VIA RENT DRIVE SRL (the trade name VIA RENT A CAR) controls the processing of the personal data on its platforms, acting as a personal data controller within the meaning of the personal data protection legislation. VIA RENT DRIVE SRL, Romanian company, registered with the Bucharest Trade Register with no. J2017006521402 CUI: RO 37527744, headquartered in 52-62^t CTurnu Magurele St., District 4, Bucharest Cty., Romania, hereinafter referred to as VIA RENT A CAR. is a company whose scope of business is the car rental activity.-

Contact us at hello@viarentacar.ro  if you have any questions or concerns about the use of your personal data and we will be eager to assist you. By using this website and/or our services, you consent to the processing of your personal data as described in this privacy policy.

We offer a wide range of services related to online car rental, including products and services such as insurance, through our website, mobile apps, e-mail and text messaging, social media ("platforms"), and to this effect will also need to enter into various services contracts. This Policy applies to all the personal data we collect while performing the actions described above or when you contact us by e-mail, live chat, phone, or post.

1. DEFINITIONS

Personal data ("personal data"): means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, identification number, location data, online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity.

Personal data processing: means any operation or set of operations which is performed on the personal data or on sets of personal data, whether or not by automatic means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller: is a natural person or company who determines the purpose and means of processing the personal data; it is the person with whom the applicant for a service would conclude or has concluded one or more contracts.

For the sake of transparency and clarity, we would like to point out that, in order to provide you with car rental and the related services and considering the European regulations on the protection of personal data, VIA RENT DRIVE SRL, as Controller, processes your personal data as we will show herein below.

 2. DATA PROTECTION PRINCIPLES

In the personal data processing activity, we are committed to the following principles of protecting such data:

• The processing is lawful, fair, and transparent. Our processing activities have legal grounds. We always consider your right to protection of personal data before processing the personal data. We will provide you with information on the processing upon request;
• The processing is limited in purpose. Our processing activities correspond to the purpose for which the personal data was collected;
• The processing is done with minimal data. We collect and process only the minimum amount of personal data necessary for the purpose of the processing: advertising, publicity, and the provision of the services by our company;
• The processing is done until the consent is withdrawn. However, we will not store personal data unless necessary and in accordance with the applicable law;
• We will do our best to ensure the accuracy of the data;
• We will do our best to ensure the data integrity and confidentiality.

3. THE RIGHTS OF THE DATA SUBJECTS

 The data subject has the following rights:

1. The right to information - which means that you need to know whether your Personal data is processed; what data is collected, where it is obtained from and by whom, and why it is processed;
2. The right of access - which means you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your collected personal data;
3. The right to update/rectification - which means you have the right to request the rectification or deletion of your Personal Data that is inaccurate or incomplete;
4. The right to erasure - which means that in certain circumstances you can request that your Personal Data to be deleted from our records. Please note that the final deletion of all data will be done in accordance with the current legislation;
5. The right to restrict the processing - namely where certain conditions apply, you have the right to restrict the processing of your Personal data in accordance with the applicable law;
6. The right to object to the processing - namely in certain cases you have the right to object to the processing of your Personal data, for example, but not limited to the case of direct marketing;
7. The right to object to automatic processing - meaning that you have the right to object to automatic processing, including profiling; and not to be subject to a decision based solely on the automatic processing. This right can be exercised whenever there is a result of profiling that produces legal effects that significantly affect you;
8. The right to data portability - you have the right to obtain your Personal data in an appropriate format or, where possible, as a direct transfer from one controller to another;
9. The right to lodge a complaint - if we refuse your request. Under the Access Rights, we will provide you with a reason we are doing so. If you are not satisfied with the way your request has been handled, please contact us;
10. The right to assistance from a supervisory authority - which means you have the right to obtain the assistance of a supervisory authority and the right to other remedies, such as claiming damages in court;
11. The right to withdraw your consent - you have the right to withdraw any consent given to process your personal data in accordance with the applicable law.

4. WHAT PERSONAL DATA WE COLLECT

 The contact form is on all pages of the website.

These are:

• first name, surname, e-mail address, telephone number.

In the case of information requested by e-mail, phone, or social networks, necessary to make a reservation or obtain an offer:

• name and surname;
• e-mail address (if you are booking online and for booking confirmation);
• home address for billing purposes;
• employer details and company address (if you are a member of a company scheme);
• the telephone numbers where we can contact you;
• the date of birth (for the permit validation and the legal requirements);
• the age of the driver, for handling additional charges for drivers under 21;
• payment information, such as the credit or debit card details for blocking a cash collateral whose value varies depending on the type of rented vehicle;
• information from your driving license, including whether you are an additional driver (for the permit validation);
• information from the identification documents, such as the national identity card/passport;
• special requests and preferences, including:
  • your preferences for optional additional products, such as protection products (window, windscreen, bodywork, tire insurance, roadside assistance) and any optional extras you have requested, e.g., child seat;
  • if a delivery or pick-up service is requested, the address where we will deliver and collect the vehicle in order to handle the additional charges;

 In the event of any accident, loss, theft or damage to the vehicle during the rent or in the event of a mechanical breakdown, we will collect the information about the incident, including your report of the incident and any police or third party reports, including the details of those involved, the nature of the injuries and/or damages to the vehicle. This information is processed for the purposes of performing the contract entered into with you (the vehicle rental contract and/or the terms of any optional extras such as the insurance); for defending our rights and legitimate business interests (e.g. to recover the costs in the event of any loss/damage to the vehicle); for complying with any legal obligations incumbent on us (e.g. to respond to various requests from the competent authorities).

In connection with the performance of the rental contract, we will process data such as the date, time, and location of the pick-up of the vehicle, the date, time and location of its return, accident history and other information relating to the vehicle and its use by you. This information is necessary for the provision of the services related to the rental contract or for legitimate business interests (e.g., for the purpose of monitoring the fleet usage).

We also process information about any misdemeanors/fines/offences (e.g., speeding, illegal parking, non-payment of tolls, etc.) found in connection with the rented vehicle and the rental period. These data are processed in order to follow up on the requests from the competent authorities in relation to these issues, or to manage the possible litigation situations in relation to such incidents.

  PERSONAL DATA COLLECTED INDIRECTLY (OBSERVED/DERIVED DATA)

1. Data gathered by video recordings and online identification of individuals (video recordings: location and images captured by the surveillance cameras installed at the VIA RENT DRIVE SRL premises, the audio recordings of telephone calls, IP address captured when using the VIA RENT DRIVE SRL websites and applications. The data is needed to ensure security and protection at the VIA RENT DRIVE SRL's premises, to improve the offered services, to deal with the complaints and any requests from the customers and to ensure the technical functionality of the online platforms used by VIA RENT DRIVE SRL.
2. Data gathered by the GPS vehicle tracking system that passively collects data and provides accurate and reliable real-time information about the vehicle location, vehicle status, fuel consumption, the maintenance scheduling.

 In addition, we collect information from your computer when you use one of our platforms, even if you do not make a booking, and in this regard please also refer to our Cookie Policy. This may include your IP address, the web browser you use and the language settings. Personal data we receive from other companies. We may obtain information about you from the social media platforms, our business partners and other third parties. For example:

• We work with affiliated business partners to offer our services on other platforms. When you make a booking on one of these platforms, we may share your personal data with them, and they may share your personal data with us.
• The companies providing the services you have booked through our platforms may need to send us information about you - for example, if your booking leads to an insurance claim or customer service dispute.

Our business partners may also send us information about you that can help us display more relevant ads. We may combine any of this information with information you provide to us directly.

 In some cases, we use social networks (FACEBOOK, WHATSAPP, INSTAGRAM, etc.) to communicate with you. We will NOT ask you to submit personal data to us through these networks. We recommend that you use the e-mail addresses displayed on the website. If you choose to submit personal data via WHATSAPP, for example, you are entirely liable. We assume NO liability for the personal data received via the social media networks.

  5. HOW WE USE YOUR PERSONAL DATA

 We request and collect your personal data in order to book your car and to ensure that you receive the best possible service. The main reasons we collect your personal data are:

• Reservations: Firstly, we use your personal data to perform and manage your booking, (or other product or service such as the insurance);

• To issue the documents for unlocking or collecting the pre-authorized amounts to the banking entities;
• Issuing insurance certificates and settling the car damage claims;
• Ensuring the necessary security measures at the company's locations through video surveillance as well as assets through the use of GPS systems on vehicles to prevent, detect and investigate unauthorized use of our vehicles and systems as per the rental agreements, and to ensure that we comply with the law and that vehicles are only used within the country as per contract between the parties. The GPS device detects violations of driving rules, such as speeding, and sends alerts putting the fleet manager in a position to remotely immobilize the vehicle and prevent the unauthorized use. The device also allows "geo-fencing"; once the vehicle crosses a predefined geographical boundary, an alert will be sent, and the vehicle's engine will be automatically immobilized. As a result, the GPS vehicle tracking technology significantly reduces the traffic accidents and controls the fleet maintenance costs, improves the operational efficiency, manages the vehicle reliability, and improves the driver safety;

• Customer service: Our customer service team needs your details to assist you, for example, to make a booking or answer any questions you may have before, during or after making your booking;
• Customer reviews: We may use your contact details to send you a short questionnaire about your booking or ask you to provide a review on one of our social media platforms (Facebook, Google). This helps us to understand and improve our services. Your review will help future customers make the right choice and help our business partners improve their services. By submitting a review, you agree that your review may be displayed;
• Marketing activities: We also use your personal data for marketing activities, which will include contacting you by phone, e-mail, or SMS with various information;
• Communicating with you: There may be other times when we will contact you by phone, e-mail, or text message to respond to questions and requests, to process rental agreements you have made or to complete a booking you have started but not completed;
• Fraud detection and prevention: To provide you with a safe and trustworthy service, we use your personal data to detect and prevent fraud and other illegal or unwanted activities.
  Similarly, we may use the personal data for security and risk assessment purposes, which may include user and booking verification. This may mean that we may sometimes put certain bookings on hold;
• Improving our services: We analyze the personal data to enhance the functionality and quality of our online services and to improve the overall experience of our users. We are always working to make our platforms more enjoyable and easier to use;
• Call monitoring: We may record the telephone calls made to register the booking or to process the rental contract to ensure that we continuously provide the highest quality service;
• Legal purposes: Finally, in some cases, we may need to use your personal data to resolve certain legal disputes, to fulfill our legal obligations or for any investigations by public authorities.

If you are an employee/representative/employee of a VIA RENT A CAR collaborator, we will process the personal data provided by you in order to conduct our specific business, and this will include:

• Conducting our activity: performing various tasks and services in connection with the performance of rental contracts concluded with our customers or for support services ancillary to our specific activity (e.g. performance of contracts concluded with your employing organization or the one you represent or concluded with you directly).
• Fraud detection and prevention: In order to provide a secure and trustworthy service to our customers, we use your personal data to detect and prevent fraud and other illegal or unwanted activities.
• Legal purposes: Finally, in some cases, we may need to use your personal data to resolve certain legal disputes, to fulfill our legal obligations or for any investigations by public authorities.

 6.WHAT IS THE LEGAL BASIS FOR THE PERSONAL DATA PROCESSING ?

  In order to process your personal data in this way, we rely on the following legal grounds:

• The performance of a contract to which you are a party: We need to use your personal data to fulfil any contract you have entered into with us. For example, when you book a car or when you represent an entity with whom we have entered into a contract, you must provide us with certain information about yourself in order to enter into the contract.
• Legitimate interests: We may use your information for our "legitimate interests" (a term that applies to any activity that we believe is an essential part of running our business effectively) while respecting your rights and the law. For example, to provide you with the most appropriate content on our platforms, to improve and promote our products and services.
• Fulfillment of legal obligations: We may use your personal data for the administrative and legal aspects of our business. For example, if we are required to collect certain information about our customers for tax or accounting purposes or if we are required to submit information to the courts of law or to regulatory authorities.
• Consent: We may rely on your consent to use your personal data in certain circumstances, for example for direct marketing purposes, to contact you to complete a booking or to obtain your review of the quality of the services we provide.

You can withdraw your consent at any time by sending a request to this effect to hello@viarentacar.ro mentioning "Privacy" in the subject line.

 7. WHO ELSE HAS ACCESS TO THE PERSONAL DATA

 There are a number of different business partners integrated into the services we provide, and, in certain situations, we may disclose your personal data to them. We will also disclose your data to other third parties, which may include the payment service providers, advertising partners and - in some cases - the public authorities.

• Our business partners: We work with business partners around the world. Some of our partners offer or promote our services and help other business partners offer and promote their own travel-related services (including insurance). Similarly, we may send our business partners some personal data relating to your booking if you have collaborated with them to make your booking. If the business partner provides customer service support, we will send them the details of your booking that they need in order to provide you with the support you require. In either case, the management of your personal data is governed by the privacy notices of these business partners
• Competent authorities: We may also disclose the personal data to the public or investigative authorities if we are required to do so by the law (or any regulation having the status of a law). This includes the courts of law, the civil and/or criminal investigation bodies, subpoenas, and orders arising from legal proceedings and investigations. We may also disclose your personal data if strictly necessary for the prevention, detection or prosecution of fraud and other criminal acts. And we may need to disclose personal data to the appropriate authorities to protect and defend our rights or property and/or the rights and/or property of our business partners.
• Third-party service providers: We may use third party service providers to process your personal data on our behalf. For example, we may use them to bill you for the services provided to you or by us to you, to arrange payments, payment guarantees, or payment returns.

We will check any third party we come into contact with to ensure that they can provide us with sufficient guarantees regarding the privacy and security of your personal data.

We will enter into written contracts with them in which there will be provisions to ensure their protection of your personal data and their compliance with the applicable law, and our data security standards and the international transfer restrictions.

  8. THE TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Please note that there may be situations where we transfer the personal data that we process to countries outside the European Economic Area ("EEA"), for example, when one of our service providers uses personnel or equipment located outside the EEA - for example, a cloud service provider located in the United States of America. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights, and freedoms and with respect to the exercise of your rights, e.g., we establish an adequate level of data protection, usually through EU Standard Contractual Clauses based on model clauses issued by the EU Commission or other available mechanisms. Should you wish to consult a copy of any relevant provisions, please contact us.

 9. HOW WE ENSURE THE SECURITY OF YOUR DATA

 Our business systems and procedures have been drawn up to include all the reasonable measures to protect your personal data and safeguard it against unauthorized access or destruction, in accordance with the Romanian and European data protection legislation. We also have specific security procedures and restrictions (both technical and physical) that limit the access to and use of any personal data we hold. Only the authorized personnel may access personal data and only for specific, authorized reasons. While we try our best, we cannot guarantee the security of the information. However, we are committed to notifying the appropriate authorities of data protection breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we lawfully and reasonably can to prevent breaches of security and to assist the authorities should breaches occur.

 Policy towards minors

We do not provide services to children under the age of 18 and reserve the right to delete any information we may receive from a child under this age. We may receive information about children in certain situations, such as an insurance claim or customer service dispute. If this happens, we will only collect and use that information with the consent of the child's parent or guardian.

 10. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will keep your personal data for the periods set out in the documents you enter into with VIA RENT DRIVE SRL in view of the purpose(s) for which it was obtained and in accordance with what is set out in this Information Notice. The criteria used to determine the lengths of retention periods include:

1. The processing (including the storage) shall be conducted for the duration of the validity of the contracts, but also after termination of the contractual relationship for the period of the statutory or contractual limitation period, including the period until the full recovery of any damage incurred by VIA RENT DRIVE SRL.

If you have given your consent to the processing of personal data for direct marketing purposes, your data will be processed for this purpose for the duration of the contractual relationship with VIA RENT DRIVE SRL, and for a period of 1 year after its termination. If you withdraw your consent to the processing of your personal data for direct marketing purposes, your data will no longer be processed for this purpose from the moment you withdraw your consent, without such withdrawal of consent to affect the lawfulness of previous processing operations.

1. The processing of data through the recording of images captured by video cameras and voice processing is kept for a period of 30 days (randomly) from the date of their recording.
2. The data captured by the GPS monitoring system is kept for 6 months from the time of collection.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider whether and how we can minimize over time the personal data we use and whether we can anonymize your personal data so that it can no longer be associated with you or identify you, in which case we may use this information without further notice.

 11. CONTACT INFORMATION

 VIA RENT DRIVE SRL

E-mail: hello@viarentacar.ro 

 We also inform you that the National Authority for the Supervision of Personal Data Processing ("ANSPDCP") operates in Romania and that you have the right to lodge a complaint when you consider that your rights have been breached by visiting the website www.dataprotection.ro.

 The Supervisory Authority

National Supervisory Authority for Personal Data Processing

Website: http://www.dataprotection.ro/
E-mail: anspdcp@dataprotection.ro
Telephone: +40 21 252 5599