customer;

iii. accidents or damages caused voluntarily by e Car Rental Ireland customer;

iv. use of e Car Rental Ireland vehicles in breach of the general terms and conditions for rental of vehicles.

This processing, aiming at reducing e Car Rental Ireland risks exposure in the performance of the rental agreements, is based on e Car Rental Ireland "legitimate interest". Should you appear on e Car Rental Ireland watch list, your booking / rental request will be rejected. As the case may be, you will be entitled to contest such decision by contacting dpo@europcar.ie.

i) Telematics:

The following data points are collected from each vehicle tracked by e Car Rental Ireland through services provided by a Telematics Service Provider:- position, speed, acceleration, impact data (location, g-force and direction of impact) and the identifier of the device in the vehicle.
This data is collected for the following reasons: -

  • Detection and prevention of loss or theft of the company vehicles
  • Management of insurance claims
  • Identification of unauthorised vehicle movements
  • Monitoring and improving customer driving behaviour
  • Management of vehicle inventory
  • The Telematics Service Provider uses data hosting service providers in Europe to host the information it collects, and use technical measures to secure data.

    The Telematics Service Provider and e Car Rental Ireland will adhere to the following obligations under GDPR law:-

  • The Telematics Service Provider will only process personal data in accordance with e Car Rental Ireland's written instructions (including when making an international transfer of personal data) unless required to do so by law.
  • The Telematics Service Provider will ensure that people processing the data are subject to a duty of confidence and will take appropriate measures to ensure the security of processing.
  • The Telematics Service Provider will only engage a sub-processor with the prior consent of the data controller and a written contract.
  • The Telematics Service Provider will assist e Car Rental Ireland in providing subject access and allow data subjects to exercise their right under GDPR.
  • The Telematics Service Provider will assist e Car Rental Ireland in meeting its GDPR obligations in relation to the security of processing, the notification of personal data breaches and data protection impact assessments.
  • The Telematics Service Provider will delete or return all personal data to e Car Rental Ireland as requested at the end of the contract.
  • The Telematics Service Provider will submit to audits and inspections, provide e Car Rental Ireland with whatever information it needs to ensure they are both meeting their Article 28 obligations, and tell e Car Rental Ireland if it is asked to do something infringing the GDPR or other data protection law of the EU or a member state.
This processing, for the purpose of protecting the integrity of our fleet, is based on our legitimate interests.

For your full information, e Car Rental Ireland carries out certain processing of your personal information through "cookies" and other tracers collected every time you visit e Car Rental Ireland website. These processing are governed by e Car Rental Ireland Cookies Policy, which we encourage you to review. You can accept or reject these cookies and other tracers by following the instructions provided in e Car Rental Ireland 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 e Car Rental Ireland and of entities of the same group and/or of entities of e Car Rental Ireland franchise network, or agent / sales intermediary appointed by e Car Rental Ireland for the purposes described in this privacy policy;

b) third party IT service providers for technical purposes in order to help e Car Rental Ireland in providing you with its 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 automation marketing services;

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

vi. Rentalmatics for the provision of vehicle Telematics data and services.

vii. Capricorn Ventis for Business Intelligence application development

viii. Trilogy Technologies for IT Managed Services in the area of Helpdesk Support and escalation services

ix. Silveram Solutions for business application development and maintenance

x. GoCanvas for mobile forms capture

xi. Jimpisoft, Lda for Car Rental Management System

xii. Mailchimp for email communication

xiii. SurveyMonkey and Clear Market Intelligence for customer feedback surveys

xiv. Microsoft for email communication and productivity systems

c) regarding the information processed for the payment of fines, to Transport Infrastructure Ireland or it's nominated servants or agents in respect of tolls, An Garda Siochana in relation to driving offences or Council authorities in respect of parking violations.

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 Car Rental Council of Ireland to the benefit of their members

e Car Rental Ireland 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 e Car Rental Ireland services, e Car Rental Ireland 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, e Car Rental Ireland 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, their level of data protection and the potential safeguards put in place by e Car Rental Ireland please contact us in accordance with Section 6(a) of this policy.

4. For what period will e Car Rental Ireland retain your personal data?

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

Purpose

Retention period

Your booking and your car rental For the duration of the commercial relationship. However, information that may evidence a right or a rental agreement, or that must 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.
Vehicles monitoring through the use of vehicle connected devices All identifiable customer data is purged after 4 years unless it is still required under legislation. We own the information we collect in its aggregate and anonymized form and we reserve the right to use such aggregate, anonymized information without restriction.
Promotional and marketing activities
  • For Executive Trust Limited customers, 3 years as from the end of the relationship with Executive Trust Limited.
  • For prospects - who are not Executive Trust Limited customers - 3 years as from the collection of your personal information OR as from the last request for information you made.
Cookies Please check e Car Rental Ireland Cookies Policy
Payment of fines For the time necessary to identify the driver (or the potential driver) liable for the infraction leading to 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.
  • The management and update of a blacklist of customers presenting certain contractual risks, namely:
  • payment incidents which have given rise to legal proceedings
  • vehicle accidents or repeated damages caused by e Car Rental Ireland customer
  • accidents or damages caused voluntarily
3 years as from the occurrence of the relevant event
The use of e Car Rental Ireland vehicles in breach general terms and conditions for rental of vehicles 5 years as from the occurrence of this event
  • Your registration as e Car Rental Ireland member, the creation of your account and the provision of your with e Car Rental Ireland ID
  • Your booking and your car rental
For the duration of the commercial relationship.
However, information that may evidence a right or a rental agreement, or that must 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.

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

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 e Car Rental Ireland and, where that is the case, to access to these personal data and to obtain further information on the characteristics of our processing ;

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;

c) right to "erasure" (or the so-called "right to be forgotten"): right to obtain the deletion of your personal data in certain circumstances ; right to "object": at any time, a right to object to the processing of your personal data to prevent e Car Rental Ireland 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 e Car Rental Ireland legitimate interest. In that case, your request will be satisfied only if you provide e Car Rental Ireland with a description of the particular situation legitimating your request and save if e Car Rental Ireland can demonstrate overriding legitimate grounds in light of your particular situation.

d) 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 e Car Rental Ireland from continuing to carry out such processing;

e) 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 e Car Rental Ireland in an Excel spreadsheet and to transmit those data to a designated third party;

f) 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 dpo@europcar.ie 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 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) For general query regarding the processing of personal data carried out by e Car Rental Ireland DPO: dpo@europcar.ie

b) To exercise your rights (access, rectification, erasure, restriction, etc.): send an email to res@europcar.ie.

7. How does e Car Rental Ireland protect your personal data?

e Car Rental Ireland is committed to protecting the information it collects through this website.

In particular, e Car Rental Ireland 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.

e Car Rental Ireland’s systems are configured with data encryption, or scrambling technologies, and industry-standard firewalls. When you send personal information to a e Car Rental Ireland 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 e Car Rental Ireland 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 e Car Rental Ireland website directing to e Car Rental Ireland partner's websites or other websites?

You may find various links to e Car Rental Ireland’s partners websites or other third party websites (e.g. for travel services) on this website. e Car Rental Ireland 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 e Car Rental Ireland is not responsible for these kind of processing. We encourage you to review the privacy policies of e Car Rental Ireland'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 24th May 2018. In case of changes to this privacy policy implemented by e Car Rental Ireland such changes will be identified by e Car Rental Ireland on this webpage.

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