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Privacy Policy and Data Protection

XTRACARS respects individual privacy, places a high value on the trust of its customers and partners, and takes its responsibilities with respect to data security very seriously. 

 

Accordingly, we set out the XTRACARS privacy policy, which explains which personal data we collect, for which purposes we may use them, how we process them, with whom we share them, for how long we store them and the ways you can contact us and exercise your rights.

 

1)      Who is the data controller?

 

GUERIN-RENT-A-CAR (DOIS), LDA, NIPC 501738681, having registered offices at Avenida Severiano Falcão, 3, 2685-379 Prior Velho, participated undertaking of Salvador Caetano Auto, SGPS, SA, NIPC 505185130, having registered offices at Avenida Vasco da Gama, 1410, 4430-247 Vila Nova de Gaia, is the data controller.

 

Because we place great importance on the privacy of the data we process, XTRACARS has a Data Protection Officer, who can be contacted using the email address epd@guerin.com.pt.   

 

 

2)      What information do we collect about you?

 

XTRACARS only collects and processes personal details directly provided by you, either by filling out a contact form or through the acquisition of a XTRACARS product or service which, in general, will be, as applicable: 

 

 

DATA CATEGORY

EXAMPLES

Credentials

Name, numbers and dates of expiry of civil identification documents (and respective images), among others.

Contact details

 

 

Address, mobile phone number, email address, among others.

Data related to work situation

 

 

 Occupation, work situation, among others.

Data related to personal situation

 

 

Date of birth, marital status, household, among others.

Economic and transactional data

 

 

Bank Details, among others.

Customer history

 

 

Responses to Satisfaction Surveys, Order Date, Contract Term, Price, Complaints History, among others.

Platform usage data

Responses to satisfaction surveys, order date, contract term, price, complaints history, among others.

Vehicle usage data

 

 

Number of kilometres, maintenance and servicing record, among others.

Application, Internet and Social Media Data

 

 

Location, use of XTRACARS social media, among others.

 

 

3)      How and why do we use your personal data?

We use your personal data to:

 

PURPOSE

 

  1. To execute and fulfil our pre-contractual and contractual obligations.

 

·         Presentation of commercial proposals.

·         Responses to reservation requests.

·         Conclusion and extension of rental agreements.

·         Among others.

 

  1. To communicate and manage our contractual relationship with you

 

·    Contacting you for administrative and/or operational reasons, ensuring that we correctly manage your relationship with us and we deal with your request and/or order.

·         Recording calls to monitor service performance.

·         Among others.

 

  1. To customise and improve your customer experience

 

·      Contacting you to complete Satisfaction Surveys regarding our services.  We believe that we have a legitimate interest in processing your personal data for these purposes, which we believe is similarly beneficial for you, as it allows us to provide you with better services and ensure the highest possible levels of Customer satisfaction. At any time, you may tell us that you no longer wish to be contacted for these reasons.

 

  1. Marketing

 

·         If you are a Customer of ours, we will use your personal data to email you our news, such as new XTRACARS products, new campaigns and new vehicles and services you may be interested in. We believe that we have a legitimate interest in sending this information, given that it will be similarly beneficial for you, improving your experience and providing access to information that we believe is very much in your interest. 

 

  • If you are not a Customer of ours, we will use your personal data to inform you of offers you may find of interest only where you have given us your express consent to do so, e.g. when you fill in a contact form and tick the relevant box.

 

For these purposes, we may also analyse your user or customer profile, specifically by means of your browsing history and/or purchasing history, to determine your preferences and thus send you customised information.

 

We will also use your personal data to send you updates on mobility products and services offered by subsidiaries of Salvador Caetano Auto, SGPS, SA, where you have given us express and explicit permission to do so.

 

We will not, at any time, share your personal data with other third-party entities for marketing purposes, unless we have your express and explicit consent to do so.

 

If you do not wish to receive marketing messages from us, you can inform us at any time by clicking on the link provided for the purpose at the bottom of any marketing email you receive from XTRACARS. If you prefer, you may inform us of your wish not to receive marketing messages via the email privacidade@guerin.com.pt.

 

  1. To comply with our legal obligations

 

·     Legal obligations to which we may be subject.

·     Response to legal, regulatory or supervisory bodies.

·     Among others.

 

  1. To manage your user registration

 

·         Should you sign up as a user of any application, reserved area or platform owned by XTRACARS, we will need to process your data to identify you as a user of those platforms and enable you to access the different features, products and services at the disposal of registered users.

 

  1. To protect our rights and property

 

·         Verification and confirmation, in conjunction with credit bureaus or other sources, and storage of information regarding any incident resulting in a possible risk in relation to future contracts, in which case your data may also be passed to the Association of Companies for the Hire of Vehicles without a Driver, for inclusion in a database of defaulting customers, and passed to claim recovery companies in the event of any non-performance of the agreement concluded.

 

 

8.       To monitor physical security

 

·         Video surveillance of our premises, where applicable.

·     Among others.

 

 

9.       Disputed Claims Management

 

·         Judicial and extrajudicial recovery.

·         Management of other conflicts.

·         Among others.

 

 

10.   Accounting, Tax and Administrative Management

 

·        Accounting and billing.

·   Tax Information, including the submission of information to the Tax Authorities.

·        Among others.

 

 

XTRACARS undertakes not to use the information relating to your personal data for any purposes other than those described above.

 

4)      How do we keep your personal data safe, and for how long do we store your data?

 

We have implemented technical and organisational measures to protect your personal data from accidental or unlawful destruction, accidental loss, alteration, dissemination or unauthorised access.

 

The time limit for storage of your data will depend on the purposes for which they are processed, i.e. we process your data for the time strictly necessary to fulfil the corresponding purpose and we may subsequently store them, duly saved and protected, for the period of time in which responsibilities arising from their processing may arise, while observing prevailing law at all times.

 

With respect to our Marketing updates, please be informed of the following:

 

·         If you have given your consent for Marketing purposes, your personal data will be retained for a maximum period of 24 months from receipt of your consent, or 60 months after acquiring a XTRACARS product and/or service, provided that, during this period, you do not withdraw your consent;

·         If you are our customer and you have a legitimate interest in receiving email messages, we will store your data until such time as you tell us that you no longer wish us to do so, by clicking on the link provided for the purpose at the bottom of any marketing email you may receive from XTRACARS.

 

Should you make any payment using one of the XTRACARS platforms, your payment will be redirected to our payment management partner who will be duly identified at that time, this entity becoming the Data Controller in relation to your personal data for this specific purpose of paying for a product/service. Any operation involving choosing the means of payment to be used and entering the data inherent to the payment process is properly protected. The information concerned is encrypted and managed with the most advanced security tools currently available.

 

Should you require further clarification regarding the security measures implemented, as well as the specific deadlines for data retention, please send an email to privacidade@guerin.com.pt.

 

 

5)      With whom do we share your personal data?

 

Your personal data are processed with the utmost confidentiality and are used solely and exclusively for the purposes identified.

 

XTRACARS guarantees that it will never sell, loan or transfer your personal data to third parties without your express and explicit consent to this effect.

To guarantee proper processing of your requests and to guarantee you the best possible service, your personal data may be shared with our partners or service providers, e.g.:

 

·         Financial Institutions

·         Providers of technological services

·         Providers of services related to customer support.

 

XTRACARS hereby guarantees that these entities also implement technical and organisational measures to guarantee the total protection of your personal data and that they will only process your data for full fulfilment of the purposes inherent to performance of the agreement.

 

XTRACARS may also transfer your personal data to (i) EAN Data Services UK Ltd, (ii) Enterprise Holdings, Inc. and/or any subsidiary (for further details, please consult the EHI Privacy Policy at https://www.enterprise.co.uk/en/privacy-policy.html ) ("EHI”), which all act as independent data controllers.

 

EHI may process your personal data for the following purposes:

·         to manage the rental and business relationship, to communicate with you or to assist you during the rental;

·         to store your data relating to any incident involving you in cases where, as a result of such incident, it is considered that there may be a risk for future rental agreements;

·         for the purpose of carrying out satisfaction surveys;

·         to send you marketing updates regarding similar products or services that EHI believes may be of interest to you, including targeted messages on the EHI and partner websites and on social networks, where you have given your explicit consent to this effect;

·         to compile statistics and analyses of your use of EHI products and services, including statistics based on anonymised data, which enable EHI to offer you and other customers better services, products and features in the future;

 

EHI is responsible for processing data received under the principles of the Privacy Shield between the USA/EU. For further information regarding compliance with the data transfer rules, or if you have any questions in relation to the privacy or use of your personal data that have not been answered by EHI, the EHI Privacy Policy may be consulted for further information regarding how to resolve this issue.

 

If your personal data have to be shared with entities that are not located within the European Economic Area, XTRACARS guarantees that they are required to comply with European legislation on the protection of personal data, namely through the conclusion of international data transfer agreements with standard contractual arrangements for that purpose.

 

Should you require further clarification regarding the exact recipients of your data and the specific safeguards applied to the transfer of your data, please send an email to privacidade@guerin.com.pt.

 

6)      What are your rights?

 

At any time and free of charge, you are entitled to ask XTRACARS to:

. provide access to the data you have given us

. edit your data

. delete your data

. restrict the processing of your data

. refrain from processing your data

. arrange the portability of your data in relation to such entity as you may indicate.

 

If you have given us your consent to process your data for any purpose, you are also entitled to remove that consent in any

 

To exercise any of the rights mentioned or for any further clarification on the processing of your personal data by XTRACARS, please send an email to privacidade@guerin.com.pt.

 

Should you exercise any of the aforementioned rights, XTRACARS will analyse your request and respond within a maximum period of 1 (one) month.

 

Please note, however, that if there is any prevailing legal standard or obligation that supersedes these rights, XTRACARS shall respond accordingly, indicating the respective grounds that prevented such action from being taken.

 

 

7)      How can I make a complaint?

 

If you are dissatisfied with the manner in which your personal data is being processed by XTRACARS, please send an email to privacidade@guerin.com.pt.

 

If you remain dissatisfied, you are entitled to submit a complaint directly to the National Data Protection Commission, as follows:

 

National Data Protection Commission - CNPD

Tel: +351 213928400

Fax: +351 213976832

Email: geral@cnpd.pt

 

 

8)      What are cookies?

 

"Cookies” are small pieces of data that are stored on your computer or smartphone through your browser or application. They only hold information related to your preferences and, as such, do not make use of your personal data.

 

XTRACARS uses cookies on its websites, apps and social networks to improve performance and Customers’/Users’ browsing experience, increasing, on the one hand, speed and efficiency of response and, on the other, eliminating the need to enter the same information repeatedly.

 

Cookies may be:

 

·         Essential, allowing you to browse the website and use your applications, as well as access secure and reserved areas, helping to improve, through the collection of anonymous information, the way the websites and applications work, as well as understanding what is of interest to our users. We use these cookies, inter alia, to remember the information entered into forms and to register visits for statistical processing. Acceptance of these cookies is a condition for using our websites and applications.

·         Functional, allowing user preferences to be remembered for browsing websites or using applications, so you do not need to reconfigure and customise them every time you visit and use them. We use these cookies, inter alia, to check if the website is displaying consistent information and to remember if we have already asked if you want to register on a form. You may at any time control whether or not these cookies are used by adjusting the settings of your browser or application.

·         Advertising, allowing advertising to be directed according to the interests of each user, to allow advertising campaigns to be directed according to browsing habits and allowing connections to social networks, such as Facebook, YouTube and Instagram, among others, in order to also direct advertising on those websites. We use these cookies, inter alia, to share information, to allow the sharing of content on social networks, as well as to question you regarding the advertising or campaigns on our websites. You may at any time control whether or not these cookies are used by adjusting the settings of your browser or application.

 

Should you require further clarification regarding the settings and our cookie policy, please send an email to privacidade@guerin.com.pt.

 

9)      Any questions or comments?

 

We welcome questions, comments and requests regarding privacy and your personal data, which should be sent to privacidade@guerin.com.pt.

 

To ensure that the information we hold about you is up to date, please contact us at privacidade@guerin.com.pt in the event of any change to your personal data.

 

Any updates to this privacy policy will always be made available at www.guerin.pt

 

 

10)   Amendments to the Privacy Policy?

 

 

XTRACARS reserves the right to change or update this Privacy Policy at any time, duly reflecting these changes on this Platform.