PRIVACY POLICY – SUMMARY

We are Autohellas Tourist and Trading Societe Anonyme and its subsidiaries operating under the Hertz, Thrifty, Dollar, Firefly and Hertz Operating Lease brands (together “we”, “us”, and “our”). This policy does not cover our affiliates or other third parties through whom you may interact with us. This is a high level summary to explain how we collect, processes, store and otherwise use information about you and your rights in relation to that information. For full information, please see the full policy below.

COLLECTION	PURPOSES
We collect information from customers or drivers during the process of reservation and rental transactions, long term rentals (operating lease) or car sale transactions, such as name, address, driving license, credit card information etc. We may collect information from you in a multitude of ways, including, but not limited to, phone calls, customer service contacts, websites and other sources, including third party service providers and business partners. We use “cookies” in our websites.	Information you provide will be used to provide you with the services you request. We will use the contact information you provide to communicate with you to provide these services. We may use your contact details to send you information about our products and services, where permitted by you. We use the cookies information for our own statistical purposes and to enable us to help our customers by improving our services and websites functionality.
SHARING	RETENTION & SECURITY
We may provide your information to designated third party service providers for the above purposes. We do not share your information to unrelated third parties but may, only with your permission, safely share your information with third party partners for marketing purposes. Your information may be transferred from the country where the services were provided to countries outside the EU such as the United States, for processing and storage in accordance with the applicable law and for the same purposes.	We use reasonable measures to safeguard Personal Data from theft, unauthorized use, disclosure, or modification. We maintain appropriate physical, technical, procedural and electronic safeguards to protect your Personal Data. We keep customer information for as long as it is necessary for the purpose for which it was collected or as allowed or required by you or by the law.
YOUR RIGHTS	QUESTIONS & CHANGES
You have all the rights according to the provisions of the (EU) 2016/679 Regulation and, generally, of the relative European and national legislation. Especially, you have the right to access, review or update the Personal Data we hold about you. In certain circumstances, you can also request rectification or erasure of your Personal Data, or reduction of our processing or object to certain processing activities. We will try our best to accommodate your request and the exercise of your rights, but we reserve the right to impose certain restrictions and requirements according to the law. Where we use consent as a basis for processing, you can always withdraw that consent.	If you have any questions or concerns about how we process your Personal Data, you may contact us as provided in the main Policy. We may modify this Policy at any time, but changes will not apply retroactively. This Policy was last updated on July 1st, 2019.

AUTOHELLAS HERTZ GROUP OF COMPANIES
CUSTOMER PRIVACY POLICY

SCOPE & CONTROLLERS

We are the Greek Company Autohellas Tourist and Trading Societe Anonyme, official franchisee of Hertz International for Greece and other seven (7) countries in which we are running business activities through our subsidiaries, as shown in the following table. Our activities include between others:

Short-term car or equipment rental services (rent a car, equipment rental)
Long-term car or equipment leasing and fleet management (operating lease)
Car maintenance and repair services
Used cars sales (wholesale and retail)

The commercial brands that we use are Hertz, Thrifty, Dollar, Firefly and Hertz Operating Lease (together “we”, “us”, and “our”).

#	Company	Country	Country Symbol
1	Autohellas Tourist and Trading Societe Anonyme	Greece	GR
2	Autotechnica Hellas S.A.	Greece	GR
3	Autotechnica (Cyprus) Ltd.	Cyprus	CY
4	Autotechnica Ltd.	Bulgaria	BG
5	Autotechnica Fleet Services SRL	Romania	RO
6	Autotechnica Serbia DOO	Serbia	RS
7	Autotechnica Montenegro DOO	Montenegro	ME
8	Anterra DOO	Croatia	HR
9	Autotechnica Fleet Services LLC	Ukraine	UA

Together we are the data controllers for the purposes of this Privacy Policy (“the Policy”).

This Policy covers the information we collect about you in connection with the abovementioned business activities, which identifies, or can be used to identify, directly or indirectly, you as an individual (“Personal Data”). It does not apply to information that cannot reasonably identify you. For example, but without limitation, aggregated anonymous data are not Personal Data.

We respect the privacy rights of our customers and are committed to protecting your privacy. This Policy explains our data handling practices with regard to your Personal Data, as well as your rights associated with that data.

Contents

Collection
Purposes
Sharing
Retention & Security
Your Rights
Questions & Changes

1. COLLECTION

We collect Personal Data that you provide during the execution of our services, on our websites, on third-party websites, on applications that we use in order to provide our services, in connection with any inquiries, reservations, rentals or purchases you make in relation to our services. We may collect your Personal Data directly or through our service providers, our subsidiaries, our franchisor, business partners and booking channel providers. For further details, see below:

1.Α. TYPES OF INFORMATION COLLECTED may include, but are not limited to:

1.Α.1. Personal Information:

full name
date and place of birth
gender
address
email address

mobile phone number
passport number
driving license or other
ID card
credit scoring and history

1.Α.2. Technological Information:

IP address
device ID
IP address
browser type
operating system
mobile device identifiers
geo-location data
state or country from which you accessed our websites

specific webpages visited
date and time of a visit
websites you visited immediately before and after visiting our websites
number of links and specific links you click within our websites
functions you use on our websites
any reservations, updates, purchases or other transactions through our websites
data you view or download from our websites
number of times you view any particular advertisements

1.Α.3. Rental Information:

booking location
rental location
return location
rental duration
frequent flyer number

payment card information
additional driver data, if any
insurance coverages
extra preferences
charges incurred

1.Α.4. Sensitive Data:

We may collect certain Personal Data that constitutes sensitive data in some countries, such as (indicatively but not limited to):

data related to health conditions (for instance, if there is an accident and we need to work with insurance and claims management companies relating to any injury you may incur)
credit scoring history data (for instance, in case of long-term car rental or car sale with installments) etc.

Please note that in case that it is needed to provide sensitive data within the framework of our provided services or purchases from us, we will use that sensitive data for our operational uses as described in this Privacy Policy, subject to your consent where required under applicable law.

1.Β. METHODS AND SOURCES OF COLLECTION may include, but are not limited to:

1.Β.1. Online collection:

from our websites
from websites of third party partners or the website of our franchisor
from our self-serve info-kiosks
from your internet browser
from our official pages in third party social networks

1.Β.2. Cookies and online data collection

We use cookies on our websites to store information in your computer or mobile device to improve your online experience. Cookies are small text files which let you navigate between pages efficiently, help us understand how this website is performing and generally improve your browsing experience. Cookies can also help to ensure the advertising you see online is more relevant to your interests.

Generally, our cookies may perform the following functions:

Essential cookies	Some cookies are vital to the operation of our websites. Without them you will not be able to navigate in the web site and to use some of its features. The basic cookies allow smooth transition from page to page on the site and are absolutely necessary for its appropriate functioning.
Functionality cookies	We do not use functionality cookies and we cannot remember your preferences and selections you have requested in previous visits to our sites.
Performance cookies	We use performance cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. These cookies don’t collect information that identifies a visitor. All information collected is aggregated and therefore anonymous and is only used to improve how our website works.
Advertising Cookies	We use cookies to serve you with advertisements that we believe are relevant to you and your interests. They are used to limit the number of times you see an advertisement as well as to measure the effectiveness of the advertising campaign. We may also use cookies placed by advertising agencies who may record that you have visited this website and share that information with other advertising organisations to enable targeted advertising to be sent to your computer.
Third Party cookies	Third party cookies are set by a different organisation to Hertz. For example, our websites may contain content embedded from, for example, YouTube, and banners delivered for Hertz through an advertising partner’s network. These sites may set their own cookies which are beyond of our control.

1.Β.3. How you can manage the use of cookies

In case that you wish to activate or deactivate the use of cookies from your browser’s settings, depending on your web browser you can visit the following web pages in order to obtain the appropriate information:

1.Β.4. Note

Our websites are not directed to individuals under the age of 13 and we do not knowingly obtain Personal Data from such individuals.

1.Β.5. Off-line collection:

from calls to or from our reservation call center, customer service, emergency road-side assistance, customer contact or member care centers
from interaction with our various licensees, affiliates and subsidiaries, including car sales and other businesses
from in-person at rental locations or leasing contracts establishments
in connection with a reservation (even an abandoned or interrupted reservation), a rental of a vehicle or equipment, or your purchase of a vehicle or equipment
from reservations you make with us through licensees, travel agents or brokers, online or in-person

from transactions you complete with us, our licensees and agents, including options you take, charges you incur and any incidents or accidents that may occur
from other companies that have business relationships with us, such as our affiliates and business partners, including airlines, hotels, and insurance companies
from companies that provide credibility information

Depending on the purposes for which we collect and use your Personal Data, as set out in this Policy, the Personal Data we collect from you may be required due to a statutory or contractual obligation, or provided by you on a voluntary basis, or necessary for us to enter into a contract with you and provide you with our services. If you do not provide your Personal Data to us we may not be able to provide the requested services (renting, leasing, maintenance, sales etc.).

2. PURPOSES

Below we have set out the various purposes for which we process your Personal Data. We have also set out the legal grounds for the processing of your Personal Data for each purpose:

2.1. OPERATIONS AND SERVICES: We may use your Personal Data to provide you with the services or products you request from us and to perform other activities related to such services or products, including billing and collection following a rental or leasing, or to communicate with you regarding:

any reservation you initiate or rental transaction you perform with us
issues related to the safety, maintenance and insurance coverage of the car that you rent with us
issues related to the safety and maintenance of the car that you have purchased from us.

Legal grounds: to perform our contract with you or to take steps at your request prior to entering into a contract with you.

2.2. OUR MARKETING: With your consent, we may use your Personal Data to provide you with marketing information, customer satisfaction or services assessment surveys, special offers and promotions via various means, including e-mail and SMS messages, in accordance with applicable law.

Legal grounds: on the basis of your consent. However, where permitted by applicable law we may lawfully use your Personal Data to send you such marketing communications (including via email) for these marketing purposes where necessary for our legitimate interests, which include promoting our products and services, special offers and promotions which may be of interest to you.

You can unsubscribe from receiving such messages at any time by contacting us at the details at Section 6 below as well as by the unsubscribe link in each e-mail message. Please note that if you exercise these choices, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that this unsubscribe process may take some time to complete, consistent with applicable law.

2.3. THIRD PARTY MARKETING: We may also share your Personal Data with a sponsor or other third party that provides you with special offers or promotions that may be of interest to you (“Third Party Provider”) where permitted.

Legal grounds: on the basis of your consent. You may instruct us at any time not to share your Personal Data covered by this Policy with such Third Party Providers where you have previously consented.

2.4. NORMAL COURSE OF BUSINESS: We may also process your Personal Data and other information if such processing is necessary:

to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process;Legal grounds: where it is necessary for compliance with a legal obligation to which we are subject
to protect the interests, rights, safety, or property of us or others.Legal grounds: where necessary for our legitimate interests, which are to protect such interests, rights, safety and property;
to enforce any terms of service on our websites or the terms and conditions of any rental, purchase, or utilizationLegal grounds: for our legitimate interests, which are to protect us and enforce such terms of service or terms and conditions.
as part of a business transaction where all or some of our assets are bought, sold, or otherwise transferred by act of law or contract; andLegal grounds: for our and third parties’ legitimate interests.
to operate our systems properly.Legal grounds: for our legitimate interests, which are the proper running of our systems and our business in order to provide our products and services to you and other customers.

2.5. WEBSITES: If you use our websites we may process your Personal Data as follows:

Aggregated or anonymized information: We may share with other third parties aggregate or anonymized information about our website users, such as your use of this website or other websites, and the services provided on this website or other websites, as well as any rental, purchase or utilization information.
Social Media: If you participate in certain public features of our websites, apps, or social media websites/apps, please note that any information you or others voluntarily disclose through use of such features, becomes available to the public and/or other users whom you have designated.If you choose to provide access credentials to designated individuals, please be aware that any information you provide to us may be visible to such individuals. .
We are not responsible for the information that you or others choose to disclose publicly and such information is not subject to this Policy.
Links to third parties: We may provide links to third-party websites or may be linked to third-party websites. Since we do not control third-party sites, and we are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing applicable third-parties with your information.

3. SHARING

3.Α. THIRD PARTY COMPANIES

We may share your Personal Data with third parties in the following circumstances:

3.Α.1. To provide services to you: We will share your personal data among ourselves, our agents, our licensees and other companies to provide services to you, including among others

to make your rental reservations
to process and/or confirm your transactions
to provide you with customer assistance

to bill and collect amounts owed in connection with your rentals
for customer satisfaction surveys and market research purposes
to help us improve our services

3.Α.2. Disclosure to companies you use: We will also share your information with companies you use in connection with your rental, including:

your credit card provider and other companies that process your charges
any intermediary you use, such as a travel agent or broker, in relation to any aspect of your rental

any operator of a membership program for which you are rewarded for renting with us, such as a frequent flyer program
any authorized car service centre which may provide car maintenance and repair services

3.Α.3. Protective and legal uses: We may use, share and disclose your personal data for legal reasons as we believe necessary or appropriate, including among others to:

comply with applicable law, including laws outside your country of residence
process, handle or otherwise respond to claims for damages, including for bodily injury or property damage
comply with legal and insurance process
respond to requests from public and government authorities including those outside your country of residence

apply our terms and conditions
recover our vehicles or any monies due, such as debt collection agencies
protect our operations or those of any of our subsidiaries
protect our rights, privacy, safety or property, and/or that of our subsidiaries, you or others
allow us to pursue available remedies or limit the damages that we may sustain

3.Α.4. Disclosure to our service providers and agents: We may use other companies as our service providers or agents to act on our behalf and assist us in the conduct of our business, performing services for us under our instruction. These services may include hosting certain websites or databases, operating “apps” for us on our social media networks’ pages, running contests, sweepstakes and other promotions for us, sending marketing communications, carrying out data analysis and conducting customer satisfaction surveys or other researches. We will always require our service providers and agents to maintain appropriate security standards to protect your personal data and use the personal data we provide to them only for the purposes we specify and according to law.

3.Α.5. Disclosure for corporate transactions: We may disclose your personal data to a third party in connection with any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

3.Β. INTERNATIONAL TRANSFERS

Some of the uses and disclosures mentioned in this Policy may involve the transfer of your Personal Data to various countries around the world that may have different levels of privacy protection than your country of residence or interaction with us, such as when you request rental services to be provided to you in a country outside the European Union (“EU”).

Where our transfer of your data is necessary to provide rental services requested by you, the legal basis for the transfer is the contractual necessity of the transfer, and your Personal Data will be processed by the company providing the services you requested in accordance with applicable local law and the relevant bi-country agreements.

Where we transfer your Personal Data to a third party outside the European Union and no legal basis applies, such as where we transfer the data to a company processing it to our instruction to enable us to provide our services, we will ensure that the required safeguards are in place for the transfer.

4. RETENTION & SECURITY

4.Α. DATA RETENTION

We retain personal data about our customers for as long as necessary for the purposes for which it was collected, or unless otherwise allowed or required by you or by law. We collect Personal Data for a number of purposes (see above) and may be required to retain it for legal (including tax, civil or other legal regulations) reasons for a period which is longer than the time we need or use the data for the purpose of providing our rental services to you. We maintain a data retention policy to cover all the Personal Data we retain across our systems. If you have any questions about the retention period applying to the Personal Data we collect about you, please contact us (see Section 6).

4.B. SECURITY MEASURES

Information is stored and accessed in various locations, including cloud services. Servers which store information are primarily located in Greece, Europe and the United States, although storage may occur in other locations as well. We use reasonable administrative, technical, personnel, and physical measures (a) to safeguard Personal Data against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of your Personal Data. To help us protect your privacy, you should maintain the secrecy of any logon IDs and passwords, Member numbers, or other identifiers or credentials you may have set up or were provided with in connection with your participation in or use of our products, services, or websites.

4.C. TRANSMISSIONS

As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted. If you have reason to believe that any account with us is no longer secure, you must immediately contact us.

We try to strike a balance between the security of your data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative. For example, but not limitation, we may send you an e-mail or a text message in unencrypted form (i.e. instantly readable) because many of our customers are unable to access encrypted (i.e. coded) e-mail or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. Such messages may contain Personal Data. Please do not include confidential information, such as your credit card number or account passwords, in any e-mail or text you send to us or on any posting you make to a public area of a third-party social network page, especially since any such posting immediately becomes public. For a more secure way to communicate with us over the Internet, please click on the “Contact Us” link on any of our websites.

5. YOUR RIGHTS

5.Α. You have all the rights according the provisions of the law. Especially, you have the right to request access to, review, and update your Personal Data covered by this Policy, and can request this by contacting us at the details set out in Section 6 below. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws. If you are a member of one of our membership or rewards programs, you may update the information in your member profile by logging into your applicable member profile.

5.B. Among others, you also have the right to:

request rectification of your Personal Data where the information that we hold about you is incorrect or incomplete;
object to the processing of your Personal Data for direct marketing purposes, including profiling to the extent it relates to direct marketing;
object to the processing of your Personal Data where our legal basis for that processing is that such processing is necessary for our legitimate interests, subject to any overriding legitimate grounds that we may have for the processing;
object to automated decision making (including profiling) in certain circumstances;
request erasure of your Personal Data in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for and there is no compelling reason for us to continue to process or store it;
request restriction of your Personal Data in certain circumstances, such as that we do not process certain of your Personal Data (other than merely by storing them) following a rental in circumstances where all matters relating to the rental have been completed and the data is being stored only to meet certain legal (e.g. tax) requirements; and
receive or ask us to transmit to another organization your Personal Data that you have provided to us which we process by automated means where our processing is either based on your consent or is necessary for the performance of a contract with you.

5.C. In addition, where we process your Personal Data on the basis of your consent, you can withdraw that consent at any time.

You can make a request to us to exercise any of these rights by contacting us as set out in Section 6 below.

6. QUESTIONS & CHANGES

6.Α. CONTACT US: We do business in many countries and aim to comply with the privacy laws applicable to the Personal Data we collect and use. Should you have a concern or request about our handling of your Personal Data, you may contact us directly via the methods described below. We will work to respond and resolve your complaints in an expeditious manner. You also have the right to lodge a complaint with a competent data protection supervisory authority in your jurisdiction.

Please contact us by emailing at gdpr@hertz.gr or writing to the address below if you have any questions, wish to exercise your rights of access, or seek other assistance as described above.

General Data Protection Regulation
Autohellas Tourist and Trading Societe Anonyme
31 Viltanioti Str., Kifissia
14564
Attica, Greece

6.Β. CHANGES: We reserve the right to change this Policy at any time for any reason by posting revisions on this webpage or on applicable apps or other sites. Such changes will be effective upon posting, but will not apply retroactively.

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