Version 1. December 2023
In this privacy policy we, AMAG Service AG (hereinafter "AMAG"), explain how we and our partners collect and process your personal data in connection with Europcar on Demand Carsharing.
AMAG attaches great importance to the security of your data. We therefore process your personal data exclusively in compliance with the data protection laws applicable to us.
1 Who processes your data
Europcar on Demand International SASU, with registered office at 13 TER Boulevard Berthier, 75017, Paris, France, and AMAG Services AG, with registered office at Steinackerstrasse 20, 8302 Kloten, Switzerland, are joint controllers in relation to the processing of your personal data on this website and in connection with Europcar on Demand`s mobility services in Switzerland.
The terms "we", "us" or "our" used in this Policy refer to these joint controllers.
2 What personal data do we process?
Your personal data is any information that enables us to identify you directly or indirectly and that we collect on our websites, in our mobile applications or as part of our mobility solution services.
2.1 Data in connection with the use of Europcar on Demand services
Usage Data is data generated from your interactions with us when you use our Services and includes the following categories of data:
2.2 Data transmitted by the user
You are free to browse our websites or applications without having to create an account. In order to use our products and services, you must register and provide the requested information. The following data is collected for registration and reservation: Identification data (first name, surname, gender, date of birth, driving licence, [identity card, depending on the country], mobile phone number, postal address), audiovisual and electronic data (email, messages, telephone conversations with our customer service, photo, video).
To subscribe to the newsletter, you must provide your e-mail address.
To pay for our products and services, you must provide your payment details (account number, card number).
If you participate in our satisfaction surveys or interact on our dedicated social media pages, we process data for your satisfaction.
a) Data collected through our connected vehicles.We collect a variety of information through our connected vehicles, including Vehicle condition, damage or accident information, vehicle performance data, operational and diagnostic data, mileage information, fuel and charge levels, vehicle location (GPS coordinates) and other vehicle information.
b) Data collected through our connected vehicles. In connection with traffic offences, we may receive information from the authorities responsible for administering fines for traffic offences.
e) a) Data that we receive from authorities. In connection with traffic offences, we may receive information from the authorities responsible for administering fines for traffic offences.
2. Why do we collect your personal data?
We offer you self-service car hire services ("car sharing") via our websites and applications. For this purpose, we collect and process your personal data for different purposes and on different legal bases as follows
Creation and management of your account: This process is necessary to identify you and to prepare and enable your future self-service vehicle reservations.
The processing of your personal data is based on the implementation of the general terms of use of our websites and applications.
b) Protection and support when using your account
Your personal data is processed on the basis of Europcar on Demand legitimate interest in supporting you in the use of your account.
c) Processing your reservation and providing our service:
d) Confirmation of your self-service vehicle reservation;
Modification or cancellation of your self-service vehicle reservation;
Communicating with you by phone or email in connection with your reservation (for example, to send you a confirmation of your reservation, to send you a reminder before and at the end of the reserved date, to answer your questions or suggestions, etc.);
Manage your vehicle reservation in self-service (provision and return of the vehicle);
· Communicate with you by phone or email in connection with your reservation (for example, to send you a confirmation of your reservation, to send you a reminder before and at the end of the reserved date, to answer your questions or suggestions, etc.);
· Manage your self-service vehicle reservation (provision and return of the vehicle);
· Management of your invoices;
· Management of possible late payments;
· Management of complaints;
· Management of compensation for damage to our vehicles;
· Management of your insurance.
The processing of your personal data is based on the implementation of our General Terms and Conditions of Use and Rental of Carsharing, which you have agreed to (the "Carsharing Contract").
a) Verification of your driving licence, either manually or with a facial recognition solution. You must submit your driving licence via our application so that we can validate it. This validation can be carried out
- manually by our customer service department or
This processing is necessary for the implementation of the car sharing contract between you and us.
- by means of facial recognition. Images of the driver's licence (front and back), your selfie or video selfie (if applicable) are collected and processed solely for the purpose of validating the driver's licence. Wherever possible, the driving licence data is read electronically from the user's driving licence images.
The facial recognition solution will only be used with your consent.Die Verwendung der Gesichtserkennungslösung erfolgt nur mit Ihrer Einwilligung.
b) Processing your payments:
- The payment of your reservation, subsequent costs (including) and, if applicable, your subscription;
This processing activity is necessary for the implementation of the car sharing contract concluded with us. If you are not a subscriber to our services, the retention of your credit card details for all future payments is based on your consent.
- the prevention of credit card fraud.
This processing activity is based on our legitimate interest to protect ourselves from credit card fraud.
c) Tracking the vehicle through the use of connected devices. Our fleet of vehicles is equipped with internet-enabled devices that allow us to
- Manage the use of the rented vehicle, in particular to check the presence of the rented vehicle in the correct departure car park at the start of the rental or in the correct arrival car park at the end of the rental, check that the vehicle is returned with the sufficient fuel level, check the kilometres driven as well as whether the purchased mileage package has been respected;
This processing activity is necessary for the fulfilment of your car sharing contract.
- Checking the condition, performance and functionality of our vehicles to ensure that each vehicle is in good condition and available for the respective user's reservation, in particular with regard to the fuel level of the tank or the battery level of a vehicle;
This processing is based on our legitimate interest in managing the fleet and being able to provide the services.
- Localisation of the vehicle in the event of theft or suspected theft;
This processing is based on our legitimate interest in protecting the integrity of our fleet.
- Locating the vehicle in the event of a suspected accident in order to provide the necessary material or medical assistance.
This processing is based on our legitimate interest in providing assistance to people.
d) Improving your online browsing experience Your usage data is processed for technical and operational purposes to enable you to navigate our websites and applications and to improve your customer experience. We use this usage data to customise our websites and applications to make navigation easier and faster, in particular to offer you the version best suited to your language and country of origin.
Please refer to our cookie policy
e) Conducting customer surveys to improve the customer experience with our products/services
This processing activity, which aims to gain a better understanding of your needs and offer you personalised features to improve your user experience, is based on our legitimate interest.
f) Advertising for our commercial and promotional activities:
- Promotions in the form of emails and SMS, as well as advertising and personalised offers specifically tailored to your interests in relation to our products and services;
- Sending newsletters;
- Organisation of competitions; the transactional emails sent to you to inform you of the status of your booking are not covered by this processing purpose.
These processing activities are based on your consent.
a) Carrying out statistical analyses: We aggregate and anonymise your data for statistical evaluations.
This processing is based on our legitimate interest in carrying out statistical analyses.
b) Administration of fines for traffic offences: This procedure serves the following purposes:
- Allocation of fines to the driver who rented the vehicle;
- Transmission of the identity of the driver who has committed a traffic offence to the competent authority (for fine processing).
This procedure is necessary to fulfil a legal obligation to which we are subject.
c) Managing and updating a list of customers with certain contractual risks for the following reasons:
- Payment incidents that resulted in a legal dispute;
- Traffic accidents or repeated damage;
- Accidents or damage caused intentionally;
- Use of our vehicles in breach of the car sharing contract.
This procedure, which aims to reduce the financial, material and reputational risks of the service, is based on our legitimate interest.
d) Checking whether you are on an international sanctions list
This processing is based on our legal obligations in relation to economic, financial or trade embargoes, which are sometimes
(a) by the United Nations Security Council,
(b) by the European Union or one of its Member States,
(c) imposed, administered or enforced by the US Government, including the Office of Foreign Assets Control ("OFAC") of the US Department of the Treasury and the US Department of State, or (d) the UK.
3. To whom will your personal data be passed on?
a) Categories of recipients
If necessary, your personal data may be transferred:
a) to our employees and authorised representatives, to other companies (including Europcar Mobility Group and AMAG Group AG), to our agents and authorised intermediaries;
b) to our subcontractors and their partners, where applicable and to the extent strictly necessary to enable us to provide you with our products and services
c) to the competent authority in the country in which you have committed a traffic offence, for the payment of appropriate fines
d) to the competent authorities, if necessary, and in accordance with applicable law.
Use of Meta
All Meta features and services available on our Website or in our Applications are subject to Meta's Privacy Policy, which you can read if you wish to obtain more information about your rights and preference options.
By using one of our websites/applications, you can:
· Use Meta's social plug-ins, e.g. you can "Like" or "Share" our content on Meta platforms;
· Accept cookies from our website or applications (also known as "Facebook pixels") that help us understand your activities, including information about your device, how you use our services, the purchases you make and the adverts you view, regardless of whether you have a Facebook account or are logged in to Facebook, for example.
· When you use these meta functions, we collect data for the following purposes:
· Displaying adverts that may be of interest to you on Facebook or Instagram, Messenger or another Facebook service;
· Measuring and analysing the effectiveness of our website, applications and advertising.
b) International data transfers
Where it is necessary or useful for the provision of our products and services, we will transfer your personal data to destinations inside or outside the EU (for the purposes set out here).
In all cases, we have put in place appropriate safeguards to protect your personal data in accordance with Regulation (EU) 2016/679 (the "General Data Protection Regulation").
For more information on the countries to which your personal data may be transferred, as well as the level of data protection there and the possible protective measures, click here.
4. How long do we store your personal data?
Customer account
Your customer account will be closed at your request.
Reservations:
5 years from the end of the reservation
Verification of your driving licence:
For the entire duration of the business relationship and 5 years after the end of the business relationship.
Processing of your payments:
For a period of 13 months from the effective date of payment. We keep your credit card number for payment of your subscription for the duration of the subscription.
Tracking our vehicle through the use of connected devices:
Until the last known location of the vehicle is replaced
Promotion of our promotions and commercial activities:
Until the requested deletion of your profile and taking into account your consent.
Performing statistical analyses:
Up to 9 months after the end of your commercial relationship with us.
Administration of fines for traffic offences:
For the time required to identify the driver (or potential driver) responsible for the offence to which the fine is attributable. This period may not exceed 45 days after the fine has been served. However, certain data may be kept for longer (up to 12 months after notification of the fine) if they are subject to interim archiving. Requests from the competent authority to process fines in the country where the reservation was made are deleted as soon as they have been processed by us.
Management and maintenance of a watch list of customers with certain contractual risks for the following reasons:
(a) payment incidents that resulted in a legal dispute;
b) Traffic accidents or repeated damage;
c) deliberately caused accidents or damage; iv. Use of our vehicles in breach of the car sharing contract.
3 years from the occurrence of the event in question.
Checking whether you are on an international sanctions list:
5 years from the collection of your data
5. What rights can they assert?
As a data subject, you have the following rights:
a) Right to information
You have the right to obtain information from us about the processing of your personal data.
In principle, a request for information is free of charge. A fee may be charged in the event of a particularly large amount of work, excessive or notorious requests for information, provided there is no legitimate interest. If you will incur costs, we will inform you in advance.
In order to exercise these rights, you must provide clear proof of your identity (e.g. a copy of your ID where your identity is otherwise not clear or cannot be verified). To assert your rights, you can contact us at the address given in section 2.
b) Right to rectification
You have the right to obtain from us the rectification of inaccurate or incomplete personal data concerning you.
c) Right to erasure
You have the right to request the erasure of your data under certain conditions. For example, you can request the erasure of your data if it is no longer necessary for the purposes for which it was collected. You can also request erasure if we process your data on the basis of your consent and you withdraw this consent.
Anfragen richten Sie bitte an:
AMAG Services AG
Steinackerstrasse 20
CH 8302 Kloten
Schweiz
oder per E-Mail an ondemand@europcar.ch
Europcar on Demand International
13 TER Boulevard Berthier
75017 Paris
Frankreich
a) Right of cancellation
You have the right to withdraw your consent at any time with effect for the future. Please send your cancellation to: privacy@amag.ch
b) Complaint
Every data subject also has the right to enforce their claims in court or to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner (http://www.edoeb.admin.ch).
6. How we protect your personal data
We are committed to protecting the data collected through this application. In particular, we implement appropriate physical, technical and organisational security measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Our systems have data encryption or encryption technologies and firewalls that comply with industry standards. When you submit personal data to a website over the internet, your data is protected using TLS (Transport Layer Security) encryption/decryption to ensure secure transmission.
Any credit card transactions you make through our websites are processed through our PCI DSS compliant payment service providers who ensure the security and protection of your payment methods and transactions.
7. Changes
We may amend this privacy policy at any time without prior notice. The current version published on our website shall apply. If the privacy policy is part of an agreement with you, we will inform you of the change in the event of an update if this is possible without disproportionate effort.
