PRIVACY POLICY

ABOUT US

This policy applies to all subsidiaries of the Autohellas Group and informs you on the processing of your personal data as a customer, prospective customer, guest or user of the Group’s website and/or applications. It also provides information about your privacy rights and how you are protected by the law.

At Autohellas we respect your privacy and are committed to protecting your data. We are responsible for collecting, handling and processing your personal data and we have appointed a Data Protection Officer (“DPO”) responsible for handling queries associated with this privacy statement. For any clarifications regarding this privacy statement, including requests to exercise your legal rights, please contact our DPO at the following contact details.

General Data Protection Office
Autohellas Tourist and Trading Societe Anonyme
31, Viltanioti Street, Kifissia
14564
Attica, Greece

You reserve the right to address at any time your local supervisory Authority in relation to data protection matters. In Greece, this is the Hellenic Data Protection Authority. You can find all relevant information at the following link: www.dpa.gr. We would, however, appreciate to be given an opportunity to address your concerns before you address the Authority; so please contact us first at the contact details set out above.

Contents

1. Collection
2. Purposes
3. Sharing
4. Retention and security
5. Your Rights
6. Questions & Changes

1. COLLECTION

We collect the Personal Data that you provide during the execution of our services, on our websites, in applications we use for the purpose of serving your needs more efficiently or in connection with any inquiries, reservations, rentals or purchases you make in relation to our services. We may collect your Personal Data directly or through our service providers, business partners, subsidiaries, franchisor or booking channel providers. More specifically:

Α. INFORMATION CATEGORIES:

We reserve the right to collect, process, store and transmit different types of personal data that concern you, which we have classified as follows:

Personal information:

Technological information:

Rental information:

Sensitive data:

Certain Personal Data we collect may constitute sensitive data, such as (indicatively but not limited to) data related to health conditions (for example, in case of an accident where we need to cooperate with your insurer or with claims management companies in relation to an injury you may have sustained).

Please note that, in case you need to provide us with sensitive personal data in the context of any services or products purchased from us, we will use such data for the operational uses described in this Privacy Policy subject to your consent, where required under applicable law.

Β. METHODS AND SOURCES OF COLLECTION:

Online collection:

Cookies and online data collection

We use cookies on our websites to store information in your computer or mobile device to improve your online experience. Cookies are small text files that allow you to navigate efficiently between pages, help us assess whether our website is functioning properly and generally improve your browsing experience. Cookies can also help to ensure the advertising you see online is more relevant to your interests.

In general, our cookies may perform the following functions:

Cookies and online data collection

If you wish to activate or deactivate the use of cookies from your web browser settings, depending on your web browser you can visit the following web pages in order to obtain the appropriate information:

• Microsoft Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Google Chrome
• Opera
• Safari
• Safari for iPad and iPhone

Note: Our websites are not addressed to individuals under the age of 13 and we do not knowingly obtain Personal Data from such individuals.

Off-line collection:

Depending on the purposes for which we collect and use your Personal Data, as set out in this Policy, the Personal Data we collect form you may be required due to a statutory or contractual obligation, or provided by you on a voluntary basis, or necessary for us to enter into a contract with you. If you do not provide your Personal Data to us we may not be able to provide the requested services (renting, leasing, maintenance, sales etc.).

2. PURPOSES OF PROCESSING

Below we have set out the various purposes for which we process your personal data. We also set out the legal grounds for the processing of your Personal Data for each purpose:

1. OPERATIONS AND SERVICES: We may use your Personal Data to provide you with the services or products you request from us and perform other activities related to such services or products, including billing and collection following a rental or leasing, or to communicate with you regarding

1. any reservation you initiate or rental transaction you perform with us
2. issues related to the safety, maintenance and insurance coverage of the car that you rent with us
3. issues related to the safety and maintenance of the car that you have purchased from us

Legal grounds: to perform our contract with you or to take steps at your request prior to entering into a contract with you.

1. OUR MARKETING: We may use your Personal Data to provide you with marketing information, customer satisfaction or services assessment surveys and offers via various means, including email and SMS messages, in accordance with applicable law.

Legal grounds: Where permitted by applicable law, we may lawfully use your Personal Data to send you such marketing communications (including via email) for these marketing purposes where necessary for our legitimate interests, which include promoting our products and services that may be of interest to you.

You can unsubscribe from receiving such messages at any time by contacting us at the details at section 6 below as well as by the “unsubscribe” link in each email. Please note that, if you exercise these options, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that the unsubscribe process may take some time to complete, in accordance with the applicable laws.

1. THIRD PARTY MARKETING: We may also share your Personal Data with a third party that provides you with special offers or promotions that may be of interest to you (“Third Party Provider”) where permitted.

Legal grounds: based on your consent, you may at any time instruct us not to share your Personal Data covered by this Policy with such Third Party Providers where you have previously consented.

1. BUSINESS ACTIVITIES: We may also process your Personal Data and other information if such processing is necessary:

1. to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process;
2. to protect the interests, rights, safety, or property of us or others;
3. to enforce any terms of service on our websites or the terms and conditions of any rental, purchase or utilization;
4. as part of a business transaction where all or some of our assets are bought, sold or otherwise transferred by act of law or contract;
5. to improve our services.

1. WEBSITES:If you use our websites, we may process your Personal Data as follows:

1. Social media: If you participate in certain public features of our websites, apps or social media websites/apps, please note that any information you or others voluntarily disclose through use of such features is made available to the public and/or other users you designate. If you choose to provide access credentials to specific individuals, please be aware that any information you provide to us may be visible to such individuals. We are not responsible for the information that you or others choose to disclose publicly and such information is not subject to this Policy.
2. Links to third parties: We may provide links to third-party websites or may be linked to third-party websites. Since we do not control third-party sites, and we are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing such third-parties with your information.

3. SHARING
4. THIRD-PARTY COMPANIES

We may share your personal data with third parties in the following circumstances:

1. To provide services to you:We will share your personal data among ourselves, our agents, our licensees and other companies to provide you with services, including among others:

2. Disclosure to companies you use:We will also share your information with companies you use in connection with your rental or purchase, including:

3. Protective and legal uses:We may use and share your personal data for legal purposes as we consider necessary or appropriate, including among others:

4. Disclosure to service providers and agents:We may use other companies as our service providers or agents to act on our behalf and assist us in conducting our business, performing services for us under our instruction. These services may include hosting certain websites or databases, operating “apps” for us on social media pages, running contests, sweepstakes and other promotions for us, sending marketing communications, carrying out data analysis and conducting customer satisfaction or other surveys. We will require our service providers and agents to maintain appropriate security standards to protect your personal data and to use the personal data we provide to them only for the purposes we specify and according to law.
5. Disclosure for corporate transactions:We may disclose your personal data to third parties in connection with any contemplated or actual reorganisation, merger, sale, spin-off, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

6. INTERNATIONAL TRANSFERS

Some of the uses and disclosures mentioned in this Policy may involve the transfer of your Personal Data to countries offering different levels of privacy protection than your country of residence or interaction with us, such as when you request rental services to be provided to you in countries outside the European Union (“EU”).

Where our transfer of your data is necessary for the provision of the rental services you have requested, the legal basis for the transfer is the contractual necessity of the transfer, and your Personal Data will be processed by the company providing the services you have requested in accordance with applicable local law and the relevant inter-state agreements.

4. RETENTION & SECURITY

DATA RETENTION

We retain personal data concerning our customers for as long as this is necessary for the purposes of processing or as required by law. We collect Personal Data for various purposes (see above) and may need to retain it for legal reasons (including for tax, civil or other legal regulations) for longer than what is necessary to provide our services. We maintain a data retention policy to cover all the personal data we retain across our systems. If you have any questions about the retention period applying to the personal data we collect about you, please contact us at gdpr@hertz.gr.

SECURITY MEASURES

Information is stored and accessed in various locations, including cloud services. The servers that store information are primarily located in Greece, Europe and the United States, although storage may occur in other locations as well. We use proper technical and organizational measures (a) to protect Personal Data against loss, theft, unauthorized use, disclosure or modification and (b) to ensure the integrity of your Personal Data. To help us protect your privacy, you should maintain the confidentiality of any login and password identifiers or other identifiers or credentials you may have created or been provided for the purpose of using our products, services and websites. As you know, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, e-mail messages, text messages, fax messages and transmissions over the Internet or wireless networks all present possibilities of loss, misuse, interception and unauthorised use of the data transmitted. If you have reason to believe that any account with us is no longer secure, you must immediately contact us.

5. YOUR RIGHTS

You have all the rights according the provisions of the law. In particular, you have the right to access and update your Personal Data covered by this Policy. To do this, you may contact us at the details set out in Section 6 below. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws. If you are a member of one of our membership or rewards programs, you may update the information in your member profile by logging into your applicable member profile.

 Among others, you also have a right to:

1. request rectification of your Personal Data when the information that we hold about you is incorrect or incomplete;
2. object to the processing of your Personal Data for direct marketing purposes, including profiling, to the extent it relates to direct marketing;
3. object to the processing of your Personal Data where our legal basis of such processing is that such processing is necessary for our legitimate interests, without prejudice to any overriding legitimate grounds we may have for the processing;
4. object to automated decision making (including profiling) in certain circumstances;
5. request erasure of your Personal Data in certain circumstances, such as where the processing is no longer necessary for the purpose it was originally collected and there is no compelling reason for us to continue to process or store it;
6. request restriction when processing your Personal Data in certain circumstances, for example, demand that we do not process your Personal Data (other than merely by storing it) following a rental or other transaction with us and that your data only be stored to meet certain legal requirements (e.g. for tax purposes); and
7. receive or instruct us to transmit to another organization the Personal Data you have provided to us, which undergoes automatic processing, where our processing is either based on your consent or is necessary for the performance of a contract or a transaction with you.

In addition, where we process your Personal Data on the basis of your consent, you can withdraw that consent at any time. You may exercise any of these rights by contacting us at the contact details set out in Section 6 below.

6. QUESTIONS & CHANGES

CONTACT US: We carry out business in several countries and aim to comply with the privacy laws applicable to the Personal Data we collect and use. If you have a request about our handling your Personal Data, you may contact us directly via the methods described below. We will work to respond and resolve your complaints in an expeditious manner. You also have a right to file a request with the competent data protection supervisory authority in your jurisdiction.

Contact us by email at gdpr@hertz.gr or at the following address if you have any questions, wish to exercise your access rights or seek other assistance as described above.

General Data Protection Regulation
Autohellas Tourist and Trading Societe Anonyme
31, Viltanioti Street, Kifissia
14564
Attica, Greece

CHANGES: We reserve the right to change this Policy at any time for any reason by posting revisions on this webpage or apps or on other sites. Such changes will be effective upon posting, but will not apply retroactively.