Privacy policy for Europcar in Greece / KINSEN HELLAS SINGLE MEMBER SOCIETE ANONYME
The company “KINSEN HELLAS SINGLE MEMBER SOCIETE ANONYME”, with registered office is at 55 Stournari street, P.O 104 32, Athens, Greece (hereinafter called as the “Company”) is the franchisee of Europcar in Greece, operating, inter alia, in the provision of rent-a-car.
As part of the above-mentioned activity, we collect and process via this website (www.europcargreece.com) personal data about you, under this Personal Data Protection Policy.
1. Personal Data that we collect and process
The Company collects and processes various categories of Personal Data in connection with this website in order to allow you to benefit from the products and services provided by both the Company and its subfranchisees, throughout Greece, as well as by other Europcar franchisees internationally.
By Personal Data, we mean not only data that identifies you directly, but also data that identifies you indirectly like your Driver ID or the Vehicle Identification Number (VIN) attached to your rental vehicle.
The categories of Personal Data that we collect include the following:
-Your identification data: surname, first name, email address, date of birth, postal address, e-mail address, telephone number, place of birth, account identifier;
-If applicable, identification data of additional driver(s): surname, first name, email address, telephone number, postal address;
-Your driver's licence (driver’s licence number, issuing country, date of issue and expiry) and that of any additional driver(s);
-Payment data: account numbers, card numbers etc;
-Information on your vehicle reservation, in particular for the management of any loyalty programs;
-Data relating to your navigation on our website;
-Data relating to your satisfaction surveys.
2. Purposes of processing- Legal Basis of processing
The Company collects and processes your Personal Data for various purposes and on the following legal bases:
Purposes of the processing | Legal basis of the processing |
Creating and managing your online customer account on our website. | This processing activity is based on the acceptance of the terms and conditions of use of our website. |
Managing your reservation and rental contract through a central booking engine, in particular to: - collect the data necessary to organize your reservation; - communicate this data to our concerned sub franchisee or another Europcar franchisee operating the service; - manage your payment. | These processing activities are based on our legitimate interest to ensure the execution of the rental services contract that you enter into with our company or our sub franchisee or another Europcar franchisee. You can choose to register your credit card for your future bookings. |
Sending you emails about special offers and promotions to promote our products and services. | This processing activity is subject to your consent. |
Sending you an email in order to collect your feedback on your rental. | This processing is based on our legitimate interest to have a better knowledge of our customers' needs and to improve our services and customer service. |
Managing your loyalty program and third party partnership loyalty program. | This processing is based on the execution of the loyalty program terms and conditions. |
Compliance with obligations imposed by the relevant legislation in force. | This processing is based on our compliance with our legal obligations. |
3. Recipients of your Personal Data
3.1. Categories of recipients
Your personal data may be communicated to our employees and/or assistants, our franchisee network, our agents and intermediaries mandated to provide you with our products and services, as well as to our subsidiaries/affiliated companies or partners, and if necessary:
a. to the relevant sub franchisee or other Europcar’s franchisee that delivers your service;
b. to our subsidiaries/affiliated companies or partners, who will process your data as processors, exclusively for the purpose of servicing you and provided that they carry out lawful and fair processing;
c. to our subcontractors, in particular our IT service providers for hosting, maintenance or development purposes, who assist us in providing you with our products and services via this website. These may be external service providers;
d. marketing agencies, which are helping us collect and analyze your customer satisfaction;
e. to any of our partners, in particular to enable you to collect loyalty points when you are a member of their program. The list of our partners is available online.
We may also disclose your personal data in accordance with applicable laws and regulations to the relevant authorities.
The Company shall take all measures to ensure that personal data which may be transmitted are always the minimum necessary.
3.2. International transfers
In order to provide you with our products and services, we may use service providers located outside the European Union. In the event that the vehicle is booked abroad, data transfers will be carried out in the country in question in order to provide you with our mobility solutions.
Depending on the assumptions, some recipients may be located in countries recognized by the European Commission as providing an adequate level of protection of personal data or in countries that have not been recognized by the European Commission as providing such a level of protection. In any case, we have implemented appropriate protection measures to protect your personal data in accordance with data protection regulations.
4. Retention period of your Personal Data
Your personal data are kept for different periods of time, depending on the purposes of the processing concerned:
Purposes of the processing | Legal basis of the processing |
Creating and managing your online customer account on our website or mobile application. | 5 years from the end of the commercial relation, in particular from the end of your last vehicle rental. |
Managing your reservation and rental contract through a central booking engine, in particular to: - collect the data necessary to organize your reservation; - communicate this data to our concerned sub franchisee or another Europcar franchisee operating the service; - manage your payment. | 5 years from the end of the relevant rental. |
Sending you emails about special offers and promotions to promote our products and services. | - If you are a Europcar customer, 3 years from the end of the business relationship, in particular from the end of your last vehicle rental. - If you are not a Europcar customer, 3 years from the collection of your personal data OR from the last time you requested information from us. |
Sending you an email in order to collect your feedback on your rental. | 12 months from the data collection. |
Managing your loyalty program and third party partnership loyalty program. | For the time of your membership in the loyalty program and then until 4 years from the end of the validity of your loyalty points. |
Compliance with obligations imposed by the relevant legislation in force. | As long as it is required by the relevant legislation in force. |
5. Rights that you may exercise regarding the processing of your Personal Data.
Within the limits and conditions allowed by the regulations in force, you can:
- access to your personal data and obtain further information on the characteristics of the processing we carry out.
- have your personal data corrected, updated and deleted (“right to be forgotten”), it being specified that deletion can only be carried out when (i) the data is no longer necessary in relation to the purposes for which it was processed, (ii) you withdraw your consent and there is no other legal basis for the processing, (iii) you object to the processing of your personal data and there is no compelling legitimate reason for the processing (iv) it has been established that your personal data has been processed unlawfully, (v) the personal data must be deleted in order to comply with one of our legal obligations;
- object to the processing of your personal data for commercial prospecting purposes.
- receive, the personal data you have provided us with, in a structured, commonly used and machine-readable format (“right to data portability”), or request us to transmit them to a third party when the processing of your personal data (i) has been carried out by automated means and (ii) is based on your consent or on the execution of a contract binding us.
- request the restriction of the processing of your personal data, which means that we will not be able to use your personal data for a defined period of time. You can exercise this right when:
a) you contest the accuracy of your personal data for a period of time that allows us to verify the accuracy of your personal data;
b) the processing of personal data is unlawful and you oppose the erasure of your personal data and instead you demand that its use be restricted;
c) we no longer need your personal data but they are still required for the establishment, exercise or defence of legal claims;
d) you object to the processing for reasons relating to your particular situation, while we are checking whether our legitimate grounds override yours.
- object, on grounds relating to your particular situation, at any time to the processing of your personal data, in which case we shall stop processing it, unless we demonstrate compelling legitimate grounds for continuing the processing which override your interests, rights, freedoms or for the establishment, exercise or defence of our legal claims.
- withdraw your consent to processing based on your consent.
The exercise of the above rights acts for the future and does not concern data processing already performed.
6. How to exercise your rights
You may exercise your rights by contacting the email address info@kinsen.gr, or by post to the address, 71 Athinon Avenue, P.O 101 73, Athens, Greece free of charge, unless they are often repeated, in which case they have an administrative cost for us, which you will be relatively burdened with.
If you exercise any of your rights, we will take all possible measures to satisfy your request within thirty (30) days of receipt of the relevant request, after informing you either of its satisfaction or of the reasons that prevent its satisfaction. That period may be extended by two (2) further months, where necessary, taking into account the complexity of the request and the number of requests.
To exercise your rights, you must prove your identity by clearly indicating your surname, first name, booking ID and any useful information enabling us to identify you (such as the place and date of your last vehicle rental). You must also give us the e-mail address or the postal address to which you would like the reply to be sent to you.
You shall always reserve the right to address the Data Protection Authority, which may accept the submission of complaints either in writing to its protocol (1-3 Kifisias Avenue, P.O 115 23, Athens, Greece) or electronically (www.dpa.gr).
7. Protection of your Personal Data
The Company uses appropriate physical, technical and organizational security measures to prevent unauthorized or unlawful processing, accidental loss of or destruction of or damage to your personal data.
8. Links redirecting to our partners’ or other sites
On this website you may find various links to the websites of our partners (e.g. for travel services). We would like to draw your attention to the fact that Personal Data Protection Policy does not apply to the processing of your personal data by our partners or other third parties, which may occur when you visit their websites. The Company is not responsible for such data processing. If you would like information on how these partners and third parties process your personal data, we invite you to consult their Privacy Policies.
9. Changes to this information notice
