Privacy Notice Portugal

Privacy Policy

 

This Privacy Notice explains how we collect, use and protect any information about you. It also informs you how to contact us if you have any questions in relation hereto and we will be more than happy to answer your questions. If you are interested in what we do with cookies and related technologies, please consult our Cookies Policy.

 

We may amend this Notice from time to time, therefore please check this Privacy Policy regularly for any updates.

 

We offer a wide range of online car rental services, including products and services such as insurance through our website, mobile applications, emails and text messages, social networks ("platforms") and in this regard we will need to conclude various service agreements. This Policy applies to all personal data we collect while performing the actions described above or when you contact us by email, live chat, phone or post.

 

1. Personal data

 

Personal data represents information targeting a person who can be identified by this data, or by corroborating or not with other information. Common examples of personal data processed by Klass Wagen during its daily operations include names, addresses, telephone numbers and other contact details, driving license, etc.

 

2. Personal data you provide us

 

a) If you are a client / potential client of KLASS WAGEN:

 

We cannot help you make a reservation or request an offer without receiving certain information from you. In order to obtain a reservation or a reservation offer, we ask you for the essential information which we need in order to provide you with the requested services. These may include the name, age, date and place of birth and contact details (email, address and phone number). It may include identification information such as passport, identity card and driving license, or information required for payments (card or bank accounts).

In addition, we collect information from your computer when you use one of our platforms, even if you do not make a reservation, and in this respect please also consult our Cookies Policy, available here. This may include the IP address, the browser you are using and the language settings.

If you contact us (for example, by phone, email or social networks), we will collect information provided to us from these sources as well.

After making the reservation, subject to your consent, we may ask you to provide a review to help us improve our services and help us ensure that future customers will benefit from quality services.

Personal data you provide us regarding other persons

You can make a reservation on behalf of someone else, for example, a friend, family member or colleague. In this situation, please make sure that this person is aware that you give us his/her details and that he/she accepted the way we manage the personal data (as described in this Notice). This is your responsibility.

Automatically collected personal data

When making a reservation, we record on which platform it was performed and how you reached our platform (for example, if you came from another site).

Even if you do not make a reservation, we may automatically collect certain information when you visit our platforms and in this respect please consult our Cookies Policy.

Personal data that we receive from other companies

We can also get information about you from the social network platforms, our business partners and other third parties. For example:

• We work with affiliated business partners in order to offer our services on other platforms. When you make a reservation on one of these platforms, we may share your personal data with them and they may share your personal data with us.
• Companies that provide the services you have reserved via our platforms may need to provide us information about you - for example, if your reservation leads to an insurance claim or a customer service dispute.

Our business partners can also send us information about you that can help us show you more relevant ads.

We can combine any of this information with the information you give us directly.

 

b) If you are a collaborator / representative / employee of a KLASS WAGEN collaborator:

 

We may obtain personal data about you when you provide a service for us or when you interact with us during our activity. The main categories of data we may process in these situations include: contact information (name, surname, home address, telephone number) or identification information (identity card, passport) or payment information (bank card or bank account).

Please see "Why do we collect and use your personal data?" for details.

 

3. Why do we collect and use your personal data?

 

a) If you are a client / potential client of KLASS WAGEN:

 

We ask for your personal data so we can be able to reserve your car and to ensure that you benefit of the best service available. These are the main reasons for which we collect your personal data but there are other reasons.

We can use your personal data in the following ways:

• Reservations: Firstly, we use your personal data to perform and manage your reservation (or any other product or service like insurance).
• Client service: Our client service team needs your details in order to be able to help you, for example, to make a reservation or to answer to any questions you have before, during or after the reservation.
• Client review: We can use your contact data to send you a short questionnaire about your reservation or to ask you to give us your feedback on one of our social media platforms (Facebook, Google). This helps us understand and improve our services. Your review helps future clients to make the right choice and it will help our business associates to improve their services. By sending a review you agree that such review can be published.
• Marketing activities: We also use your personal data for marketing activities, which will include: contact by phone, e-mail or SMS with information about the insurance products which you did not include in your reservation.
• Communication with you: There could be moments when we will contact you by phone, e-mail or SMS, to answer the questions and request addressed to us in order to detect and prevent fraud and other illegal and unwanted activities. Similarly, we can use your personal data in security and risk evaluation purposes, which may include verification of the users and reservations.
• Improving our services: We analyze the personal data to improve functionality and our online services quality and in order to improve our users whole experience. We always work to make our platforms more enjoyable and easy to use.
• Calls monitoring: It is possible to record the phone calls made to register the reservation or ongoing of the lease agreement in order to ensure that we continuously offer the best quality service.
• Legal purposes: Eventually, in some cases, it is possible to be necessary to use your personal data in order to resolve certain legal issues, to fulfill our legal obligations or for any investigation of the public authorities.
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b) If you are a collaborator / representative / employee of a KLASS WAGEN collaborator:

 

We will process the personal data you will provide to us, in order to perform our specific activity and this action will include:

• Performing our activity: Performing various tasks and services in connection to the implementation of the agreements concluded with our clients or for auxiliary support services to our specific activity (e.g. carrying out agreements concluded by your employer organization or which you represent or concluded directly with you).
• Detecting and preventing fraud: In order to offer a secure and trustful service to our clients, we use your personal data in order to detect and prevent fraud and other illegal or unwanted activities.
• Legal purposes: Eventually, in some cases, it is possible to be necessary to use your personal data in order to resolve certain legal issues, to fulfill our legal obligations or for any investigation of the public authorities.

 

4. What is the legal basis for the processing of personal data?

 

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

• Performing an agreement to which you are a party: We need to use your personal data to perform any agreement you have concluded with us. For example, when reserving a car or representing an entity with which we have entered into a collaboration agreement, you must disclose us certain information about you in order to be able to conclude the agreement.
• Legitimate interest: We can use your information for "our legitimate interest" (a term that applies to any activity we believe to represent an essential part for the efficient performance of our business activity), while respecting your rights and the law. For example, to give you the most appropriate content on our platforms, to improve and promote our products and services.
• Fulfillment of the legal obligations: We may use your personal data for the administrative and legal aspects of our activity. For example, if we are required to collect certain information about our clients for tax or accounting purposes, or if we are required to provide information to the courts or to the regulatory authorities.
• Consent: We can rely on your consent to use your personal data under certain circumstances, for example for direct marketing purposes, to contact you in order to finalize a reservation or to find out your review of the quality of the services offered by us. You may withdraw your consent at any time by submitting a request to [email protected] by mentioning "Privacy" in the subject.

 

5. To which third parties we are disclosing your personal data and why?

 

There are a number of business partners integrated in the services we are providing and in certain cases, we may share your personal data with them. We will also disclose your personal data to other third parties, which may include payment services suppliers, marketing partners and in certain cases, to public authorities.

Our business partners: we are working with business partners from all over the world. Some of our partners are offering or promoting our services, helping also our other partners to promote their own travel related services (including insurance). Among our business partners we name the Booking Holding Inc group (Agoda.com, Booking.com, priceline.com, KAYAK and OpenTable). When you are performing a booking on their platform, they will send us part of the personal data you have provided to them. In a similar manner, we may disclose to them certain information related to your booking, if you have worked with them for the purpose of finalizing the booking. If the business partner is offering client support services, we will send him the details of your booking in order to provide you the support requested. In any of these cases, the management of your personal data will be governed by the privacy notices of those business partners. When you are making a booking on the website of one of our business partners, please consult also its privacy notice to determine how your personal data is being processed. When you are buying a product or service provided by one of our business partners, we will send them the personal data requested in order to provide you such product or service. In the end, it is also possible to exchange information regarding our users with our business partners in order to detect / prevent fraud, but only what is strictly necessary.

Competent authorities: We may disclose the personal data also with the public authorities or investigation bodies if we are required to do so by law (or by any regulation assimilated to a law). This may include court orders, subpoena, and orders arising from proceedings and legal investigations. We may also disclose your personal data if this is strictly necessary for preventing, detecting or solving cases of fraud and other criminal actions. It may also be necessary to disclose your personal data to protect our rights or property or the rights or property of our business partners.

Third party services suppliers: We may use third party services suppliers for processing your personal data on our behalf. For example, we may use your personal data for invoicing the services provided to us or by us, to organize payments, payment warranties or payment refunds.

We will check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your data. We will have written contracts with them which provide assurances regarding the protections that they will give to your data and their compliance with our data security standards and international transfer restrictions.

 

6. Do we transfer personal data outside the European Economic Area?

 

We also transfer the personal data we process to countries outside the European Economic Area (”EEA”), for example, when one of our service providers use staff or equipment based outside the EEA – e.g. a cloud services 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 the exercise of your rights, e.g. we establish an adequate level of data protection, usually through EU Standard Contractual Clauses based on the EU commission’s model clauses or other safeguards available. If you would like to see a copy of any relevant provisions, please contact us.

 

7. What security measures we apply to protect your personal data?

 

Our systems and procedures have been organized so as to include all the reasonable security measures necessary to protect your personal data against unauthorized access and destruction, in accordance with the Romanian and European legislation regarding personal data. Also, we have specific procedures and restrictions (technical and physical) limiting the access and use of the personal data we hold. Only authorized personnel may access such personal data and only for authorized and specific grounds.

 

8. How we are processing personal data of children?

 

We do not offer services for children under age of 18 and we reserve the right to delete any information we may receive from a children under this age. It is possible to receive information about children in certain cases, for example in case of an insurance claim or dispute in connection to the client service. If this happens, we will collect and use such information only with the consent of the child’s tutor or parent.

 

9. For how long we store your personal data?

 

How long we retain your personal information depends on the purpose for which it was obtained and its nature. We will keep your personal information for no more than the time required to fulfil the purposes described in this Privacy Notice unless a longer retention period is permitted by law. We have implemented appropriate measures to ensure your personal information is securely destroyed in a timely and consistent manner when no longer required. 

In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

 

10. What are your rights in connection to your personal data provided to us?

 

Except for certain cases provided by law and certain scenarios, depending on the processing activity we are carrying it out, you have the right to request access to, correction, or deletion of your personal data, as well as to ask for data portability. You are also entitled to object to the processing of your personal data in certain instances. If we process your personal data based on your consent, you may withdraw it for the future at any time. You can also lodge a complaint with a supervisory authority.

If you would like further information about your data protection rights, including rights about access to data and correction of inaccurate data, please contact us and send an email to [email protected]. We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

If you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the competent National Authority for Supervising the Processing of Personal Data, located at: 28-30 G-ral Gheorghe Magheru Blvd, 1st District, 010336, Bucharest, Romania, [email protected].

 

11. Who is responsible for the processing of your personal data on our platforms?

 

Klass Wagen Portugal LDA (operating under the commercial name of Klass Wagen) is controlling the manner in which your personal data is being processed, acting in capacity of controller in the sense provided by the applicable data protection legislation. Klass Wagen Portugal LDA is a private limited liability company, incorporated under the laws of Portugal and headquartered at Alameda dos Oceanos, Edifício n.º41 O, Piso 3, Escritório 32B, Código-Postal 1990-203, Lisboa.

If you have any questions, concerns or comments regarding our practices or this Privacy Notice, please send an e-mail to [email protected].

 

12. What does Opting out mean?

 

If you do not want to take advantage of our special offers, price discounts and the support of Klass Wagen's team in finalizing your reservation, please use the Opt out button.