PERSONAL DATA PROTECTION POLICY

 

The Company under the corporate name “KINSEN HELLAS SINGLE MEMBER SOCIETE ANONYME”, with registered offices in Athens, 55 Stournari st, postal code 10432 (hereinafter referred to as the “Company”, or “we”, “us”, or “our(s)”), is Franchisee of EUROPCAR in Greece, operating, among others, on the provision of services of car rental (rent-a-car).

Within the frame of the above mentioned operation, we collect and process, throw the present website (www.europcarlease.gr) Personal Data about you, undertaken in accordance with the present Personal Data Protection Policy.

 

1. Personal Data Collected and Processed

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 our company itself, or its sub-franchisees within the territory of Greece, as well as the rest of Europcar’s franchisees internationally.

By the term 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 rented vehicle.

The categories of Personal Data that we collect include the following:

-Your identification data: surname, first name, date of birth, postal address, email 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 license number, country of issuance, date of issuance and expiration) and the driver’s license 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 Data Processing- Legal Base of Processing

The Company collects and processes personal data that concern you, for various purposes, following the down-bellow Legal bases:

 

Purposes of the Processing	Legal base of the processing
Managing your reservation and rental contract through a central booking engine, in particular to: – collect the data necessary to organise your reservation  – manage your payment	These processing activities is based on our legitimate interest to ensure the execution of the rental services contract that you enter into. 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 based on your consent.
Sending you an email in order to collect your comments 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 to the obligations imposed by the applicable legislation.	This processing is based on our compliance to our legal obligations.

 

 

Your personal data may be communicated to our employees and/ or agents, our sub-franchisee network, our authorized representatives and intermediaries, mandated to provide you with our products and services, as well as to subsidiary/related/ cooperating with our Company companies and more specifically:

a. to our relevant sub-franchisee or Europcar’s franchisee that delivers the rental service to you, 

b. to subsidiary/related/ cooperating with our Company companies, which will process your data as data processors, exclusively for the purpose of your service and on the condition that they perform a legitimate and appropriate 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 through the present website. The abovementioned may be external service providers.

d. marketing agencies to help us analyse our customers’ satisfaction data.

e. to 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 according to the applicable laws and regulations.

Our Company undertakes all measures to provide, that the personal data that may be forwarded, are the minimum necessary.

 

In order to provide you with our products and services, we may use service providers located outside the European Union. 

Depending on the place of the provision of services, 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.

 

Your personal data are kept for different periods of time, depending on the purposes of the processing concerned:

Purposes of the processing	Time of retention
Creating and managing of your online customer account on our website or mobile application.	5 years from the end of the commercial relation and more specifically from your last car rental.
Managing your reservation and rental contract through a central booking engine, in particular to: – collect the data necessary to organise your reservation  – communicate this data to the concerned sub-franchisee, or Europcar’s franchisee operating the service. – manage your payment	5 years from the end of the 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 commercial relation and more specifically from your last car 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 an email, in order to collect your comments 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 to the obligations imposed by the applicable legislation.	For the time recommended by the applicable legislation.

 

Within the limits and conditions allowed by the regulations in force, you can:

– have access to your Personal Data and obtain further information on the characteristics of the processing we perform.

– ask for your Personal Data to be corrected, updated and deleted (“right to be forgotten”), 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 on a structured, commonly used and machine readable format (“right to portability”), or request us to transmit them on 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 limitation 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 dispute 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 object to the deletion of your personal data and instead demand its use to 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 the legitimate reasons pursued by us take precedence over your own.

– object to the processing of your personal data, at any time, for reasons relating to your particular situation, therefore we will stop processing them, unless we manifest due legal reasons for the continuation of the processing that take precedence over your interests, rights, freedoms, or for the founding, exercise or advocacy of our legal claims.

– withdrawing your consent on processing, provided that processing is based on your consent.

The exercise of the above mentioned rights acts for the future and does not concern already performed data processing.

 

You may exercise your rights by addressing to our e-mail address info@kinsen.gr  or by post to our address 71, Athens Avenue postal code 10173, Athens, for free, unless if it is repeated often and they bare administrative costs to us, which you will relatively burden.

Provided you exercise any of your rights, we will take any necessary measures for the fulfilment of your request within thirty (30) days from the receipt of the relative request, informing you either for its fulfilment, or for the reasons that prevent its fulfilment. The above deadline can be extended for two (2) more months, if necessary, taking into account the complexity of the request and the number of the requests.

To exercise your rights, you must prove your identity by clearly indicating your surname, first name, your identifying reservation number 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 physical address to which you would like the reply to be sent to you.

Moreover, you always reserve the right to address to the Hellenic Data Protection Authority, who may receive the submission of relevant complaints either in writing to its protocol (1-3, Kifisias Avenue 11523, Athens) or electronically (www.dpa.gr).

 

Our Company implements all adequate physical, technical and organizational security measures, to prevent unauthorized or unlawful processing, accidental loss of or destruction of or damage to your personal data.

 

On the present 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 the present 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. Our 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.

 

The present Personal Data Protection Policy was lastly updated on the 31.01.2022.