PRIVACY NOTICE
This Privacy Notice in connection to personal data (also referred to as the "Notice") is intended to inform our Clients about how ALEKSIA AUTO Ltd. ("we", "us", "our") collect and process personal data in the course of car rental activities.
GENERAL PROVISIONS
Please note that according to the legislation, including EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, in force since 25 January 2018 ("the Regulation"), "personal data" (hereinafter referred to as "data" or "your data") means any information or set of information through which, directly or indirectly, your identity can be established, in particular through the use of an identifier, such as name, identification number, e-mail address, telephone number, location data, etc., or through one or more specific signs connected to to your physical, economic, cultural or social identity signs.
Administrator of your data in connection with the reservation and/or rental of Green rent-a-car is ALEKSIA AUTO Ltd., UIC 202516238, with registered office and address of management: 8200 Pomorie, 17-19 Evropa Street. Contact details and ways to contact us are listed at the end of the Notice.
WHAT KINDS OF DATA DO WE COLLECT AND FOR WHAT PURPOSES?
When you contact us, whether in our Client center or through our Website greenrentacar.bg, we may receive directly from you or ask you to provide us with certain information about yourself. In most cases, we require your personal data for the purpose of concluding an Agreement, to comply with a legal obligation or to protect our legitimate interest. Without this information, we would not be able to make a reservation or enter into a car rental agreement with you. Of course, for some of our services, you provide us with this information by choosing and agreeing to send us information about yourself. If you share with us data of other persons (for example, data of an additional driver or accompanying persons in connection with the conclusion of additional insurance), you are responsible for collecting this data in accordance with legal requirements and the obligation to notify persons whose data you provide to us and acquaint them with the Notice.
Depending on the services you use, we may collect and process the following information about you:
| Data categories | Data types | Purpose of use |
|---|---|---|
| Personal identification data | Identity card or passport data - names, PIN or date of birth | To identify you when booking or concluding rent agreement and in compliance with regulatory requirements. |
| Identity document details | Identity card number or passport number, date and place of issue, validity term | In connection with the conclusion and implementation of a rent agreement. |
| Data from the driving license | Document number, date and place of issue and term of validity, data on acquired legal capacity | In connection with the conclusion and implementation of a rent agreement and to comply with regulatory requirements. |
| Address | Permanent address, as well as address of residence in the country if you are a foreigner | Opportunity to contact you in connection with the implementation of the rent agreement To protect the legal interest. |
| Contact information | Phone number and e-mail address | Opportunity to contact you in connection with the conclusion and performance of a contract, for example by sending you a confirmation of the reservation or we will contact you if necessary. |
| User profile data | Username, e-mail, password | For the purpose of creating a profile and personal settings and managing the services used. |
| Financial data | IBAN/account number, credit/debit card |
Issuance of financial and accounting documents related to the reservation and/or concluded contract, such as invoices and bills and in connection with payment for the services provided. |
| Data about your health | Information about your health, including information about illness or disability | Conclusion of additional insurance, requiring prior information provided with your consent. Settlement of insurance claims or other claims related to damages caused during or in connection with the performance of a rent agreement. |
| Traffic data | Information about your device, date and duration of access, information about the browser and the information system you use, IP address | To protect the interests of the Company to ensure the security of our internal communications and systems, protection against viruses and other malicious programs. To obtain information about the traffic on our site. |
| Positioning data | GPS tracking of rented cars | To protect the interests of ensuring the security of our property and the implementation of the contract.. |
| Video recording | Your images of general video surveillance recordings of certain parts of our customer centers or car parks | ЗTo protect the interests of ensuring the security of property, information and premises, as well as ensuring the security of employees and visitors.. |
| Audio recording | Record your voice when calling the national contact phone | In connection with the activities of providing our services and customer service. |
ON WHAT LEGAL BASIS DO WE PROCESS YOUR DATA?
In order to be able to process your data, the Company refers to various legal grounds, including:
• or concluding and executing a lease agreement or the related services we provide to you;
• to comply with our regulatory obligations, such as obligations under tax law or the need to provide information to administrative or judicial authorities;
• for our legitimate interest, including in ensuring the protection of premises, property, networks and information, employees and visitors;
to establish, exercise our rights under, or to defend ourselves against legal claims;
• Your explicit consent (only when required or permitted by law), such as the use of certain types of cookies or the sending of promotional offers, surveys to evaluate the services we provide, and more. If the Company invokes your consent as a legal basis to process your data, you may withdraw your consent at any time.
WITH WHOM DO WE SHARE YOUR DATA?
In carrying out our activities we need to share your data with some of the following categories of persons:
• Regulatory, state and judicial bodies
We may disclose and provide your data to the competent state authorities in the manner prescribed by law and in cases where there is a corresponding obligation to provide them. We may also disclose and provide your data to the competent state authorities in cases where we will bear certain administrative or property liability as the owner of the rented car - for example, in case of a violation of traffic rules from your part, established by technical means.
• Service providers
The category of your data is determined according to the necessity and nature of the assigned service - e.g. banks and other payment service providers with whom we arrange payments or payment guarantees, accountants, auditors and lawyers; service providers such as building and maintaining ERP or IT systems, hosting services; of private bailiffs in connection with the realization of the legitimate interests of the Company, in case of need for forced collection of amounts due by you.
• Business partners
The Company may provide your names, telephone and e-mail contact address to third parties, our suppliers or Clients with whom we provide our services.
The Company will provide your data to others if this becomes necessary to achieve the purposes of their processing after notifying you and obtaining consent, where applicable.
In all cases, we enter into written agreements with our service providers and business partners, requiring them to ensure the protection of your personal data.
Please note that our Website may contain links to other pages and social networks that we do not control and are not responsible for the way personal data is processed. It is recommended that you read the privacy policies and information on each website you visit. This Notice applies only to the data we collect through our Website or otherwise.
TRANSMISSION OF PERSONAL DATA OUTSIDE BULGARIA
We do not intend to provide your data to individuals or organizations outside the European Union. If this is necessary in exceptional cases, we will inform you in advance and take the necessary protection measures.
HOW LONG DO WE PROCESS YOUR DATA?
We process your data for as long as is necessary to achieve the purposes for which it was collected or until the expiry of the statutory deadline.
It is in our legitimate interest to retain certain of your personal information after the conclusion of the Agreement. According to the approved internal policy, the terms for storage of some of the categories of data are:
• 5 years from the performance of the Agreement - until the expiration of the statutory preclusive or limitation periods for filing claims;
• 10 years for accounting data;
• up to 3 months for audio and video recordings;
• up to 3 months for traffic data and geolocation data.
Notwithstanding the above deadlines, we will not delete data if it is necessary for the purposes of pending administrative or judicial proceedings or in the process of settling an insurance claim.
HOW DO WE PROTECT YOUR DATA?
In order to protect your data, we have taken and will continue to take the necessary measures in accordance with the applicable regulations and laws on personal data protection and data security, including requiring our service providers to apply the necessary measures to protect personal data and secure your data. Depending on the timeliness, implementation costs and nature of the data to be protected, we have implemented technical and organizational measures to prevent and prevent risks such as destruction, loss, alteration, unauthorized access, unauthorized or malicious use of your data.
AUTOMATED ALGORITHMS AND PROFILING
We do not use programs to automatically process your personal data and make decisions, including for your profiling.
WHAT ARE YOUR RIGHTS WITH REGARD TO THE PERSONAL DATA PROCESSED BY US?
СAccording to the provisions of the General Data Protection Regulation (EU 2016/679), you have certain rights in relation to your personal data, and you should keep in mind that some of these rights may arise and be exercised only on certain grounds of processing of your personal data, and some of your rights are subject to certain restrictions or exceptions.
In accordance with applicable law and under the conditions set out therein, you have the right to:
• access to your data;
You have the right to request information about whether we process your personal data, what categories, for what purposes, to whom we provide your data, etc. Based on your written request, we will provide you with a free copy of your personal data that we process. We reserve the right to charge a fee for providing additional copies in the event of excessive duplication of requests.
• request correction of inaccuracies in your personal data;
We undertake to correct or supplement inaccurate data upon receipt of the relevant request from you. We would like to remind you that it is your responsibility to ensure, to the best of your knowledge, the accuracy, completeness and timeliness of the information you provide to us.
• request a restriction on the processing of your personal data;
You have the right to request that we limit the processing in each of the following cases: if you dispute the accuracy of your data; if the processing is illegal, but you do not want the data to be deleted, instead you request a restriction on their processing; if we no longer need the data, but you require them to establish, exercise or defend legal claims; or if you have objected to the processing of data on the basis of a legitimate interest.
• request the deletion of your personal data;
You have the right to request the deletion of your data: when it is no longer needed for the purposes for which it was collected, when you withdraw your consent to processing and there is no other legal basis for processing or when you object to processing based on legitimate interest and this interest has no advantage over your rights. Despite your request for deletion, we have the right to continue to process your personal data in order to comply with our statutory obligations or when processing is necessary to establish, exercise or defend legal claims.
• to object to any processing of your personal data that is not based on the legitimate interests of the Company.
In this case, we will suspend the processing, unless there are convincing legitimate grounds for the processing, which take precedence over your interests, rights and freedoms.
• the portability of your personal data;
You may exercise the right of portability only in cases where the data is processed in an automated manner and when we process your data on the basis of your consent or on the basis of an Agreement to which you are a party. You should keep in mind that exercising the right of portability does not lead to the deletion of your data. Under these conditions, you have the right to receive your data in a structured, widely used and machine-readable format or to request that your data be transferred to another administrator, if technically feasible.
• in cases where we process your data on the basis of your consent, you have the right to withdraw your consent at any time;
In the event that you withdraw your consent, this will not affect the lawful processing of data prior to the withdrawal.
• to submit a complaint with the competent supervisory authority in case your rights have been violated or to go to court if you have suffered from illegal processing of your personal data.
If you believe that we do not process your personal data in accordance with applicable regulations, please contact us to clarify the matter. However, you have the right to submit a complaint with the Data Protection Commission or to seek protection of your rights in court.
DO YOU HAVE QUESTIONS OR DO YOU WANT TO FILE A COMPLAINT?
If you have any questions regarding the processing of your data or wish to exercise your respective rights, you can contact the Data Protection Officer:
• on the phone: 0885/ 889 100
• on site in the administrative office: Burgas, 19 Industrialna Str.,
• Monday to Friday 9:00 - 18:00 or
• e-mail: office@greenrentacar.bg
You can send your request or complaint in electronic or written form, and you have the opportunity to use the Request Sample, which you can get in any of our Client centers or download from our website (greenrentacar.bg).
In case of submitting a request / complaint by e-mail, it is necessary to start from the e-mail address with which you are registered in the information system of greenrentacar.bg and provided by you personally when booking or concluding a car rental agreement.
When submitting the request in writing, it is necessary to submit it in person or by explicitly authorizing another person with a notarized power of attorney.
If you believe that the Company processes your data illegally, you have the right to file a complaint to the Commission for Personal Data Protection at:
1592 Sofia
2 Tsvetan Lazarov Blvd.
e-mail: kzld@cpdp.bg
website: www.cpdp.bg.