This Privacy Statement sets out the details about the personal data relating to you that we collect through the website, how this data is processed and to whom it may be disclosed. This statement also explains your rights under applicable data protection legislation, including the General Data Protection Regulation (GDPR), regarding the processing of your data.
Etrawler Unlimited Company, operating under the By City Car Rental brand, with tax identification number 4693898K and registered in Cartrawler, Classon House, Dundrum Business Park, Dundrum, Dublin 14, Ireland, is the operator of the Platform and, consequently, is responsible for the treatment of personal data described in this Data Protection Statement. References to "us", "our" and "our" in this statement are references to the marks (as the case may be).
We offer our customers car rental and other land transport services, such as buses, trains and transfer taxis (“Transport”), as well as additional travel-related services and products. From the moment your personal data is transferred to the transport provider, the latter becomes a separate data controller.
You can contact us using the details at the end of this statement or, if you have any questions regarding the processing of your personal data, you can contact our Data Protection Officer at the email address: dpo@cartrawler.com.
In order to process your Transport reservation or your reservation for any additional services, we will ask you for certain information, such as your name, address, e-mail address, payment information and reservation details. We also collect certain information from the device you use to access our Platform, such as your IP address, the browser you use and the type of device you use. In addition to the information we collect, we sometimes receive information collected on our behalf by third parties, for example, when you see an Azores Autos ad on a third party website.
Most of the personal data we collect about you is information provided by you. This may include the following:
• Transport Fare: if you request a Transport fare, we will collect your name, e-mail address, IP address and fare reference. If you contact us by phone, we will also collect your phone number and a recording of your call with us.
• E-mails and Abandon Calls: if you initiate a reservation but do not complete it, we will collect limited details, such as your name, e-mail address and telephone number (depending on your method of communication with us).
• Reservation Details: when making a reservation with us, we will ask you for information necessary to process the reservation or a refund. Such information will include your name, address, e-mail address, telephone number and payment details.
• Questions and Complaints: If you contact our Customer Support team with a question or complaint, we will record the details of the question or complaint and how it was handled in our systems. We may also request additional details about the question or complaint from the relevant provider of the Transport service or other service, which will also be recorded in our systems.
• Insurance Policy: if you carry out an insurance policy with one of our insurance partners, we will collect your name, address, email address, telephone number, booking reference, IP address and payment details to facilitate the purchase of your insurance policy.
• Other additional products and services: if you book or purchase any other additional services, such as parking, we will ask you for information necessary to process your order. Such information will include your name, address, e-mail address, booking reference phone number, IP address and payment details.
• Taxi Booking Details on Request
• If you register with our on-demand taxi application, we will collect your name, email address, customer ID (if relevant) and the corresponding password and payment details.
• When using our on-demand taxi application, we will collect your name, email address and payment details. We will also collect your location data when using our application and during your trip.
• Location data: if you are using our services on a mobile device and have enabled location services, we will collect your location to help you find Transport services or other local services. We also use your IP address to determine which country you are in when making a reservation.
• Loyalty Program data: if you join our Loyalty Program (for example, the My Account program), we will store the details of your name, email address, phone number, date of birth, username and password and your booking reference history.
• Marketing by E-mail / Telephone: when we collect your e-mail address and / or your telephone number, we will keep your preferences regarding the reception of marketing about our products and services and those of third parties.
• Surveys: If you participate in a survey, we will save your survey responses with your name and email address.
When you use our Platform, we use various technologies to automatically collect details about the device you are using and how you are interacting with the Platform. This information includes:
• Device Details: We automatically collect details about the device you are using, including the IP address, the device ID, the browser you are using and the operating system used by the device.
• How You Interact With Our Platform: we keep details about how you use our Platform. For example, the date and time you accessed it, the pages you visit, how long you stay on the pages, where you clicked on a page and details about any system failures or errors you may have encountered.
• How You Accessed the Platform: whenever possible, we record how you accessed our Platform (for example, if you accessed it from a search engine or by clicking on one of our ads).
Although we mainly collect information directly provided by you, there are circumstances in which we collect information from third party sources. These circumstances include:
• Third parties: we operate a program under which third parties advertise our Platform. If you click on one of these ads, you will be redirected to our Platform through a technology that allows us to know from which third company you were redirected. Next, we check if you made a reservation and if you do, we assign that reservation to the third party in question for the purpose of paying them a commission. However, we do not provide any personal customer information to the third party.
• Service Provider: if there are problems with your Transport service provider or other services, the provider should contact us with information about the problem.
• Ads: when we work with third parties to display ads, we may use technologies such as cookies or pixel tags to record details of your interaction with those ads. This data is sometimes sent to us through cookies and pixel tags set by these third parties. The data is sent anonymously.
• Other individuals: in cases where you provide us with personal data on behalf of another person, you confirm that you have the respective consent for that purpose and that you will provide a copy of this Privacy Statement.
The main reason why we use your personal data is to process your reservations for Transport services or additional services and to resolve any problems or questions that may arise regarding those reservations. We also use your personal data for a few other reasons, such as adjusting our ads and marketing emails to ensure they are relevant to you, as well as controlling your use of our Platform to help us improve and tailor our presentation.
Below, you can read more details about our data processing and the legal basis that justifies this treatment:
• Transport Rate: we process your personal data to provide you with your Transport rate. The processing of this data is carried out on the legal basis that is necessary to process your order before the potential signing of a Transport contract.
• E-mails and Abandon Calls: we proceed with the processing of personal data to contact the customer and understand if he encountered problems when trying to make a reservation. We do this based on our legitimate interest in ensuring the quality of customer support and that there are no problems with our Platform.
• Call Recordings: calls may be recorded for training and quality control purposes based on our legitimate interest.
• Reservations: we use your personal data to process reservations made with us and with Transport providers and to allow you to manage your reservations on the Platform. When we process personal data for this purpose, we do so with the legal basis that is necessary for the signature or the execution of a contract for the supply of our Transport reservation service.
• Insurance Policy / Other Product or Additional Service: if you subscribe to an insurance policy with one of our insurance partners associated with your Transport reservation or book another additional service, we process your data to facilitate the reservation of that service. When we process personal data for this purpose, we do so with the legal basis that is necessary for signing or executing a contract with you in order to provide this service.
• Questions and Complaints: When you send us a question or complaint about a Transport reservation or other additional service, we will process your personal data so that we can answer your question or resolve your complaint. When we process personal data in the context of a question or complaint, we will do so based on our legitimate interest in resolving the customer's questions and complaints. If you voluntarily provide us with data relating to your health, we will process that personal data on the basis of your explicit consent to use it to resolve your question or complaint.
• Application for Booking Taxis on Request: we process your data to facilitate your login and use of the Application for Taxis on Request. This treatment has the legal basis of signing or executing a contract.
• Loyalty program: when there is a loyalty program, we use your personal data to manage the loyalty program, add / deduct loyalty points and notify the customer about loyalty rewards. We treat these data with the legal basis that is necessary for the performance of our contract with you.
• Email and Telephone Marketing: when we collect your email address and / or telephone number when providing you with a service, depending on the marketing preferences you define, we may send you marketing about products and services that we believe that may interest you. We send this marketing content based on our legitimate interest or, on occasion, consent.
• Provide and Improve our Services: when we collect data regarding your use of our Platform and our services, such as the details of your device and the way you interact with our Platform and our services, we use this data to provide the our services and personalize your experience. We also use the data to test new features that we are considering to implement, to analyze how our Platform is used and to evaluate and improve our services. Whenever possible, we use this data anonymously. All of this treatment of your personal data is based on our legitimate interest in the operation, improvement and protection of our services.
• Statistics / Reports: we use data on reservations to create internal reports on how our business is operating. We also use this data for other purposes of business statistics and to try to predict future trends that may affect the business. This treatment is carried out collectively, so that it is not identified in the reports or statistics made.
• Advertising: we want to ensure that when you see an ad from Holiday Autos, Argus Car Hire, Dégrifauto, Cabforce or another brand, it will be relevant to you and your interests, whether it appears on a Platform operated by us, in our marketing emails or on a third party website. We may also use the same information to show you ads for carefully selected third-party products and services. When you use our Platform, we use the surveys you make to adjust our ads according to your interests. For example, if you have been looking for car rental options in Berlin, we may use this information to show you car rental ads in Berlin on our Platform and on third party websites that may be of interest to you. We may also use data about your past transactions on our Platform to adjust our ads. We process your personal data for this purpose based on our legitimate interest in ensuring that our advertisements or third party advertisements are efficient.
• Surveys: if you agree to participate in a survey, the processing of your data will be done based on our legitimate interest.
• Fraud Detection and Prevention: we may use your personal data in order to prevent and detect fraud based on our legitimate interest.
You are not required to provide us with any personal data. However, if you want to make a Transport reservation or enjoy an additional service, you must provide us with the necessary information in our reservation system. If you do not provide the necessary information, we will not be able to process your reservation. Likewise, you may be asked to provide certain information if you contact the customer support team with a question or complaint. We will inform you when such information is needed.
In order to process your reservation we will need to send your details to the relevant Transport provider. If you contact us with a question or complaint regarding a reservation, we may also share details of the question or complaint with the Transport provider, so that we can resolve it.
If you purchase another service, we may need to share your personal data with third party service providers so that they can provide you with that service. If you make a claim under an insurance policy, we may have to share your personal data with the insurer or other person responsible for the claims.
As part of our advertising programs, we may share your personal data with third parties, who will combine it with data they have about you to adjust the ads displayed on third party sites (which may be our ads or ads that we provide on behalf of the 3rd). When shared, this data is protected by encryption or other security measures.
We also use some service providers to help us provide our services, some of which will have access to your data (for example: we use several software service providers that store our data as part of their services). When we involve third parties in the processing of your data, we make sure that they respect your privacy rights and that they treat the data in accordance with data protection legislation. More details follow:
• Hosting providers: we use several cloud and colocation service providers to help us host and manage our data.
• Payment Processors: we use third-party payment processors to help us receive payments on our Platform.
• Technology Providers: includes service providers that help us protect our network, systems and emails.
• Customer Service Providers: We use third party service providers to provide customer support outside of working hours.
• Auditors: we have an internal and external audit function provided by third parties. Auditors help us to ensure that we are in compliance with our legal obligations, including those regarding our processing of personal data. In certain circumstances, this may mean that they may have access to our personal data processing systems or that they may need to check how we have processed certain personal data.
• Fraud databases: we can use external fraud detection and prevention databases that are available in the sector, as well as publicly available information, in order to prevent and detect possible criminal or fraudulent activities.
• Police authorities: we may share your data with police authorities so that they can investigate, detect or prevent possible criminal or fraudulent activities based on compliance with legal obligations.
In certain circumstances, we will transfer your personal data outside the European Union, to a country not recognized by the European Commission as providing a level of protection of personal data equivalent to that provided by the European Union. The most common situations are those in which we transfer personal data to a Transport provider so that they can process your reservation. We may also transfer your personal data outside the European Union due to the operation of our business, as in the case of using a service provider based in another jurisdiction. If we transfer your personal data outside the European Union, we will make sure that appropriate measures are taken to protect your personal data and to comply with our obligations under applicable data protection legislation. This may include signing standard contracts approved by the European Commission with the entity to whom we transfer personal data or ensuring that the company to whom we transfer personal data has agreed to comply with an approved transfer mechanism, within the scope of the Protection Shield EU-US Privacy Policy.
If you would like to obtain more details about the steps we have taken regarding the transfer of your personal data or copies of the agreements we have created regarding transfers, please contact us using the contact information at the bottom of this statement.
We retain your personal data in accordance with our record retention policy. The record retention policy operates based on the principle that we keep personal data no longer than the period of time necessary for the purpose for which we collect it and in accordance with any requirements imposed by law. This means that the retention period for your personal data will vary depending on the type of personal data. For example:
• Transaction data: we will retain the details of your reservations and your interaction with us regarding those reservations for the time necessary to facilitate your reservation and resolve any problems that may occur. When your marketing preferences allow us to send you marketing messages, such data will be retained according to the details below.
• Loyalty program data: we retain data relating to loyalty programs for as long as necessary to facilitate the management of our loyalty program.
• Email Marketing: we will keep a copy of the personal data necessary to send you marketing messages for as long as necessary to facilitate your marketing preferences. As part of this, we will also retain certain information regarding your transactions so that we can personalize our marketing messages.
• Management of legal claims: when we establish the period of time during which we keep personal data, we check whether that data may be necessary to defend legal claims. If this data is necessary, we may retain it until the statute of limitations ends with respect to the type of claim that can be made (which can range from 2 to 12 years).
This Platform uses cookies. Cookies are small, simple text files that are sent from a website and stored on your computer, tablet or mobile phone when you access that website. Information related to your access to a website is stored in these cookies. To find out more about the cookies we use, access our cookie policy.
In circumstances where we process your personal data based on your consent, you are entitled to withdraw that consent at any time. You can withdraw your consent by contacting us using the contact information at the bottom of this statement. If your consent relates to receiving email marketing, you can use the link to unsubscribe from the email. Please note that if you withdraw your consent, we will no longer be able to provide you with the service in question.
You have the following rights, in certain circumstances, with respect to your personal data:
• Right to access data: you have the right to request a copy of the personal data we hold about you, in addition to other information about our treatment of your personal data.
• Right to rectification: you have the right to ask for any incorrect data about yourself to be corrected or, if we have incomplete information, you can ask for the respective update to be complete.
• Right to erasure: you have the right to ask us to delete the personal data we hold about you. This is sometimes referred to as the right to be forgotten.
• Right to restrict treatment or object to treatment: you have the right to ask us to stop processing your personal data for specific purposes or to object to our processing of your personal data for specific purposes.
• Right to data portability: you have the right to ask us to provide you or a third party with a copy of your personal data in a structured format and readable by common programs.
To exercise any of the rights mentioned above, contact us using the contact information at the bottom of this statement.
We constantly review our privacy statement and will inform you of any updates made to this website.
If you have questions or complaints regarding our handling of your data, you can contact us through the following contact forms:
By mail: Data Protection Officer, ETrawler Unlimited Company, Classon House, Dundrum Business Park, Dundrum, Dublin 14, Ireland
By email: dpo@cartrawler.com
You also have the right to submit a complaint to the Irish Data Protection Commission if you are not satisfied with the handling of your personal data by Holiday Autos, Argus Car Hire, Dégrifauto or Cabforce. Details on how to submit a complaint can be found at (https://www.dataprotection.ie/docs/Contact-us/11.htm) or you can call the Data Protection Commission at 353 (0 ) 761 104 800.