DATA PROTECTON POLICY

This policy was last updated on January 2017.

• Island Car Rental, subsidiary of Auto Trade Ltd. (“ICR” “we”, “our” or “us”), we respect your privacy. We implemented this privacy policy (“Privacy Policy”) to explain to you how we use and protect the personal information we may gather from and about our customers by means of our websites, mobile applications, online booking widgets (i.e. online booking applications run by our third-party partners such as hotel providers, airlines, etc), our corporate, rental, and sales locations, and from third-party sources. By using our websites or mobile applications, you consent to the collection, use, and disclosure of your information, as described in this Privacy Policy.


• The nature of the business and operations require us to retrieve your reservation and booking information with our third party payment processor. ICR has received the Comodo Privacy Seal signifying that this privacy statement and our practices have been reviewed for compliance with the Comodo program viewable on the validation page available by clicking the Comodo seal. If you have questions or complaints regarding our privacy policy or practices, please contact us reservations@islandcar.dm and we will respond to you within a reasonable period of time unless otherwise required by law. If you are not satisfied with our response you can contact Comodo by visiting their website https://www.comodo.com



The Types of Information We Collect




Information Collected About You



• You may provide us with certain information in connection with a transaction or in your interactions with our websites and at our locations. When you are asked to provide personal information, you may decline. If you choose not to provide the information, you may not be able to use some products or services. The personal information we may collect includes:


• Your name, contact information, driver’s license number and expiration date, emergency contact information, and date of birth;


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


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


• Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;


• Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents, Car Sales lead providers or similar providers).


• With your consent, we may access location-based information from your mobile device or based on your IP address.


• Information Collected and Stored Automatically


• By visiting our websites, certain information may be automatically provided to us by your computer. For each visitor to our websites, our webservers automatically recognize the visitor’s domain name or IP address. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, webservers can identify your computer by its IP address. In addition, we may collect your browser type and operating system as well as your internet service provider (ISP), referring and exit pages, date and time stamp, and/or clickstream data. We collect similar information when visiting our websites with your mobile device, including mobile device brand, model, mobile operation system and carrier. Except as otherwise explained in this policy, we may combine the non-personal information we collect from you (as described above and as described below, under “Cookies & Pixel Tracking”) with your personal information in order to tailor our websites and enhance your online experience by saving your preferences and/or to help identify site features, advertisements and offers that may be of interest to you.



How We Use This Information



• We use the information we collect for the following purposes:


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


• To verify a valid ID when submitting a photo of yourself and drivers license. We do not store this information for any other purpose


• To service your account or membership with us, respond to your questions and contact you when necessary.


• To provide you with discounts, coupons, sweepstakes, offers and other information, opportunities, and services that may be of interest to you. You may receive these offers in advertising that is directed to you via third-party sites and media properties, including in social media. You may be able to opt-out of these ads by clicking on an icon in the ad or through the privacy settings in each media property.


• To assist us in providing better products and services (for example, we may contact you by telephone, mail or email to assist us in evaluating the performance of our staff, to assess the quality of product and service 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, which statistics are only used to enable us to provide better customer service, products, features and functionality to you and other customers in the future.


• To protect our rights and property


• We may combine the information that you submit to us with information related to your transactions with us, such as rental location and vehicle type. We may also combine this information with data we receive about you from third parties who assist us in processing requests, maintaining our data, and optimizing our services.


• Except where prohibited by law, we retain information we collect for commercially reasonable periods of time or in accordance with specific policies. Information collected for a specified purpose will only be used for that purpose and, after a reasonable period of time, will no longer be actively stored when that purpose has been fulfilled. Inactive data may, however, continue to be used for statistical, marketing, archiving, and other analytical purposes.



How Your Information May Be Shared



• We may disclose the information we collect from and about you to our subsidiaries for the purpose of providing the transactions you have requested and for marketing purposes. Our affiliates and our subsidiary employees in our IT, marketing, operations and customer service divisions may use your information, as described in this Policy. We also may disclose your information to other third parties: (1) when required by law or in response to legal process; (2) without legal process in response to a request from law enforcement relating to a criminal investigation; (3) to protect our rights, privacy, safety or property, or of the public; (4) for administrative, technical support or other business purposes to facilitate our transactions with you (i.e. for your insurance replacement, corporate rental or through one of our partners), analyze our data, conduct mobile analytics services, or to maintain and improve our services (subject to confidentiality agreements as appropriate); (5) to permit us to pursue available remedies or limit damage that we may sustain; (6) to enforce the terms of any rental agreement or our websites’ terms and conditions; (7) to assist with the administration of frequent flyer or other rewards programs; (8) if the rights of another individual might be violated and (9) otherwise with your consent.


• We may disclose your personal information to third-party service providers (such as a payment processor to bill you for goods or services, an email provider to send email communications to you on our behalf, or the provider of our live chat feature in order to offer you customer service). These service providers are contractually required to maintain the confidentiality and security of your information. However, your information may be accessible to U.S. or EU authorities in accordance with applicable laws


• We may also share aggregated or de-identified information about our customers with our advertising and marketing partners, and third-party media properties, including social media sites to allow them to send targeted advertising messages on our behalf.



Choices You Can Make About Your Information



• Throughout our websites, we provide choices about the collection, use, and sharing of your information. For example, you must affirmatively request to receive email advertisements from us, our affiliates and/or business partners concerning information about special offers, promotions and new features, products and services. You may choose to opt back in to our email advertisements at any time, in which case your most recent action will prevail. We will give you an opportunity to opt-out of the gathering of your personally identifiable information, specific uses of your personally identifiable information and any marketing promotions.



Testimonials



• We may post customer testimonials/comments/reviews on our websites which may contain personally identifiable information. We will obtain your consent via email prior to posting the testimonial. To request the removal of your testimonial, please contact us through one of the methods listed below in the Contacting Us section.



Linked Sites



• Our websites may contain links to other websites (such as those of our marketing partners or advertisers), which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any website that you may access through our website.



Data Security and Integrity



• The security of the information you provide is very important to us and we try to provide secure transmission of your information. For certain transactions on certain of our websites, we may use Secured Sockets Layer (SSL) technology to secure the transfer of information. Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information transmitted over the Internet. Once we receive your information, we take steps that we believe are reasonably appropriate to protect its security, both internally and from outsiders, from loss, misuse, unauthorized access, disclosure, alteration and destruction, and to ensure the integrity of the data we collect. We use a combination of technological, physical, administrative and policy methods as well as organizational controls and non-disclosure or confidentiality agreements as we deem appropriate to protect this data.


• If you have a user name and password for any of the features on our websites, you have the responsibility of keeping your password secret. You should not reveal your password to anyone. We will not ask you in an unsolicited telephone call or email for your password. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.



Global Data Transfers and Processing



• We will use your information in the country in which your service and transaction occurs. Please be aware that, unless prohibited by law, your use or continued use of our websites and mobile applications signifies your express consent that information may be transferred to or stored on servers and processed outside the country of your residence, including any of the countries where we do business. Please also be aware that the privacy laws of the United States or other countries where information may be stored may not be as comprehensive or offer as much protection as the laws of other countries including your country of residence. You may request us not to make such transfers, but if you do, we may not be able to provide some or all of our products or services to you. Island Car Rental participate in and have certified their compliance with the US Based Comodo Privacy Shield Framework. Island Car Rental is responsible for the processing of personal data it receives, under the Comodo Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf.
  With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Island Car Rental is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Island Car Rental may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


• When transferring personal data to countries outside the European Economic Area, we comply with European Union law by using standard contract clauses approved by the European Commission, or by adopting other means to ensure that adequate safeguards are applied, or by obtaining your consent.



Changes in Terms


• We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.



Contacting ICR


• The accuracy and completeness of the information we collect is very important to us and we make efforts to ensure that the information we have is accurate and up-to-date. In addition to the options provided to you in this Policy, if you wish to opt-out of direct marketing or review, amend, correct, update or delete personally identifiable information we have collected about you or limit how we use it, contact us at the information provided below. In addition to rights to review, amend, correct, update and delete personal data, you may also have rights to object to some processing of personal data. Please also contact us if you have any questions about privacy on our websites. You may contact us via email at reservations@islandcar.dm, and we will attend to your request and make any necessary revisions. We reserve the right not to allow access to your information if we believe in good faith that such disclosure is prohibited by law or if the rights of another individual might be violated.