Welcome to the Privacy Policy of Compass Self Drive.
Please read this, as it is important that you understand how we collect and use your personal information – meaning all information relating to a living individual and which either identifies, or may be used to identify, that individual.
We may change portions of this Privacy Policy from time to time. If we make a change which significantly affects your rights, or to the extent we are permitted to do so, significantly changes how we use your personal information, we will notify you by way of a prominent posting on our website, email and or postal mail prior to the change becoming effective.
This Privacy Policy covers the personal information Compass Self Drive collects uses and discloses through your use of our products and services online and offline.
Compass Self Drive needs to collect personal information from you to rent a vehicle or provide other services. We collect personal information when you give it to us by telephone, fax, postal mail, email or at the counter and on completion of an application or rental agreement.
The personal information which we collect is necessary to allow us to be able to provide the products and services offered to you or sometimes to comply with a legal obligation on Compass Self Drive. For example, when you rent a vehicle from us we will require information such as your name, address, payment information and driving licence. Failure to provide this information will render us unable to provide you with a vehicle.
Sometimes, we will combine the personal information supplied by you with other information from other sources in order to provide you with best service possible. These other sources may include:
•Your employer if you are using a corporate account
•Police and law enforcement agencies if you are involved in an accident during your rental, or suffer any loss, damage or theft of the vehicle, or if you incur any speeding, parking, toll or other traffic-related fines or commit any traffic offences during your rental.
This information is used for purposes detailed below. The bases in data protection law which allow Compass Self Drive to use your personal information are:
1.You have provided your consent to us using your personal information for that purpose. (For example where you have given us your consent to send you electronic marketing)
2.We need to use that personal information to be able to fulfil our contract with you. (For example using your information for vehicle rentals)
3.The data processing is necessary for the purposes of our legitimate interests, provided we have balanced these against your rights and interests.
4.We are required to comply with a legal obligation. (For example when responding to government or law enforcement requests)
Our legitimate interests are: (a) to ensure effective administration and management of your relationship with us including rental transactions.; (b) to understand how our customers use our services and to manage our vehicle fleet; (c) to carry out research and analysis on what products or services our customers want or how they would like us to improve our services and products; (d) to understand how our customers use our website and identify issues in how the website is used and how we can improve the experience of using it.; (e) to tell our customers about the services we can offer; (f) understand and respond to customer feedback; (g) to better tailor the promoyions and benefits that we offer to our customers; (h) to prevent, detect or investigate unauthorised use of our vehicles and systems ansure we comply with the law and our policies; and (i) to manage any disputes and accidents and take legal or other professional advice.
We will collect technical information about your devices when you use our website where permitted. See Online Data below.
RENTING A VEHICLE
When you make a reservation or rent a vehicle we collect information to allow us to provide you with our services (For example renting a vehicle, including completing the rental agreement in accordance with our Terms and Conditions, providing any requested optional extras, taking payment, pre-authorisations and security deposits and providing discounts and offers or other benefits) and for our legitimate business interests (For example research and development of new products and services, undertaking fraud and security checks and enforcing our legal rights) The information we collect includes:
1.Name
2.email address (if you book online or wish to receive email receipts
3.Home address (for licence validation and billing)
4.Employer details and business address (if you are using a corporate account)
5.Telephone/Contact numbers
6.Date of Birth (For licence validation and legal and insurance requirements)
7.Gender (For licence validation)
8.Payment information (Credit or Debit card details)
9.National Insurance number (For licence validation only - we do not store it)
10.Drivers licence information for all drivers (For licence validation and insurance requirements)
11.Additional identification (Photo ID/ recent utility bill – for security and anti-fraud purposes)
12.Special requests and preferences regarding optional extras including damage waivers and where a delivery/collection service is available the delivery/collection addresses and details of any optional extras requested.
13.Other information which we may require to facilitate the rental transaction.
Some vehicles are equipped with a global positioning system or tracking device which may collect information about the vehicle. See Vehicle Data below.
If you have an accident or suffer any loss, theft or damage to the vehicle during your rental or suffer any mechanical failure, we will collect information regarding such incident including your report of the incident and any police or other third party report including details of those involved, together with the nature of any personal injuries and/or damage to the vehicle and optional extras. We will use this information to complete our contract with you (For example the vehicle rental agreement and/or the terms of any optional insurances); for our legitimate business interests (For example in recovering the costs of any loss or damage caused to the vehicle); for complying with any legal obligation on us (For example making any required notification of the incident to appropriate authorities); and establishing, exercising or defending legal claims arising as a result of such incident,
During your rental we will collect where and when you rented the vehicle, where and when you returned the vehicle, insurance preferences, fuel consumption, mileage, accident history and other information related to the vehicle and your use of it. This information is required in order to provide you with the services you requested under the rental contract or for our legitimate business interests (For example to monitor the usage of our vehicle fleet)
In addition to the purposes listed above,we use this information to better understand our customers and provide you with relevant offers.
We will also collect information about any speeding, parking, toll or other traffic related fines that you incur or any traffic offences that you commit during your rental where these are provided to us by any law enforcement agency. We will use this information to deal with such fine or offence in accordance with the terms of your rental agreement with us.
Where you inform us that you have a medical disability which requires an adapted vehicle or other driver aid we will use that information in order to provide you with the service you requested and where you have given us your explicit consent to us using that information.
When you call us from any phone we may record or monitor the call for quality control, training or similar purposes.
VEHICLE DATA
Some vehicles we provide have been manufactured or equipped with on-board devices which connect to the internet (connected car) which allow us to send commands to and receive certain information from the vehicle, including vehicle location data from a Global Positioning System (GPS). If you rent a connected car from us your personal information will be processed in accordance with this policy and the Connected Cars Privacy Addendum included in our Terms and Conditions (or such other notice regarding connected cars as we may provide you in the future).
PHOTOS AND VIDEO
As indicated by signs, our premises are equipped with video surveillance systems as well as cameras which record as our vehicles enter/depart our yard.
ONLINE DATA
When you visit and use our website Compass Self Drive automatically collects technical information. This is what we collect and why we collect it.
IP addresses and other information are collected automatically: We may collect your IP address when you visit our website to help us diagnose problems with our computers, for system administration, and to audit the use of our website. We do not link IP addresses to anything personally identifiable. In certain circumstances we may use IP addresses to help us identify you when you feel it is necessary to enforce compliance with our Website Terms and Conditions to protect our service, site, users and others. We may also collect your browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our site (e.g. HTML pages,graphics etc.), operating system, date/time stamp and/or clickstream data to analyse trends in the aggregate and administer the site.
Session Replay: When you visit our website, we will sometimes also record information about your browsing session on the site, including which pages you visited and any forms on the website which you completed. We review this information to identify any technical issues in the operation of our site and to improve the user interface on our site. We use a third party to help us with this service and this information will be passed to that third party for that purpose but this information is not passed to any other third party.
Cookies and other similar technologies: Please refer to our Cookies Policy for details of how we use cookies.
MARKETING
Compass Self Drive may share personal information with third parties (as detailed in the Information Sharing section) to help us with our marketing and promotional projects, such as managing our social media pages, running contests and other marketing promotions, or sending marketing communications.
We will only use your personal information to send you marketing where you have given us your consent to receive marketing or we are otherwise permitted by applicable law to do so. This marketing will be sent to you either electronically or to your postal address.
If you do not want to receive promotional and marketing post, email and text messages from Compass Self Drive you can withdraw your consent to direct marketing or tell us you do not want to receive such marketing at any time.
ANALYTICS
We use analytic software, such as Google Analytics to help us better understand the functionality of our software on our website. These software tools record technical information including about your device together with usage information such as how often you use our website, which pages you visit o the website, aggregated usage, performance data and information about your visit to the site, including details of some of theURL clickstream to, through and from our website.
CHILDREN
Compass self Drive’s website and services are not from children under the age of 16. This includes links to any other websites which we may provide for your convenience. We don’t knowingly collect personal information from children for any reason. If you think Compass Self Drive has received personal information of your child or another minor please contact our Data Controller.
INFORMATION SHARING
Compass self drive may use and share your personal information and vehicle data to other organisations as follows:
Your employer or organisation in order to provide you with benefits of a corporate arrangement and to understand how you use our services and to improve our business
Purpose: [a] Verify drivers licences and other government identification [b] Verify eligibility to use designated account or discounts [c] Connect with your corporate and commercial accounts
Legal Basis for Processing: 1) Performance of contract 2) Legitimate interests 3) Legal obligation or 4) Consent
Brokers in order to perform our contract with you when you book a rental through their service and to protect our business from fraud and bad debts
Purpose: [a] Make and confirm your rental reservation [b] Process payments and refunds [c] Provide customer assistance [d] Handle debt collection [e] Fraud check
Legal Basis for Processing: 1) Legitimate interests
Booking Engines in order to perform our contract with you when you use a booking engine and to understand how you use our services and to improve our business
Purpose: [a] Make and confirm your rental reservation [b] Verify eligibility to use designated account and or discount codes [c] Process payments and refunds [d] To protect or defend the rights or well-being of us, our employees, customers or others.
Legal Basis for Processing: 1) Performance of contract 2) Legitimate interests
Credit Card Issuers in order to obtain payment from you
Purpose: [a] Process payments and refunds [b] Fraud check [c] handle debt collection
Legal Basis for Processing: 1) Performance of Contract 2) Legitimate interests
Corporate account manager in order to provide you with benefits of a corporate or association arrangement and to understand how you use our services and to improve our business
Purpose: If you are renting with a corporate or commercial entity account we may share personal information with the organisation that manages the account for their own purposes. We recommend that you review their privacy policy to learn more about their privacy practices.
Legal Basis for Processing: 1) Performance of contract 2) Legitimate interests
Marketing agent in order to provide you with benefits of a corporate or association programme and to understand how you use our services and to improve our business
Purpose: [a] To protect or defend the rights or well-being of us, our employees customers or others
Legal Basis for Processing: 1) Performance of contract 2) Legitimate interests
IT service providers including IT platform providers and website analytics service providers in order to perform our contract with you and to understand how you use our services and to improve our business
Purpose: [a] Support our IT systems and infrastructure [b] Provide maintenance services for our IT systems and infrastructure [c] Provision of data hosting and other data processing services [d] Provide analytics services relating to your use of the website to identify any technical or user interface issues and/or improvements in connection with the website
Legal Basis for Processing: Legitimate interests
Government,regulatory and law enforcement agencies in order to meet our legal obligations
Purpose: [a] To verify your driver’s licence and ensure you meet our safe driver criteria [b] As requested by these agencies if the disclosure is required or permitted by law [c] To take action regarding illegal activities, traffic offences or violation of terms of service [d] If we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person [e] As otherwise required or permitted by law
Legal Basis for Processing: 1) Legal Requirement 2) Legitimate interests
Insurance companies and claims handlers in respect of any insurance product you purchase in connection with your rental
Purpose: [a] Provide and service the insurance product you have requested [b] Manage any claims that may be made under the relevant insurance policy
Legal Basis for Processing: 1) Performance of contract 2) Legitimate interests
We may also transfer or assign your personal information to third parties as a result of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganisation or liquidation. Or if we are involved in defending a legal claim, information about you that is relevant to such claim may be disclosed to third parties as a result of, or in connection with, associated legal proceedings.
We may, in accordance with the Marketing section, share our information with businesses and promotional partners (where you have provided your consent to such information sharing) in order to send you information about products and services you may like. If you decide you no longer want to receive such promotional and marketing messages, please read the Your Choices section to find out how you can opt out.
YOUR CHOICES
If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from Compass Self Drive or any promotional partners from time to time in relation to to which you might receive in accordance with the marketing section, you can best opt out by using one of the following methods:
If you do opt out of receiving promotional and marketing messages,we can still contact you regarding our business relationship with you, such as account status and activity update, survey requests in respect of products and services we have provided to you after you rent from us, reservation confirmations or respond to your enquiries or complaints, and similar communications.
If you want to close your account, stop doing business with Compass Self Drive, or otherwise opt out of Compass Self Drive collecting, using or disclosing your personal information, please contact our Data Controller.
Please also see your rights set out in Your Privacy Rights section.
SAFEGUARDS
We take the safety of your personal information very seriously. We take reasonable steps to make sure your information is protected from unauthorised use, access, disclosure, alteration, destruction or loss. For financial or payment information, we sure firewalls and Transport Layer Security (TLS) encryption. We take security extremely seriously but as no system can be 100% secure, we can’t completely guarantee the protection of your personal information, any more than any other organisation can.
We do not ask for financial or payment information, such as your credit card number, password, account number or PIN number in an email, text or any other communication that we send to you. Please always check that any website on which you are asked for financial or payment information in relation to our rentals or services is operated by Compass Self Drive or its affiliates. If you do receive a suspicious request, do not provide your information and report it by contacting our Data Controller.
You are responsible for keeping your account password and PIN numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security you must notify our Data Controller as soon as possible.
INFORMATION RETENTION
Compass Self Drive keeps your personal information for no longer than is is reasonably necessary or required by law. The type and purpose of information will determine how long we keep it.
The criteria we use to determine the retention period for certain categories of data is as follows:
YOUR PRIVACY RIGHTS
You may have - in accordance with applicable data protection laws - the following rights when it comes to our handling of your personal information:
Please contact our Data Controller at the address below if you would like to exercise any of these rights or if you have any concerns about the way we process your personal information. You are also free to lodge a complaint with the supervisory authority if you feel that we process your personal information in a way that is against applicable law.
DATA CONTROLLER
Donald Macdonald
Compass Self Drive
60 Low Glencairn Street
Kilmarnock
KA1 4DD
Telephone: 01563 537799
Email: dmacd@compass-selfdrive.co.uk