Avis Budget Group Corporate Privacy Notice
Effective Date: January 1, 2020
Last updated: January 1, 2020
Welcome to the Privacy Notice of Avis Budget Group, Inc. (“ABG,” “we,” “us,” or “our”). This Privacy Notice covers the personal information we collect, use and disclose through your use of our website: www.avisbudgetgroup.com and http://ir.avisbudgetgroup.com/ (the “Website”).
Please click on the following sections to learn more about our Privacy Notice. You can tell when this Privacy Notice was last updated by looking at the link and at the date at the top of the Privacy Notice. If we make changes to this Privacy Notice, we will post the changes here. If we make a change that significantly affects your rights, we will notify you by way of a prominent posting on our Website, prior to the change becoming effective. If you have an account with us, we may also notify you about material changes to this Privacy Notice by e-mail (sent to the e-mail address provided in your account) or as otherwise required or permitted by law. Any changes to this Privacy Notice will become effective upon posting of the revised Privacy Notice. Use of our Website following the posting of a new Privacy Notice constitutes your acceptance of the revised Privacy Notice then in effect. As such, we encourage you to review this site from time to time for the latest information on our privacy practices.
Region-Specific Disclosures
California Residents: If you reside in the State of California in the United States, please see additional California-specific privacy disclosures that address the collection, use, disclosure and other processing of personal information that supplement this Privacy Notice and may fall outside its scope.
European Union Residents: If you reside in the European Union, please see additional EU-specific privacy disclosures that address the collection, use, disclosure and other processing of personal information that supplement this Privacy Notice and may fall outside its scope.
BY USING OUR WEBSITE YOU UNDERSTAND AND ACKNOWLEDGE THAT WE WILL COLLECT AND USE YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE. If you have questions, comments, or suggestions, you can always contact us using any of the ways described in the Contact Us section.
1. WHO WE ARE
As used in this Privacy Notice, “ABG,” “we,” “us,” or “our” refers to the Avis Budget Group, Inc.
2. THE TYPES OF INFORMATION WE COLLECT, AND HOW WE COLLECT THEM
We collect information from you in accordance with this Privacy Notice any time you contact us, interact with us, or use our Website. If you do not provide the information we request, we may not be able to provide features of our Website to you.
Personal Information
- Some of the information we collect can personally identify you, including, for example, your name, email, contact information, and information related to your use of the Website.
- We may record or monitor any call you make to us for quality control, to enforce our rights, or for training or similar purposes.
- When you visit or use our Website or interact with us using e-mail, texts or other forms of electronic communication, we may we use cookies, pixel tags, beacons, scripts and similar technologies to automatically collect certain information, including, for example, your IP addresses, MAC addresses, device identifier, browser type, Internet service provider (“ISP”), location, how you interact with our Website, referral/exit sites, operating system, date/time stamp, and clickstream data.
- We treat any non-personal information that is linked to or combined with personal information as personal information.
Non-Personal Information
- We may also collect information that does not personally identify you.
- We may aggregate, anonymize, pseudonymize, or de-identify personal information to create non-personal information.
3. HOW INFORMATION IS USED
Personal Information
We use your personal information to:
- provide you with our Website;
- respond to your requests and communications;
- diagnose problems with our Website;
- improve our Website and communications with our customers and partners;
- respond to legally binding requests from law enforcement, regulatory authorities or other third parties;
- defend, protect or enforce our rights, property, or applicable terms of service;
- prevent fraud or the recurrence of fraud;
- assist in the event of an emergency; and
- comply with applicable law.
We use cookies, pixel tags, beacons, scripts and similar technologies to adjust and optimize our content, to provide you with useful functionalities, to help us make our Website more convenient and efficient, to help us analyze usage trends and patterns, and to tailor online advertisements by us and our partners to you. We may also use analytic software, such as Google Analytics and others, to help us to better understand how our Website functions on your device and for research and development. We may use third party platforms to help us promote interest-based advertisements to you, we may use web tracking tools as described above or a process called hashing, which involves converting the e-mail address, phone number or other contact information you have provided to us into a unique value that these platforms may compare to a unique value created on their platforms. You have options when it comes to cookies and other web tracking tools.
You can set your browser or device to refuse all cookies or to indicate when a cookie is being sent. However, some features or services may not function properly without cookies. Some browsers support a “Do Not Track” feature, which is intended to be a signal to Websites that you do not wish to be tracked across different Websites you visit. Our Website does not currently change the way they operate based upon detection of a Do Not Track or similar signal. As the internet and other e-commerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.
We may retain your information for as long as necessary for the processing purpose(s) for which the information was originally collected and any other legitimate business purpose, including, for legal, archival, accounting, and/or audit purposes.
Non-Personal Information
We may use non-personal information for any and all purposes, and we keep it for as long as we have a business need to do so.
4. HOW INFORMATION IS SHARED
Personal Information
The nature of our business and operations require us to share certain personal information. We may share your personal information with our third-party service providers and partners to help:
- us:
– with the uses described in the How Your Information Is Used section above;
– comply with your directions or any additional consent you have provided us; and - us and our business and promotional partners send you information about products and services you may like. You may revoke your consent to receive marketing and promotional e-mails from us and our business and promotional partners.
We may share Website usage information, including searches, transaction and profile information (but not your name) with our partners for the purpose of making the online advertisements on our Websites and other Websites that display our advertisements more relevant.
We may share your personal information with law enforcement and regulatory authorities or other third parties as required or permitted by law for the purpose of:
- responding to a subpoena, court order or other legal processes;
- defending, protecting or enforcing our rights;
- assisting in the event of an emergency; and
- complying with applicable law.
We may also share personal information with third parties in the event of a merger or acquisition, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. To the extent that local laws require it, we will provide you notice on our Websites or via e-mail of our intent to transfer personal information to a third party for this purpose.
Non-Personal Information
We share non-personal information with our third-party service providers and partners as reasonably necessary to meet our business needs.
5. YOUR CHOICES
Email marketing
If you would like to opt-out of receiving marketing e-mails, click the “unsubscribe” at the bottom of an e-mail we sent you, or log into your account and update your profile, or contact a developer site customer service representative.
Access to your information
Where available under local applicable privacy law, you may have the right to request the personal information that we collect, use and disclose about you. You may also have the right to not receive discriminatory treatment for exercising your access right.
To submit a request or designate an authorized agent to make a request, please refer to the Contact Us form for more information.
Deleting your information
Where available under local applicable privacy law, you may have the right to request that we delete your personal information, subject to some exceptions. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your personal information, unless an exception applies. You may also have the right not to receive discriminatory treatment for exercising your deletion right.
To submit a request or designate an authorized agent to make a request, please refer to the Contact Us form for more information.
6. HOW YOUR INFORMATION IS PROTECTED
The security of your personal information is important to us. We take reasonable steps to make sure your information is protected from unauthorized use, access, disclosure, alteration, destruction or loss. Firewalls and encryption are used to protect your more sensitive personal information. You are responsible for keeping your account safe. Please be mindful that hackers and scammers may impersonate us or our Website. For more information about phishing, please visit https://www.consumer.ftc.gov/articles/0003-phishing. If you suspect an unauthorized use or security breach of your information, you must notify our customer service as soon as possible! We are not responsible or liable for any loss or damage if your account passcode is stolen or used inappropriately.
7. CHILDREN’S PRIVACY
Our Website is not for children under the age of 13. We do not knowingly collect personal information from children. If you think we have received personal information from children under the age of 13, please contact us immediately.
8. EUROPEAN RESIDENTS
This section only applies to you if you are a resident of a member state of the European Union or the European Economic Area,
If you have any questions or concerns regarding the use of your personal information, please contact us at DPO@abg.com.
8.1 Basis for Using Personal Information
According to applicable EU data protection law, there are a number of legal grounds that permit ABG to use your personal information for the purposes stated within this Privacy Notice. The legal grounds are:
- that you provided your consent to us using your personal information for that purpose (for example, where you have given us your consent to send you electronic marketing);
- that we need to use that personal information in order to fulfil out contract to provide products or services to you (for example, using your information to provide our API for your website);
- that the processing is necessary for the purposes of our legitimate interests, provided we have balanced these against your rights and interests; and
- where we need to comply with a legal obligations (for example, responding to government or law enforcement information requests).
Our legitimate interests for using your personal information are:
- to ensure effective administration and management of your relationship with us;
- to understand how our customers use our services;
- to carry out research and analysis on our services or products and how to improve our services and products;
- to understand how you use our Website and identify any issues in how the Website is used and how we can improve the usage experience;
- to tell you about the various products and services we can offer;
- to understand and respond to your feedback;
- to better tailor and personalize the promotions and benefits that we can offer;
- to prevent, detect, or investigate unauthorized use of our Website and systems and ensure we comply with law and our policies; and
- to manage any dispute and take legal or other professional advice.
8.2 Information Sharing
ABG may use and share your information and vehicle data to affiliated and non-affiliated organizations as follows:
Third party recipient
Purpose of disclosure
Legal Basis for Processing
IT service providers including IT platform providers and Website analytics service providers in order to in order to perform our contract with you and to understand how you use our services and to improve our business
• Support our IT systems and infrastructure;
• Provide maintenance services for our IT systems and infrastructure;
• Provision of data hosting and other data processing services;
• Provide analytics services relating to your use of our Website to identify any technical or user interface issues and/or improvements in connection with the Website
• Legitimate interests.
Government, regulatory and law enforcement agencies in order to meet our legal obligations
• As requested by these agencies if the disclosure is required or permitted by law;
• To take action regarding illegal activities or violations of terms of service;
• If we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; and
• As otherwise required or permitted by law.
• Legal requirement; or
• Legitimate interests.
8.3 International Transfers
The information we collect from you may be transferred to, and stored by, IT vendors who operate on our behalf. We also transfer information to a number of providers of business application – such as CRM and marketing applications – as well marketing service providers. These providers are primarily located in the United States.
The United States does not benefit from a decision issued by the EU Commission regarding protection afforded to personal information. Adequacy of data protection is instead ensured by standard data protection clauses we have in place with that third party. A copy may be requested via our Data Protection Officer at the address below.
Given the global nature of our business, we also transfer information within the group companies of Avis Budget Group, Inc as for certain activities the group uses shared IT functions. Transfers from within the European Union for these purposes are primarily made to the United States, although transfers may be made to other countries as well. The United States and many of the other countries located outside the European Union do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal information in that country. Adequacy of data protection is instead ensured by standard data protection clauses we have in place with the recipient. A copy may be requested via our Data Protection Officer at the address below.
8.4 Your Privacy Rights
You may have – in accordance with applicable EU data protection laws – the following rights when it comes to our handling of your personal information:
- Right of access – you may have the right to request a copy of the personal information we have about you and to request supporting information explaining how the personal information is used;
- Right of rectification – you may have the right to request that we rectify inaccurate personal information about you;
- Right of erasure – you may have the right to request that we erase personal information about you;
- Right to restrict processing – in some situations, you may have the right to request that we do not use the personal information you have provided (for example, if you believe it to be inaccurate);
- Right to data portability – you may have the right to receive your personal information in a structured, commonly used and machine-readable format and to transmit such information to another controller;
- Right to withdraw consent – where we process your personal information based on consent (including direct marketing consents), you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal we may continue to use your personal information as permitted or required by law;
- Right to object – where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
In addition, if specifically provided for under your local law, you will have a right to define post-mortem guidelines – meaning you may define guidelines regarding the storage, erasure and disclosure of your personal data after your death.
Please contact our Data Protection Officer at the address below if you would like to exercise any of these rights or in case you should have any concerns about how we process your personal information. You are also free to lodge complaint with the supervisory authority, should you feel that we process your personal information in a way that is against applicable EU data protection law.
8.5 Data Controller and Contact Details
You can also contact our Data Protection Officer in respect of any issues or questions you have regarding our processing of your personal information. They can be contacted at:
Email: dpo@abg.com
Postal Address: Data Privacy Officer, Avis Budget House, Park Road, Bracknell, Berkshire, RG12 2EW, United Kingdom
Telephone: +44 (0)1344 426644
9. THIRD PARTY COLLECTION
Our Website may include links to and from our affiliates and partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies different from ours and you should review their privacy policies to understand the privacy practices of their services.
Our Website is built using WordPress, and we encourage you to review the WordPress privacy policy so that you understand if/how they collect and/or use your information.
10. GEOGRAPHIC LOCATIONS
We generally store your personal information in the United States. As a part of our normal business operation, we may at times need to transfer some of your personal information outside of the United States. If we do so, we will take reasonable steps to ensure your information is treated and protected no less securely than it is in the United States. This Privacy Notice is intended to be governed by the laws of the State of New Jersey and meet the laws and requirements of the United States, which may not necessarily be consistent with the laws and regulations of the country where you live.
11. CONTACT US
If you have questions, comments, or suggestions, you can always contact us in the following ways. For your protection, we may need to verify your identity before assisting with your request, such as verifying that the information used to contact us matches the information that we have on file.
I want to…
How to reach us
Contact Avis Budget Group
Submit a form on our Contact Us page.
- Ask questions, give feedback, or make requests regarding ABG’s Privacy Notice and practices
- Notify ABG that we may have received personal information of a child under 13
E-mail: ABGprivacy@avisbudget.com
Mail: Avis Rent A Car System, LLC.
379 Interpace Parkway
Parsippany-Troy Hills
NJ 07054
Attn: Privacy Officer
Phone: 866-284-7669
Fax: 973-496-3444
Access, request deletion, update or correct some of my information
Email: ABGprivacy@avisbudget.com;
For California residents, fill out our form: California Resident Rights Request Form;
For EU residents, email: DPO@abg.com
Request to stop receiving marketing e-mails from ABG
(1) Click “unsubscribe” at the bottom of an e-mail we sent you; or
(2) Log into your account and update your profile; or
(3) Contact any customer service representative.
California Privacy Notice
Effective Date: January 1, 2020
Scope of Disclosures
This California Privacy Notice (the “CA Disclosures”) supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).
These CA Disclosures describe how we collect, use, disclose, and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 (CCPA). Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined the CCPA.
Personal Information Disclosures
For purposes of these CA Disclosures only, we use the term “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of these Disclosures, personal information does not include:
- Publicly available information from government records.
- Information maintained in a form that is not linked to a particular individual, such as de-identified, aggregated or anonymized information.
- Information excluded from the CCPA’s scope, such as:
– Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
– Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
- Information relating to our job applicants, employees, contractors and other personnel of ABG, which is not governed by these CA Disclosures.
Collection and Use of Personal Information
We collect various categories of personal information in connection with our Website. Please review The Types of Information We Collect, And How We Collect Them section of the Privacy Notice to learn more about the personal information we collect.
In the last 12 months, we have collected the following categories of personal information:
Category of Personal Information Collected
Categories of Sources
Identifiers, such as your name, alias, postal address, unique personal identifier, Internet Protocol address, email address, or other similar identifiers.
- Directly from you
- Third parties you direct to share information with us
California Customer Records (Cal. Civ. Code § 1798.80(e)), such as name, signature, address, telephone number, credit card or debit card information, or any other financial information. (Some personal information included in this category may overlap with other categories.)
- Directly from you
- Third parties you direct to share information with us
Internet/Network Information, such as information on a customer’s interaction with a website, application, or advertisement.
- Directly from you
- Third parties you direct to share information with us
Purposes for Collecting Personal Information
We collect, use, or disclose personal information about you for one or more of the following purposes:
- provide you with our Website;
- respond to your requests and communications;
- diagnose problems with our Website;
- improve our Website and communications with our customers and partners;
- respond to legally binding requests from law enforcement, regulatory authorities or other third parties;
- defend, protect or enforce our rights, property, or applicable terms of service;
- prevent fraud or the recurrence of fraud;
- assist in the event of an emergency; and
- comply with applicable law.
Disclosure of Personal Information
As described in our Privacy Notice, we share personal information with third parties for business purposes.
We disclose your personal information to the following categories of third parties:
- Our service providers: We engage a number of third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, marketing and advertising services, and other similar services, subject to contractual terms restricting the collection, use and disclosure of your personal information for any other commercial purpose.
- Third parties at your request. We share your personal information with third parties with your consent or at your direction, including where necessary to validate your eligibility for a discount as a member of a third-party partner.
- Businesses as needed to provide services. We may share personal information with third parties you engage with through or to provide our services, or as needed to fulfil your request or transaction.
- Our affiliate companies. We may share your personal information with other companies owned or controlled by ABG, and other companies owned by or under common ownership as ABG, which also includes our subsidiaries (i.e., any organization we own or control, such as Zipcar) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns;
- Security providers. We may share your personal information with third-party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule, regulation or the policies of ABG;
- Business partners. We may disclose personal information to third parties with whom we partner to provide co-branded services where such disclosure is necessary to fulfil your request or application;
- Ad networks and advertising partners. We work with third party Ad Networks and Advertising Partners to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use. These parties may collect information directly from your browser or device when you visit our services through cookies or other tracking technologies. This information is used to provide advertising-related services such as reporting, attribution, analytics and market research;
- Analytics providers. We work with third party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our services;
- Law enforcement and third parties pursuant to legal request. From time to time, we may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- Third parties in the context of a corporate transaction. We may disclose personal information as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of ABG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by ABG about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.
In the previous 12 months, we have disclosed all of the categories of personal information we collect, explained in the table above, to third parties for a business purpose. In the previous 12 months, we have not sold personal information.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources of the personal information;
- The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
- The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
- The business or commercial purposes for collecting or selling the personal information.
The Right to Request Deletion
You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising these rights.
However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.
“Shine the Light”
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).
How to Exercise Your California Consumer Rights
Please note, when you submit a request to us, that request will only be processed with respect to the ABG brand to which you have submitted such request.
To Exercise Your Right to Know or Right to Deletion
To exercise your Right to Know and/or your Right to Deletion, please submit a request by:
Filling out our form: California Resident Rights Request Form, or calling 866-284-7669.
We will need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity, if the rights of another individual might be violated or as otherwise permitted by law. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age. Please contact us at ABGprivacy@avisbudget.com to inform us if you, or your minor child, are under the age of 16.
California’s “Shine the Light” Law
At the time of this writing, we do not provide your personal information to third parties for their direct marketing purposes, as described in California’s “Shine the Light” law (Civil Code Section §1798.83).
Authorized Agent
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the “Last Updated” date at the beginning of these Disclosures. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Contact Us
If you have any questions or requests in connection with these Disclosures or other privacy-related matters, please address inquiries to us as described in the Contact Us section of the Privacy Notice.