Avis Budget Group Privacy Notice

Avis Budget Group Privacy Notice

BY USING ANY OF OUR WEBSITES, APPS, PRODUCTS OR SERVICES, YOU UNDERSTAND AND ACKNOWLEDGE THAT WE WILL COLLECT AND USE YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE. If you have questions, comments, or suggestions, you can always contact us using any of the ways described in the CONTACT US section.

1. THE TYPES OF INFORMATION WE COLLECT, AND HOW WE COLLECT THEM

We collect information from you, directly and through third parties, in accordance with this Privacy Notice any time you contact us, interact with us, or use our website, App, products or services. If you do not provide the information we request, we may not be able to provide our products or services to you.

Personal Information.

• Some of the information we collect can personally identify you, including, for example, your name and contact information, birthdate, government identification, payment information, membership ID, program ID, whether you are a part of a corporate or rewards program, payment arrangements, insurance arrangements, and information related to your rentals or use of products or services we provide or enable. For example, when you make a reservation, or join one of our programs, we collect your personal information such as: your name and contact information; birthdate; driver license and other appropriate government identification; payment information, including credit or debit card information (we collect security codes when you make a payment, but we do not keep them); information to process your discounts, such as coupons, discount codes, and membership numbers or codes; and other information that may be necessary to rent you a vehicle, provide you with services, contact you about these services or verify your identity. If you participate in an insurance program through us or are involved in an accident or property damage, we may collect additional information about your insurance provider and/or coverage.
• We may record or monitor any call you make to us for quality control, to enforce our rights, or for training or similar purposes. We may collect photos and videos in some instances, such as when you choose to share them with us in connection with one of our optional membership services or on social media or when we receive a notice of a traffic violation that includes a picture or video. Our rental locations may also be equipped with cameras and/or video security surveillance systems.
• When you download, visit or use our websites or Apps or interact with us using e-mail, texts or other forms of electronic communication, we may we use cookies, pixel tags, beacons, scripts and similar technologies to automatically collect certain information, including, for example, your IP addresses, MAC addresses, device identifier, browser type, Internet service provider (“ISP”), location, how you interact with our websites and/or Apps, referral/exit sites, operating system, date/time stamp, and clickstream data.
• We also collect personal information about you from third parties, including information from third party travel booking channels; service providers; licensees; airlines, hotels, membership clubs, payment card companies, advertisers and other partners; from your employer; from your social media services consistent with your information sharing settings on such services; and from other third-party sources that are lawfully entitled to share your information with us.
• We may collect information about relevant health conditions when necessary to provide adaptive driving devices.

Connected Car Data

•  Some of our rental vehicles are connected cars. A connected car is a vehicle equipped with features, telematics systems, on-board devices, or built-in services and technologies that are capable of collecting data about the vehicle and its use, including, for example, the vehicle’s condition, damage and accident events and records, performance, operation and diagnostic data, information on mileage, acceleration, braking, speed, fuel consumption, fuel level, tire pressure, odometer, location and direction, and other vehicle-related information (collectively, “Connected Car Data” or “Vehicle Data”). Typically, this information is associated with the vehicle only and maintained as non-personal information, as described in the Non-Personal Information section below. If we link this information to you, we will treat it as personal information.
• Use of features and built-in services and technologies in connected cars are subject to the terms and conditions posted by the vehicle manufacturer and/or the technology provider, which may include system and service limitations, warranty exclusions, limitations of liability, wireless service provider terms, and user responsibilities. Some or all of these features are turned on at all times, even when other services or other media in the vehicle are turned off. If you are unsure whether your rental vehicle is a connected car, please speak to a member of our team at the rental location or contact the Rental Station Manager. Details on the connected car features in our rental vehicles are also set out in the “Vehicle Details” section of the Rental Agreement. We cannot guarantee that a vehicle without connected car features will be available at your time of rental.
• Depending on the technology used in your rental vehicle, vehicle manufacturers and built-in services such as ‘Apple CarPlay’ or ‘OnStar’ may also collect Connected Car Data or other personal information from the vehicle pursuant to their privacy policies. For more information about this third party information collection, please refer to the Third Party Collection section below.

Location Information

• We may collect information about your location from our websites, your mobile devices, and your visits to our locations. You may opt out of our collection of information about your location from mobile devices at any time by turning off transmission of geolocation data and push notifications on your mobile device.
• We may also at times connect certain location-related Connected Car Data to you.

Non-Personal Information

• We may also collect or transform information so that it is maintained in a form that is not linked to a particular individual, such as vehicle information that is not connected to a passenger or other aggregated, de-identified or anonymized information (“non-personal information”). This Privacy Notice does not apply to non-personal information, which we collect, use and disclose for a variety of purposes. However, any non-personal information that is linked to or combined with personal information will be treated as personal information subject to this Privacy Notice.

Biometric Information

• QuickPass Biometric Identity Verification: Avis and Budget may offer customers contactless rental experiences through our QuickPass service. To use the QuickPass service, we ask customers at enrollment to scan a copy of their driver’s license and take a real-time selfie image of their face (the “Enrollment Selfie”) using our mobile application. We transmit these images to a trusted third-party service provider that uses a combination of machine learning tools and statistical algorithms to confirm the authenticity of the driver’s license and perform a biometric facial comparison to determine whether the faces contained in the driver’s license and Enrollment Selfie belong to the same person. Through this process, our trusted third-party service provider generates a “Confidence Score” representing the confidence level that the images of the individuals match, which we use in determining our level of confidence that the individual submitting the Enrollment Selfie is the same person as the individual on the driver’s license. We do not receive any facial biometric information generated from the images, and our third-party service provider is contractually limited to processing this information on our behalf and is required to destroy the images and any biometric information promptly after processing in accordance with a data retention schedule. We do not use, disclose or retain facial biometric information for any other commercial purposes.
• Mobile Application Authentication: Some of our mobile applications require you to log in to access your account or interact with your connected car.  We may provide you the ability to log in or authenticate yourself using facial, fingerprint or other biometric recognition technology available through your mobile device.  If you choose to utilize these login features, information about your facial geometry, your fingerprint or other biometric information will be collected by your mobile device for authentication purposes.  We do not store or have access to this biometric information.  Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful.  If the authentication was successful, you will be able to access the applicable mobile application or feature without separately providing your credentials.

2. HOW INFORMATION IS USED

Personal Information

We use your personal information to:

·         provide you with our websites, Apps, products and services;

·         provide you with additional services or functionalities (for example, to facilitate contactless rentals, to provide remote lock/unlock, to remote disable engine/cancel ignition, and to automatically receive the vehicle location, odometer, fuel level and other information in connection with your rental);

·         administer your rental, manage your rental records and to calculate your fees (for example, to automatically record the start of your rental, any exchange or upgrades, and the fuel or mileage usage and charges);

·         communicate information regarding your reservation or rental. These communications are transactional or service related and will be sent via email, text, push notification or phone calls;     

·         diagnose problems, analyze trends, and assess our performances;

·         provide roadside assistance;

·         provide you with discounts;

·         improve our operations and services;

·         better understand our customers’ preferences;

·         better understand how our vehicles are being used;

·         tailor our services, promotions and offers to our customers;

·         research and develop new products and services;

·         maintain our fleet;

·         recover lost, stolen or towed rental vehicles;

·         interact with you in person, through our services or on third-party platforms (such as social media sites);

·         provide you with, and improve, relevant marketing or offers from us and our partners, and to inform our advertising and marketing campaigns;

·         run our contests, sweepstakes or promotions;

·         enable third-party vehicle applications and services;

·         improve road safety and reduce traffic;

·         respond to legally binding requests from law enforcement, regulatory authorities or other third parties;

·         ensure the security of our or another’s premises, property or other assets;

·         defend, protect or enforce our rights or applicable terms of service;

·         prevent fraud or the recurrence of fraud;

·         assist in the event of an emergency; and

·         comply with applicable law.

We use cookies, pixel tags, beacons, scripts and similar technologies to adjust and optimize our content to your preferences, to provide you with useful functionalities, to remember your previous rentals and your travel preferences, to help us make our website, Apps, products and services more convenient and efficient, to improve our services, to help us analyze usage trends and patterns, and to tailor online advertisements by us and our partners to you and we may use third party vendors to assist with these efforts. We may also use third party tools to monitor user experience information on our Website. These tools automatically record how you interact with our Website including mouse clicks and movements, page scrolling and any text keyed into website forms. We use this information for site analytics, optimization and to improve website usability. We also use analytic software, such as Google Analytics and others, to help us to better understand how our websites and Apps function on your device and for research and development. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, which uses third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/ and you can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On, at https://tools.google.com/dlpage/gaoptout/.

We may use third party platforms to help us promote interest-based advertisements to you or to offer integration with third-party services (such as the Facebook Like button). These providers use cookies or similar tracking technologies to collect information about your use of our websites, including our mobile apps, over time so that they may deliver the integrated services or play or display ads on our services, on other websites, apps or services you may use, and on other devices you may use. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to facilitate integrated services or to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. You have options when it comes to cookies and other web tracking tools.

You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. However, some features or services may not function properly without cookies. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our websites do not currently change the way they operate based upon detection of a Do Not Track or similar signal. As the internet and other e-commerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.

We use information about your location (including, at times, by linking personal information with location information of the rental vehicle you are using) primarily to locate our nearest rental location, send you location-based notifications (i.e., nearby special offers), arrival and return notifications, vehicle location, and upgrade availabilities. We also use information about your location for the same purposes we use your personal information, including to provide you with, and improve, relevant marketing or offers from us and our partners.

Data Retention

We may retain your information for as long as you have an account with Avis, Budget, Payless, or Budget Truck Rental, as needed to provide you our services, or as otherwise necessary for the processing purpose(s) for which the information was originally collected and any other legitimate business purpose, including, for legal, archival, accounting, and/or audit purposes. If you close your account or request we provide you our services, we may retain your information because we have a legal, auditing or account obligations or it is in our archive system and cannot be separated from other information.

Your Opt-Out Choices

·         If you would like to opt-out of receiving marketing e-mails: Click the “unsubscribe” at the bottom of an e-mail we sent you, or log into your account and update your profile, or contact any customer service representative.

·         If you would like to opt-out of receiving marketing text messages: For Avis, text the word “STOP”. For Budget, text the word “STOP”. For more information and additional terms about text messages, please see our SMS Policy here.

·         If you would like to opt-out of receiving tailored online advertisements from us and our partners: Set your browser or device to refuse all cookies or to indicate when a cookie is being sent. Check your specific browser’s website to learn how to adjust your cookie settings. Please note that if you opt-out of tailored advertising, you will continue to receive general ads. To learn about online advertising and your choices click here: http://www.networkadvertising.org/choices/ or http://www.aboutads.info/choices/ (if you are a US visitor) or http://www.networkadvertising.org/choices/ or http://youradchoices.ca/choices/ (if you are a Canadian visitor). You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences.  Some ABG companies partner with an advertising company (Rokt). To the extent ABG companies have partnered with Rokt, you may also opt out of certain advertising offers provided by our advertising partner, Rokt, by following the instructions set forth in Rokt’s Privacy Policy, currently available at https://rokt.com/privacy-policy/.  You must perform the opt-out on each browser or device you use. These opt-out choices may not affect online advertising that is not cookie-based. Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you may need to opt-out again. Please note that when you “opt-out” of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our services.  In addition, third parties may still use cookies to collect information about your use of our services, including for analytics and fraud prevention as well as any other non-advertising purpose.

·         You can stop sharing the location information of your mobile device through the applicable ABG App by turning off location services or by uninstalling the App. If you would like to uninstall the ABG app: Use the standard uninstall processes as may be available as part of your mobile device or via the application marketplace or network from which you downloaded the app.

·         You may also be able to limit mobile interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. You may be able to limit the use of location data for advertising purposes by adjusting your location services settings on your mobile device.

To facilitate the uses of personal information identified in this Privacy Notice, we may share your personal information with a variety of third parties, including our service partners and business partners.

We may share your personal information with our third-party service providers and partners to help us with our marketing and promotional projects, such as managing our social media pages, running contests, sweepstakes and other promotions, or to comply with your directions or any additional consent you have provided us.

In addition, Budget Truck may share your personal information with third parties who use this information to provide you with information and marketing messages about products or services that may interest you. These parties may use your information in accordance with their own privacy policies and terms.

If you are renting with a corporate, membership or other similar commercial entity account, we may share personal information with the organization that manages the account for their own purposes. We recommend you review their privacy policy to learn more about their privacy practices.

We and our business and promotional partners send you information about products and services you may like. For example, we may help to arrange hotel rentals, flights or other services from our business partners, and share personal information with our business partners in order to provide those services and facilitate your reservations. We may also work with third parties, such as our airline and payment card partners, to allow us and our partners to deliver advertisements to our shared customers. Our partners may be able to provide more relevant offers to you based upon information that we share about your rentals, as well as information in your loyalty program profile. Additionally, we may allow third-party partners to recognize you when you visit that partner’s website or app, or to recognize you as one of their customers when you visit our websites or apps so that they may provide more relevant offers to you. You may revoke your consent to receive marketing and promotional e-mails and text messages from us and our business and promotional partners. Please note that revoking consent to receive marketing and promotional e-mails and text messages does not affect our non-promotional or non-marketing communications, including, for example, communications about the status and activities of your accounts, billing communications, responses to your requests, post-service feedback or survey requests, confirmations, and similar communications.

We may share website usage information, including searches, transaction and profile information (but not your name) with our partners for the purpose of making the online advertisements on our websites and other websites that display our advertisements more relevant.

We may also let you share some of our online content on social media websites through hosted sharing links and icons. We do not track or store a record of each time a third party shares our online content. If you choose to participate in posting or sharing activities, you should remember that it may be viewed by the public via ABG’s website, in RSS feeds, APIs (application program interfaces) and may also be made available to other websites. As a result, your public activities may appear on third-party websites, blogs, or feeds. ABG is not responsible for the information that may be shared publicly. Our websites may include social media features, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our website, and may set a cookie so that the Like button feature works properly. Any social media feature is governed by the privacy policies of the website providing the feature. We encourage you to read the privacy policies of any website you visit.

We may share your personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law, including for the purpose of:

·         responding to a subpoena, court order or other legal processes;

·         defending, protecting or enforcing our rights;

·         assisting in the event of an emergency; and

·         complying with applicable law.

We may also share personal information with third parties in the event of an actual or potential merger or acquisition, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. To the extent that local laws require it, we will provide you notice on our websites or via e-mail of our intent to transfer personal information to a third party for this purpose.

Personal Location Information.

We only share information about your location with:

·         our third-party service providers to help provide our services or third-party services you have requested;

·         third-parties for whom you have provided consent, including, for example, with partners who provide location-based marketing; or

·         law enforcement and regulatory authorities or other third parties as required or permitted by law, including for the purpose of:

o    responding to a subpoena, court order or other legal processes;

o    defending, protecting or enforcing our rights;

o    to locate an overdue or suspected stolen or lost vehicle

o    assisting in the event of an emergency; and

o    complying with applicable law.

4. HOW YOUR INFORMATION IS PROTECTED

The security of personal information is important to us. We take reasonable steps designed to protect personal information from unauthorized use, access, disclosure, alteration, destruction or loss. You are responsible for keeping your account safe. Do not share your passcode, membership and pin numbers with anyone. Please be mindful that hackers and scammers may impersonate us or our website. For more information about phishing, please visit https://www.consumer.ftc.gov/articles/0003-phishing. If you suspect an unauthorized use or security breach of your information, you must notify our customer service as soon as possible! We are not responsible or liable for any loss or damage if your account passcode, membership numbers and pin numbers are stolen or used inappropriately.

5. CHILDREN’S PRIVACY

Our websites, Apps, products, and services are not for children under the age of 13. We do not knowingly collect personal information from children. If you think we have received personal information from children under the age of 13, please contact us immediately.

6. THIRD PARTY COLLECTION

Our websites and Apps may include links to and from the websites of our affiliates and business partners. We do not control how personal information is collected or used on those websites, so please review the privacy policy of any website you visit as a result of following any links to or from the websites of our affiliates and business partners.

Many ABG branded locations or franchises are independently owned and operated. Click here  to learn more about independent locations or franchises.

Depending on the technology used in your rental vehicle, vehicle manufacturers and built-in services, such as OnStar, Uconnect, Bluetooth, Apple CarPlay, and Android Auto, may also collect Connected Car Data from our vehicles pursuant to their privacy policy and share the Connected Car Data with us. Please note, Connected Car Data may be received by the manufacturer of the connected car or the owner of the built-in service prior to it being received by us. We encourage you to review the manufacturer’s and the relevant built-in service’s privacy policies and other terms and conditions related to Connected Car Data to understand what personal information is being collected from the connected car and the purposes for which it is being collected. If you choose to sync your information or a device to the car (using Bluetooth, USB or otherwise), data from you or your device may be accessed and stored on the car’s systems, such as the infotainment system. Please always unpair your device and ensure that you take the necessary steps to remove your information from the system when you return the car at the end of your rental period. If you do not do this, your information may be retained in the system and could be accessed by anyone who is authorized to use the car. We are not responsible for any data that is left in the vehicle as a result of your use.

7. GEOGRAPHIC LOCATIONS

We generally store your personal information in the United States. As a part of our normal business operation, we may at times need to transfer some of your personal information outside of the United States. If we do so, we will take reasonable steps designed to ensure your information is treated and protected no less securely than it is in the United States. This Privacy Notice is intended to be governed by the laws of the State of New Jersey and meet the laws and requirements of the United States, which may not necessarily be consistent with the laws and regulations of the country where you live. If you are a resident of the European Union, please use the appropriate website for your location, which can be found here rather than using this website.

8. CONTACT US

If you have questions, comments, or suggestions, you can always contact us in the following ways. We may need to verify your identity before assisting with your request.

9. INDEPENDENT LOCATIONS

Please note, many Avis, Budget, Payless and Budget Truck locations are owned and operated by an independent licensee and not owned or controlled by ABG or any ABG affiliate or subsidiary. This Privacy Notice only applies to our processing of your personal information and does not apply to the processing of your personal information by an independent licensee. Each of these independent licensees is responsible for its own collection and processing of personal information and may collect, use or disclose personal information differently than described in this Privacy Notice.  

In particular, the licensee is responsible for its own collection and processing of payments and may engage in its own e-mail campaigns and other forms of marketing to you. Because we do not control the independent licensee’s use of personal information and we are not responsible for the independent licensee’s compliance with applicable privacy laws, you should direct any questions about a licensee’s privacy practices to the specific licensee.