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Privacy Policy

UFODRIVE

PRIVACY NOTICE

This is the privacy notice (“Privacy Note”) for UFODRIVE, S.A. and UFODRIVE, LLC (“UFODRIVE” “we,” “us,” or “our”). This Privacy Notice covers the Personal Information we collect, use and disclose through your use of our websites, mobile applications (“Apps”), products and services, either online or offline (collectively, “Services”).

If we make changes to this Privacy Notice, we will post the changes here. If we make a change that significantly affects your rights, we will notify you by way of a prominent posting on our websites and in our Apps, prior to the change becoming effective. If you have an account with us, we may also notify you about material changes to this Privacy Notice by e-mail (sent to the e-mail address provided in your account), through our Apps, or as otherwise required or permitted by law. Any changes to this Privacy Notice will become effective upon posting of the revised Privacy Notice. Use of our websites, Apps, products and services following the posting of a new Privacy Notice constitutes your acceptance of the revised Privacy Notice then in effect. As such, we encourage you to review this site from time to time for the latest information on our privacy practices. In some cases, we may provide additional disclosures or privacy notices specific to certain products, services, or programs. Those additional terms supplement, and are to be read in conjunction with, this Privacy Notice.

BY USING ANY OF OUR WEBSITES, APPS, PRODUCTS OR SERVICES, YOU UNDERSTAND AND ACKNOWLEDGE THAT WE WILL COLLECT AND USE YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE. 

INFORMATION WE COLLECT AND HOW WE USE IT

The principal purposes for which we collect and store your personal and financial information are to process your rental, allow you to reserve and use our vehicles, authorize payment, bill you, respond to your inquiries, improve and communicate with you about our products and services and maintain your account with us.

Personal Information. Some of the information we collect can personally identify you (“Personal Information”), including, for example, your name and contact information, birthdate, government identification, payment information, payment arrangements, insurance arrangements, and information related to your rentals or use of products or services we provide or enable. For example, when you make a reservation, we collect your Personal Information such as: your name and contact information; birthdate; driver license and other appropriate government identification; payment information, including credit or debit card information; and other information that may be necessary to rent you a vehicle, provide you with services, contact you about these services or verify your identity. When you download, visit or use our websites or Apps or interact with us using e-mail, texts or other forms of electronic communication, we may we use cookies, pixel tags, beacons, scripts and similar technologies to automatically collect certain information, including, for example, your IP addresses, MAC addresses, device identifier, browser type, Internet service provider (“ISP”), location, how you interact with our websites and/or Apps, referral/exit sites, operating system, date/time stamp, and clickstream data.

Vehicle Data. Our rental vehicles are equipped with features, telematics systems, on-board devices, or built-in services and technologies that are capable of collecting data about the vehicle and its use, including, for example, the vehicle’s condition, damage and accident events and records, performance, operation and diagnostic data, information on mileage, acceleration, braking, speed, fuel consumption, fuel level, tire pressure, odometer, location and direction, and other vehicle-related information (collectively, “Vehicle Data”). Typically, this information is associated with the vehicle only and maintained as Non-Personal Information, as described in the Non-Personal Information section below. If we link this information to you, we will treat it as Personal Information.

Non-Personal Information. We may also collect or transform information so that it is maintained in a form that is not linked to a particular individual, such as vehicle information that is not connected to a passenger or other aggregated, de-identified or anonymized information (“Non-Personal Information”). This Privacy Notice does not apply to Non-Personal Information, which we collect, use and disclose for a variety of purposes. However, any Non-Personal Information that is linked to or combined with Personal Information will be treated as Personal Information subject to this Privacy Notice.

Mobile Application Authentication. Some of our mobile applications require you to log in to access your account or interact with your vehicle. We may provide you the ability to log in or authenticate yourself using facial, fingerprint or other biometric recognition technology available through your mobile device. If you choose to utilize these login features, information about your facial geometry, your fingerprint or other biometric information will be collected by your mobile device for authentication purposes. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful. If the authentication was successful, you will be able to access the applicable mobile application or feature without separately providing your credentials.

HOW PERSONAL INFORMATION IS USED

We use your Personal Information to:

  • provide you with our websites, Apps, products and Services;
  • provide you with additional services or functionalities (for example, to facilitate contactless rentals, to provide remote lock/unlock, to remote disable engine, and to automatically receive the vehicle location, odometer, energy level and other information in connection with your rental);
  • administer your rental, manage your rental records and to calculate your fees (for example, to automatically record the start of your rental, any exchange or upgrades, and the fuel or mileage usage and charges);
  • communicate information regarding your reservation or rental. These communications are transactional or service related and will be sent via email, text, push notification or phone calls;
  • diagnose problems, analyze trends, and assess our performances;
  • provide roadside assistance;
  • provide you with discounts;
  • improve our operations and services;
  • better understand our customers’ preferences;
  • better understand how our vehicles are being used;
  • tailor our services, promotions and offers to our customers;
  • research and develop new products and services;
  • maintain our fleet;
  • recover lost, stolen or towed rental vehicles;
  • interact with you in person, through our services or on third-party platforms (such as social media sites);
  • provide you with, and improve, relevant marketing or offers from us and our partners, and to inform our advertising and marketing campaigns;
  • run our contests, sweepstakes or promotions;
  • enable third-party vehicle applications and services;
  • improve road safety and reduce traffic;
  • respond to legally binding requests from law enforcement, regulatory authorities or other third parties;
  • ensure the security of our or another’s premises, property or other assets;
  • defend, protect or enforce our rights or applicable terms of service;
  • prevent fraud or the recurrence of fraud;
  • assist in the event of an emergency; and
  • comply with applicable law.

We use cookies, pixel tags, beacons, scripts and similar technologies to adjust and optimize our content to your preferences, to provide you with useful functionalities, to remember your previous rentals and your travel preferences, to help us make our website, Apps, products and services more convenient and efficient, to improve our Services, to help us analyze usage trends and patterns, and to tailor online advertisements by us and our partners to you.

We may use third party platforms to help us promote interest-based advertisements to you or to offer integration with third-party services. These providers use cookies or similar tracking technologies to collect information about your use of our websites, including our mobile apps, over time so that they may deliver the integrated services or play or display ads on our services, on other websites, apps or services you may use, and on other devices you may use. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to facilitate integrated services or to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. You have options when it comes to cookies and other web tracking tools.

You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. However, some features or services may not function properly without cookies. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our websites do not currently change the way they operate based upon detection of a Do Not Track or similar signal. As the internet and other e-commerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.

Data Retention

We may retain your information for as long as you have an account with us, as needed to provide you our Services, or as otherwise necessary for the processing purpose(s) for which the information was originally collected and any other legitimate business purpose, including, for legal, archival, accounting, and/or audit purposes. If you close your account or request we provide you our Services, we may retain your information because we have a legal, auditing or account obligations or it is in our archive system and cannot be separated from other information.

HOW INFORMATION IS SHARED

To facilitate the uses of Personal Information identified in this Privacy Notice, we may share your Personal Information with a variety of third parties, including our service partners and business partners.

We may share your Personal Information with our third-party service providers and partners to help us with our marketing and promotional projects, such as managing our social media pages, running contests, sweepstakes and other promotions, or to comply with your directions or any additional consent you have provided us.

We may share website usage information, including searches, transaction and profile information (but not your name) with our partners for the purpose of making the online advertisements on our websites and other websites that display our advertisements more relevant.

We may share your Personal Information with law enforcement and regulatory authorities or other third parties as required or permitted by law, including for the purpose of:

  • responding to a subpoena, court order or other legal processes;
  • defending, protecting or enforcing our rights;
  • assisting in the event of an emergency; and
  • complying with applicable law.

We may also share Personal Information with third parties in the event of an actual or potential merger or acquisition, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. To the extent that local laws require it, we will provide you notice on our websites or via e-mail of our intent to transfer Personal Information to a third party for this purpose.

Personal Location Information.

We only share information about your location with:

  • our third-party service providers to help provide our services or third-party services you have requested;
  • third-parties for whom you have provided consent, including, for example, with partners who provide location-based marketing; or
  • law enforcement and regulatory authorities or other third parties as required or permitted by law, including for the purpose of:
  • responding to a subpoena, court order or other legal processes;
  • defending, protecting or enforcing our rights;
  • to locate an overdue or suspected stolen or lost vehicle
  • assisting in the event of an emergency; and
  • complying with applicable law.

HOW INFORMATION IS PROTECTED

The security of Personal Information is important to us. We take reasonable steps designed to protect Personal Information from unauthorized use, access, disclosure, alteration, destruction or loss. You are responsible for keeping your account safe. Do not share your passcode, account and pin numbers with anyone. Please be mindful that hackers and scammers may impersonate us or our website. If you suspect an unauthorized use or security breach of your information, you must notify us as soon as possible. We are not responsible or liable for any loss or damage if your account passcode, account numbers and pin numbers are stolen or used inappropriately.

CHILDREN’S PRIVACY

Our websites, Apps, products, and services are not for children under the age of 13. We do not knowingly collect Personal Information from children. If you think we have received Personal Information from children under the age of 13, please contact us immediately.

GEOGRAPHIC LOCATIONS

We may store your Personal Information in the United States, United Kingdom and/or Europe. If your information is stored outside of the United States, we will take reasonable steps designed to ensure your information is treated and protected no less securely than it is in the United States. This Privacy Notice is intended to be governed by the laws of the State of Delaware and meet the laws and requirements of the United States, which may not necessarily be consistent with the laws and regulations of the country where you live.

CONTACT US

If you have questions about our handling of Personal Information, you may write to us at This email address is being protected from spambots. You need JavaScript enabled to view it..

California Privacy Notice

Last Updated: July 19, 2022

Scope of Disclosures

This California Privacy Notice (the “CA Disclosures”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California ("consumers" or "you").

These CA Disclosures describe how we collect, use, disclose, and otherwise process Personal Information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined the CCPA.

Personal Information Disclosures

For purposes of these CA Disclosures only, we use the term “Personal Information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

For the purposes of these Disclosures, Personal Information does not include:

  • Publicly available information from government records.
  • Information maintained in a form that is not linked to a particular individual, such as de-identified, aggregated or anonymized information.
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
  • Information relating to our job applicants, employees, contractors and other personnel of UFODRIVE, which is not governed by these CA Disclosures.

 

Collection and Use of Personal Information

 

We collect various categories of Personal Information in connection with our Services. Please review “Information We Collect And How We Use Them” section of the Privacy Notice to learn more about the Personal Information we collect.

In the last 12 months, we have collected the following categories of Personal Information:

 

Category of Personal Information Collected

Categories of Sources

Identifiers, such as your name, address, phone number, email address, date of birth, passport or other government identification information, driver’s license information, account information, membership or program ID, or other similar identifiers.

· Directly from you

· Our business partners and affiliates

· Third parties you direct to share information with us

· Information providers

   

California Customer Records (Cal. Civ. Code § 1798.80(e)), such as driver’s license number, fraudulent activity flags, insurance provider and coverage information, health information, passport number, debit card information, credit card information, bank account information or other payment or financial information.

· Directly from you

· Our business partners and affiliates (including security providers)

· Third parties you direct to share information with us

   

Protected Classification Characteristics, such as age, gender, and relevant disability information for providing adaptive driving devices.

· Directly from you

· Third parties you direct to share information with us

   

Commercial Information, such as information about whether you are part of a corporate or rewards program, products or services purchased or considered and your use of our services, including reservation details.

· Directly from you

· Third parties you direct to share information with us

   

Biometric Information, such as facial geometry used for identity verification purposes.

· Directly from you 

   

Internet/Network Information, such as device information, log, and analytics data.

· Your browser or device

   

Geolocation Data, such as information about your physical location collected from geolocation features on your device or UFODRIVE vehicle, including your IP address and GPS (e.g. latitude and/or longitude).

· Your browser or device

· Your UFODRIVE vehicle

   

Sensory Information, such as pictures and videos you provide us or we record in connection with our services or the surveillance of our premises, and audio recordings of phone calls between you and us, where permitted by law.

· Directly from you

   

Professional/Employment Information, including the business or organization you are associated with and, where applicable, your title with that business or organization and information relating to your role with the business or organization.

· Directly from you

· Third parties you direct to share information with us

   

Other Personal Information, such as your travel or flight information, your driving records, claim information, driver behavior information and additional information you provide to us directly or through a third-party service, including messages you send us through our services or make available to us on social media.

· Directly from you

· Our business partners and affiliates

· Third parties you direct to share information with us

· Your UFODRIVE vehicle

   

Inferences, including information generated from your use of our websites and your driving, vehicle and rental history reflecting your preferences.

· Your browser or device

· Generated or derived from the Personal Information described above

 

Purposes for Collecting Personal Information

We collect, use or disclose Personal Information about you for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information, such as to create your account, process your transaction or respond to your inquiry.
  • To communicate with you, including via email, text message, push notification, social media and/or telephone calls.
  • To improve road safety and reduce traffic.
  • To operate, maintain, and provide to you the features and functionality of the services.
  • To verify your identity and confirm the authenticity of your identity documents.
  • To market to you, including through email, direct mail, phone or text message, and to run our contests, sweepstakes or promotions.
  • To personalize your experience and to deliver custom content and product and service offerings relevant to your interests, including targeted offers and ads through our websites, Apps, third-party sites, or on other devices you may use.
  • To recognize you and remember your information when you return to our websites and services.
  • To help maintain the safety, security, and integrity of our property and services, including UFODRIVE vehicles, technology assets, and business.
  • For testing, training, research, analysis, and product development, including to develop and improve our services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To ensure the security of our or another’s premises, property or other assets.
  • To defend, protect or enforce our rights or applicable terms of service.
  • To prevent fraud or the recurrence of fraud.
  • To assist in the event of an emergency.
  • To evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UFODRIVE’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by UFODRIVE about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.
  • To comply with applicable law.

 

Disclosure of Personal Information

As described in our Privacy Notice, we share Personal Information with third parties for business purposes. We do not sell your Personal Information to any third parties for marketing or other uses.

We disclose your Personal Information to the following categories of third parties:

  • Our service providers: We engage a number of third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, marketing and advertising services, and other similar services, subject to contractual terms restricting the collection, use and disclosure of your Personal Information for any other commercial purpose.
  • Third parties at your request. We share your Personal Information with third parties with your consent or at your direction, including where necessary to validate your eligibility for a discount as a member of a third-party partner.
  • Businesses as needed to provide services.We may share Personal Information with third parties you engage with through or to provide our Services, or as needed to fulfil your request or transaction, including, for example, payment processing services or third-party travel booking services.
  • Security providers. We may share your Personal Information with third-party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule, regulation or the policies of UFODRIVE.
  • Business partners. We may disclose Personal Information to third parties with whom we partner to perform joint promotional activities or co-branded services, and such disclosure is necessary to fulfil your request or application.
  • Ad networks and advertising partners. We work with third party Ad Networks and Advertising Partners to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use. These parties may collect information directly from your browser or device when you visit our Services through cookies or other tracking technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
  • Analytics providers. We work with third party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our services.
  • Social networks. We may disclose Personal Information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks;
  • Law enforcement and third parties pursuant to legal request. From time to time, we may disclose Personal Information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • Third parties in the context of a corporate transaction. We may disclose Personal Information as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of UFODRIVE’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by UFODRIVE about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.

 

In the previous 12 months, we have disclosed all of the categories of Personal Information we collect, explained in the table above, to third parties for a business purpose.

Additionally, as is common practice among companies that operate online, we do allow certain advertising networks, social media companies and other third-party businesses to collect and disclose your Personal Information directly from your browser or device through cookies and related technologies when you visit or interact with our Sites, use our apps or otherwise engage with us online. Please see the Third-Party Tracking and Online Advertising section below for more information about how third parties use cookies and related technologies to collect information automatically on our Sites and other online services, and the choices you may have in relation to those practices.

 

Your California Privacy Rights

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

  

 
 

The Right to Know

You have the right to request any or all of the following information relating to your Personal Information we have collected and disclosed in the last 12 months, upon verification of your identity:

· The specific pieces of Personal Information we have collected about you;

· The categories of Personal Information we have collected about you;

· The categories of sources of the Personal Information;

· The categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

· The categories of Personal Information we have sold and the categories of third parties to whom the information was sold, if applicable; and

· The business or commercial purposes for collecting or selling the Personal Information, if applicable.

 

 

The Right to Request Deletion

You have the right to request the deletion of Personal Information we have collected from you, subject to certain exceptions.

 

 

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

However, please note that if the exercise of these rights limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

 

“Shine the Light”

 

 

 

How to Exercise Your California Consumer Rights Please note, when you submit a request to us, that request will only be processed with respect to the UFODRIVE brand to which you have submitted such request. To exercise your Right to Know and/or your Right to Deletion, please submit a request by:

 

  • Emailing UFODrive at This email address is being protected from spambots. You need JavaScript enabled to view it.
 
 

We will need to verify your identity before processing your request, which may require us to request additional Personal Information from you. We will only use Personal Information provided in connection with a Consumer Rights Request to review and comply with the request. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity, if the rights of another individual might be violated or as otherwise permitted by law. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

 

Third-Party Tracking and Online Advertising

We utilize third-party partners to engage in online advertising. These ad networks, social media companies and other third-party businesses collect your Personal Information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. These third parties use your Personal Information to serve relevant ads on our websites, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements. Please see our Privacy Notice for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices. 

 

California’s “Shine the Light” Law

We do not provide your Personal Information to third parties for their direct marketing purposes, as described in California’s "Shine the Light" law (Civil Code Section §1798.83).

 

Authorized Agent

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

 

Updates to These CA Disclosures

We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.

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