The present document being the Privacy Statement sets out details of the personal data relating to you that may be collected in assistance of the Luckycar.com website and any mobile sites and applications relating to Luckycar, how such data will be processed and to whom it may be disclosed. This notice also explains your rights under applicable data protection law, including the EU General Data Protection Regulation (“GDPR”), in relation to our processing of your data.
Luckycar and related applications are being operated by a Positive Technologies company, whose registered office is Andorra, Canillo, El Tarter, Sola del Tarter, Trineu 1-4-B. ETrawler ("ETrawler") is a company whose registered office is at Classon House, Dundrum Business Park, Dundrum, Dublin 14, Ireland, is the operator of the booking engine, or the Platform, and therefore the controller of the personal data which is described in this data protection notice.
We introduce you to ETrawler for the purposes of rendering the vehicle rental and ancillary travel related products and services (“Services”). You can contact ETrawler directly using the below mentioned link, or if you have any queries in relation to the processing of your personal data you can also contact us by emailing firstname.lastname@example.org. In most of the below described cases our company does not control your personal data since we do not operate the booking engine, or the Platform, and therefore we do not get your personal data in this connection, but ETrawler does. The Privacy Statement of ETrawler you may find at https://www.cartrawler.com/ct/privacy-policy/. Data that is being processed
In order to process your booking of any above mentioned services you will be asked for certain information, such as your name, address, email address, payment information and booking details. This information will be needed by ETrawler in order to arrange rendering you the Services. Also certain information will be collected from the device you use to access our website, such as your IP address, what browser you use and what type of device you are using. In addition to the information that may be collected in assistance of our website, we sometimes receive information that is collected on our behalf or on behalf of ETrawler by third parties, such as when you see a Luckycar advert displayed on a third party site.
Most of the personal data that is being collected about you will be information that you have given yourself. This may include the following:
- Abandonment E-mails and Phone Calls – If you commence but do not complete a booking, limited details such as your name, e-mail address and phone number (depending on yourchosen method of communication) still will be collected.
- Booking Details - When you make a booking you will be asked for information that is needed in order to process the booking. This will include your name, address, email address, phone number and your payment details.
- Queries and Complaints - If you contact the customer service team with a query or a complaint, the details of the query or complaint and how it is dealt with will be recorded. Further details about the query or complaint may be requested from the relevant transportation or other service provider, which may be also recorded.
- Insurance Policy – If you take out an insurance policy with one of ETrawler's insurance partners, your name, address, e-mail address, phone number, booking reference, IP address and payment details will be collected to facilitate the purchase of your insurance policy.
- Other ancillary products and services – If you book or purchase any other ancillary service, you will be asked for information that is needed in order to process your request. This will include your name, address, e-mail address, phone number, booking reference, IP address and payment details.
- Location Data - If you are using the booking services on a mobile device and you have enabled location services, your location will be recorded to help you find local transportation or other services. Your IP address will be used to determine what country you are in when you make a booking.
- Loyalty Programme Data - If you join the loyalty programme, the details of your name, e-mail address, phone number, date of birth, username and password and your historic booking references will be stored.
- Email Marketing - When your email address will be collected your preferences will be stored regarding receipt of marketing emails in relation to our products and services and those of third parties.
- Surveys - If you participate in a survey, your responses to the survey along with your name and e-mail address will be recorded.
Personal information that is being collected automatically:
When you use our website services and the booking engine available there, various technologies are being used to automatically capture details about the device you are using and how you interact with the booking engine. This information includes:
- Device Details – the details about the device you are using, including its IP address, its device ID, the browser you are using, and the operating system that the device uses are being automatically collected.
- How You Interact with the website and the booking engine – the details about how you use these, e.g. the date and time that you visit, what pages you visit, how long you stay on the pages, where you have clicked on a page, and details of any crashes or system bugs you may have encountered will be automatically collected.
- How You Reached the website and the booking engine - Where possible, it is recorded how you arrived on our website and accessed the booking engine (e.g. whether you arrived from a search engine, or by clicking on one of our adverts).
Sources of Personal Data
Although mainly the information is being collected directly from you, there are circumstances where it is collected from third party sources. These circumstances include:
- Third Parties – For the purposes of advertising a programme is being used under which third parties advertise our website on our behalf. If you click on one of those advertisements you are directed to ETrawler’s Platform using a technology that allows them to understand which third party referred you. Then the track is being done if you make a booking, and if you do that booking is being attributed to the relevant third party for the purposes of paying them a commission. However, the third party doesn’t get any personal information in relation to you.
- Service Provider - If there are any issues with a service provider, the service provider may contact us or ETrawler with information about the issue.
- Advertisements - When the cooperation with third parties is being made in order to display advertisements the technologies like cookies or pixel tags may be used to record details of your interaction with those advertisements. This data is sometimes collected through cookies and pixel tags that are set on our behalf by those third parties. If data is so collected it will be done on an anonymised basis.
Purposes of Processing and Legal Basis
The main reason of your personal data usage is to process your bookings for car rental and ancillary Services and to deal with any queries or issues that may arise in relation to those bookings. Your personal data may be also used for certain other reasons, such as tailoring the adverts and marketing emails to ensure that they are relevant to you and monitoring your use of the Platform to help to make improvements and tailor the display.
The following are further details of the processing and the legal basis which justifies this processing:
- Abandonment E-mails and Phone Calls – Your personal data may be processed in order to contact you and clarify whether you encountered any issues when seeking to make a booking. This is done on the basis of the legitimate interest in ensuring quality customer service and that there are no issues with the Platform.
- Bookings - Your personal data will be used in order to process bookings with the service providers, and to let you manage your bookings through the Platform. Where your personal data will be processed for this purpose ETrawler will do so either on the basis that it is necessary for the performance of a contract or on the basis of their legitimate interests in providing the booking service.
- Insurance Policy / Other Ancillary Product or Service – If you take out an insurance policy with one of ETrawler’s insurance partners in connection with your reservation or book another ancillary service, your data will be processed in order to facilitate the booking of that Service. Where your personal data is processed for this purpose ETrawler or it’s service provider will do so either on the basis that it is necessary for the performance of a contract with you, or on the basis of the legitimate interests in providing you with that Service.
- Queries and Complaints - When you send a query, or have a complaint, about a booking or about any other ancillary Service, your personal data will be processed in order to answer your query or in order to resolve your complaint. Where your personal data is processed in the context of a query or complaint we or Etrawler will do so on the basis of our legitimate interest in resolving customer queries and complaints. If you volunteer data in relation to your health, that personal data will be processed on the basis that you explicitly consent using it in order to resolve your query or complaint.
- Loyalty Programme – Where a loyalty programme exists, your personal data is used in order to administer the loyalty programme, to add/deduct loyalty points and to notify you of loyalty rewards. This data is processed on the basis that it is necessary for the performance of the contract with you.
- Email Marketing - Where your email address is collected in the context of providing you with a service, then depending on the marketing preferences you have expressed, you may be sent emails about products and services that may be of interest to you. These marketing e-mails are being sent on the basis of the legitimate interests in marketing our products and services.
- Providing and Improving the Services - Where your data is collected in relation to your use of the Platform and Services, such as your device details and how you interact with the Platform and Services, this data is used in order to deliver the Services and personalise your experience. This data is also used to test new features that are being about to be introduced, to analyse how the Platform is used, and to evaluate and improve the Services. Where possible this data is used on an anonymous basis. All of this processing of your personal data is on the basis of the legitimate interests in operating, improving and securing the Services.
- Analysis/Reporting - Your data is being used in relation to bookings in order to create internal reports regarding how the booking business is operating. This data is also used for other commercial analysis purposes, and to try to predict future trends that may affect the business. This processing is undertaken on an aggregated basis, so you are not identifiable from the reports or analysis that is produced.
- Advertising – In order to ensure that when you see a Luckycar advert it will be relevant to you and your interests, whether the advert appears on a Platform, in our marketing emails or on a third-party site. This information may also be used to show you adverts for carefully selected third-party products and services. When you are using the Platform the searches you have made are being used in order to tailor the adverts to your interests.
- Surveys - If you agree to participate in a survey, your data is being processed on the basis of your consent.
Personal Data that is Required
You are not obliged to provide any of your personal data. However, if you want to make a booking, or avail of an ancillary service, you will need to provide the information that is requested by the booking engine. If you don't provide this information, your booking won’t be able to be processed. Similarly, you may be required to provide certain information if you contact the customer services team with a query or complaint. You will be informed where such information is required.
Recipients of Data
In order to process your booking your details are to be sent to the relevant Service provider. If you contact us with a query or complaint in relation to a booking we may also share details of the query or complaint with the Service provider so that we can resolve it.
If you purchase another service your personal data may be shared with the third-party service provider so that they can provide you with that service. If you make a claim under an insurance policy your personal data may be shared with the underwriter or other appointed claims handler.
As part of the online advertising programmes your personal data may be shared with third parties, who will combine it with data that they hold about you in order to tailor adverts that appear on third-party websites (which may be our own adverts, or adverts we serve on behalf of third parties). Where this data is shared it is protected using encryption or other security measures.
A number of service providers is used to assist in providing the Services, some of whom will have access to your data (e.g. various software service providers who host the data as part of their services). Where a third party is engaged to process your data certain procedures apply in order to make sure that they respect your privacy rights and that they process data in accordance with data protection law. Further details are as follows:
- Hosting Providers - various cloud service and co-location providers are being used to help to host and manage the data.
- Payment Processors - third-party payment processors are being used by ETrawler in order to assist with taking payments on the Platform.
- Technology Providers - This includes service providers who provide services such as helping to secure the network, systems and emails.
- Customer Service Providers –a third party service provider is being used to provide customer service outside working hours.
- Auditors - ETrawler has an internal and external audit function that is provided by third parties. The auditors help them to ensure that they are complying with the legal obligations, including in relation to their processing of personal data.
There are certain circumstances where your personal data will be transferred outside of the European Union to a country which is not recognised by the European Commission as providing an equivalent level of protection for personal data as is provided for in the European Union. The most common of these is where your personal data is transferred to a Service provider so that they can fulfil your booking. Your personal data may also be transferred outside of the European Union in connection with the operation of the business, such as when a service provider is used that is based in another jurisdiction. If your personal data is transferred outside of the European Union, it will be ensured that appropriate measures are in place to protect your personal data and to comply with the obligations under applicable data protection law. This may include entering into contracts in the form approved by the European Commission with the entity to whom your personal data has been transferred, or ensuring that the company to which your personal data has been transferred has agreed to abide by an approved transfer mechanism, such as the EU-US Privacy Shield framework.
Your personal data is retained in accordance with the record retention policy. The record retention policy operates on the principle that your personal data is kept for no longer than is necessary for the purpose for which it is collected, and in accordance with any requirements that are imposed on us by law. This means that the retention period for your personal data will vary depending on the type of personal data.
The Platform or the website may contain links to other websites or you may have arrived here via a link from another website. This Privacy Statement only applies to the Platform and the services introduced by Luckycar in connection with the Platform. When you link to other websites you should read their own privacy statements.
Important Information about Consent: In circumstances where your personal data is processed on the basis of your consent, you are free to withdraw that consent at any time. You can withdraw your consent by contacting us using the contact details at the bottom of this statement. If your consent relates to receiving email marketing you can use the unsubscribe link in the email. Please note that if you withdraw your consent we may not be able to continue to provide the related service to you.
You have the following rights, in certain circumstances, in relation to your personal data:
- Right to access the data - You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
- Right to rectification - You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information such that it is complete.
- Right to erasure - You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
- Right to restriction of processing or to object to processing - You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
- Right to data portability - You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.
In order to exercise any of the rights set out above, please contact us at using the contact details at the bottom of this statement.
Changes to the Privacy Statement
We keep our privacy statement under regular review and we will place any updates on this web page.
Questions and Complaints
If you have any queries or complaints in connection with our processing of your personal data, you can get in touch with us using the following contact details:
WHAT ARE COOKIES?
To book a car on our website, you need to have cookies enabled – see the section on Managing cookies. If you do not wish to enable cookies you will still be able to browse the site and use it for research purposes. Most web browsers have cookies enabled, but check Managing Cookies for help to turn them on should you need to.
Please be aware that cookies cannot harm your computer. We do not store personally identifiable information such as credit card details in cookies we create, but we do use encrypted information gathered from them to help improve the user’s experience of the site. For example, they help us to identify and resolve errors.
We’re providing you with this information as part of our initiative to comply with recent legislation and to ensure that we’re honest and clear about your privacy when using our website.
OUR COOKIES POLICY
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
Here’s a list of the main cookies that we use, and what we use them for. You’ll find information about third party cookies on the next tab.
Except for essential cookies, all cookies will expire after 30 days.
THIRD PARTY COOKIES
When you visit Luckycar you may notice some cookies that are not related to Luckycar. When you visit a page that contains embedded content, for example from YouTube, you may be sent cookies from these websites. We don't control the setting of these cookies, so we suggest you check the third-party websites for more information about their cookies and how to manage them.
Some of the third party cookies we use are “analytical” cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Third party cookies in relation targeted advertising are also set when you visit our website. Please see Banner Advertising tab for further details
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
If you have not enabled cookies on your browser it will mean that the shopping experience on your browser will be limited to browsing and researching, you will not be able to purchase goods.
To enable cookies
If you're unsure about the type and version of web browser you use to access the Internet:
For PCs: click on 'Help' at the top of your browser window and select the 'About' option
For Macs: with the browser window open, click on the Apple menu and select the 'About' option
How to check cookies are enabled for PCs
- Google Chrome
Click on 'Tools' at the top of your browser window and then click Options
Click the 'Under the Hood' tab, locate the 'Privacy' section, and click the 'Content settings' button
Now select 'Allow local data to be set'
- Microsoft Internet Explorer 6.0, 7.0, 8.0
Click on 'Tools' at the top of your browser window and click 'Internet options' , then click on the 'Privacy' tab
Ensure that your Privacy level is set to Medium or below, which will enable cookies in your browser
Settings above Medium will disable cookies
- Mozilla Firefox
Click on 'Tools' at the top of your browser window and select Options
Then click the Privacy icon
Click on Cookies, then select 'allow sites to set cookies'
Click on the Cog icon at the top of your browser window and select the 'Preferences' option
Click on 'Security', check the option that says 'Block third-party and advertising cookies'
Click on 'Menu' at the top of your browser window and select 'Settings'
Then select 'Preferences', select the 'Advanced' tab
Then select 'Accept cookies' option
- Safari on OSX
Click on 'Safari' at the top of your browser window and select the 'Preferences' option
Click on 'Security' then 'Accept cookies'
Select the 'Only from site you navigate to'
- All other browsers
Please check your documentation or your online help files.
Further information about cookies
If you'd like to learn more about cookies in general and how to manage them, visit www.aboutcookies.org (opens in a new window - please note that we can't be responsible for the content of external websites).
BANNER ADVERTISING ON OTHER WEBSITES
The purpose of this type of advertising is to provide you with a range of products based on what you’re viewing on our website, which are presented to you when you visit other selected websites. The adverts may highlight offers deemed relevant to your browsing history. The technology behind some of these adverts is based on cookies.
Please be assured that the data contained in the cookies used in these adverts is completely anonymous and does not contain any of your personal details.