CALIFORNIA RESIDENTS

California’s “Shine the Light” law – Civil Code section 1798.82 – permits residents of California to opt-out of disclosure of Personal Data to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Data with third parties for marketing purposes at any time by submitting a request in writing to Our contact address below. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes. California law also permits residents of California to request and obtain from Us once per calendar year, free of charge, a list of (i) the third parties (if any) to which Personal Data was disclosed for their direct marketing purposes in the prior calendar year and (ii) the categories of Personal Data disclosed to those third parties.

Under the California Consumer Privacy Act (“CCPA”), you have the following rights:

• (1) the right to access your Personal Information and request certain Personal Information We have collected about you in the preceding 12 months including (a) the categories of Personal Information collected about you; (b) the categories of sources providing that Personal Information; (c) the categories of third parties with whom We have shared that Personal Information; and (d) the business purpose for collecting that Personal Information; and (e) the specific pieces of Personal Information we collect, use, disclose, and sell. You may make such a request up to twice in a 12-month span;
• (2) the right to request we delete your Personal Information no longer necessary to fulfil our legal obligations or protect Our legal rights;
• (3) the right to opt out of the “Sale” of your Personal Information We have collected. If you exercise that right, please note that pursuant to the CCPA We may have to subsequently inform you that you need to opt-in if the sale of your Personal Information is required to complete a transaction you have initiated. If opting-in is required, We will provide you with the necessary instructions; and
• (4) the right not to receive discriminatory treatment for the exercise of your rights under CCPA.

COMPLAINTS
Please contact Us as specified below if you have any questions, need access to your Personal Data, or otherwise need assistance. We also are responsible for third-party agents that are processing such data on our behalf, unless we prove that we are not responsible for the event giving rise to the damage. We are also subject to the investigatory and enforcement powers of the Federal Trade Commission with respect to the Framework. Should you have a concerns or complaints about the handling of your Personal Data being in violation of this Privacy Policy, you may contact us directly via the methods described below in the “Contact Us” section. We will work to respond and resolve your complaints in an expeditious manner.

CHANGES
We reserve the right to change this Privacy Policy at any time for any reason by posting revisions on this Webpage or on applicable apps or other sites. Such changes will be effective upon posting, but will not apply retroactively. Whenever We make a material change, We will note the date of such update in the introductory paragraph above, and post a note on the home page of our applicable websites.

DATA COLLECTION (WHAT & HOW)

We, both directly and through Our service providers, business partners, discount sponsors, licensees, advertisers, and booking channel providers, collect Personal Data that you provide on Our websites, on third-party websites, on applications, and offline in connection with any inquiries, reservations, rentals, purchases, or services. Information collected about your use of Our websites, applications, or other websites may be combined with personal or other information about you from other online or offline sources. We also will collect Personal Data across all the devices you use to access websites or applications of Us and Our designated service providers.

Providing your Personal Data to Us may be required due to a legal obligation which could be a statutory or contractual obligation, may be on a voluntary basis or may be necessary for us to enter into the contract with you, depending on the purposes for which we collect and use your Personal Data as set out in this Privacy Statement. However, if you do not provide your Personal Data to Us this may result in disadvantages to you, e.g. we may not be able to provide certain products or services to you. However, unless otherwise stated, not providing your Personal Data will not result in legal consequence for you.

Do not provide information about others unless you are authorized to do so and have obtained consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information, that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

TYPES OF INFORMATION COLLECTED: The types of information collected regarding you and your interactions with Us may include, but is not limited to: 

Personal Information:

• Your name,
• Email address
• Phone number
• Residency address
• Date and place of birth
• Gender
• Age
• Passport number
• Driver’s license or other ID or other photograph
• Information that may constitute biometric data, such as facial scans
• Credit score and history
• Criminal history
• Background

Technological Information

• IP address
• Device ID
• IP address
• Browser type
• Language
• Operating system
• Mobile device identifiers
• Geo-location data
• The state or country from which you accessed Our websites;
• The specific webpages visited;
• The date and the time of a visit;
• The websites you visited immediately before and after visiting Our websites;
• The number of links and specific links you click within Our websites;
• The functions you use on Our websites;
• Any reservations, updates, purchases, or other transactions through Our websites;
• The data you view or download from Our websites; and
• The number of times you view any particular advertisements

Rental Information

• Payment card information
• Video of you and interaction with Us
• Membership organization number
• Frequent flyer number
• Loyalty program
• Organizational affiliations
• Employee ID number
• Employer name and contact information
• booking location
• Rental or purchase location
• Return location
  Geographical areas visited Preferences and usage information
• Charges incurred
• Purchase prices and details
• Itinerary information
• Data related to claims

PURPOSES FOR PROCESSING

OPERATIONS AND SERVICES: We, both directly and through our service providers, business partners, discount sponsors, licensees, and booking channel providers, may use your information to provide you with the services or products you request from Us.

We may use your information to communicate with you regarding any reservation you initiate or rental transaction; your membership/status in one of Our membership programs; or changes to the terms or features of any of Our membership programs to which you belong.

We therefore process your Personal Data for these purposes to the extent necessary to perform our contract with you or to take steps at your request prior to entering into a contract with you.

For United States Residents, so that We may communicate with you, you give Us your consent to call you on or send text messages to your mobile telephone/device. You also consent to Our use of auto-dialers and pre-recorded messages in connection with any such telephone call or text message, including calls or texts to mobile telephone numbers. We will not charge you for such calls or texts.

Cali2way may take action on the basis of your driving behavior and driving behavior data (including, but not limited to geolocation, speed, mileage, braking, and damage data) derived from in-vehicle telematics and other devices or gauges or on the basis of other criteria relevant to your rental and usage of Our vehicles. Actions may include suspension or termination of your ability to continue to rent vehicles from Cali2way or its affiliates. Cali2way may also provide or sell this information to third parties.

OUR MARKETING: We, both directly and through Our service providers, business partners, discount sponsors, licensees, advertisers, and booking channel providers, 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.

Where We have obtained your consent to send these marketing communications to you, We therefore process your Personal Data for these purposes 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) without your consent. Where permitted by applicable law We may also process your Personal Data 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 below under “Contact Us” as well as the unsubscribe link in each e-mail message. You can also request at any time that We do not to use your Personal Data covered by this Privacy Policy to provide you with special offers and promotions by contacting Us at the details below under “Contact Us”. 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 opt-out process may take some time to complete, consistent with applicable law. 

SECURITY

• 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.
• 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 your credit card number or 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.

DATA RETENTION & INTEGRITY

• We retain personal data about Our customers for as long as necessary for the purposes for which it was collected, or unless otherwise allowed by law. Information is stored and accessed in various locations, and cloud services and storage may be utilized. Servers which store information are primarily located in the United States 

INDIVIDAL RIGHTS – ACCESS, CORRECTION, SALE PROHIBITION & PORTABILITY

We may retain your Personal Data as is necessary to fulfill the purposes for which the Personal Data was collected. We may also retain this Personal Data as required by law or contract, in order to fulfill Our legal obligations and protect Our legal rights. However, once the purpose for the collection is no longer valid, and there is no legal reason for Us to retain your Personal Data, you have the Right to be Forgotten and may request Us to delete your Personal Data. You may make this request by contacting Us via the mechanism provided below in the “Contact Us” section of this Policy. If We are unable to delete your Personal Data due to one of the reasons described in this Policy, We will provide you with the reason We are unable to fulfill your request.
To access, review, or update your Personal Data covered by this Privacy Policy, please contact Us at the details set out in the “Contact Us” section 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. If you are a member of one of Our membership or rewards programs, you may update your member profile by logging into your applicable member profile.