Data Protection Policy 2018
Context and Overview
- Policy Prepared by: Suki Sanghera
- Approved by management on: 17/05/2018
- Policy operational on: 25/05/2018
- Next Review Date: 25/05/2018
Why this policy exists
- Complies with data protection law and follow good practice
- Protects the rights of staff, customers and partners
- Is open about how it stores and processes individuals’ data
- Protects itself from the risk of a data breach
Data Protection and the Law
The Data Protection Act 1998 describes how organisations including Terminus Contract hire must collect, handle and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully.
The Date Protection Act is underpinned by eight important principles. These say that Personal Data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than necessary
- Processed in accordance with rights of data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area (EEA), Unless that country or territory also ensures an adequate level of protection
The Types of 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 store locations. When you are asked to provide personal information, you may decline. If you choose not to provide the information, you may not be able to use some products or services. The personal information we may collect includes:
- Your name, contact information, date of birth, driver’s license number, start and expiration date, Group class, National insurance number and emergency contact information;
- Vehicle rental information, including the location of where the vehicle is rented, date of rentals, type of rental and your preferences;
- Your credit card details, Terminus Contract hire online user account details, membership, passport information .
- Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;
- Photographs of you and your driver’s license or your receipts through camera features available at our branches ,websites or via email;
- Financial information that may be necessary to facilitate the purchase or lease of a vehicle from a Car Sales or Fleet Management location;. (Additional notices will be provided to you at the time of that transaction).
- Additional contact information about you that we may obtain through third parties with whom we do business (BVRLA RISK, PRO Hire Risk and HireGuard)
With your consent, we may access location-based information or collect location markers from your mobile device or based on your IP address. We may use this information to provide you with notifications related to our locations, return information, local offers or other information that may 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. If you have allowed us to utilise your location information in the past and wish to revoke the permissions, please change the settings on your device.
If permitted by law, in certain areas of our sites, we provide you with the ability to enter your friend’s name and contact information in order for us to send your friend a one-time email inviting him or her to visit the sites. We also provide you with the ability to enter a friend’s or another individual’s name and contact information in order to make bookings for that friend or other individual. You must have obtained the consent of your friends before making such submissions. The information you provide will not be used for any further marketing purpose unless your friend requests services or we otherwise obtain consent from that person. Please be aware that when you use any send-to-a-friend functionality on our sites, your name and email address may be included in the communication sent to your friend.
Information Collected and Stored Automatically
What are cookies and pixel tags?
‘Cookies’ are short strings of text sent to your web browser when you visit a website, which may be “session-only” or “persistent” last for more than one visit to allow a visitor to personalise their experience.
‘Similar technologies’ refer to features which perform a comparable function to cookies although they are technically different.
‘Pixel tags’ are small blocks of code on webpages or in our emails that allow us to read and set cookies. Pixel tags are often used in connection with cookies to help operate our websites and emails, and collect information about online activity.
Why do we use these technologies?
Vehicle Operation and Location Data
Our vehicles may be equipped with a vehicle telematics system provided by the manufacturer or other (“Telematics System”). Some or all Telematics System functionality may or may not be active during rental periods. Telematics Systems may provide us with use of, disclosure of or access to (1) location information, (2) crash notification and related crash data and (3) operational condition, mileage, diagnostic and performance reporting of vehicles (“Telematics Data”), as permitted by law.
If you choose to use the Telematics System (Vehicle Navigation), 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.
Our websites and online marketing are not directed to, and Terminus Contract hire does not knowingly collect personal information from, children under the age of 18 or your country’s age of minority. 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 email us at firstname.lastname@example.org
How We Use This Information
We use the information we collect for the following purposes:
- To assist the transactions that you request, such as reserving and renting motor vehicles.
- To provide customer service related to your interactions with us or to respond to your inquiry.
- To verify your identity for fraud prevention purposes. We do not store this information for any other reason.
- To contact you regarding an incomplete online membership form or reservation.
- To contact you about a citation or claim.
- To provide you with discounts, coupons, sweepstakes, offers and other information, opportunities and services that may be of interest to you. You may receive these offers in advertising via third-party sites and media properties, including on social media. You may be able to opt out of these ads by clicking on an icon in the ad or through the privacy settings in each media property.
- 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.
- To compile statistics and analysis about our customers’ use of our websites, products and services, which statistics are only used to enable us to provide better customer service, products, features and functionality to you and other customers in the future.
- To protect our rights and property.
We retain information we collect for commercially reasonable periods of time or in accordance with specific laws or policies. Information collected for a specified purpose will only be used for that purpose and, after a reasonable period of time, will no longer be actively stored when that purpose has been fulfilled. Inactive data may, however, continue to be used for statistical,
marketing, archiving and other analytical purposes.
How Your Information May Be Shared
We may disclose the information we collect from and about you for the purpose of providing the transactions you have requested and (with your consent) for marketing purposes. In addition to those stated within this Policy, Telematics Data from rental vehicles may be disclosed to, accessed by or used by Terminus Contract Hire, emergency service providers, others who may assist in responding to an accident, telematics service operators or those with whom we have a legal or contractual obligation to provide such data.
We also may disclose your information to other third parties:
- when required by law or in response to legal process;
- without legal process in response to a request from law enforcement relating to a criminal investigation;
- to protect our rights, privacy, safety or property, or that of the public;
- for administrative or technical support or other business purposes to facilitate our transactions with you (i.e. for your insurance replacement, corporate rental or through one of our partners);
- to analyse our data, conduct mobile analytics services or to maintain and improve our services (subject to confidentiality agreements as appropriate);
- to permit us to pursue available remedies or limit damage that we may sustain;
- to enforce the terms of any rental agreement or our websites’ terms and conditions;
- if the rights of another individual might be violated and;
- otherwise with your consent.
We may disclose your personal information to third-party service providers (such as a payment processor to bill you for goods or services, an email provider to send email communications to you on our behalf or the provider of our live chat feature in order to offer you customer service). These service providers may be located in a country different from your country of residence, such as the United States or a European Union member country. These service providers are contractually required to maintain the confidentiality and security of your information. However, your information may be accessible to authorities in accordance with applicable laws.
We may also share aggregated or de-identified information about our customers with our advertising and marketing partners, and third-party media properties, including social media sites to allow them to send targeted advertising messages on our behalf.
We may post customer testimonials/comments/reviews on our websites which may contain personally identifiable information. We will obtain your consent via email prior to posting the testimonial. To request the removal of your testimonial, please contact us through one of the methods listed below in the contact us section on our website
Data Security and Integrity
The security of the information you provide is very important to us and we try to provide secure transmission of your information. For certain transactions on some of our websites, we may use Secured Sockets Layer (SSL) technology to secure the transfer of information. While we strive to protect your personal information, we cannot guarantee the security of any data transmission over the Internet. Once we receive your information, we take steps that we believe are reasonably appropriate to protect it from loss, misuse, unauthorised access, disclosure, alteration and destruction to ensure the data’s integrity. We use a combination of technological, physical, administrative and organisational controls as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your data.
If you have a user name and password for any of the features on our websites, you are responsible for keeping your password secret. You should not reveal your password to anyone. We will not ask you in an unsolicited telephone call or email for your password. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.
Global Data Transfers and Processing
We will use your information in the country in which your service and transaction occurs. Please be aware that, unless prohibited by law, your use or continued use of our websites and mobile applications signifies your express consent that information may be transferred to or stored on servers and processed outside the country of your residence. Please also be aware that the privacy laws of the United States or other countries where information may be stored may not be as comprehensive or offer as much protection as the laws of other countries including your country of residence. You may request us not to make such transfers, but if you do, we may not be able to provide some or all of our products or services to you.
Terminus Contract Hire along with our third party agent ProHire PLC are responsible for the processing of personal date it receives. Prohire PLC ( a software programme and associated database used for independent car and van rental businesses) uses a duel firewall and takes extra precautions to keep our and your data safe. The Data received is stored in a locked place on site and is only accessible to a few select members of staff. Each account is password Protected and has an up-to-date Microsoft antivirus program which is updated daily. All these measures are in place to ensure the privacy and safety of all customers private data.
Changes to this Policy
The accuracy and completeness of the information we collect is very important to us and we make efforts to ensure that the information we have is accurate and up-to-date. In addition to the options provided to you in this Policy, if you wish to opt out of direct marketing or review, amend, correct or update personally identifiable information we have collected about you, contact us using the information provided below. For email marketing please use the unsubscribe link located at the footer of each email.