Privacy policy

Last revised: July 13, 2020

JYP Rentals LLC, for and on behalf of its subsidiaries (collectively, “JYP Rentals LLC”, “we”, or “us”) cares about privacy and wants you to be familiar with how we collect, use, process and disclose your personal information. This Privacy Policy covers our privacy practices in connection with your access to or use of our websites and applications (“Platform”), including when you communicate with us or other JYP Rentals LLC users via the Platform (collectively “Services”), or when you otherwise provide us with personal information.

Information We Collect from You

For All Transactions:

We collect:

CONTACT INFORMATION, including:

• Name
• Address
• Phone numbers
• Email addresses

When Renting

When Renting a vehicle with JYP Rentals LLC

Driver Qualifications and Identify Verification, including:

• Driver’s license information, including photographs you submit of you and your driver’s license.
• Insurance information
• Passport
• Proof of residence
• Personal references

Transaction Information, including:

• Vehicle rental information
• Rental and return locations
• Dates of the rental
• Type of rental and your vehicle preference
• Ancillary products purchased
• Photographs you submit of receipts through the camera feature available on some of our mobile applications and websites
• Billing information
• Charges
• Payments
• Credit Card information

Loyalty and Affiliation Information, including:

• JYP Rentals LLC, Alamo, or National rewards and loyalty information
• Online user account details
• Corporate Account ID numbers
• Membership numbers
• Frequent flyer or travel partner affiliations

Claims Information

• Information related to details of accidents involving our vehicles, including that of any third parties such as involved individuals, witnesses, and police reports

Health Information, including:

• Information about relevant health conditions you have that assist us in providing you with adaptive driving devices; or related to claims involving injuries

Optional Information, including:

• Emergency contact information
• Any preferences or special requirements you may have

When using our Websites and Mobile Applications

We collect:

Browser Information, including:

• Web logs
• Geo-location

Device Information, including:

• Unique device identifiers
• IP address
• Operating system
• Geo-location information

With your consent, we will access location-based information, such as zip code, postal code, city, metropolitan area or geographic region from your mobile device. We will use this information to provide you with notifications related to our locations, return information, local offers or other information that we think will be helpful in providing you with better services. We are only able to identify you using the location-based information if you log into one of our mobile applications. The location-based information is retained for seven years. This data is hosted by our analytics providers.

With your consent, our application will utilize your device's camera. If you have allowed us to utilize your location information or your device's camera in the past, and wish to revoke the permissions, please change the settings on your device.  

For other online information collected please see our Cookie Policy

When Participating in Surveys or Promotions

We collect:

• Marketing preferences
• Feedback on services provided

Information We Collect from Third Parties

Third parties provide us with additional information about you or your household, including:

• Referral sources, such as third-party online booking sites (who provide us general contact information and a booking confirmation number to facilitate the rental), your employer (general contact information), credit unions, and your insurance provider (general contact and policy information);
• Where applicable, our Refer-A-Friend, or similar programs.
• Hotel, airline and membership clubs who provide us your general contact information and booking information;
• Third parties who, for fraud prevention purposes, provide us with identity-related verification and document authentication;
• Credit and financing partners, including credit reporting agencies, who facilitate the completion of credit applications when financing a vehicle purchase;
• Franchisees who provide us information regarding your rental transactions;
• Service providers, such as customer support (customer service-related information and enquiries made by you), security services (footage of you from our CCTV system), and customer survey providers (your response to our customer service surveys);
• Marketing providers who provide information to assist us to better communicate our products and services, including email acquisition services, data hygiene services, data brokers, and market research partners and platforms.

Vehicle Data

Our vehicles may be equipped with technology that collects and transmits data from your rental vehicle. This may include information collected from event data recorders, global positioning devices, OnStar® systems, or any other similar technology. When installed and where permissible, this technology will enable us to collect and use information such as:

• location information.
• collision information; and
• vehicle operation information, such as operational condition, mileage, tire pressure and fuel status, and other diagnostic and performance information.

Once collected, this information may be combined with information you have provided us and used to generate safety, performance, and other similar information so that we can deliver better services. Our use of the information may also include storage of this information after the expiration of your rental agreement.  Renting a vehicle does not prohibit us from obtaining and using data collected from the vehicle. Your use of the Vehicle Data Systems made available to you is subject to the terms and conditions and privacy policy posted by the applicable Vehicle Data Systems provider and/or vehicle manufacturer (in the case of OnStar, information is available at www.onstar.com), which may include system and service limitations, warranty exclusions, limitations of liability, wireless service provider terms, privacy practices, descriptions of use and sharing of information and user responsibilities. See a list of manufacturers from which we purchase vehicles on the Vehicle Manufacturers page.

Our use of information collected from the rental vehicle may include sharing information with third parties as described in this policy.

If you pair your mobile device with the rental vehicle’s satellite navigation or infotainment systems, your personal information may be transferred to and stored on these systems. We cannot guarantee the privacy or confidentiality of such information and it is your responsibility to wipe your personal information from these systems before returning the vehicle.  Otherwise, the next users of the vehicle will be able to access this information.

If you download a mobile application made available by the vehicle manufacturer and you register the rental vehicle in that app, your use of the app may result in the sharing of personal data, vehicle information, location information and driving characteristics with the vehicle manufacturer. Your use of these apps is strictly governed by the vehicle manufacturer’s terms and conditions and privacy policy.  Prior to returning the rental vehicle, it is your responsibility to either remove the app or delete the rental vehicle from the app.

In the European Union, our vehicles are required to be equipped with eCall technology, which is activated if your vehicle is involved in an accident. eCall will automatically call and provide information regarding the accident to emergency services. We will also use, disclose and have access to this information.   

Vehicle Data will be shared with emergency service providers, others who assist in responding to an accident, telematics service operators or those with whom we have a legal or contractual obligation to provide such data.

Children's Privacy

Our websites and online marketing are not directed to, and JYP Rentals LLC Holdings does not knowingly collect personal information from, children under the age of 18 or your country's age of minority. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please contact us using the link at the top of this page.

How We Use Information About You

We use the information we collect from you or about you to provide you with our services and for the following purposes:

Where it is necessary for us to enter into a contract with you and provide services to you for the duration of the contract, including

• To assist the transactions that you request, such as reserving, renting, purchasing or leasing motor vehicles.
• Unless where consent may be required by applicable law, to communicate important information regarding your reservation, rental, lease or purchase of a vehicle.  These communications are transactional in nature and will be sent to you via email, text or calls.
• To provide customer service related to your interactions with us or to respond to your enquiry.
• To enroll you in our loyalty programs and send information relating to your ongoing membership of these programs.

Where necessary for us to comply with a legal obligation, including

• To use and share information about your vehicle's location with emergency services in the event that you are involved in a road accident;
• To use and share information with government and regulatory authorities when required by law or in response to legal process, obligation, or request, including checking appropriate sanction lists.

Where it is necessary for our legitimate interests, as listed below, and where our interests are not overridden by your data protection rights, including

• To communicate important information about your rental and provide you great service. These communications, which are transactional in nature, will be sent to you via email, text or calls;
• To assist us in providing better products and services: for example, to evaluate the performance of our staff, to assess the quality of products and services received and to help us improve our websites, facilities and services.  Unless where consent may be required by applicable law, your feedback may be requested via email, text or call.
• To compile statistics and analysis about our customers' use of our websites, products and services. These statistics are used only to enable us to provide better customer service, products, features and functionality to you and other customers in the future;
• Where permissible, to develop a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you;
• To protect our legal rights and manage the security of our networks and property, including to protect our websites from spam and abuse. For example, we will use CCTV to ensure the security of our premises;
• For loss prevention, we maintain a record of individuals whose past interactions with us indicate they may present a non-payment or safety risk;
• To use and share your information with third parties to prevent fraud and protect our business interests and rights, privacy, safety and property, or that of individuals and the public. We will do this to respond to law enforcement request, collect unpaid bills, to avoid liability for penalties you incur (e.g. traffic citations) and for claims processing purposes;
• For fraud prevention purposes, to verify identity and authenticate identity-related documentation as well as additional points of contact for rental related communications through personal references.
• To use and share your information with third parties to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any rental agreement or our websites' terms and conditions;
• To enable us to use vehicle data systems for purposes listed in the Vehicle Data section above;
• Unless where consent may be required by applicable law, to send you certain promotional or targeted marketing communications, opportunities and services that may be of interest to you. These will include invitations to join our loyalty programs, upgrade announcements, communications regarding an incomplete online membership form or reservation, and offers related to other services and products we offer. Some of these offers will be received in advertising on non-JYP Rentals LLC sites, including on social media;
• To de-identify or aggregate personal information collected about you and use it for any lawful purpose; and
• To transfer your data as described in the “Global Data Transfers and Processing” section.

Where you have given consent, as required by your country’s applicable law, including

• To assist us in providing you with the most appropriate vehicles, such as those with adaptive driving devices. In some cases, this will require us to infer or explicitly collect information about your health or physical condition;
• To send one-time use security tokens via text
• Where applicable, to ask for you feedback by email, text or call, to assist us in providing better products and services: for example, to evaluate the performance of our staff, to assess the quality of products and services received and to help us improve our websites, facilities and services.
• Where applicable to ask if you want to receive by email or text promotional or targeted marketing communications, opportunities and services that may be of interest to you. These will include invitations to join our loyalty programs, upgrade announcements, offers and discounts, online communications regarding an incomplete online membership form or reservation and offers related to other services and products we offer. Some of these offers will be received in advertising on non-JYP Rentals LLC sites, including on social media;
• You can choose to withdraw your consent at any time; however, such withdrawal does not affect the lawfulness of processing before your withdrawal.

Retention of Your Personal Information

We retain your personal information for as long as we need to fulfil our business purposes, as set out below:

Rental transactions

We keep the data associated to your rental agreement for up to seven years from the date of the rental, subject to other local legal requirements. We keep records of payments you have made for two years from the date of the transaction (depending on the location of the rental).

Car Sales

We keep the data associated to the sale of a vehicle for up to ten years from the date of sale, subject to other local legal requirements.

Claims

We keep the data associated to claims involving our renters or other individuals for the life of the claim and up to ten years from conclusion of our obligation, subject to other legal requirements

Customer service-related queries

We keep general queries for three years, unless you make a complaint, in which case, we keep complaint data for seven years.

Marketing and analytical purposes

We keep data linked to cookies and other online identifiers up to three years. We keep other marketing information, such as email subscription and loyalty enrollment data for up to seven years after your last interaction with us.

Disputes & law enforcement

If we are involved in litigation or a governmental or regulatory investigation, then we keep data throughout the period of litigation or investigation and for five years after that. If a settlement means that we must keep data for longer, then we keep data for the period required to administer the settlement. If we provide data to law enforcement agencies, then we keep a record of this for one year beyond the end of the investigation.

Who We Share Information With 

As a global provider of transportation solutions, we share your information as follows to provide a seamless transactional experience.  

Subsidiaries

We share your contact, driver qualification, transactional, loyalty and affiliation, health, optional information, claims information, car sales financial and personal information, and car sale transactional information with our subsidiaries for providing the transactions you have requested and (with your consent and where applicable) for marketing purposes. See the Subsidiaries page for a list.  The list is subject to change from time to time and you should periodically review it for changes. Our subsidiaries’ employees in our IT, marketing, operations and customer service divisions will use your information, as described in this Privacy Policy, including, if required by applicable law, to send you information about products and services or respond to your inquiry.

Franchisees

The nature of the business and operations require us to share your contact information, and where applicable driver qualification, transactional, loyalty and affiliation, and (if applicable) health information with our franchisees ("Franchisees").  See the Franchisees page for a list. The list subject to change from time to time and you should periodically review it for changes.  For these transactions, the Franchisee is an independent data controller or equivalent under applicable law and will maintain its own privacy policy in respect of the rental data that you provide to the Franchisee. You are encouraged to check the privacy policy of the Franchisee that is applicable to your transaction.

To identify who is the data controller or equivalent under applicable law in respect of your personal information, see the Key Facts information provided in your rental reservation, the rental terms and conditions or visit the Contact Us page.

Fulfillment Providers

We may use a fulfillment provider to carry out your rental car transaction. For example, if you make a reservation for a car and driver in countries that require a driver, we will send your Contact and Transactional Information to the fulfillment provider in those countries. Where car and driver services are made available for you to reserve, these services are fulfilled by the company disclosed at the time of reservation.  While made available through our branded websites, these companies are independent operators.

After your purchase of a vehicle from one of our Car Sales locations, and at your request, to facilitate additional vehicle options (leather seats, tinted windows, etc.) we will share your contact and (where applicable) car sales transactional Information with the companies that provide those products or services. For these transactions, the fulfillment provider is an independent data controller or equivalent under applicable law and will maintain its own privacy policy in respect to the information that you provide to the provider. You are encouraged to check the privacy policy of the provider that is applicable to your transaction.

Our Service Providers and Business Partners

We will share your:

Contact, driver qualification, transactional, claims information, car sales financial and personal information, and car sale transactional information

• Payment, administrative and technical support providers
• Our insurance replacement, corporate rental or other customers or partners to facilitate the vehicle repair, rental transaction, and rewards programs with JYP Rentals LLC Holdings group members    
• Vehicle recovery agents
• Debt collection providers
• Credit Reporting Agencies
• Identity and address verification providers
• Claims processors

Health Information

• Claims processors
• Adaptive device providers

Contact and transactional information

• Toll and citation processors

Contact, Transactional, Loyalty and Affiliation Information:

• For insurance replacement, corporate rental or other customers or partners to facilitate the rental transaction and rewards programs with JYP Rentals LLC Holdings group members;
• Companies who conduct customer research or satisfaction surveys on our behalf;
• Communication providers which send email, text and other marketing and service-related communications to you on our behalf; In the European Union, our communications provider, Twilio, may collect and process certain information from you as a controller to provide these services.   Please visit Twilio’s privacy notice here to learn more about their data practices.
• Customer support providers, such as the provider of our live chat feature, in order to provide you customer service;

Web and Mobile Information

• Analytics and technology providers for location-based services and to analyze, enhance and manage our data in order to provide, maintain, and improve our services;
• Web and mobile application session replay partners allow us to replay user sessions to improve browsing experience and troubleshoot errors; and

Anonymized and De-identified information

• Our advertising and marketing partners and third-party media properties, including social media sites, with whom we share aggregated or de-identified information about our customers, to allow them to send targeted advertising messages on our behalf (subject to confidentiality agreements as appropriate).

Government Authorities

Your personal information may also be shared with government authorities as outlined above.

Sale, Merger or Change in Control

Your information may also be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of JYP Rentals LLC Holdings' businesses or assets. This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your personal information or as otherwise may be required or permitted by law.

Testimonials

We may post customer testimonials on our websites which may contain your contact information. We use a third-party provider to manage this process. This provider is responsible for obtaining your consent as necessary, removing content upon your request and answering any questions you may have.

Social Media Widgets

Our websites may include social media features, such as the Facebook button. These features may collect your IP address, pages you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our site. Your interactions with these features are governed by the privacy policy of the company providing it.

If you use one of these social media sites and do not want them to collect data through our website and link it to your member data, you must log out of your user account before visiting our website and delete the relevant cookies. You can also block social plug-ins with browser add-ons. See the social media site for their plug-in instructions or see our Cookie Policy for more information.

Selling your Information

JYP Rentals LLC does not sell your personal information to third-parties.  While we do not sell your data, under Nevada law residents still may submit a request to not have their data sold.  If you are a Nevada resident you can exercise this right by  accessing  our Global Privacy Portal on our Contact Us page.

While we do not sell your data, as is common with companies with an online presence, some of our advertising uses information collected by businesses from our digital properties, including IP addresses, digital identifiers, information about your web browsing, and how you interact with our properties and ads, in order to provide you with relevant ads across the Internet and for other analytics purposes. These companies may sell that information to other businesses for advertising and other purposes.

Under the California Consumer Protection Act, California residents have the right to opt out from sales of their personal information.  California residents can exercise that right by visiting www.privacyrights.info to opt out from sales of this type of personal information by businesses that participate in the opt out tool.

Global Data Transfers And Processing

In order for us to operate and provide you services globally, the information you provide us or that we collect may be transferred or accessed by entities around the world, including:

Franchisees/Corporate-Owned Locations

If you book a reservation to be fulfilled by a franchisee in another country or an JYP Rentals LLC corporate-owned location (e.g., in the United States, Canada, Germany, Spain, France, Ireland and the United Kingdom), we will transfer your personal information to that country in order to facilita6te your requested transaction.

JYP Rentals LLC Global Information Systems Based in the United States

JYP Rentals LLC maintains its global information systems in the United States.  If you provide us or if we collect personal information about you outside the United States, we will transfer and maintain your personal information in the United States.

When we transfer your personal information and process it in the United States, we do so in accordance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (described below) and European Commission-approved standard contractual clauses.

Third Party Service Providers

We utilize third party service providers who are located outside the countries where we have corporate-owned locations, such as call center support, claims processors and IT providers. When we transfer your personal information to our third-party service providers who are located outside the EEA, we use European Commission-approved standard contractual clauses.

Visit the Contact Us page for the data controller applicable to your transaction.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

JYP Rentals LLC Holdings participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom, and Switzerland, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles.

To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List. With respect to information received or transferred pursuant to these Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

JYP Rentals LLC Holdings is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. JYP Rentals LLC Holdings complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, the United Kingdom, and Switzerland, including the onward transfer liability provisions.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Your Rights

EU General Data Protection Regulation (GDPR) and UK Data Protection

If GDPR and/or UK Data Protection is applicable to your transaction in the European Economic Area, United Kingdom, or Switzerland, you have the right to:

• Opt-out of some collection or uses of your personal information, including the use of cookies and similar technologies and the use of your personal information for marketing purposes, and the anonymization of your personal information for data analyses;
• Access your personal information, rectify it, restrict or object to its processing, or subject to exemptions under law, request its deletion;
• Receive the personal information you provided to us to transmit it to another company;
• Withdraw any consent provided; and
• Where applicable, lodge a complaint with your supervisory authority.
• Contact our Data Protection Officer (DPO@ehi.com) or submit a privacy compliant through our Global Privacy Portal form.

California

Under the California Consumer Protection Act (CCPA), California residents have certain rights with respect to personal information about them we have collected.  If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

• Right to access the personal information we have collected about you and learn how we collect this information, our purpose in collecting it, and the types of parties we may have disclosed it to;
• Right to delete the personal information we have collected from you; and
• Right to opt-out of our sale(s) of your personal information, if applicable.
• The right not to receive discriminatory treatment for the exercise of [the relevant] privacy rights conferred by the CCPA

Canada

If you are a resident of Canada, you have the right to:

• Access your personal information and rectify it;
• Withdraw any consent provided; and
• Where applicable, lodge a complaint with your supervisory authority.

Exercising Your Rights

You may exercise any applicable rights described above by accessing our Global Privacy Portal on our Contact Us page.  If you wish to lodge a complaint with a supervisory authority, in Europe you may contact the necessary supervisory authority. In Canada you may contact the Privacy Commissioner of Canada by visiting https://www.priv.gc.ca/cu-cn/index_e.asp or at Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3. 

We may require additional information from you to verify your identity and residence before we can process your request.  For California residents wishing to exercise their rights under the CCPA you must provide your driver’s license or official state identification document in order to provide proof of residence.  Please be sure to redact your photograph and all identifying information, other than your name, address and driver’s license number.  We also reserve the right to restrict access to your information or to limit your rights (e.g., if such disclosure is prohibited by law or if the rights of another individual might be violated).  In some instances, this may mean that we are able to retain your personal information even if you withdraw your consent.

California residents may designate an authorized agent to make a CCPA request on your behalf by completing and signing the form available here. 

Marketing Preferences

You will be able to opt out of direct marketing communications from JYP Rentals LLC Holdings and our subsidiaries, affiliates and Franchisees by following the instructions in each communication you receive.  You may also contact us directly using the link at the top of this page.

You can opt out of display ads you see on non-JYP Rentals LLC sites by clicking on the ad choices icon in the ad or through the privacy settings on the site.

Changes To These Policies

As necessary, we will update our Privacy Policy and Cookie Policy to reflect changes in our privacy practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site or as otherwise may be required or permitted by law, prior to the change becoming effective. We encourage you to periodically review this site for the latest information on our privacy practices.