Privacy Policy for Connected Vehicles Ireland

Privacy Policy for connected vehicles Ireland

Europcar international and Europcar Ireland, acting as joint controllers, uses “Connected Vehicles” as they are known, meaning that the vehicles which we hire to you are equipped with certain technologies such as sensors, onboard devices, etc. These technologies collect data about the vehicle and how it is being used. This information is linked to the vehicle registration number and processed by reference to that number. In certain circumstances, this information could be linked to your identity or data relating to you. As such, we therefore treat it as personal data, in compliance with this Privacy Policy. This Privacy Policy explains why we process your personal data and explains your rights and the courses of action available to you. This Privacy Policy relates solely to “Connected Vehicles”. If you require information about other processing activities involving personal data, please consult the Europcar General Privacy Policy: https://www.europcar.ie/terms-and-conditions/privacy-policyYou should note that the manufacturer of our rental vehicles may be able to access some data from the vehicle, in its capacity as a data controller, for the purpose of improving vehicle models and services. We do not share your identity or any information from which you could be directly identified with any vehicle manufacturer. If you would like more information about the processing activities carried out by any vehicle manufacturer, we invite you to consult the manufacturer’s website directlyWhat data do we collect? We may collect a variety of information from your Connected Vehicle, including the following: the condition of the vehicle, information regarding damage to the vehicle or accidents, vehicle performance data, operational and diagnostic data, mileage information, acceleration and braking speeds, fuel consumption and fuel levels, tyre pressures, odometer readings, the location of the vehicle, together with other vehicle-related information.When you connect a mobile device to your rental vehicle (via Bluetooth, UBS port or any other method), you should be aware that any data on your mobile device could be synchronised with the vehicle. As this processing activity is performed on your initiative, Europcar considers that it is a purely personal processing activity. Please however ensure that you remove all of your personal data from the vehicle before you return it. If you need help to remove your data from the vehicle system, please ask a member of the Europcar’ team. If you become aware that a previous driver of your rental vehicle has not removed his or her data, please either delete it immediately or inform a member of the Europcar team.For what purpose does Europcar collect your personal data? The data is processed for the following reasons only: - managing the rental journey (vehicle delivery, collection, maintenance, invoicing, etc.); - identifying and preventing property- related offences and fraud; - ensuring that you meet your obligations under the rental agreement (for example, if the vehicle is not returned at the end of the rental period or is used outside of the contractually agreed region); and - detecting, verifying and investigating vehicle damage and accidents.On what legal basis is your personal data processed? Personal data collected to manage the rental journey and to ensure that you comply with your obligations under the rental agreement are processed on the basis of the contract entered into between you and the relevant Europcar entity or franchisee. Personal data collected to prevent property-related offences and fraud and to detect, verify and investigate damage to the vehicle and accidents involving the vehicle are processed on the basis of the legitimate interest of Europcar. Our legitimate interest in using your personal data is to prevent property related offences and fraud as well as the detection, verification and investigation of damage to the vehicle and accidents involving the vehicle.Who are the recipients of the personal data we collect? Categories of recipients Your personal data will be disclosed, as necessary to: - authorised personnel of Europcar and of entities of the group (franchisee network and agents); - third parties service providers for technical purposes, in particular telecommunication service providers and car manufacturers; and - in the event of vehicle damage and accidents, for the purpose of investigation by competent authorities, experts and insurers. International transfers Insofar as is necessary to provide you with Europcar services, we will, to the extent necessary for the purposes defined in this policy, transfer personal data outside the EU. Depending on individual circumstances, certain recipients of personal data may be located in countries which have been recognized by the European Commission as ensuring an adequate level of data protection or, equally, in countries which have not been recognized as such. In any event, Europcar has put in place appropriate safeguards to protect your personal data, in compliance with the EU regulation no.2016/679.For what period will Europcar retain your personal data? The data is retained for a maximum of 12 months. In the event of claims and property-related offences, investigation of vehicle damage and accidents, personal data could be retained until such matters are resolved (including until the completion of any legal or judicial process).What rights can you exercise with respect to the processing of your personal data? In accordance with EU regulation no.2016/679, you have the following rights: a) right of "access": to obtain confirmation as to whether or not your personal data is being processed by Europcar, and, where that is the case, to obtain access to such personal data and to obtain further information on the nature of our processing activities; b) right to “rectification": to secure the rectification of inaccurate personal data or the right to have incomplete personal data completed, including by means of providing a supplementary statement; c) right to "erasure" (also known as the "right to be forgotten"): to secure the deletion of your personal data in certain circumstances; d) right to "object": to object, at any time, to the processing of your personal data by Europcar; e) right to "data portability": where the processing of your personal data is necessary for the performance of the contract you entered into with us and carried out by automated means, the right to receive such data provided to Europcar, in an Excel spreadsheet and to forward this data to a designated third party. f) If you wish to exercise any of these rights, please contact us by e-mail at dpo@europcar.com. You can also contact us by post: EUROPCAR INTERNATIONAL 13 Ter Boulevard Berthier 75017 Paris France In addition, you have the right to lodge a complaint about the processing of your personal data with the body regulating data protection in your country (in Ireland this is the Data Protection Commissioner) or with the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy, 75007 Paris, France. If your vehicle is part of a professional fleet, please note that your employer may also have a specific privacy policy.