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. WHO WE ARE

As used in this Privacy Notice, “ABG,” “we,” “us,” or “our” refers to Avis and Budget companies within the Avis Budget Group, Inc. and their subsidiaries and affiliates, including Avis Rent A Car System, LLC, Budget Rent A Car System, Inc. and Budget Truck Rental, LLC.

2. 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 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 link your ABG account with your social media profile 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.

·         We treat any non-personal information that is linked to or combined with personal information as personal information.

Non-Personal Information.

·         We may collect non-personal information from features in our rental vehicles, vehicle telematics systems and associated devices, including, for example, our vehicle’s condition; damage and accident records; performance, operation and diagnostic data; information on mileage, acceleration, velocity, fuel consumption, fuel level, tire pressure, odometer, location and direction, and other vehicle information (“Vehicle Data” or “Connected Car Data”). Use of features is 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. Vehicle manufacturers may also collect information from our vehicles pursuant to their privacy policy and share the Vehicle Data with us. You can review their privacy notice and other terms and conditions related to Connected Car Data on the applicable vehicle manufacturer’s website. We cannot guarantee that a vehicle without these features will be available at your time of rental.

·         We may aggregate, anonymize, pseudonymize, de-identify or aggregate personal information to create non-personal information.

Location Information.

·         We may collect information about your location, which is personal information, 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 or push notifications on your mobile device.

·         We also use Vehicle Data to collect information about the location of our rental vehicles, which is non-personal information.

·         When we link information about your location with information about the location of a rental vehicle you are using, we treat the combined location information as personal information.

3. HOW INFORMATION IS USED

Personal Information.

We use your personal information to:

·         provide you with our website, App, products and services;

·         provide you with additional services or functionalities (for example, 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);

·         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 to our customers;

·         research and develop new products and services;

·         maintain our fleet;

·         recover lost, stolen or towed rental vehicles;

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

·         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;

·         to 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. 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 use third party platforms to help us promote interest-based advertisements to you, we may use web tracking tools as described above or a process called hashing, which involves converting the e-mail address, phone number or other contact information you have provided to us into a unique value that these platforms may compare to a unique value created on their platforms. 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 may retain your information for as long as 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.

Personal Location Information.

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.

We may retain your information for as long as you have an account with Avis, Budget 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” to 48400. For Budget, text the word “STOP” to 36300.

·         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 visitors).

·         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.

Non-Personal Information.

We may use non-personal information (including Vehicle Data and vehicle location information that has not been combined with personal information) for any and all purposes, and we keep it for as long as we have a business need to do so.

4. HOW INFORMATION IS SHARED

Personal Information.

The nature of our business and operations require us to share certain personal information. We may share your personal information with our third-party service providers and partners to help:

·         us:

o    with the uses described in the How Your Information Is Used section above;

o    with our marketing and promotional projects, such as managing our social media pages, running contests, sweepstakes and other promotions; and

o    comply with your directions or any additional consent you have provided us; and

·         us 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. 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 share your personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law 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.

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 may also share personal information with third parties in the event of a 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.

Non-Personal Information.

We share non-personal information, including Vehicle Data, with our third-party service providers and partners as reasonably necessary to meet our business needs.

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; or

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

We also may share information about your location with law enforcement and regulatory authorities or other third parties as required or permitted by law 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.

5. HOW YOUR INFORMATION IS PROTECTED

The security of your personal information is important to us. We take reasonable steps to make sure your information is protected from unauthorized use, access, disclosure, alteration, destruction or loss. Firewalls and encryption are used to protect your more sensitive personal information. 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.

6. SOCIAL MEDIA

You may be able to link your favorite social media and personal device profiles such as Facebook, Twitter, LinkedIn and Google with your Avis and Budget account. This can help personalize and streamline your ABG experience. It’s optional, and you can link and unlink your account(s) at any time.

If you do decide to link, ABG may collect some of the following personal information from your social media or personal device profile, including:

·         name, profile picture, gender, birthday, and other information that you have provided;

·         professional information such as your current and prior work history;

·         likes, activities and interest information; and

·         e-mail.

We collect this information to help us:

·         customize offers and deals on our website;

·         send you relevant e-mail offers with special deals and discounts;

·         send you relevant offers by mobile phone text messages;

·         update your profile information on our website;

·         allow you to publish check-in and check-out information to your linked social media accounts;

·         allow you to share your upcoming trips with friends; and

·         allow you to view your friends’ that have linked their profiles upcoming trips.

You may unlink your account by logging onto each ABG account that you have linked and selecting “Unlink” next to the social media profile you want to unlink.

We 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.

7. 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.

8. YOUR CALIFORNIA PRIVACY RIGHTS

We do not share your personal information with third parties for their own direct marketing purposes without your consent. If you are under 18 years old in California, in certain circumstances, you may request and obtain removal of personal information or content shared by you and posted on our Website or App. Please be mindful that this would not ensure complete or comprehensive removal of the content or information posted on our Website or App by you. To make any request pursuant to California privacy law, please contact ABGprivacy@avisbudget.com.

9. THIRD PARTY COLLECTION

Our websites and Apps may include links to and from our affiliates and partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies different from ours. If you choose to use OnStar, UConnect, Bluetooth, Apple CarPlay, Android Auto or other similar software or services on our vehicles, please check out their privacy policies to understand the privacy practices of their services. To prevent the next driver from accessing your information, please always unpair your device and delete any personal data that may be stored on the car’s infotainment system upon returning the car.

10. 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 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: https://www.budget.ca/en/legal-documents/international-websites  rather than using this website.

11. 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.

12. INDEPENDENT LOCATIONS

Many Avis and Budget locations are independently owned and operated. Each of these locations collects, uses and discloses personal information for its own purposes. ABG does not control the independent licensee’s or franchisee’s use of this personal information. Please ask to review the privacy notice for that location.

When you are dealing with an independent location, the licensee or franchisee is responsible for collecting and processing payment and may engage in its own e-mail campaigns and other forms of marketing to you. ABG is not responsible for the compliance of the independent location with privacy laws. However, if you believe the independent location is violating privacy laws, you may report this to ABG’s Global Privacy Office at ABGprivacy@avisbudget.com.