- 1. Who processes your personal data collected through this website?
- 2. For what purposes does Executive Trust Limited collect your personal data?
- 3. Who are the data recipients of the personal information we collect about you?
- 4. For what period will Executive Trust Limited retain your personal data?
- 5. What rights can you exercise with respect to the processing of your personal data?
- 6. Who to contact when you have a query regarding the processing of your personal data?
- 7. How does Executive Trust Limited protect your personal data?
- 8. What rules apply to the processing of your personal data when clicking on links placed on Executive Trust. Limited website directing to Executive Trust Limited partner's websites or other websites?
1. Who processes your personal data collected through this website?
Executive Trust Limited trading as Van Rental Ireland ("VRI"), whose registered office is located at 35 Northwood Court, Northwood Business Park, Santry, Dublin 9 Ireland (hereinafter referred to as "VRI") is responsible for the processing of your personal data (i.e. any information that would allow to identify you, either directly or indirectly) collected through this website.2. For what purposes does VRI collect your personal data?
VRI processes personal data that you voluntarily provide to VRI through this website for the following purposes:
a) Your registration as VRI member, creation of your account and providing you with a VRI ID. This processing is necessary to identify you and to prepare and facilitate your future booking / rental agreements with VRI.
b) Your booking and your car rental agreement:
i. to confirm and guarantee your booking;
ii. to modify or cancel your booking;
iii. to exchange with you in relation to your booking / rental (e.g. to provide you with information on your booking / rental, to send you reminder notice before your check-in / check-out, to respond to your questions or suggestions);
iv. to manage your rental (delivery and return of the vehicle);
v. to manage your invoices;
vi. to manage the payment of arrears;
vii. to manage potential claims;
viii. to manage the recovery of potential damages to VRI vehicle;
ix. to manage your insurance.
This processing is necessary for the booking and the performance of the rental agreement concluded with VRI.
c) Your payment for VRI products / services.
This processing is necessary for the performance of the rental agreement. For your full information, VRI can only retain your credit card information, subject to your express consent in order to facilitate future payments.
d) The improvement of VRI products / services on the basis of customer surveys you have completed.
This processing, aiming at having a better understanding of VRI members' needs and offering you customized functions to enhance your experience of VRI products / services, is based on VRI's '"legitimate interest".
e) The operation of VRI live web chat to provide you with preliminary online assistance.
This processing, aiming at creating more proximity and establishing a closer relationship with you by notably answering more quickly your queries, is based on VRI"legitimate interest".
f) Promotional and marketing activities, namely:
i. the sending of email and SMS notifications for special promotions / deals;
the recording of your rental history to suggest you preferred products / services when looking for new booking / rentals
ii. the recording of your rental history to send you special offers and make you benefiting from special advantages depending on your volume and frequency of your orders;
iii. the sending of emails about a booking you did not complete or send you a summary about a booking enquiry;
iv. the management of your loyalty program and membership card;
v. the organization of promotional contests / sweepstakes;
vi. the management and update VRI's customers / prospects database.
Direct marketing processing activities, i.e. any commercial message from VRI aiming at promoting VRI products / services, are subject to your express consent.
By exception, if you are already an VRI existing customer and that the message concerns products / services similar to those you have already purchased, the underlying processing aiming at promoting these products / services will not be based on your consent but on VRI "legitimate interest".
g) The management of fines, in particular:
i. to transfer to the Transport Infrastructure Ireland or it’s nominated servants or agents in respect of tolls, An Garda Siochana in relation to driving offences or Council Authorities in respect of parking violations the identity of the driver (or potential driver);
ii. to satisfy fines collection procedure to which VRI may be subject.
This processing is required by law.
h) The management and update of a watch list of customers presenting certain contractual risks based on:
i. payment incidents which have given rise to legal proceedings;
ii. vehicle accidents or repeated damages caused by VRI customer;
iii. accidents or damages caused voluntarily by VRI customer;
iv. use of VRI vehicles in breach of the general terms and conditions for rental of vehicles.
This processing, aiming at reducing VRI risks exposure in the performance of the rental agreements, is based on VRI "legitimate interest". Should you appear on VRI watch list, your booking / rental request will be rejected. As the case may be, you will be entitled to contest such decision by contacting firstname.lastname@example.org.
The following data points are collected from each vehicle tracked by VRI through services provided by a Telematics Service Provider:- position, speed, acceleration, impact data (location, g-force and direction of impact) and the identifier of the device in the vehicle.
This data is collected for the following reasons: -
- Detection and prevention of loss or theft of the company vehicles
- Management of insurance claims
- Identification of unauthorised vehicle movements
- Monitoring and improving customer driving behaviour
- Management of vehicle inventory The Telematics Service Provider uses data hosting service providers in Europe to host the information it collects, and use technical measures to secure data.
- The Telematics Service Provider will only process personal data in accordance with VRI’s written instructions (including when making an international transfer of personal data) unless required to do so by law.
- The Telematics Service Provider will ensure that people processing the data are subject to a duty of confidence and will take appropriate measures to ensure the security of processing.
- The Telematics Service Provider will only engage a sub-processor with the prior consent of the data controller and a written contract.
- The Telematics Service Provider will assist VRI in providing subject access and allow data subjects to exercise their right under GDPR.
- The Telematics Service Provider will assist VRI in meeting its GDPR obligations in relation to the security of processing, the notification of personal data breaches and data protection impact assessments.
- The Telematics Service Provider will delete or return all personal data to VRI as requested at the end of the contract.
- The Telematics Service Provider will submit to audits and inspections, provide VRI with whatever information it needs to ensure they are both meeting their Article 28 obligations, and tell VRI if it is asked to do something infringing the GDPR or other data protection law of the EU or a member state.
The Telematics Service Provider and VRI will adhere to the following obligations under GDPR law:-
For your full information, VRI carries out certain processing of your personal information through "cookies" and other tracers collected every time you visit VRI website. These processing are governed by VRI Cookies Policy, which we encourage you to review. You can accept or reject these cookies and other tracers by following the instructions provided in VRI Cookies Policy.
3. Who are the data recipients of the personal information we collect about you?
3.1 Categories of recipients
Your personal data will be disclosed, as necessary / relevant, to:
b) third party IT service providers for technical purposes in order to help VRI in providing you with its products / services. The main IT service providers are:
i. Cap Gemini, for business applications development and maintenance;
ii. Sopra Steria, for data center maintenance and user support services;
iii. Unisys, for hardware implementation and maintenance;
iv. SalesForce, for automation marketing services;
v. Google Inc., in particular for hosting services and business applications.
vi. Rentalmatics for the provision of vehicle Telematics data and services.
vii. Capricorn Ventis for Business Intelligence application development
viii. Trilogy Technologies for IT Managed Services in the area of Helpdesk Support and escalation services
ix. Silveram Solutions for business application development and maintenance
x. GoCanvas for mobile forms capture
xi. Jimpisoft, Lda for Car Rental Management System
xii. Mailchimp for email communication
xiii. SurveyMonkey and Clear Market Intelligence for customer feedback surveys
xiv. Microsoft for email communication and productivity systems
c) regarding the information processed for the payment of fines, to Transport Infrastructure Ireland or it’s nominated servants or agents in respect of tolls, An Garda Siochana in relation to driving offences or Council authorities in respect of parking violations.
d) regarding the information processed for the purpose of the management and update of a watch list of customers presenting certain contractual risks, to the vehicle rental agencies branch of the Car Rental Council of Ireland to the benefit of their members
VRI can also disclose your personal data to the extent required by law and/or by competent authorities.
3.2 International transfers
As necessary to provide you with VRI services, VRI will, to the extent necessary for the purposes set forth herein, transfer your personal data outside the EU to the abovementioned third parties.
Depending on the case, certain recipients may be located in countries which have been recognized by the European Commission as ensuring an adequate level of data protection or in countries which has not been recognized as ensuring such a level of protection. In any case, VRI has put in place appropriate safeguards to protect your personal data, in compliance with the EU regulation no.2016/679.
To find more information regarding the countries where your personal data can be transferred, their level of data protection and the potential safeguards put in place by VRI please contact us in accordance with Section 6(a) of this policy.
Your personal data are retained for different period, depending on the purposes of the processing:
|Your booking and your van rental||For the duration of the commercial relationship. However, information that may evidence a right or a rental agreement, or that must kept in compliance with a legal requirement, may be subject to an intermediate archiving policy for a period of time that does not exceed the time that is necessary for the purposes for which it is kept, in accordance with applicable legal provisions.||Payment ̵ Payment card information||
Upon effective completion of the payment.
|Vehicles monitoring through the use of vehicle connected devices||All identifiable customer data is purged after 4 years unless it is still required under legislation. We own the information we collect in its aggregate and anonymized form and we reserve the right to use such aggregate, anonymized information without restriction.|
|Promotional and marketing activities||
|Cookies||Please check VRI Cookies Policy|
|Payment of fines||For the time necessary to identify the driver (or the potential driver) liable for the infraction leading to the fine. However, relevant information can be kept for a longer period of up to 12 months after receipt of the fine, subject to an intermediate archiving policy.|
||3 years as from the occurrence of the relevant event|
|The use of VRI vehicles in breach general terms and conditions for rental of vehicles||5 years as from the occurrence of this event|
||For the duration of the commercial relationship.
However, information that may evidence a right or a rental agreement, or that must kept in compliance with a legal requirement, may be subject to an intermediate archiving policy for a period of time that does not exceed the time that is necessary for the purposes for which it is kept, in accordance with applicable legal provisions.