Privacy policy

INTRODUCTION

Here is the PRIVACY NOTICE of the companies that belong to the OK MOBILITY GROUP.  If you would like more detailed information about the aforesaid companies you can click on the following linkData controllers and contact details in each country where there is a complete list of these companies and their contact details.

It is important that you read this privacy notice carefully, so that you can understand and find out about what we do with your personal data in our company. You must bear in mind that, given the services that we supply we might have to share the information with our franchisees and/or independent licensees. This Privacy Notice does not apply to the OK MOBILITY GROUP offices that are owned by and/or run by a franchisee and/or independent licensee that are not owned by or controlled by OK MOBILITY GROUP or by one of its affiliate or subsidiary companies.

If you would like to find out what the aforesaid independent establishments are at the moment click here. In any case and, if you have any more questions or enquiries about what our franchisees and independent licensees use your personal information for, please get in touch with us by sending us an email to juridico@okmobility.com.

OK MOBILITY GROUP might change parts of this Privacy Notice in time, which is why you should check its content regularly. If we make a change that significantly affects your rights or, insofar as we are authorised to do so, we make significant changes about how we use your personal information, we will notify you of this by publicising and highlighting it on our websites, by email and/or post before the change actually become effective.

This Privacy Notice covers the personal information that the OK MOBILITY GROUP companies obtain, use and disclose when you use their products and services, both online and physically.

OK MOBILITY GROUP needs to obtain your personal information to:

• Rent you a vehicle or provide you with another one of the services we supply.
• OK GROUP obtains personal information when you supply us with it, such as for example, over the phone, fax, by post, email, at the counter, when you make a request or fill in a registration form, when you join our customer loyalty plan or when you visit a website or the OK GROUP mobile apps or when you use our products and services.

If you do not provide us with the personal information that we ask you for we cannot provide you with the service required. In this case, you will be informed about this and what the consequences will be if you do not provide us with your personal information. We also have to keep the information that you provide us with to comply with all the legal obligations of the OK MOBILITY GROUP companies.

Sometimes we will combine the personal information that you give us with other information that we receive from other sources and/or third parties. This information might include any type of data that is relevant for the purposes of your reservation. These third parties might be.

• Travel agencies or external reservation services that you use to make your reservation;
• Your company or association if you are using a company/association account;
• Our licensees and subsidiaries in order to set up a preferential account or if you are making a reservation in a rental service establishment and you are being assisted by our subsidiaries or licensees in another establishment assisted by us; and
• Police and other law enforcement agencies if you have been in an accident while you were renting a vehicle or the rental vehicle has been lost, damaged or stolen or if you have been given a fine for speeding, parking badly, on a toll road, or any other type of traffic fine or if you have committed a driving offence while renting the vehicle.

The existing data protection regulation provides for different cases when OK MOBILITY GROUP can use your personal information for these purposes:

1. that you have given your consent to us using your personal information for this purpose (for example, when you have given your consent for us to send you electronic communications);
2. that we need to use this personal information to comply with our service and product supply agreement with you (for example, using your information to rent vehicles or to incorporate it into our customer loyalty programme.
3. that the data processing is necessary to safeguard our legitimate interests.
4. when we need to comply with a legal obligation (for example, responding to requests for information from the government or the law enforcement agencies).

Our legitimate interests are:

A. Ensure the efficient administration and management of your relationship with us, including the vehicles your rent and/or purchase from us;

B. Understand how the customers use our services and how we can run our fleet of vehicles;

C. Carry out research and studies about the products and services that our customers want or about how you would like us to improve our products and services;

D. Understand how our customers use our website and apps and detect any problem that might arise in relation to how the websites and apps are used and about how we can improve our customers’ experience of using these;

E. Inform our customers about the different products and services that we can supply;

F. Understand and respond to comments and observations from our customers;

G. Improve the adaptation and the customization of the sales promotions and benefits that we offer our customers;

H. Prevent, detect or investigate the unauthorised use of our vehicles and systems and make sure that we comply with the laws and our policies; and

I. Deal with any disputes or accidents and get legal or professional advice.

When you use our website we will obtain technical information about your devices as long as this is allowed. Have a look in the WEBSITE Data section to find out about how we obtain data online.

DATA ABOUT THE VEHICLE RENTAL PROCESS

When you make a reservation, rent a vehicle or join one of our programmes, such as, for example, a corporate programme or our customer loyalty programme, we obtain information to offer you our services, the information that we obtain includes:

• The name;
• The email address (if you are making a reservation online or you want to be sent e-invoices);
• The personal address (to check the driving license or the invoicing details);
• The data about the company and the registered office (if it is a member of a corporate programme);
• The telephone numbers where we can get in touch with you;
• The date of birth (to check the driving license and the compliance of the legal requirements);
• The gender (to check the driving license)
• The information about the payment such as, for example, your credit or debit card data (the security code is only obtained for the transaction, we do not keep this);
• Tax identification number (if it is specifically requested);
• Information about the driver’s driving license and/or any identification document issued by the government, even if you are an additional driver when renting the vehicle in question (to check the driving license and make sure the legal regulations are being complied with);
• Information in any other type of identification document such as a passport or a national identification document if the driving license does not have a photo on it or you cannot be recognised in it and/or proof of your address such as, for example, a water, electricity or telephone bill (for security and antifraud reasons). The information that we obtain and process might include your photograph when you have been informed about this;
• Special discount codes, member numbers, participation in associations, corporate award programmes (if special discounts, special privileges or point programmes are requested);
• Requests and special preferences, including:
• Your preferences in relation to optional extras such as exemptions for loss or damage or other types of protection;
• When you use a pick up and drop off service, the address where the vehicle will be dropped off or picked up and the optional extras that you request; and
• Any other information that might be necessary to rent a vehicle to you or/and provide you with services.

While you rent a vehicle we will obtain data about where and when you have rented the vehicle, where and when you have returned the vehicle, your insurance coverage preferences, fuel consumption, mileage, accident record and any other information concerning the vehicle and how it is used. This information is requested to provide you with the services engaged under contract pursuant to the rental agreement or to defend our legitimate commercial interests.

As well as the aforesaid purposes, we will use this information to understand our customers better and to provide them with offers that suit their profile the best.

When you phone us (from any telephone), we can record or monitor the phone call for quality control, training or similar reasons.

Hereinafter, there are details of some of the more specific cases:

IN THE EVENT OF AN ACCIDENT:

If you have an accident, or the vehicle is lost, damaged or stolen while you are renting it, or it breaks down, we will obtain the information about this incident, which includes your report of the incident and any other policy or report from third parties, including the data from the people involved, together with the type of the physical injuries and/or any damage done to the vehicle and optional extras. We will use this information to comply with the agreement that we have signed with you (such as for example, the vehicle rental agreement and/or the terms of any optional extra such as, for example, an insurance policy); for our legitimate commercial interests (such as, for example, to claim back the costs of any loss or damage done to the vehicle); to comply with any legal obligation that is imposed on us (such as for example, to notify the competent authorities about the incident); and to establish, exercise or defend the legal claims that arise as a result of this incident.

Likewise, we can make it easier for you to pay said penalty through an OK MOBILITY partner, as long as you give your consent to do so.

ASSIGNMENTS:

Independent and/or Franchise Licensees and Network Providers

in order to fulfil our contract, rectify any data or complete it in order to clearly identify the driver of the vehicle, when required by Traffic, facilitate the payment of penalties and understand how you use our services and improve our business.”

IN THE EVENT OF FINES:

We will also obtain information about fines for speeding, parking tickets, toll roads or any other type of traffic fine that you get or any driving offence that you commit while you are renting one of our vehicles, which the law enforcement agencies have supplied us with. We will use this information to deal with the fine or the offence pursuant to the terms established in the vehicle rental agreement that you signed with us.

When you inform us that you have a medical disability and you need an adapted vehicle or another type of assistance for the driver, we will use this information to provide you with the service requested, as long as you have given your consent for us to use this information.

WHEN BUYING A GIFT VOUCHER:

When you buy a gift voucher or gift certificate, we will obtain the name and the email address of the person it is meant for to complete your order. We will only use this information for the specific purpose that it was supplied for. If you think that one of your contacts has supplied us with your personal information and you want us to remove it from our databases, please get in touch with our customer service department, the contact details are provided hereinafter in the sectionData controller and contact details in each country.

OK GROUP CUSTOMER LOYALTY PROGRAMME

If you decide to join our customer loyalty programme, so that we can create an account for you in our programme in accordance with the terms and conditions specified in it, we will keep the following information:

1. Your name and surname
2. Email
3. Contact details,
4. Driving license details and
5. Date of birth.

We will use this information and the data related to your history of renting vehicles with us and your future rentals, so that you can make the most of the benefits of being a member of the customer loyalty programme and so that we can offer you more benefits as well as the ones you are entitled to under the programme, such as, for example, discounts, free improvements and other advantages.

We will also use this information to customize the messages that we might send you and/or the sales promotions that we might offer you while you are a member of the customer loyalty programme. We will also use this information for our internal analysis on how clients use our service and to improve these.

OK MOBILITY GROUP automatically collects technical information when you download, visit or use our websites and/or the apps of any of the companies of the Group. There are more details in this section about the technical information we obtain and why we need it.

• IP Addresses and other information that is obtained automatically: We might obtain your IP address when you visit our websites to help us diagnose problems with our mainframe computers, to run systems, supply information added to our business partners and to audit the use of our website. Normally we do not link the IP addresses to any data that is personally identifiable. In certain specific circumstances we might use the IP addresses to identify you if we think that this is necessary to be able to comply with the terms and conditions of our website or to protect our service, website, users or third parties. We might also collect data about the type of browser you use, Internet Service Provider (ISP), the referring/exit pages, the files seen on our website (such as for example, HTML pages, graphics, etc.), operating system, date/time stamp and/or clickstream  to analyse the aggregate trends and run the website.
• Session reproduction: When you visit our website sometimes we will also record data about your browsing session on the website, including the pages you visit and the forms that you have filled in on the website. We will study this information to detect any possible technical problems that might arise in the operations of our websites and to improve your user interface. We will use the services of an external third party to help us with this service and this information will be passed on to this third party for these purposes, although it will not be disclosed to any other third party.
• Cookies and other similar technology: Please read our Cookies Policy that is located in https://okmobility.com/en/cookies-policy for more information on how to use the cookies.
• Mobile web analytics:  When you download and use our Apps we will use mobile web analytics software to help us understand the functions of our App in your mobile device better. Our analytics can record the frequency with which you use the App, how you use it, the aggregate usage, the performance data and from where you have downloaded the App. Have a look in theAnalyticssection to find out more on how we use the information to carry out the analysis.
• Mobile GPS and Push Notifications:  When you use our  OK Mobility Apps we can obtain location markers using the GPS of your device, as long as you give your consent for us to do this. Knowing where you are approximately helps the App provide you with a better service such as, for example, find the nearest OK Mobility rental office or points that might be of interest to you. It also helps us send you push notifications and other messages based on your location (such as, for example, special offers in the surrounding area) and to supply certain services such as, for example, arrival and return notifications, supply information about where the vehicle is located, improvements available, etc. We only share this information with our supply chain mapping supplier so that we can provide you with our services. To make sure that you receive the appropriate messages we need to obtain certain information about your device such as, for example, the operating system and the user’s identification details. If you change your mind about sharing your location or being sent push messages from the App, change the settings of the configuration of your mobile device to turn off the transmission of the geolocation data or to stop the transmission of push notifications at any time. Remember you have to turn off these functions if you don’t want to be sent any more customized information based on your location or special offers according to the location.

MARKETING AND ANALYTICS

OK MOBILITY GROUP might share personal information to help us with our sales promotion and marketing projects such as, for example, the management of our pages in social media sites, organising competitions, giveaways and other sales promotions or to send marketing messages.

We will only use your personal information to send you marketing when you have given us your permission to send it to you or when we are authorised to do so pursuant to the provisions established in the applicable law. You will be sent this marketing via email, SMS, push notifications or by post.

If you do not want to be sent any advertising and marketing by post, emails or messages from OK MOBILITY GROUP and our associates you can withdraw your consent concerning the direct marketing at any time or tell us that you do not want to receive any more commercial messages.

Furthermore, we use analytics software such as, for example, Adobe Analytics, Google Analytics, among others, to help us understand better how our software in our websites and Apps in your device work. These software tools will record technical information including, but not limited to, information about your device together with the information about use, such as, for example, the frequency with which you use our website or App, the features that you use or don’t use on the website, or what pages you visit on the website, aggregated use, performance data, when you downloaded the App and information about your visit to the website, including details about the clickstream in a uniform resource locator (URL) to, through and from our website. Have a look at our Cookies Policy for more information about these tools.

SHARING INFORMATION

OK MOBILITY GROUP might use and share your personal information and data about the vehicle with subsidiary and non-subsidiary organisations pursuant to the following terms:

Third party recipientPurpose of the disclosureLegal grounds of the processingIndependent licensees and/or

franchisees and network suppliers to comply with our agreement with you, to understand how you use our services and to improve our business Process and confirm your rental reservation;Compliance of the agreement;Supply our award programme and update the members’ points and awards;Legitimate interests;Connect with your corporate and business accounts;Legal obligation; orHelp with the browsing assistance or itinerary planning;ConsentHelp customers; Sort out parking, traffic or toll road fines; Processing all the claims related to accidents and/or injuries; Provide roadside assistance services; Protect or defend our rights or well-being,

that of our employees, customers and others; Check the safe driver criteria for drivers so that they comply with the requirements; Travel agents to comply with our agreement with you when you use a travel agent, to understand how you use our services and to improve our business Process and confirm your vehicle rental reservation;Compliance of the agreement; orProcess payments and refunds;Legitimate interests.Help with browsing assistance or itinerary planning; Help customers; Provide roadside assistance; Protect or defend our rights or well-being, that of our employees, customers and others; Your company or organisation in order to provide you with the benefits of a corporate or association programme, to understand how you use our services and to improve our business Check driving licenses and any other official identification document.Compliance of the agreement; orVerify your right to use a designated account

and the discount codes;Legitimate interests.Connect with your corporate and business accounts; Intermediaries in order to comply with our agreement with you when you book a rental vehicle using their services and to protect our business against fraud and non-payment Process and confirm your vehicle rental reservation;Legitimate interests.Process payments and refunds;Help customers;Manage debt collection;Determine whether there is fraud.Booking engines to comply with our agreement with you when you use a booking engine, to understand how you use our services and to improve our business Process and confirm your vehicle rental reservation;Compliance of the agreement; orVerify your right to use a designated account and the discount codes;Intereses legítimos.Process payments and refunds; Protect or defend our rights or well-being, that of our employees, customers and others; Credit card issuers to receive the payments you make Process payments and refunds;Compliance of the agreement; orDetermine whether there is fraud.Legitimate interests.Manage debt collection; Corporate account managers in order to provide you with the benefits of a corporate or association programme, to understand how you use our services and to improve our business If you are renting a vehicle using a corporate or association account or that of any other similar business entity, we might share your personal data with the organisation that runs the account for its own purposes. We recommend checking its Privacy Policy to find out more about its privacy principlesCompliance of the agreement;Legitimate interests. Marketing agents in order to provide you with the benefits of a corporate or association programme, to understand how you use our services and to improve our business Supply our award programme and update the points and prizes of the members;Compliance of the agreement; orProtect or defend our rights or well-being, that of our employees, customers and others;Legitimate interests.Computer service suppliers,

including computer platform suppliers and website analytics service suppliers in order to comply with our agreement with you, to understand how you use our services and to improve our business Support our computer systems and infrastructures;Legitimate interests.Supply maintenance services for our computer systems and infrastructures;Supply data hosting services and other data

processing services;The provision of analytics services related to your use of our website to detect any technical problems or user interfaces and/or improvements associated with the website;Administrative, regulatory and law enforcement agencies to comply with our legal obligations Check your driving license and ensure that our safe driver criteria is complied with;Legal obligation; orAs requested by these agencies if the disclosure is compulsory or it is allowed according to the law;Legitimate interests.Take measures concerning illegal activities, traffic offences or breaches of the service terms and conditions; If we believe in good faith that there is an emergency in which your safety or that of another person is threatened; and As required and allowed by the Law. Insurance companies and claims handlers regarding any insurance product that has been acquired in association with your vehicle rental  Supply and provide the insurance product that you have requested;Compliance of the agreement; orDeal with the claims that might be made pursuant to the applicable insurance policy.Legitimate interests.

We can also transfer or pass on your personal information to third parties as a result of, or in relation to a sale, merger, consolidation, change of control, transfer of assets, bankruptcy, restructuring or liquidation. Moreover, in the case in question, the defence against a legal claim, we might pass on information about you to third parties, which is relevant for this claim, as a result of or in relation to the associated legal proceedings.

In accordance with the terms established in the Marketingsection, we might share your information with sales promotion and business associates (when you have given us your consent to share this information) to send you information about the products and the services that you might like. If you decide that you do not want to receive these promotional and marketing messages anymore, read theYour Options section to find out how you can exercise your right to withdraw the consent you gave previously.

INTERNATIONAL TRANSFERS

Rentals

Seeing as we give our customers the chance to rent vehicles and benefit from the services that we supply in many parts of the world, we will pass on your personal information to our subsidiaries, independent licensees and travel agencies to these places so that we can process your request to rent a vehicle and/or enter into a rental agreement with you. The exact place where your personal data will be transferred to will depend on where you rent the vehicle. The list of these places is available on our website https://okmobility.com/en/rent/.

This data is passed on insofar as it is necessary to comply with the terms of an agreement that you have signed or as precontractual measures. Alternatively the compliance of the data protection is guaranteed by including the data protection clauses with the corresponding recipient. You can request a copy of these data protection clauses from our data protection office that is located at the address stated inData controller and contact details in each country.

The United States is not party to any decision issued by the European Union Commission concerning the protection of personal information. Instead, the compliance of data protection is guaranteed through the data protection type clauses that we have established with these third parties. You can request a copy of these clauses at our data protection office at the address stated in the section Data controller and contact details in each country.

Given the global nature of our business, we also pass on information within the companies of the OK MOBILITY GROUP, because for certain activities of the group shared computer functions are used.

YOUR PRIVACY RIGHTS

1. How do we collect your personal data?
   We collect data provided directly by customers, either when they request a service by filling in the forms provided for this purpose or from data provided by them over the course of the contractual relationship via different means, such as claims or requests for information made to the customer services department. The Customer shall be responsible for the truthfulness of this information and for and updating it
   When filling in a form on our website, you are obliged to fill in the fields marked with an * (asterisk). If you do not provide this data, we may be prevented from complying with certain obligations. This data will sometimes be shared with partner or third party websites. This shall always be clearly indicated. If these parties process your personal data, this shall be declared in their privacy policies.

2. Legitimation for the use of your personal data.
   We inform you that the processing of your data is legitimated by:
3. • Your consent.
   • The preparation or execution of a contract.
   • To comply with a legal obligation.
   • To protect your ‘vital interests’.
   • The need to process personal data to satisfy a task of general interest
   • Due to our ‘legitimate interests’ or those of our employees.

3. Purposes and grounds for processing your personal data
   Your data may be processed for the following purposes:
4. • Purpose 1: To provide the contractual service, the information that you provide is processed to offer you the requested service and to bill you. The data provided shall be retained for the duration of the commercial relationship or the years required to comply with legal and contractual obligations.
   • Purpose 2: To send information about the fees, promotions and offers of OK MOBILITY or the remaining brands linked to the OK MOBILITY group of companies applicable to the contracted service or those which are similar.
   • Included in this purpose is the use of your personal data to send you communication related to the provision, improvement and updating of services, as well as advertising about promotions applicable to your service, or other services, including added-value services, which you may find interesting.
   • Purpose 3: Development of commercial actions about products and services offered by other companies in the OK MOBILITY group.
   • If you give your consent,OK MOBILITY will be able to develop commercial actions to ensure that you are sent offers and promotions about products and services from companies in the OK Group via any channel.
   • Purpose 4: Development of commercial actions about products and services offered by third party companies belonging to the leisure, culture, insurance, financial services, tourism, health or automotive industries.
   • If you give consent,OK MOBILITY will be able to develop commercial actions to ensure that you are sent offers and promotions from third party companies from the leisure, culture, insurance, financial services, tourism, health or automotive industries, via any channel.
   • Purpose 5: Disclosing your data to companies in the OK MOBILITY group.
   • If you give your consent,OK MOBILITY shall disclose your data to the remaining companies in the Group for the following purposes: 1. To be able to share information and, by studying the collected information, to complete statistical studies to carry out commercial actions of great value for both parties (e.g. to identify the offices where vehicles are rented from most frequently). 2. To allow the remaining companies in the Group to contact you directly via any communication channel, to develop commercial actions about products or services.

4. Who do we disclose your data to?
   Personal data processed by OK MOBILITY may be disclosed to the following recipients to comply with the aforementioned purposes:
5. • State, Autonomous Community and Local Public Administration, to comply with legal obligations.
   • State security bodies and forces, to comply with legal obligations.
   • Courts and Tribunals, to comply with legal obligations.
   • The Tax Authorities, to comply with legal obligations.
   • Banking entities, for financing matters to execute a contract.
   • OK MOBILITY companies, if you give consent for this

5. Data retention period
   Personal data shall be retained for the duration of the contractual relationship with the customer and beyond this, until you decide to request the erasure of your data or until this is legally necessary, if you gave consent. Once the contractual relationship has come to an end, if you decide to request the erasure of your data, it shall be erased in compliance with the data protection regulations which implicates its blocking. This is only available at the request of Judges and Tribunals, the tax Authority, or competent Public Administration during the prescription period of the resulting actions.

6. In any case, if there are any outstanding disputes at the end of the contractual relationship deriving from challenging the invoice or attempts to recover payment, data may be retained which these disputes are being processed, while there is no definitive resolution. When a resolution is reached, the data shall be blocked and then erased, and may only then be used for probationary purposes.

6. Data protection and your rights
   OK MOBILITY informs that they shall process data in a legal, loyal, transparent, appropriate, suitable, limited, accurate and updated way. For this reason, OK MOBILITY shall adopt all reasonable measures so that data is erased or rectified without delay if it is not accurate.
   In compliance with the rights established in data protection regulations in force, you may exercise the following rights:
7. • Right to access: Know what type of data we are processing and the characteristics of the processing that we are carrying out.
   • Right to rectification: You may request the modification of your data if it is inaccurate or not correct.
   • Right to portability: To obtain a copy of your data which is being processed in an interoperable format.
   • Right to limitation of data processing in cases contemplated by Law.
   • Right to erasure: Request the erasure of your data when processing is no longer necessary.
   • Right to opposition: Request that commercial communication is no longer sent and that direct marketing profiles are no longer made, in the aforementioned terms.
   • Right to withdraw previously granted consent. The request shall be processed within approximately 20 days.

You may exercise your rights by writing to: OTHMAN KTIRI GROUP SL, at the following company address: AVDA GRAN VÍA ASIMA, 36-A, 07009 Palma, Majorca, Spain, or by emailing: rgpd@okmobility.com indicating the right that you wish to exercise and enclosing the required documentation. On the Spanish Data Protection Agency website, you will find a series of templates which shall help you to exercise your rights. To consult all Data Protection information related to  OK MOBILITY and the companies belonging to this society, refer to: DATA PROTECTION