Privacy policy related to personal data processing

Enterprise Holdings, Inc., through its independent regional subsidiaries (collectively “Enterprise Holdings”) and network of independent franchisees and fulfillment partners operating the Enterprise Rent-A-Car, National Car Rental, Alamo Rent A Car brands provides global reservation and rental management services.  This site is for an authorized franchisee.  For data sharing and global booking practices of Enterprise Holdings, see the Enterprise Holdings Global Privacy Policy.

For information about the privacy practices of the authorized Franchisee for this country, please see below.

We, Enterprise Romania, respect the privacy of all our customers and we will treat/process personal data very carefully, in proper technical and organizational security conditions. Therefore, we will dedicate all the necessary resources and efforts to process your data in full accordance with the (EU) Regulation 2016/679 (“General Data Protection Regulation” or “GDPR”), as well as with any other law applicable on Romanian territory.

By this document we want to inform you about the manner in which we collect, use, transfer and protect your personal data when you interact with us in relation with our products and services, also by means of our website or our consultants.

We reserve the right to update and modify this Privacy Policy from time to time, in order to reflect any changes in the processing of your personal data, or any other amendments of the legal requirements. In the event of such change, we will post on our website the amended version of the Privacy Policy, therefore we ask you to review periodically the content of this Privacy Policy.

Who we are

Enterprise Romania is the commercial name of the company TOURING RENT AUTO Ltd., a Romanian legal person, whose main business object is the rental and leasing of cars and light road vehicles, and secondary businesses include trade in cars and light vehicles, car maintenance and repairing, activities of insurance agents and brokers.

TOURING RENT AUTO Ltd. has its registered office in Bucharest, District 1, 5A, Al. I Cuza Boulevard, correspondence address in Bucharest, 3-5, Reinvierii Street, Europa Primex Building, ground-floor, with the single European Registration and Identification Number ROONRC.J40/3879/2001, Fiscal Code RO 13831826, duly represented by Mr. Anastasiu Michael-Dragos, in his capacity of Administrator.

Enterprise Romania is a franchise of Enterprise Holding Inc, 600 Corporate Park Drive, St. Louis, MO 63105, United States.

We are open to find out your opinions, as well as to provide you with any additional information that you might need regarding the processing of you data. In this respect, we encourage you to contact our Data Protection Officer at the e-mail address dpo@enterprise.ro or by post or courier at the address in Bucharest, 3-5 Reinvierii Street, Europe Primex Building, District 2 – with the subject: to the attention of the Data Protection Officer.

What information we collect

Information Collected About You.

In order to provide the requested services, we need your following data:

• Surname and given name(s)

You will provide us with some information in connection with a transaction or in your interaction with our website and at our locations. We collect the following types of personal information from you:

• Your name, contact information, date of birth, driving license number and expiration date, and emergency contact information;

• Vehicle rental information, including the location of where the vehicle is rented, date of rental, type of rental and your preferences;

• Your credit card details, online user account details, membership/corporate ID numbers, passport information and frequent flyer or travel partner affiliations.

• E-mail address

Since we are a franchise of Enterprise Holdings, Inc. and/or its subsidiaries („Enterprise”), Enterprise can give us access to information regarding your booking and data. For such transactions, we and Enterprise are independent data controllers. In addition, Enterprise has access to your data, as explained below in the section entitled „Whom We Share Your Information With”.

Third parties provide us with additional information about you. There can be the following categories of partners, including:

• Referral Sources, such as third party online booking sites (who provide us general contact information and a booking confirmation number to facilitate the rental), your employer (general contact information) and your insurance provider (general contact and policy information).

• Hotel, airline and membership clubs, who provide us your general contact information and booking information.

• Credit reporting agencies, who, for fraud prevention purposes, provide us with identity-related information.

• Service Providers, such as customer support (customer service-related information and enquiries made by you), marketing providers (information to assist us to better communicate our products and services).

Vehicle Operation And Location Data

The vehicles may be equipped with:

(i) emergency notification functions such as an eCall system and (ii) telematics systems and infotainment („Telematics Systems”), which are independently controlled by the producer (“OEM”) of your vehicle.

The eCall system is provided in order to be sure that both you and your passengers receive assistance in case of accident. If a vehicle has been declared, or there are suspicions that it might be stolen or lost, we will request access to the data of the telematics system from its producer. Producer’s contact data and the required confidentiality agreement, which may include system and service limitations, warranty exclusions, limitations of liability, description of use, right to access and register information, your individual rights and any data regarding the transfer outside the European Economic Area may be found on producer’s website or by accessing the vehicle dashboard.

When you use satellite navigation or the infotainment system of this vehicle, you are responsible for any piece of information stored in systems after using the vehicle. We cannot guarantee the privacy or confidentiality of such information and you must wipe it before you return the vehicle to us. Otherwise, the next user of the vehicle will have access to it.

Children’s privacy

• We do not collect personal information regarding children.

How we use information about you

We use the information we collect from you or about you to provide you with our services and for the following purposes:

• Where it is necessary for us to enter into a contract with you and provide services to you for the duration of the contract, including

• To assist the transactions that you request, such as reserving, renting, purchasing or leasing motor vehicles.

• To provide customer service related to your interactions with us or to respond to your enquiry.

• Where necessary for us to comply with a legal obligation, including

• To share information about your vehicle’s location with emergency services in the event that you are involved in a road accident.

• To share information with government and regulatory authorities when required by law or in response to legal process, obligation or request.

• Where it is necessary for our legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, including

• To communicate important information about your rental, such as arrival and return alerts.

• 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.

• To develop a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you.

• To protect our legal rights and manage the security of our networks and property. For example, we will use CCTV to ensure the security of our premises and we maintain Do Not Rent lists of customers that are non-payment or safety risks.

• To share your information with third parties in order to prevent fraud and protect our business interests and rights, privacy, safety and property or that of the public. We will do this to collect unpaid bills, to avoid liability for penalties you incur (e.g. fixed penalty notices for driving offences) and for claims processing purposes.

• To share your information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any rental agreement or our websites’ terms and conditions.

• Where you have given consent, including

• To allow us to use telematics.

• To send you certain promotional or targeted marketing communications, opportunities and services that might be of interest to you.

• To send you text messages (SMS) in order to provide you with time-sensitive communications related to your transaction (e.g., construction delay at airport branch), extended rental opportunities, customer experience surveys, marketing promotions such as coupons, discounts, last-minute specials or loyalty and rewards information.

You can exert your option regarding such a processing by selecting/ticking the relevant boxes from the forms/documents used for collecting personal data.

No matter the case, if at a certain moment you want to stop the processing of your personal data by Enterprise Romania, you can anytime ask us to stop any data processing.

At the same time, you can unsubscribe anytime, by using the button “Dezabonare” or „Unsubscribe”, if you don’t want to receive newsletters or information stuff from us anymore.

Retention of Your Personal Information

We retain your personal information for as long as we need to fulfill our business purposes for a period of 10 years.

Whom we share information with

Affiliates

We share the information that we collect about you with our affiliates (“The Affiliates”) in order to release documents or facilitate the provision of the services that we offer.

Enterprise

We share your personal information with Enterprise for the following purposes:

• To manage your rental and for Enterprise to communicate with you or help you with your rental.

• Related to any incident resulting from your transactions or to other authorized driving agreements with Enterprise, if Enterprise thinks that, following such an incident, you or another authorized driver may be a risk for future rentals.

• Enterprise and third party service providers conduct customer’s satisfaction surveys by phone.

• To send you marketing communications regarding similar products or services that Enterprise regards as being interesting, including targeted advertising on Enterprise’s websites, selected partner websites and social networks.

• To compile statistics and analysis about you – and any authorized users of the products and services of Enterprise, including statistics based on anonymous data, which enables Enterprise to offer your customers and other customers in the future better services, products, characteristics and functionalities.

When we allow the sharing of such information with Enterprise, we and Enterprise operate as independent data controllers. Enterprise retains its own privacy policy regarding the information provided to Enterprise. You are encouraged to read the privacy policy of Enterprise, which can be found here: https://www.enterprise.co.uk/en/privacy-policy.html.

Our Service Providers And Business Partners

We will share your information with third parties, such as:

(1) payment, administrative and technical support providers,

(2) insurance, corporate rental or other customers or partners to facilitate the rental transaction,

(3) communication providers that send email and other marketing and service-related communications to you on our behalf,

(4) customer support providers, in order to provide customer service to you,

(5) debt collection providers,

(6) claims processors, and

(7) our advertising and marketing partners and third-party media properties, including social media sites, with whom we share aggregated or de-identified information about our customers, to allow them to send targeted advertising messages on our behalf, to manage our data, conduct mobile analytics services and to maintain and improve our services (subject to confidentiality agreements as appropriate).

Government Authorities

Your personal information may also be shared with government authorities as outlined above.

Sale, Merger or Change in Control

Your information may be also transferred to another company in the event of a transfer, change of ownership, re-organization or assignment of all or part of our businesses or assets. This will occur if the partiers have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified by us in such cases.

Global data transfers and processing

The information that you provide to us or that we collect may be transferred or accessed by entities around the world, including:

• Enterprise: If you book a reservation with us or an Enterprise corporate-owned location, we will transfer your personal information to Enterprise. Enterprise Holdings, Inc. is based in the United States and it also has offices in the United States, Canada, Germany, Spain, France, Ireland and the United Kingdom.

• Third Party Service Providers: We use third party service providers who are located outside the countries where we are located, such as the EU. When we transfer your personal information to our third party service providers who are located outside Romania, we use European Commission – approved standard contractual clauses.

Your rights

In relation with us, you as a data subject enjoy the following rights:

• Right to be informed means you have the right to be informed about the manner in which your data are processed and the reason of processing.

• Right of access means you have the right to obtain a confirmation from us whether we process or not the personal data related to you and, in affirmative case, to access that data and information regarding the manner in which the data are processed.

• Right to data portability refers to the right to receive the personal data in a structured, commonly used and machine-readable format, and the right to transmit that data directly to another controller, if this is technically possible.

• Right to object is the right to object to processing of personal data, unless the processing is necessary for the performance of a task carried out for reasons of public interest or there is a legitimate interest of the controller. When personal data are processed for direct marketing purposes, you have the right to object to processing at any time, freely and with no justification, using if necessary the Unsubscribe function included in the marketing stuff.

• Right to rectification refers to rectification of inaccurate personal data without undue delay. The rectification shall be communicated to each addressee to whom the data was sent, unless this proves to be impossible or requires disproportionate efforts.

• Right to erasure (“Right to be forgotten”) means you have the right to ask us to erase your personal data without undue delay, when one of the following reasons is applicable: the personal data are no longer necessary in relation to the purposes for which they were collected or processed; you withdraw your consent and there is no other legal ground for processing; you object to the processing and there are no overriding legitimate grounds for the processing; the personal data have been unlawfully processed; the personal data have to be erased for compliance with a legal obligation; the personal data have been collected in relation to the offer of information society services.

• Right to restriction of processing can be exerted in case the data subject contests the accuracy of the data, for a period that allows us to verify the accuracy of the data; the processing is unlawful and the data subject opposes the erasure of the personal data and requests restriction instead; in case Touring Rent Auto no longer needs the personal data for processing, but the data are required by the data subject for the establishment, exercise or defense of legal claims; in case the data subject has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.

• Rights related to automated individual decision-making, including profiling. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or similarly significantly affects him/her. These provisions shall not apply if the decision:

a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;

b) is authorized by Union or State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or

c) is based on the data subject’s explicit consent.

In case you, directly or by means of an agent, exert your rights mentioned above obviously in an ungrounded, unjustified or excessive manner, mainly because you do this repeatedly, Touring Rent Auto may:

– either charge a reasonable fee, taking into account the administrative costs related to the provision of information or communication, or for taking the requested measures;

– or decline your request.

In addition, we acknowledge your right to complain before a surveillance authority and seek legal redress.

To exert such rights, you may submit a written, dated and signed request to the Personal Data Protection Officer within Enterprise Romania, to the e-mail address: dpo@enterprise.ro or to the following correspondence address: Touring Rent Auto, Bucharest, 3-5, Reinvierii Street, Europa Primex Building, 2nd floor, District 2.

We reserve the right not to allow access to your information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent.

Marketing Preferences

You have the right to object to marketing communications (e.g.., direct marketing, graphical notices, etc..) by a written request.

How we protect your data

We commit to ensuring personal data security by taking proper technical and organizational measures, in accordance with the industry standards.

Your personal data is transmitted by using encoding algorithms. We store such data on secured servers, at the same time ensuring data redundancy.

Despite the measures taken to protect your personal data, we warn you that transmission of information over the Internet, in general, or by means of other public networks, is not entirely secure, and there is a risk for your data to be seen and used by unauthorized third parties. We cannot be held responsible for such vulnerabilities of some systems that are beyond our control.

Changes to these policies

As necessary, we will update this Privacy Policy to reflect changes in our privacy practices. Therefore, we encourage you to review our policy by accessing the link http://enterprise.ro/en/politica-confidentialitate/.

Data control – Contact information

If you are making a rental or visiting a website or mobile site in the following countries, the data controller is listed below.

Country: Romania

Data Controller: Touring Rent Auto

Contact data: dpo@enterprise.ro

 

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