Security and Privacy Policy

 

Privacy Policy

1 Protecting your privacy

The worldwide rental system operated as Europcar is owned by Europcar International, a French Corporation.  A number of independently owned licensees also trade as Europcar in Australia, New Zealand and internationally.

In Australia, Europcar is the trading name of CLA Trading Pty Limited ABN 81 082 220 399 and in New Zealand Europcar and InterRent are the trading names of BVJV Limited (Company number 1171885).

For the purposes of this Privacy Policy, Europcar refers to CLA Trading Pty Ltd and our Related Entities and brands in Australia and in New Zealand, to BVJV Limited and our Related Companies (We, Us).

This Privacy Policy applies to all your dealings with us whether at one of our division offices, through our call centres or via our Websites.

We draw your attention to section 3 of our policy and the use by Europcar of vehicle GPS tracking devices.  By hiring a Europcar Vehicle, you expressly consent to Europcar using tracking devices on the Vehicle during the rental period and collecting, using and retaining information from the tracking devices in accordance with Our Privacy Policy.

You accept this Privacy Policy and expressly consent to our collection, use and disclosure of your Personal Information as described in this Privacy Policy by using our Websites, enquiring about our Services or acquiring our Services. 

This document provides you with information on how we collect, use, store and disclose your personal information.  If you want more information, please use the contract details set out in section 15 of this Privacy Policy.

2 Definitions

In this policy:

Credit Information means Personal Information that we obtain from a Credit Reporting Body (including any information derived from such information) or any information we provide to a Credit Reporting Body.

Credit Report means a report from a Credit Reporting Body the primary purpose of which is to assist with the assessment of the creditworthiness of an individual.

Credit Reporting Body has the meaning given in section 7 of this Privacy Policy.

Personal Information has the meaning given under the Privacy Act.

Privacy Act means the Privacy Act 1988 (Cth) or where applicable, the Privacy Act 1993 (NZ).

Privacy Policy means this document setting out the policy of CLA Trading Pty Limited and BVJV Limited relating to the privacy of your Personal Information.

Privacy Officer means Europcar's first point of contact for privacy related matters (the Privacy Officer can be contacted using the details in section 15 below).

Related Entities has the same meaning as under the Corporations Act 2001 (Cth) and in New Zealand Related Companies has the same meaning as under the Companies Act 1993 (NZ) and each includes our franchisees.

Sensitive Information has the same meaning as under the Privacy Act.

Services means the offers and services provided by us, including vehicle hire services and the Europcar Privilege Loyalty Programs.

Website means www.europcar.com.au and www.europcar.co.nz and other websites and forms of social media where you post comments or we interact with you.

The meaning of any general language is not restricted by any accompanying example and the words 'includes', 'including', 'such as', 'for example' or similar words are not words of limitation.
 

3 What Personal Information do we collect and why do we need it?

3.1 Personal Information we collect

To provide you with our Services, we need to collect Personal Information.  If we do not collect the Personal Information or if any of the Personal Information you provide is incomplete or inaccurate, we may not be able to provide the Services or those Services may be compromised.

Depending on the nature of the Services we provide to you, the personal information we collect may include:

- your name, email address, telephone numbers and address;

- date of birth;

- Sensitive Information, for example, if you advise us of any disability;

- banking information including  account details, credit card details and expiry dates;

- drivers licence number (including taking a photocopy of your licence);and in Australia, state of origin;

- a copy of identity verification documentation (e.g. copy of passport, utility bill or Medicare card) 

- frequent traveller program number;

- information on a professional group to which you belong (e.g. you may disclose that to obtain a discount available to members of that group);

- vehicle preference;

- company name and employee number;

- contact details of individuals who can provide professional references and other information required;

- credit information Credit Report from a credit reporting body (as further detailed in section 7 of this privacy policy);

- reservations and rental details including dates, times and places of vehicle hire;

- information relevant to vehicle damage which may include filming the vehicle at the time it is collected and returned (which may include incidental filming of the occupants of the vehicle); and

- any other Personal Information relevant to the Services we provide to you.


3.2 Vehicle tracking and locating

Europcar uses GPS tracking or other electronic tools (GPS device) to enable the geographical locations of its vehicles to be tracked or located.   

Information from the GPS device may be used:

- to provide information to the police or other authorities in the event that the vehicle is stolen or is not returned at the end of the hire period;

- in the event of an accident or incident relating to the vehicle during the hire period, e.g. to verify the location of the vehicle at the time of the alleged accident or incident;

- to identify the exact location of the vehicle in the event of a reported breakdown and to provide that location to breakdown responders (e.g. the local Automobile Association);

- to identify whether the vehicle is being used in an area prohibited under the terms and conditions of rental;

- to locate the vehicle in the event of an emergency; or

- for any other purpose permitted under the Privacy Act or any other law.
 

4 How do we collect the Personal Information?

We aim to collect Personal Information directly from you.  We may also collect Personal Information:

- when you complete a form, make inquiries or apply to rent a vehicle from or through us;

- from other members of the Europcar Group;

- from your company or organisation when you use our services under a corporate account or other arrangement;

- from our program partners if you are a member of a frequent traveller or other program and rent or make inquiries of renting a vehicle through them;

- from our contracted service providers;

- from Credit Report bodies;

- from debt collection agencies if you (or an entity you are guaranteeing) default in a payment to us;

- through our website, electronic systems such as applications and by other electronic communication channels (e.g. when you send us an email or post an entry on our Facebook page or other social media sites);

- from third parties;

- from publicly available sources of information;

- when we are required to do so by law;

- when you log onto or connect to our Website and our server automatically records information your browser sends (e.g. your IP address, how and when you travel through our Website, the pages and documents accessed information about your usage (e.g. by way of cookies) and other information provided by downloading information from our website).  However, unless your name is part of your email address or you specifically provide it, our server does not automatically collect this information; and

- when you enter a competition or promotion with us, participate in a survey or register to receive information from us or register to receive information on any of our Services.

If at any time you supply Personal Information to us about any other person (e.g. another member of your household or you post a photo on our Facebook page), you represent and we accept that information on the basis that you are authorised to do so and that the relevant person has consented to the disclosure to us.

5 CCTV and other imaging

We may film vehicles as they exit and re-enter a Rental Station for security purposes and to confirm the condition of the vehicle and to identify any damage which may have occurred during the rental period. Any film taken of the vehicle may be high resolution and may include images of the occupants of the vehicle from which it may be possible to identify the occupants of the vehicle. Any filming of the occupants is purely incidental.  The film will be used for the purpose of identifying damage, recovering payment for any damage and any other purpose authorised under the Privacy Act.

For security purposes we have CCTV cameras in some of our locations and your image may be recorded.

6 How do we use your Personal Information?

We use the Personal Information we collect for operational purposes and to:

- provide our Services;

- verify the accuracy of the information (including Personal Information) you provide to us when renting a vehicle;

- comply with our contractual and other legal obligations;

- respond to medical emergencies;

- process your inquiries and improve our Services;

- advise you of additional services or information which may be of interest to you;

- develop our products and services;

- decide whether to provide you with credit if you have requested credit from us (as further detailed in section 7 of this Privacy Policy);

- improve the quality of your visit to our Website;

- send you our newsletters or email alerts unless you have opted out of receiving such communications;

- manage your participation to a competition or a prize draw; and / or

- contact you in the context of the services that you have requested through the website.

7 Credit information

This section 7 applies if you apply for credit from us or you are a guarantor or officer of a company to whom we provide credit.

7.1 Credit Reporting Bodies

To assist us in assessing your credit worthiness, we may provide information about you to a Credit Reporting Body (CRB) in order to obtain a Credit Report from the CRB. The information provided to the CRB includes Personal Information required to enable the CRB to provide us with the Credit Report. If we decide to provide credit to you, we may also provide information to the CRB about the credit that we provided to you. The information that we may provide to a CRB may include:

- personal particulars (e.g. your name, sex, address, previous addresses, date of birth, name of employer and your driver's licence number);

- details concerning your application for credit or commercial credit and the amount requested;

- advice that we are a current credit provider to you;

- advice of any overdue accounts, loan repayments and / or any outstanding monies are no longer overdue in respect of any default that has been listed;

- that your overdue accounts loan repayments or any outstanding monies are no longer overdue in respect of any default that has been listed;

- information that, in our opinion you have committed serious credit infringement (that is fraud or you have shown an intention not to comply with your credit obligations);

- advice that cheques drawn by you or payments made by you for one hundred and fifty dollars ($150.00) or more, have been dishonoured more than once; or

- that credit provided to you by us has been paid or otherwise discharged.

A Credit Report may include information about previous applications for credit and credit that has been provided.  It may include payment and default information, including information about court judgments or insolvency.

You may request access to any Credit Information that we hold about you, or you may request that we update, correct or delete such information.  We will deal with any such request in accordance with section 13 of this Privacy Policy. 

You may request the CRB not to use or disclose your Credit Information in some circumstances, e.g. if you believe you are or have been a victim of fraud.

The CRBs that we disclose personal information to, and obtain Credit Reports from, include:

Dun and Bradstreet (Australia) Pty Ltd

Telephone: 1300 734 806

Website: www.checkyourcredit.com.au

If you wish to complain about how we have dealt with any of your Credit Information you may contact our Privacy Officer and you may also complain to the independent privacy regulator in your country. Relevant contact details are in section 15 of this Privacy Policy. 

7.2 Use or disclosure of Credit Information

We may use or disclose Credit Information for the following purposes:

- to assess an application for credit or for any other consumer credit related purpose;

- we believe on reasonable grounds that a serious credit infringement has been committed and the information is used in connection with that infringement; or

- the use is required or permitted by law.

8 Marketing

We may use and disclose your Personal Information to provide you with information on offers, products and services offered by Europcar, its Related Entities or Related Companies, franchisees and licensees, its partners or affiliates.

We do not use Sensitive Information for marketing purposes.

If at any time you no longer wish to receive any marketing material from us that is sent to you in electronic form, you can unsubscribe from receiving such marketing material by clicking on the unsubscribe link and following the prompts.  You can also request that we do not use or disclose your Personal Information for marketing purposes.

9 Disclosure of personal information

We may be required to disclose your Personal Information by law, by court order or to investigate suspected fraud or other unlawful activity.

We may also disclose your Personal Information to third parties in certain circumstances including:

- if you agree to the disclosure;

- when we use it for the purpose for which it was collected, e.g. to provide you with Services;

- in circumstances where you would reasonably be expected to consent to information of that kind being passed to a third party;

- where disclosure is required or permitted by law;

- where it is required to be disclosed for audit purposes;

- to our Related Entities or Related Companies;

- if disclosure will prevent or lessen a serious or imminent threat to someone's life or health; or

- where it is reasonably necessary for the enforcement of the criminal law, a law imposing a pecuniary penalty or for the protection of public revenue.

We do not disclose Sensitive Information about you unless you agree or, in the circumstances of disclosure, would reasonably expect us to make the disclosure.

10 Disclosure of personal information off-shore

We may disclose Personal Information to our parent company Europcar International, based in France. Customer telephone calls may be handled by a call centre based in the Philippines.  Also if you use our service to rent a car in a country other than Australia or New Zealand, it will be necessary for us to transfer your Personal Information to the relevant overseas partner in that Country. The Personal Information that we will transfer to the relevant overseas partner will be information that is necessary for the service to be provided to you.  This will include your name and contact details.

Depending on which country you are renting the car in, the overseas partner may not be subject to any privacy obligations or to any principles similar to the Australian Privacy Principles or the New Zealand Information Privacy Principles.  The overseas recipient may also be subject to a foreign law which could compel disclosure of personal information to a third party, for example, an overseas authority.  However, we take reasonable steps to ensure that all our overseas partners will handle and protect your Personal Information in the same way that we do.

11 Considerations when you send information to us

While we do all we reasonably can to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure, including investing in security software, no data transfer over the Internet is 100% secure.

If you access a partner or service website (e.g. hotel, airline or overseas partner's website) from our website, you do so and provide personal information in accordance with the terms and conditions under which the provider of that website operates. We do not have any control over, and do not accept any responsibility for, such websites or the handling of any personal information that is obtained through such websites.

The open nature of the Internet is such that information exchanged via the Internet may be accessed and used by people other than those for whom the data is intended. If you send us any information, including (without limitation) Personal Information, it is sent at your own risk.

While we are not in a position to give you advice on Internet security, if you provide Personal Information to us electronically (e.g. by way of our Website or using an electronic system such as an application), there are some things you can do which may help maintain the privacy of your information, including:

- ALWAYS closing your browser when you have finished your session;

- NEVER providing Personal Information when using a public computer; and

- NEVER disclosing your user name and password to another person.

You are responsible for all actions taken using your username, email or password.  If at any time you believe your username or password has been compromised, you should immediately contact us and also change your password.

You should also contact us immediately if you believe:

- someone has gained access to your Personal Information;

- we have breached our privacy obligations or your privacy rights in any way; or

- you would like to discuss any issues about our privacy policy.

12 How your information is stored

We endeavour to keep our information systems and files secured from unauthorised access.  Those who work with us are aware of the importance we place on protecting your privacy and their role in helping us to do so.

Our procedures to securely store Personal Information include electronic and physical security measures, staff training and use of password protection software.

When the Personal Information that we collect is no longer required, we will remove or de-identify the Personal Information as soon as reasonably possible.  We may, however, retain Personal Information for as long as is necessary to comply with any applicable law, for the prevention of fraud, for insurance and governance purposes, in our IT back-up, for the collection of any monies owed and to resolve disputes.

13 Access and correction of your Personal Information

You may request access to your Personal Information or that we correct any inaccurate or out of date information by contacting our Privacy Officer using the details in section 15 below.  

We may refuse to comply with your request where we are entitled to do so under law. Where we agree to provide you with access to your Personal Information, we may make this conditional on us recovering our reasonable costs of doing so.  For security purposes, before we provide you with access to your Personal Information, we may ask you to provide evidence of your identity.

You may request the source of any of your Personal Information that we have collected from a third party and used for direct marketing.  We will provide this at no cost, unless under the Privacy Act or other law there is a reason for this information being withheld, this may include where it is impractical or unreasonable for us to provide this information.

If we do not agree to your request for access to, or correction of, your Personal Information, we will give you a written notice of refusal setting out the reasons for the refusal (except to the extent it would be unreasonable to do so) and the mechanisms available to you to complain about the refusal.

14 Changes to our Privacy Policy

This document sets out our current Privacy Policy.

Our Privacy Policy will be updated from time to time. You should review our Privacy Policy each time you visit our Website or provide us with Personal Information.

15 Contact details

If you would like further information on our Privacy Policy or if you have any concerns over the protection of the information you have given to us or that we have collected from others (including if you wish to complain about how we have dealt with your personal information), please contact us by contacting our Privacy Officer at:

Attention: The Privacy Officer

Mail: Europcar Australia / New Zealand

         189 South Centre Road

         PO Box 1139

         Tullamarine VIC 3043 AUSTRALIA

Email:   info@europcar.com.au (Australia) or info@europcar.co.nz (New Zealand) - (mark the email for the attention of the Privacy Officer)

We will aim to respond to your query within 30 days.

More information about your rights and our obligations in respect to privacy and information on making a privacy complaint are available from:

 

In Australia, the Office of the Australian Information Commissioner at:

Website:    www.oaic.gov.au

Post:    GPO Box 5218, Sydney NSW 2001

Email:     enquiries@oaic.gov.au

 

In New Zealand, the Privacy Commissioner at:

Website:    www.privacy.org.nz

Post:     PO Box 10 094, The Terrace, Wellington 6143.

Email:    enquiries@privacy.org.nz

 

Reservations: 1300 13 13 90

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