This Privacy Policy explains how your personal data is collected and used when you visit [website address] (the “Website”) or rent a vehicle through us. It is drafted in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and Spanish Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights (“LOPDGDD”).
1. Data Controller
2. Personal Data We Collect
- Identification and contact data: full name, date of birth, passport or ID card number, driving licence details, address, phone number and email.
- Booking and contract data: rental dates, selected vehicle, delivery address, signed Rental Agreement, vehicle condition reports and photographs.
- Payment data: security deposit and payment records. We do not store full card numbers; card payments are processed by [payment provider / terminal provider].
- Vehicle location and driving data: GPS location, speed and mileage of the rented vehicle during the rental period.
- Traffic fines and incidents: notices of fines, accident reports and damage records linked to your rental.
- Website data: IP address, browser type and cookie data, as described in our Cookie Policy.
3. Purposes and Legal Bases
| Purpose | Legal basis (GDPR) | Retention period |
|---|---|---|
| Handling booking requests and answering enquiries | Pre-contractual steps at your request, Art. 6(1)(b) | Until the enquiry is closed, max. [12] months if no rental follows |
| Concluding and performing the Rental Agreement | Performance of a contract, Art. 6(1)(b) | Duration of the contract, then for the limitation period of legal claims (5 years, Art. 1964 Spanish Civil Code) |
| GPS monitoring of location, speed and mileage | Legitimate interest in protecting the vehicle and verifying compliance with the contract, Art. 6(1)(f) | [6] months after the end of the rental, or longer if needed for a pending claim or fine |
| Identifying the driver to traffic authorities and handling fines | Legal obligation, Art. 6(1)(c) (Spanish Traffic Law) | As long as the fine procedure may be open |
| Accounting and tax records | Legal obligation, Art. 6(1)(c) | 6 years (Art. 30 Spanish Commercial Code) |
| Website analytics and non-essential cookies | Consent, Art. 6(1)(a) | See Cookie Policy |
You are informed of GPS monitoring before signing the Rental Agreement. GPS data is used only for the purposes listed above and is not used for profiling or marketing.
4. Who We Share Your Data With
We do not sell your personal data. We may share it only with:
- the vehicle owner (if different from the Data Controller), to the extent necessary to perform the Rental Agreement;
- insurance companies, in case of an accident, damage or theft;
- traffic authorities (DGT), police and courts, where required by law;
- service providers acting on our behalf, such as website hosting, GPS tracking platform and communication tools ([list providers]), bound by data processing agreements.
5. International Transfers
Some service providers (for example, messaging or hosting services) may process data outside the European Economic Area. In such cases, transfers are based on an adequacy decision of the European Commission (including the EU–US Data Privacy Framework) or on Standard Contractual Clauses.
6. Your Rights
You have the right to:
- access your personal data;
- rectify inaccurate data;
- request erasure of your data;
- restrict or object to processing;
- receive your data in a portable format;
- withdraw consent at any time, without affecting processing carried out before withdrawal.
To exercise your rights, contact us at [email] and attach a copy of an identity document. We will respond within one month.
If you believe your rights have been infringed, you may file a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es).
7. Data Security
We apply appropriate technical and organisational measures to protect your data against loss, misuse and unauthorised access.
8. Minimum Age
Our services are intended only for persons who meet the minimum driver age set out in our Rental Terms and Conditions. We do not knowingly collect data from minors.
9. Changes to This Policy
We may update this Privacy Policy from time to time. The current version is always available on the Website, with the date of the last update shown at the top.