Privacy Policy

We are The Hertz Corporation, its rental businesses and subsidiaries operating under the Hertz, Hertz 24/7, Dollar, Thrifty and Firefly brands (together “we”, “us”, and “our”). This policy does not cover our licensees or affiliates or other third parties through whom you may interact with us. This is a high level summary to explain how we collect, processes, store and otherwise use information about you and your rights in relation to that information. For full information, please see the full policy below.

THE HERTZ CORPORATION EU CUSTOMER PRIVACY POLICY

SCOPE & CONTROLLERS

We are The Hertz Corporation, a U.S. company, and those of its subsidiary companies which operate in Europe (see the table below) to provide vehicle rental services to our customers under the Hertz, Hertz 24/7, Dollar, Thrifty and Firefly brands (together “we” , “us” , and “our”).

Together we are the data controllers for the purposes of this Privacy Policy (“the Policy”).

We also use a network of licensees in provision of our services worldwide and are affiliated to many other companies through ownership. As our licensees, affiliates and entrusted third-party vendors are independent companies, they are not owned or controlled by us and are not covered by this Policy. We are not responsible for the privacy practices of our franchisees, licensees and other third parties with whom you may transact.

This Policy covers the information we collect about you in connection with our vehicle rental businesses, which identifies, or can be used to identify, you as an individual (“Personal Data”). It does not apply to information that cannot reasonably identify you. For example, but without limitation, aggregated anonymous data are not Personal Data.

We respect the privacy rights of our customers and are committed to protecting your privacy. This Policy explains our data handling practices with regard to your Personal Data, as well as your rights associated with that data.

1. COLLECTION

We collect Personal Data that you provide on our websites, on third-party websites, on applications and offline 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, discount sponsors, licensees, advertisers and booking channel providers. For further details, see below:

1. THE TYPES OF INFORMATION COLLECTED may include, but are not limited to:

Personal information:

Technological information:

Vehicle Rental Information:

Vehicle-related information (telematics):

We may use in-vehicle data systems to collect data about the vehicle’s condition and performance (including mileage, fuel and other operational data) and the driver’s operation of the vehicle during their rental for safety, security and claims management reasons and may retain this data as necessary for these purposes.

We may also have the ability to track the vehicle’s location throughout the duration of a rental, although we will only access this information in circumstances where the driver is in breach of the rental agreement, by failing to return the vehicle on time or by driving into unauthorised territories.

Sensitive data:

We may collect certain Personal Data that constitutes sensitive data in some countries, such as data about (i) health conditions (for instance, if you ask us to accommodate a disability, such as by provision of hand controls, or if there is an accident and we need to work with insurance and claims management companies relating to any injury you may incur) or (ii) membership of a trade union (or similar organization) if you use a CDP Number that only members of that union or organization can use. Depending upon applicable local law, we may be unable to process such sensitive data without your consent.

Please note that if you wish to rent with us or our licensees and need to provide sensitive data, we will use that sensitive data for our operational uses as described in this Privacy Policy, subject to your consent where required under applicable law.

1. METHODS AND SOURCES OF DATA COLLECTION may include, but are not limited to:

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 which let you navigate between pages efficiently, remember your preferences, help us understand how this website is performing and generally improve your browsing experience. Cookies can also help to ensure the advertising you see online is more relevant to you.

Generally, our cookies may perform the following functions:

If you would like to disable cookies or change the cookie settings on any of our websites, please go to the Manage my cookies link at the bottom of the webpage for full information and to record your preferences.

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

Apps

With regard to mobile apps, any app’s collection and use of Personal Data that is materially different from what’s described in this Policy will be supplemented by an individual privacy policy that will require acceptance for that specific app.

As the internet and other eCommerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.

Offline 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 from you may be required due to a statutory or contractual obligation, provided 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 this may result in disadvantages to you. In particular, we may not be able to rent to you. However, unless otherwise stated, not providing your Personal Data will not result in legal consequence for you.

2. PURPOSES

Below we have set out the various purposes for which we process your Personal Data. We have 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 to perform other activities related to such services or products, including billing and collection following a rental, or to communicate with you regarding (i) any reservation you initiate or rental transaction; (ii) your membership/status in one of our membership programs; or (iii) changes to the terms or features of any of our membership programs to which you belong.

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 personal information to provide you with marketing information, special offers and promotions through a variety of means, including email, in accordance with applicable laws.

Legal basis: based on your consent. However, to the extent permitted by law, we may lawfully use your personal information to send you such marketing communications (including by email) where it is necessary for our legitimate interests. This includes products and services, special offers and promotions 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 the unsubscribe link in each e-mail message. Please note that if you exercise these choices, 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 this process may take some time to complete, consistent with applicable law.

1. 
   THIRD PARTY MARKETING:We may also share your Personal Information with a sponsor or other third party who may provide you with special offers or promotions that may be of interest to you (“Third Party Providers”), where permitted.

Legal basis: based on your consent. You can instruct us at any time not to disclose your personal information covered by this Policy to such third parties, even if you have previously consented to this.

Please note that (i) this process may take some time to complete in accordance with applicable law; and (ii) that even after such process has been completed, your personal and other information may continue to be shared with CDP sponsoring companies (see below), our affiliates (including affiliated websites under common ownership and control), and designated service providers in accordance be forwarded with this policy.

1. 
   PURPOSES RELATED TO OTHER THIRD PARTIES:As part of our Services, we have partnered with third party organizations who sponsor a special discount code (called a CDP [Customer Discount Program Number]) and customer, employee, or other number that you provide to the completion of a rental or purchase (“ Sponsorship Organization“). Because of our relationship with these sponsoring organizations, we may be required to provide this information about you and your use of our Services in connection with your relationship with these organizations, such as (i) to confirm your eligibility to rent with these numbers, (ii ) to determine your compliance with the rules established by the sponsoring organization for the use of the numbers, or (iii) to enable them to pay your rental costs. If you do not want us to share relevant personal information with the sponsoring organization for these or other disclosed purposes, you must not use the number associated with it.

Legal basis: performance of our contract with you when you use a CDP, member, employee or other number.

Sponsoring organizations may have different privacy practices than we do. Therefore, we recommend that you read the sponsoring organization’s privacy policy for the purposes for which they are using your information. Because we do not control the privacy practices of the sponsoring organization, they may differ from ours. Because of your relationship with the sponsoring organization, they may use personal information they receive from us for the purposes set out in their privacy policies or similar communications, including authorizing their agents to receive and process your information on their behalf.

1. 
   NORMAL COURSE OF BUSINESS:We may also process your Personal Data and other information if such processing is necessary:
2. to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process;

Legal grounds: where it is necessary for compliance with a legal obligation to which we are subject.

ii.to protect our interests, rights, safety, or property as well as the legitimate interests, rights, safety or property of others;

Legal grounds: where necessary for our legitimate interests or that of a third party to protect such interests, rights, safety and property. For example, in defense of claims brought against us in connection with your rental of our vehicle;

iii. to enforce any terms of service on our websites or the terms and conditions of any rental, purchase, or utilization;

Legal grounds: for our legitimate interests, which are to protect us and enforce such terms of service or terms and conditions.

1. 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; and

Legal grounds: for our and third parties’ legitimate interests.

1. to operate our systems properly.

Legal grounds: for our legitimate interests, which are the proper running of our systems and our business in order to provide our products and services to you and other customers.

1. TELEMATICS:We may use in-vehicle data systems to collect data about the vehicle’s position, condition and performance during your rental. Use may include:

i.to collect data relating the vehicle’s condition and performance during the rental (including vehicle damage, mileage, fuel use and other operational data) to improve the accuracy of our billing processes on return of the vehicle;

Legal grounds: for our legitimate interests to ensure accurate charging for your uses of the vehicle, including for fuel and damage, during your rental.

ii.to collect data relating to the driver’s operation of the vehicle during the rental for safety, security and claims management reasons, including to contact the renter if the data suggests there is a security, safety or operational issue that we need to bring to your attention.

Legal grounds: for our legitimate interests to enable us to defend and manage claims arising out of accidents involving the rental vehicle; to ensure we meet our safety and security obligations in relation to the vehicle and each rental;

iii.to track the vehicle’s location throughout the duration of a rental in order to access such information solely where the driver is in breach of the rental agreement (by failing to return the vehicle on time or by driving into unauthorised territories) or to assist in the defence and management of claims following an accident involving the vehicle.

Legal grounds: for our legitimate interests to protect our assets, enforce our terms and conditions and defend and manage claims.

iv.to track the vehicle to enable us to provide information to you as you drive about areas of historic or leisure interest, restaurants, service or fuel stations or other places or services of interest;

Legal grounds: on the basis of your consent.

v.to share with you, your employer or others information about your driving performance (such as speed) during your rental;

Legal grounds: with your consent to each specific use requested.

1. WEBSITES:If you use our websites we may process your Personal Data as follows:
2. Aggregated or anonymized information:We may share with other third parties aggregate or anonymized information about our website users, such as your use of this website or other websites, and the services provided on this website or other websites, as well as any rental, purchase, or utilization information.
3. 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, becomes available to the public and/or other users whom you have designated.

If you choose to provide access credentials to designated 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.

iii. Links to third parties: We may provide links to third-party websites, or may be linked to from 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 applicable third-parties with your information.

3. SHARING
4. THIRD PARTY COMPANIES

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

1. To provide you with Services:We share your Personal Data among us, our agents, licensees and other companies to provide you with Services, including to:

1. Disclosure to companies you use:We also share your information with companies you use in connection with car rental, including:

iii. Safe and Lawful Uses: We may share and disclose your personal information for legal reasons that we believe are necessary or appropriate, including to:

1. Disclosure to Our Service Providers and Agents:We may use companies other than our service providers or agents to act on our behalf and to assist us in conducting our business and providing services to us under our direction. These services may include: hosting certain websites or databases, operating “apps” for us, on our social media network pages, conducting sweepstakes, contests and other promotions for us, sending marketing communications that Conducting data analysis and customer satisfaction surveys or other research. We will seek to require our service providers and agents to use reasonable standards of security to protect our personal information and to protect the personal information
2. Disclosure for Corporate Transactions:We may disclose your personal information to third parties in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with bankruptcy or similar proceedings).
3. INTERNATIONAL TRANSFERS

Some of the uses and disclosures set out in this Policy may involve the transfer of your personal information to different countries around the world, which may have different levels of data protection than the country in which you reside or interact with us, for example if you provide vehicle rental services in a country outside the European Union (“EU”) request.

Where our transfer of your data is necessary to provide the vehicle rental services you have requested, the legal basis for the transfer is a contractual necessity for the transfer. Your Personal Data will be processed by the company providing the services you have requested in accordance with applicable local laws.

When we transfer your personal information to a third party outside the EU and no legal basis applies, such as when we transfer the information to a company who will process it on our instructions in order to be able to provide our services, we will ensure that the necessary safety precautions for the transfer are in place. These include that (i) the company receiving the data is located in a country recognized by the EU as a country with adequate security measures; (ii) that if the transfer is to the United States, the receiving company participates in the EU-US Privacy Shield (see below); or (iii) we have EU-approved standard contractual clauses in place with the recipient to protect the data.

1. EU-US Privacy Shield Framework:We may store your personal information on servers located primarily in the United States. The Hertz Corporation and its US affiliates (individually and collectively, the “Company”) participate in the Privacy Shield. The Company’s participation applies to Personal Data inbound into the United States from the EU. We are committed to handling such EU Personal Data in accordance with the Privacy Shield Principles, including notice, choice, responsibility for onward transfer, security, data integrity and purpose limitation, access and recourse, enforcement and liability. For more Privacy Shield notices, visit the US Department of Commerce’s Privacy Shield Listing at www.privacyshield.gov
2. 
   EU Standard Contractual Clauses:When we transfer personal information outside of the European Economic Area to companies or other organizations in the US that do not participate in the Privacy Shield, or to a country that does not have an adequacy authority from the EU Commission, we implement the EU-approved ones Standard Contractual Clause to ensure your personal information is protected. You can request a copy of these Standard Contractual Clauses by contacting us as set out in Section 6 below.
3. RETENTION & SECURITY
4. DATA RETENTION
   We retain personal data about our customers for as long as we believe is necessary for the purposes for which it was collected, or unless otherwise allowed or required by law. We collect Personal Data for a number of purposes (see above) and may be required to retain it for legal (including tax) reasons for a period which is longer than the time we need or use the data for the purpose of providing our rental services to you. 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 (see Section 6).
5. SECURITY MEASURE

Information is stored and accessed in various locations and cloud services. Servers which store information are primarily located in the United States and Europe, although storage may occur in other locations as well. We use reasonable administrative, technical, personnel, and physical measures (a) to safeguard 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 secrecy of any logon IDs and passwords, Member numbers, or other identifiers or credentials you may have set up or were provided with in connection with your participation in or use of our products, services, or websites.

1. TRANSMISSIONS
   As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted. If you have reason to believe that any account with us is no longer secure, you must immediately contact us.

We try to strike a balance between the security of your data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative. For example, but not limitation, we may send you an e-mail or a text message in unencrypted form (i.e. instantly readable) because many of our customers are unable to access encrypted (i.e. coded) e-mail or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. Such messages may contain Personal Data. Please do not include confidential information, such as your credit card number or account passwords, in any e-mail or text you send to us or on any posting you make to a public area of a third-party social network page, especially since any such posting immediately becomes public. For a more secure way to communicate with us over the Internet, please click on the “Contact Us” link on any of our websites.

5. YOUR RIGHTS
6. You have the right to request access to, review, and update your Personal Data covered by this Policy, and can request this by contacting 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.
7. You also have the right to:

i.request rectification of your Personal Data where the information that we hold about you is incorrect or incomplete;

1. object to the processing of your Personal Data for direct marketing purposes, including profiling to the extent it relates to direct marketing;

iii. object to the processing of your Personal Data where our legal basis for that processing is that such processing is necessary for our legitimate interests, subject to any overriding legitimate grounds that we may have for the processing;

1. object to automated decision making (including profiling) in certain circumstances;
2. request erasure of your Personal Data in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for and there is no compelling reason for us to continue to process (or store) it;
3. request restriction of your Personal Data in certain circumstances, such as that we do not process certain of your Personal Data (other than merely by storing them) following a rental in circumstances where all matters relating to the rental have been completed and the data is being stored only to meet certain legal (e.g. tax) requirements; and

vii. receive (or ask us to transmit to another organization) your Personal Data that you have provided to us which we process by automated means where our processing is either based on your consent or is necessary for the performance of a contract with you.

1. In addition, where we process your Personal Data on the basis of your consent, you can withdraw that consent at any time.

You can make a request to us to exercise any of these rights by contacting us as set out in Section 6 below.

6. QUESTIONS & CHANGES
7. CONTACT US: We do business in many countries and aim to comply with the privacy laws applicable to the Personal Data we collect and use. For our cross-border processing activities, we have designated Hertz Europe Service Centre Ltd (IE) as the entity for such activities. Should you have a concern or complaint about our handling of 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 the right to lodge a complaint with a competent data protection supervisory authority in your jurisdiction.

Please contact us by emailing euprivacy@hertz.com or writing to the address below if you have any questions, wish to exercise your rights of access, or seek other assistance as described above.

Data Protection Officer
Hertz Europe Limited
11 Vine Street
Uxbridge, Middlesex,
UB8 1QE, UK

EU Customers SAR Handling Team
Hertz Europe Service Centre Ltd
Swords Business Park
Co. Dublin, Ireland

For any other questions regarding Customer Support, please contact us by clicking here.

1. 
   CHANGES: We reserve the right to change this Policy at any time for any reason by posting revisions on this webpage or on applicable apps or other sites. Such changes will be effective upon posting, but will not apply retroactively. Whenever we make a material change, we will note the date of such update in the introductory page above, and post a note on the home page of our applicable websites.