Privacy Policy
Last modified: Aug 27, 2022
We are AutoGIRL, a Vehicle Rental Company of Cars, Boats, and Jets (together “we”, “us”, and “our”). This policy does not cover our licensees or affiliates or other third parties through whom you may interact with us. This is a high-level summary to explain how we collect, process, store and otherwise use information about you and your rights in relation to that information. For full information, please see the full policy below.
COLLECTION
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SHARING
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YOUR RIGHTS
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PURPOSES
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RETENTION & SECURITY
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QUESTIONS & CHANGES
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AUTOGIRL
CUSTOMER PRIVACY POLICY
SCOPE & CONTROLLERS
We are AutoGIRL, a Nigerian Vehicle Rental Company of Cars, Boats, and Jets, which operates in Nigeria to provide vehicle rental services to our customers under AutoGIRL (together “we” , “us” , and “our”).
Together we are the data controllers for the purposes of this Privacy Policy (“the Policy”).
We also use a network of licensees in the provision of our services locally and have an affiliate program. As our licensees, affiliates and entrusted third-party vendors are independent companies, they are not owned or controlled by us and are not covered by this Policy. We are not responsible for the privacy practices of our franchisees, licensees, and other third parties with whom you may transact.
This Policy covers the information we collect about you in connection with our vehicle rental businesses, which identifies, or can be used to identify, you as an individual (“Personal Data”). It does not apply to information that cannot reasonably identify you. For example, but without limitation, aggregated anonymous data are not Personal Data.
We respect the privacy rights of our customers and are committed to protecting your privacy. This Policy explains our data handling practices with regard to your Personal Data, as well as your rights associated with that data.
Contents :
1. COLLECTION
We collect Personal Data that you provide on our websites, on third-party websites, on applications, and offline in connection with any inquiries, reservations, rentals, or purchases you make in relation to our services. We may collect your Personal Data directly or through our service providers, business partners, discount sponsors, licensees, advertisers, and booking channel providers. For further details, see below:
a. TYPES OF INFORMATION COLLECTED may include, but are not limited to:
Personal Information:
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Technological Information:
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Rental Information:
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Vehicle sourced information (telematics)
We may use in-vehicle data systems to collect data about the vehicle’s condition and performance (including mileage, fuel, and other operational data) and the driver’s operation of the vehicle during their rental for safety, security and claims management reasons and may retain this data as necessary for these purposes.
We may also have the ability to track the vehicle’s location throughout the duration of a rental, although we will only access this information in circumstances where the driver is in breach of the rental agreement, by failing to return the vehicle on time or by driving into unauthorised territories.
Sensitive Data:
We may collect certain Personal Data that constitutes sensitive data such as data about (i) health conditions (for instance, if you ask us to accommodate a disability, such as by provision of hand controls, or if there is an accident and we need to work with insurance and claims management companies relating to any injury you may incur) Depending upon applicable local law, we may be unable to process such sensitive data without your consent.
Please note that if you wish to rent with us or our licensees and need to provide sensitive data, we will use that sensitive data for our operational uses as described in this Privacy Policy, subject to your consent where required under applicable law.
- METHODS AND SOURCES OF COLLECTION may include, but are not limited to:
Online collection:
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Cookies and online data collection
We use cookies on our websites to store information in your computer or mobile device to improve your online experience. Cookies are small text files that let you navigate between pages efficiently, remember your preferences, help us understand how this website is performing, and generally improve your browsing experience. Cookies can also help to ensure the advertising you see online is more relevant to you.
Generally, our cookies may perform the following functions:
Essential cookies |
Some cookies are vital for the operation of our websites. Without them, you would not be able to move through the website and use some of its features. Essential cookies enable information you provide and decisions you take regarding your rental to be remembered from page to page in the booking process. Because these cookies are essential, we do not enable you to choose to disable them on our website. |
Functionality Cookies |
We use functionality cookies to allow us to remember preferences you have requested in previous visits including changes you have made to customise the site to your liking. We also use functionality cookies to provide you with enhanced services such as allowing you to watch a video online. The information these cookies collect is anonymised and used in relation to that website only. |
Performance Cookies |
We use performance cookies to analyse how our visitors use our websites and to monitor website performance. This allows us to provide a high quality experience by customising our offering and quickly identifying and fixing any issues that arise. These cookies don’t collect information that identifies a visitor. All information collected is aggregated and therefore anonymous and is only used to improve how our website works. |
Advertising Cookies |
We and our advertisers use cookies to serve you with advertisements that we believe are relevant to you and your interests. They are used to limit the number of times you see an advertisement as well as to measure the effectiveness of the advertising campaign. We may also use cookies placed by advertising agencies who may record that you have visited this website and share that information with other advertising organisations to enable targeted advertising to be sent to your computer. |
Third Party Cookies |
Third party cookies are set by a different organisation to AutoGIRL. For example, our websites may contain content embedded from, for example, YouTube, and banners delivered for AutoGIRL through an advertising partner’s network. These sites may set their own cookies. |
Our websites are not directed to individuals under the age of 13, and we do not knowingly obtain Personal Data from such individuals.
(ii) Apps
With regard to mobile apps, any app’s collection and use of Personal Data that is materially different from what’s described in this Policy will be supplemented by an individual privacy policy that will require acceptance for that specific app.
As the internet and other eCommerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.
Offline collection:
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Depending on the purposes for which we collect and use your Personal Data, as set out in this Policy, the Personal Data we collect from you may be required due to a statutory or contractual obligation, provided on a voluntary basis, or necessary for us to enter into a contract with you.
If you do not provide your Personal Data to us this may result in disadvantages for you. In particular, we may not be able to rent to you. However, unless otherwise stated, not providing your Personal Data will not result in legal consequences for you.
PURPOSES
Below we have set out the various purposes for which we process your Personal Data. We have also set out the legal grounds for the processing of your Personal Data for each purpose:
- OPERATIONS AND SERVICES: We may use your Personal Data to provide you with the services or products you request from us and to perform other activities related to such services or products, including billing and collection following a rental, or to communicate with you regarding (i) any reservation you initiate or rental transaction; (ii) your membership/status in one of our membership programs; or (iii) changes to the terms or features of any of our membership programs to which you belong.
Legal grounds: to perform our contract with you or to take steps at your request prior to entering into a contract with you.
- OUR MARKETING: We may use your Personal Data to provide you with marketing information, special offers and promotions via various means, including e-mail, in accordance with applicable law.
Legal grounds: on the basis of your consent. However, where permitted by applicable law we may lawfully use your Personal Data to send you such marketing communications (including via email) for these marketing purposes where necessary for our legitimate interests, which include promoting our products and services, special offers, and promotions which may be of interest to you.
You can unsubscribe from receiving such messages at any time by contacting us at the details in Section 6 below as well as the unsubscribe link in each e-mail
message. Please note that if you exercise these choices, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that this process may take some time to complete, consistent with applicable law.
- THIRD PARTY MARKETING: We may also share your Personal Data with an affiliate or other third party that provides you with special offers or promotions that may be of interest to you (“Third Party Provider”) where permitted.
Legal grounds: on the basis of your consent. You may instruct us at any time not to share your Personal Data covered by this Policy with such Third Party Providers where you have previously consented.
Please note that (i) this process may take some time to complete, consistent with applicable law; and (ii) even after such process is completed, your personal and other information may continue to be shared with our affiliates (including affiliated websites under common ownership or control), and designated service providers in accordance with this Policy.
- NORMAL COURSE OF BUSINESS: We may also process your Personal Data and other information if such processing is necessary:
- to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal processes;
Legal grounds: where it is necessary for compliance with a legal obligation to which we are subject.
Ii. to protect our interests, rights, safety, or property as well as the legitimate interests, rights, safety, or property of others;
Legal grounds: where necessary for our legitimate interests or that of a third party to protect such interests, rights, safety, and property. For example, in defense of claims brought against us in connection with your rental of our vehicle
iii to enforce any terms of service on our websites or the terms and conditions of any rental, purchase, or utilization;
Legal grounds : for our legitimate interests, which are to protect us and enforce such terms of service or terms and conditions.
Iv. as part of a business transaction where all or some of our assets are bought, sold, or otherwise transferred by act of law or contract; and
Legal grounds: for our and third parties’ legitimate interests.
- to operate our systems properly.
Legal grounds: for our legitimate interests, which are the proper running of our systems and our business in order to provide our products and services to you and other customers
- TELEMATICS: We may use in-vehicle data systems to collect data about the vehicle’s position, condition, and performance during your rental. Use may include
- to collect data relating to the vehicle’s condition and performance during the rental (including vehicle damage, mileage, fuel use, and other operational data) to improve the accuracy of our billing processes on return of the vehicle;
Legal grounds: for our legitimate interests to ensure accurate charging for your uses of the vehicle, including for fuel and damage, during your rental.
- to collect data relating to the driver’s operation of the vehicle during the rental for safety, security, and claims management reasons, including to contact the renter if the data suggests there is a security, safety, or operational issue that we need to bring to your attention.
Legal grounds: for our legitimate interests to enable us to defend and manage claims arising out of accidents involving the rental vehicle; to ensure we meet our safety and security obligations in relation to the vehicle and each rental;
iii .to track the vehicle’s location throughout the duration of a rental in order to access such information solely where the driver is in breach of the rental agreement (by failing to return the vehicle on time or by driving into unauthorised territories) or to assist in the defence and management of claims following an accident involving the vehicle.
Legal grounds: for our legitimate interests to protect our assets, enforce our terms and conditions and defend and manage claims.
- iv. to track the vehicle to enable us to provide information to you as you drive about areas of historic or leisure interest, restaurants, service or fuel stations, or other places or services of interest;
Legal grounds: on the basis of your consent.
- V. to share with you, your employer, or others information about your driving performance (such as speed) during your rental;
Legal grounds: with your consent to each specific use requested.
- WEBSITES: If you use our websites we may process your Personal Data as follows:
| i. | Aggregated or anonymised information: We may share with other third parties aggregate or anonymized information about our website users, such as your use of this website or other websites, and the services provided on this website or other websites, as well as any rental, purchase, or utilization information. | ||||||
| ii. | Social media: If you participate in certain public features of our websites, apps, or social media websites/apps, please note that any information you or others voluntarily disclose through use of such features, becomes available to the public and/or other users whom you have designated. If you choose to provide access credentials to designated individuals, please be aware that any information you provide to us may be visible to such individuals. We are not responsible for the information that you or others choose to disclose publicly and such information is not subject to this Policy. |
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| ii | Links to third parties :We may provide links to third-party websites, or may be linked to third-party websites. Since we do not control third-party sites, and we are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing applicable third parties with your information. SHARING(a) THIRD PARTY COMPANIES We may share your Personal Data with third parties in the following circumstances: (i) To provide services to you: We will share your personal data among ourselves, our agents, our licensees and other companies to provide services to you, including to:
(ii) Disclosure to companies you use : We will also share your information with companies you use in connection with your rental, including:
(iii) Protective and legal uses: We may use, share and disclose your personal data for legal reasons as we believe necessary or appropriate, including to:
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(iv) Disclosure to our service providers and agents: We may use other companies as our service providers or agents to act on our behalf and assist us in the conduct of our business, performing services for us under our instruction. These services may include hosting certain websites or databases, operating “apps” for us on our social media networks’ pages, running contests, sweepstakes and other promotions for us, sending marketing communications, carrying out data analysis and conducting customer satisfaction surveys or other research. We will seek to require our service providers and agents to maintain appropriate security standards to protect your personal data and use the personal data we provide to them only for the purposes we specify.
(v) Disclosure for corporate transactions: We may disclose your personal data to a third party in connection with any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
RETENTION & SECURITY
(a) DATA RETENTION
We retain personal data about our customers for as long as we believe is necessary for the purposes for which it was collected, or unless otherwise allowed or required by law. We collect Personal Data for a number of purposes (see above) and may be required to retain it for legal (including tax) reasons for a period which is longer than the time we need or use the data for the purpose of providing our rental services to you. We maintain a data retention policy to cover all the Personal Data we retain across our systems. If you have any questions about the retention period applying to the Personal Data we collect about you, please contact us (see Section 6).
(b) SECURITY MEASURES
Information is stored and accessed in various locations and cloud services. Servers which store information are primarily located in Nigeria, although storage may occur in other locations as well. We use reasonable administrative, technical, personnel, and physical measures (a) to safeguard Personal Data against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of your Personal Data. To help us protect your privacy, you should maintain the secrecy of any logon IDs and passwords, Member numbers, or other identifiers or credentials you may have set up or were provided with in connection with your participation in or use of our products, services, or websites.
(c) TRANSMISSIONS
As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted. If you have reason to believe that any account with us is no longer secure, you must immediately contact us.
We try to strike a balance between the security of your data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative. For example, but not limitation, we may send you an e-mail or a text message in unencrypted form (i.e. instantly readable) because many of our customers are unable to access encrypted (i.e. coded) e-mail or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. Such messages may contain Personal Data. Please do not include confidential information, such as account passwords, in any e-mail or text you send to us or on any posting you make to a public area of a third-party social network page, especially since any such posting immediately becomes public. For a more secure way to communicate with us over the Internet, please click on the “Contact Us” link on any of our websites.
YOUR RIGHTS
| a) | You have the right to request access to, review, and update your Personal Data covered by this Policy, and can request this by contacting us at the details set out in Section 6 below. While we will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws. You also have the right to:
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