1.      Who processes your personal data collected through this website?

GoCar Ireland, whose registered office is located at 24 Northwood Court, Northwood Business Park, Santry, Dublin 9, Ireland, (hereinafter referred to as “GoCar” or as “us”) is responsible for the processing the personal data belong to you (the “User(s)” or “You”). Your personal data refers to any information that would allow us to identify you, either directly or indirectly and which is collected through this website or our Android or IOS mobile applications.

2.      Which type of personal data is collected?

Usage data

The navigation on GoCar’s sites and applications (as well as the use of any third party’s application embedded and/or available therein), implies the communication to GoCar of usage data, which is implicitly acquired during the navigation of the user through the internet communications protocol (“Usage Data”).

Usage data includes among other, the IP addresses or domain names of the devices utilized by the Users, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within GoCar) and the details about the path followed within GoCar with special reference to the sequence of pages visited, and other parameters about the device’s operating system and/or the user’s IT environment.
Usage data is not collected for the purpose of identifying the User. However, you must be aware that the identification may be possible through further elaborations and associations, as well as with information held by third parties.

Data communicated by the User

Users are free to navigate the GoCar sites or applications but, to use the service, Users need to register and disclose the information requested in the relevant forms in a complete and truthful manner.

Whenever a field is described as “optional” or “not compulsory” or is not marked with “*” symbol it means that user is free not to communicate the requested data and that the registering of the User can go ahead notwithstanding the absence of this information. The Data collected by GoCar for registration purposes are: first name, last name, gender, date of birth, driving license, mobile phone number, email address, address.

User’s personal data shall be processed upon User’s prior, free and informed consent, and solely for the purposes outlined in the present privacy policy.

The explicit, optional and voluntary sharing of User’s email address in the contact forms provided on GoCar implies that the relevant email address, as well as any other data communicated, is acquired by GoCar for satisfying the contact request. Users are kindly invited to not share any third parties’ data unless this communication is strictly necessary for the request made. Users are responsible for any third party personal data obtained, published or shared through GoCar and confirm that they have the third party’s consent to provide the data to GoCar.

In addition to the information contained in this privacy policy, GoCar may provide the User with additional and specific information concerning other services or the collection and processing of personal data upon request.

3.       For what purposes does GoCar collect your personal data?

Through our website and mobile applications GoCar provides you with carsharing rental services. To that end, GoCar processes personal data that you voluntarily provide to GoCar for the following purposes:

a. Your registration as a GoCar member and creation of your account

This processing is necessary to identify you and to prepare and facilitate your future carsharing rental bookings with GoCar.

b. The processing of your booking:

  • to confirm your carsharing rental booking;
  • to modify or cancel your carsharing rental booking;
  • to exchange with you in relation to your booking (e.g. to provide you with information on your booking, to send you reminder notice before your check-in/check-out, to repond to your questions or suggestions);
  • to manage your carsharing rental booking (delivery and return of the vehicle);
  • to manage your invoices;
  • to manage the payment of arrears;
  • to manage potential claims;
  • to manage the recovery of potential damages to GoCar vehicles;
  • to manage your insurance.

The processing purposes highlighted above are necessary for the booking and the performance of the carsharing rental terms and conditions  entered into with GoCar (the “Carsharing Agreement”).

c. Payment purposes

This processing is necessary for the performance of the Carsharing Agreement, which is concluded between you and GoCar. For the duration of our commercial relationship with you, GoCar shall retain your credit card information in order to facilitate your subscription and booking payments.

d. GoCar vehicles monitoring through the use of vehicle connected devices :

GoCar provides its carsharing rental services in a fully digital and automated way through GoCar’s software platform and onboard vehicle technology. As a result, GoCar’s fleet is equipped with devices which feature internet connectivity.

The purpose of such devices and the data collected through them enables GoCar:

  • to monitor the state, the performance and the functionalities of GoCar vehicles. For example, this allows GoCar to verify whether the fuel tank of the vehicles is sufficiently full or not, if the vehicle battery level is appropriate or not etc… Such information aims to ensures that each Vehicle is in good working condition and is available for User bookings.
  • to identify potential breaches of the Carsharing Agreement (for example making sure that the User has (i) returned the Vehicle with the sufficient level of fuel, (ii) not exceeded the kilometer package purchased, (iii) returned the Vehicle to the dedicated parking spot etc…);

This processing, aiming at protecting the integrity of GoCar fleet, is based on GoCar’s “legitimate interest”.

e. GoCar vehicles monitoring based on geolocation systems and its internet access devices:

As a result, Users must be aware that (i) geolocation systems and (ii) internet connection devices are embedded in GoCar’s fleet of carsharing vehicles.

Geolocation systems have been installed by GoCar to verify the presence of the rented vehicle in the correct departure area at the start of the rental and to verify the presence of the rented vehicle in the correct return area at the end of the rental. Such geolocation systems allow GoCar to make sure that the Vehicles are situated in their designated area and are available for booking.

Such information shall also be used for the purposes listed below:

  • to prevent any fraud and/or damaging action against its property as well as to provide Users with a better service. For example, geolocation systems allow GoCar to make sure its Vehicles are returned on time in their designated parking or alternatively (i) allow Users to extend their booking or (ii) mitigate any consequences for the User whose Vehicle has been delayed.
  • Location of the vehicle in the event of theft or suspected theft;
  • Location of the vehicle in the event of a suspected accident in order to provide assistance or emergency medical treatment.

The location of the User is collected solely for the above purposes.

This processing, aiming at protecting the integrity of GoCar’s fleet, is based on GoCar’s “legitimate interest” and is necessary for the performance of the Carsharing Agreement between you and GoCar.

f. Improvement of your navigation experience

Usage Data of the User is solely processed to permit the navigation of the User on GoCar’s sites and applications from an operational and technical point of view and to improve the User’s navigation experience. Based on such Usage Data, GoCar will be able to adapt its website to ensure an easier and quicker navigation. For example, Usage Data allows us to make sure GoCar’s website is the most relevant to you depending on your language and country of origin.

g. Improvement of GoCar services on the basis of:

  • customer surveys you have completed;
  • the recording of your carsharing history to suggest you pre-selected options when looking for new booking.

This processing, aiming at having a better understanding of GoCar members’ needs and offering you customized functions to enhance your experience of GoCar products/services, is based on GoCar’s “legitimate interest”.

h. Promotional and marketing activities, upon your consent, namely:

  • the sending of email and SMS for special promotions/deals as well as customized advertisements and promotions that are targeted to your specific interest about GoCar products/services;
  • the sending of GoCar’s newsletters;
  • the sending of emails about a booking you did not complete or send you a summary about a booking enquiry;
  • the management of your loyalty program;
  • the organization of promotional contests/sweepstakes;
  • the management and update of GoCar’s customers/prospects database

Direct marketing processing, i.e. any commercial message from GoCar aiming at promoting GoCar services, are subject to your express consent.

By exception:

  • if you are already a GoCar existing customer and that the message concerns services similar to those you have already purchased, the underlying processing will not be based on your consent but on GoCar’s “legitimate interest”; and
  • the sending of transactional emails (concerning for example the updating of the Carsharing Terms and Conditions, the confirmation of your booking…) are necessary for the performance of the Contract between you and GoCar.

i. Statistical purposes

This processing aims at carrying out anonymous and aggregated statistical analyses of the usage data of the customer.

j. The management of fines:

This processing aims to:

  • to transfer to the relevant competent authority – dealing with the processing of fines – the identity of the driver who has committed a traffic violation or offence;
  • to satisfy fines collection procedure to which GoCar may be subject.

This processing is required by law.

k. The management and update of a watchlist of customers presenting certain contractual risks based on:

  • payment incidents which have given rise to legal proceedings;
  • vehicle accidents or repeated damages caused by GoCar customer;
  • accidents or damages caused voluntarily by GoCar customer;
  • use of GoCar’s vehicles in breach of the Carsharing Terms and Conditions.

This processing, aiming at reducing GoCar risks exposure in the performance of the Carsharing Agreement, is based on GoCar’s “legitimate interest”.

l. The processing of personal data for the purpose of law enforcement

Should any willful act of misconduct, fraud or criminal offence (other than traffic violations or offences mentioned above) be perpetrated against GoCar, personal data could be used, under certain circumstances, for ascertaining individual responsibilities and transferred to competent authorities.

In addition, your personal data may be processed for the purpose of fulfilling duties and obligations laid down in applicable laws and regulations. The User declares to be aware that GoCar may be required to reveal personal data upon request of the relevant public authorities.

For your full information, GoCar carries out certain processing of your personal information through “cookies” and other tracers collected every time you visit GoCar website. These processing are governed by GoCar Cookies Policy, which we encourage you to review. You can accept or reject these cookies and other tracers by following the instructions provided in GoCar Cookies Policy.

4.      Who are the data recipients of the personal information we collect about you?

4.1 Categories of recipients

Your personal data will be disclosed, as necessary and/or relevant to:

  1. the authorized personnel of GoCar and the entities of the same group (including the Europcar group to which GoCar belongs) and/or entities – the case being – belonging to GoCar’s franchise network for the purposes described in this privacy policy;
  2. the sub-processors of GoCar, which are third-party service providers that collect data in order to help GoCar in providing you with its products/services. The main IT service providers are:
    1. Google Inc., in particular for hosting services and business applications.
    2. Rentalmatics for the provision of vehicle Telematics data and services.
    3. Capricorn Ventis for Business Intelligence application development
    4. Trilogy Technologies for IT Managed Services in the area of Helpdesk Support and escalation services
    5. Matrix Internet for business application development and maintenance
    6. Mailchimp, Sendgrid and Zendesk for email and web chat communication
    7. SurveyMonkey for customer feedback surveys
    8. Microsoft for email communication and productivity systems
  3. regarding the information processed for the payment of fines, to the relevant competent authority – in the country where the User made the booking – dealing with the processing of fines;
  4. GoCar can also disclose your personal data to the extent required by law and/or by competent authorities.

The Data communicated is limited to that which is strictly necessary to provide our services. The communication of such Data shall be limited to that which is required to allow GoCar to meet its contractual and legal obligations. Whenever Your personal data is shared with a third-party, GoCar will only do so after entering into a contract with the third-party in which the latter undertakes to protect all personal data using appropriate security measures and not to use that personal data for purposes other than those disclosed above.

4.2 International transfers

As necessary or useful to provide you with GoCar products/services, GoCar may – for the purposes set forth herein – transfer your personal data outside the EU to third-parties, as identified in Appendix 2.

Depending on the case, certain recipients may be located in countries which have been recognized by the European Commission as ensuring an adequate level of data protection or in countries which has not been recognized as ensuring such a level of protection. In any case, GoCar has put in place appropriate safeguards to protect your personal data, in compliance with the EU regulation no.2016/679 (the “General Data Protection Regulation”).

5.      For what period will GoCar retain your personal data?

Your personal data are retained for different period, depending on the purposes of the processing:

Purpose

Retention period
▪         Your registration as a GoCar member and the creation of your account

▪         Your carsharing rental booking

 For the duration of the commercial relationship.

However, please note that:

  • your registration information and booking history will be archived for a period varying between 6 to 9 months as of the moment you have requested the cancellation and deletion of your registration account. Such delay in the deletion and or anonymization of your personal data shall be strictly limited for the purposes of protecting GoCar against any fraudulent or criminal activity;
  • information that may evidence a right or that must be kept in compliance with a legal requirement (such as invoices or proof of transactions), may be subject to an intermediate archiving policy for a period of time that does not exceed the time that is necessary for the purposes for which it is kept, in accordance with applicable legal provisions.
▪         Payment The only information GoCar can access concerning your payment method is a token representing the card details of the cardholder. 

However, such information that may evidence a payment is subject to an intermediate archiving policy for a period of time of 13 months after the effective payment for a credit card and 15 months for a deferred debit card, to be used only if the transaction is disputed;

▪         GoCar vehicles monitoring through the use of vehicle connected devices ▪          Up to 4 years as from the end of your commercial relationship with GoCar
▪         GoCar vehicles monitoring based on geolocation systems ▪          Up to 4 years as from the end of your commercial relationship with GoCar
▪         Improvement of your navigation experience and GoCar services depending on your preferences ▪         Up to 9 months as from the end of your commercial relationship with GoCar.
▪         Promotional and marketing activities ▪         For GoCar customers, up to 3 years as from the end of the commercial relationship with GoCar

▪         For prospects – who are not GoCar customers – up to 3 years as from the collection of your personal information OR as from the last request for information you made
▪         Statistical Analysis ▪         Up to 9 months as from the end of your commercial relationship with GoCar.
▪         Cookies ▪         Please check GoCar Cookies Policy
▪         Payment of fines For the time necessary to identify the driver (or the potential driver) liable for the infraction leading to the fine. However, relevant information can be kept for a longer period of up to 12 months after receipt of the fine, subject to an intermediate archiving policy.

Requests from the relevant competent authority dealing with the processing of fines in the country where the booking has been made will be deleted once the requests have been proceeded by GoCar.

▪         The management and update of a watchlist of customers presenting certain contractual risks, namely:
i. payment incidents which have given rise to legal proceedings
ii. vehicle accidents or repeated damages caused by GoCar customer
iii. accidents or damages caused voluntarily		 3 years as from the occurrence of the relevant event
                iv.            the use of GoCar vehicles in breach of the Carsharing Terms & Conditions 5 years as from the occurrence of this event

6.      What rights can you exercise with respect to the processing of your personal data?

At any time, you can view and/or update your personal profile, which includes member registration, driver information and rental preferences information, through the “My profile” section accessible on the GoCar website. You will be able to change your password, update or correct phone number, address, and driving licence information and update your car rental and travel preferences including means of payment.

As per EU regulation no.2016/679 (the “General Data Protection Regulation”), you can also benefit from the following rights:

  1. right of “access”: right to obtain confirmation as to whether or not your personal data are being processed by GoCar, and, where that is the case, to access to these personal data and to obtain further information on the characteristics of their processing;
  2. right “to rectification”: right to obtain the rectification of inaccurate personal data or, taking into account the purposes of the processing, the right to have incomplete personal data completed, including by means of providing a supplementary statement;
  3. right to “erasure” (or the so-called “right to be forgotten”): right to obtain the erasure of your personal data in certain circumstances; right to “object”: at any time, a right to object to the processing of your personal data to prevent GoCar from continuing to carry out such processing:
  4. where your data are processed for direct marketing purposes;
  5. where your personal data are processed on the basis of GoCar’s legitimate interest. In that case, your request will be satisfied only if you provide GoCar with a description of the particular situation legitimating your request and save if GoCar can demonstrate overriding legitimate grounds in light of your particular situation.
  6. right to “withdraw your consent”: where the processing of your personal data is based on your consent, a right to withdraw your consent to the processing of your personal data at any time and to prevent GoCar from continuing to carry out such processing;
  7. right to “data portability”: where the processing of your personal data is based on your consent and by automated means, the right to receive the personal data you provided to GoCar, in an Excel spreadsheet[1] and to transmit those data to a third party;

If you wish to exercise any of these rights, please contact us via email at info@gocar.ie. In addition, in GoCar’s promotional and marketing emails and other communications, GoCar also includes instructions on how to unsubscribe.

To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.

As per article 77 of the EU regulation no. 2016/679, you can lodge a complaint about the processing of your personal data with the body regulating data protection in your country[2] if you consider that the processing of your personal data infringes the said EU regulation no. 2016/679.

7.      How does GoCar protect your personal data?

GoCar is committed to protecting the information it collects through this website.

In particular, GoCar uses appropriate physical, technical and organizational security measures to prevent unauthorized or unlawful processing, accidental loss of or destruction of or damage to your personal data.

GoCar’ systems are configured with data encryption, or scrambling technologies, and industry-standard firewalls. When you send personal information to a GoCar website over the Internet, your data is protected by the SSL (Secure Sockets Layer) encryption/decryption to ensure safe transmission.

Any credit card transaction you make through GoCar websites is done through our Secure Server Technology. This technology notably:

  1. assures your browser that your data is being sent to the correct computer server, and that the server is secure;
  2. encodes the data, so that it cannot be read by anyone other than the secure server;
  3. checks the data being transferred to ensure it has not been altered.

8.      Who to contact when you have a query regarding the processing of your personal data?

  1. For general query regarding the processing of personal data carried out by GoCar please contact info@gocar.ie
  2. To exercise your rights (access, rectification, erasure, restriction, etc.) please contact info@gocar.ie
  3. For legal notifications: GoCar Ireland, 24 Northwood Court, Northwood Business Park, Santry, Dublin 9, Ireland.

9.      Changes to this Privacy Policy

This privacy policy was published on May 24th 2018. In the case of changes to this privacy policy by GoCar, such changes will be identified by GoCar on this webpage.

When a change impacts a processing carried out on the basis of your consent, GoCar will contact you to obtain a new consent.

 

[1] Or any other commonly used and machine-readable format.

[2] The country where you have your habitual residence, place of work or place of the alleged infringement.