Privacy Policy

When you inquire about, request, or use any vehicle rental service provided by Europcar Hungary (hereinafter referred to as the “Rental”), we process a range of personal data in connection with, during, or for the purposes of providing such service. This data processing is carried out in accordance with the applicable laws, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter: “GDPR”). We hereby inform you about the details of how your personal data is processed and your rights related thereto.

Data Controller: EuRent Autókölcsönző Kft. (registered office: 1238 Budapest, Szentlőrinci u. 195853 hrsz.; company registration number: 01 09 063627), acting as the Hungarian franchise partner of Europcar International S.A.S.U. (hereinafter referred to as “Europcar Hungary”).

Contact details of the Data Protection Officer: Mailing address: 1238 Budapest, Szentlőrinci u. 195853 hrsz. E-mail: gdpr@europcar.hu

Europcar Hungary offers both permanent (typically for more than 1 month) and regular individual rental options for an indefinite period, as well as individual, one-off, short-term rental options for both private and corporate customers.

In each of the above cases, the specific rental constitutes an individual contractual relationship (the ‘Rental’) under the Europcar Hungary General Rental Conditions (the ‘GRC’). All individual Rentals are therefore subject to the provisions of the GRC (available at https://www.europcar.com/ hu-hu/p/jogi-rendelkezesek/ altalanos-berleti-feltetelek) and the Renter's individual declarations in relation to the Rental are recorded in a separate document. All these documents together constitute the individual rental contract (hereinafter referred to as the ‘Individual Rental Contract’). It is the responsibility of the person concluding the Rental, who must also declare it, that he/she is over 21 years of age, or 25 years of age in certain categories, has obtained his/her driving licence at least 1 year previously and is therefore legally entitled to conclude the Individual Rental Contract and issue the related declarations in accordance with clause 2.1 of the GRC.

For all Rentals, please note that Europcar Hungary, as well as the financial service providers involved in credit card payments, have a statutory duty to detect suspicious transactions. Only the person providing the personal data provided during the rental and payment process is responsible for the truthfulness, accuracy and lawfulness of their use. However, Europcar Hungary will also take the necessary steps to verify the accuracy of the data, by scanning the data of the presented document and driving licence in certain cases and locations by means of an IT tool to verify the validity and authenticity of the document, and by storing an image of the photograph on the document for a limited period (30 days). However, Europcar Hungary will not copy the identification document and the driving licence (in its entirety), nor will it take a photograph of the whole document!

Certain conditions, discounts or services offered by Europcar Hungary are linked to specific legal or natural persons, for which eligibility must be verified in advance.

If the Rental is carried out through any of the sub-sites of www.europcar.com, Europcar Hungary will participate in the provision of the service as the addressee of Europcar International S.A.S.U. (headquarters: 13 ter Boulevard Berthier, 75017, Paris, France), whereby the data detailed below will be processed in the same way as the data processed in the course of the rental services provided by Europcar Hungary in the context of its own operations.

It is possible to request information in person and rent a car at Europcar Hungary offices during office opening hours. You can find the list of our offices and their contact details here: https://www.europcar. com/en-hu/places/car-rental- hungary.

In case you are only inquiring in person about rental options, prices, and other conditions, no data recording takes place. Europcar Hungary processes personal data only in connection with an actually concluded Rental. In such cases, the data is recorded in Europcar Hungary’s own administrative system and is used to generate Individual Rental Contracts containing the specific terms. In case the contract is concluded as part of so-called assistance services, the data is recorded on a pre-printed data sheet, and the information on it is subsequently entered into the administrative system.

The conclusion of the Individual Rental Agreement, which also requires the completion and signing of the following documents: - Rental data sheet - Acceptance of the General Terms and Conditions (GRC) - Declaration acknowledging the data processing information related to the Rental - Objective liability declaration - Approval of card hold, or card hold declaration - If applicable: permission to leave the country

- the details of the natural person or person designated as the contact person of the renter and, if different, the person(s) using the vehicle (hereinafter ‘Driver Data’): full name of renter, user(s) date and place of birth of renter type of renter (individual or legal person) number of driver's licence category of driver's licence date of issue of driver's licence expiry date of driver's licence issuer of driver's licence number of the identification document of the renter, user(s) of the vehicle date of issue of the identification document of the renter, user(s) of the vehicle expiry date of the identification document of the renter, user(s) of the vehicle

- credit card details: name of credit card holder as shown on the credit card credit card number expiry date of credit card

- details of vehicle pick-up: route number, if relevant off-site pick-up request, if relevant place and time of check-in (vehicle pick-up) place and time of check-out (vehicle drop-off)

- signature of renter

- details of the hired vehicle, conditions of hire

- in all cases, an accounting voucher (type of account, name, billing address, tax number, EU tax number) and a receipt for cash receipt, and a terminal receipt for payment by credit card, accompanied by a terminal slip signed by the cardholder or a declaration of approval of card blocking

- promotional code, if available

- contact details (hereinafter ‘Contact Details’): e-mail address home address telephone number

In relation to the Rental: performance of the contract pursuant to Point (b) of Article 6 (1) GDPR, if the renter is a natural person; and in relation to a non-natural person renter, Europcar Hungary processes the Contact Details of the natural person in accordance with Point (f) of Article 6 (1) GDPR in order to pursue the legitimate interest of the natural person contacting the renter, to the extent necessary for the purpose, in line with the opinion of the Hungarian National Authority for Data Protection and Freedom of Information (hereinafter: “NAIH”) No. NAIH/2018/2570/2/V.

With regard to the documentation of payments and the issuing of invoices: pursuant to Point (c) of Article 6 (1) of the GDPR (fulfilment of a legal obligation) Act C of 2000 on Accounting /hereinafter referred to as "Act on Accounting”/) and under Points (e), (da) of Article 169 of Act CXXVII of 2007 on Value Added Tax /hereinafter referred to as “VAT Act"/) and under Point (f) of Article 6 (1) of the GDPR (legitimate interest) in respect of the content of the invoice data beyond the legally required data content.

All documents of the Rental will be kept for 8 years after the issue of the last invoice related to the Rental, pursuant to Article 169 (2) of Act C of 2000 on Accounting (hereinafter referred to as “Act on Accounting”).

When scanning the documents and identity cards presented by the Renter, the image of the portrait contained therein will be kept for 30 days.

The Contact Details will be updated as necessary, based on the indication of the data subject, in order to maintain contact.

for issuing receipts and invoices: invoicing software partner offices assistance service driver service insurance (in case of damage)

The rental can be arranged via the Europcar Hungary website (https://europcar.com/en-hu/), by email (europcar@europcar.hu), or in the case of a long-term rental contract, via direct partner access. The process is basically the same as that set out in point 1.1 above, however, the electronic correspondence will also be stored together with the contractual documents.

In the case of online rental arrangements, the documents referred to in point 1.1 will also be issued prior to the receipt of the vehicle concerned by the Rental.

The security deposit to be paid by the Renter will be determined at the time of the conclusion of the Individual Rental Contract, in accordance with point 6.2 of the General Conditions of Contract. The rules on the use and repayment of the security deposit are set out in the same point. The pre-authorisation approved by the cardholder for the payment of the security deposit will be renewed every 30 days if the rental period exceeds this period.

The Renter is obliged to pay a security deposit in respect of the vehicle rented under the Individual Rental Contract to ensure full compliance with the contractual obligations undertaken, thus, in particular but not limited to clause 5.2 of the GRC.

Data set corresponding to point 1.1.

The legal basis for processing is the performance of the Individual Rental Contract with the renter in accordance with Point (b) of Article 6 (1) of the GDPR.

In accordance with point 1.1.

In accordance with point 1.1.

When the rented vehicle is handed over and taken over, reports are taken, which include the condition of the vehicle and any occurrent damage at the time of the handover and the takeover.

In case the vehicle is handed over by the user of the vehicle at the service station or other pre-arranged location, the collection process is not carried out at the time of delivery and with the participation of both parties, but Europcar Hungary takes photographs of any occurrent damage on site at the beginning of the opening hours.

The handover-takeover report for international one-way rentals is also taken by Europcar Hungary when the vehicle is dropped off at a Europcar Hungary office, which also includes the condition of the vehicle, any occurrent damage (with photo) at the time of pick-up, and is signed by the parties involved. The documents of this takeover are forwarded to the foreign franchise partner concerned.

Proving the handover and takeover of the vehicle rented under the Individual Rental Contract and of the condition of the vehicle as recorded at these times.

In addition to the data set out in point 1.1, the reports shall record the fact, place and date of handover and return of the rented vehicle; the kilometres driven or mileage; any damage observed during the handover and any photographs taken thereof; and the signature of the relevant reports.

The legal basis for processing is the performance of the Individual Rental Contract with the Renter in accordance with Point (b) of Article 6 (1) of the GDPR.

In accordance with point 1.1.

In accordance with point 1.1.

After taking the rented vehicle over, Europcar Hungary may require the Renter to make additional payments in addition to the rental fee for a number of reasons, including:

- compensation in case of damage(s) recorded at the time of takeover (return) but not yet recorded at the time of handover (clause 11 of the GRC),

- so called “no show fee” (clause 4.3 of the GRC),

- cancellation of the reservation within 48 hours (clause 4.3 of the GRC)

- late and off-site drop-off (clause 5.4 of the GRC),

- parking and traffic fines (point 6.1 of the GRC).

In the case of international or domestic reservations, if no cancellation is made but the vehicle is not collected ("no show" case) or the cancellation is made during a cancellation period that is not free of charge (cancellation charge case), Europcar Hungary is entitled to claim the corresponding fee.

Europcar Hungary claims the amount of the fine in the decision from the public roads enforcement from the Renter (vehicle user) after payment of the fine.

According to the decision from the police, Europcar Hungary primarily charges the credit card provided at the time of the conclusion of the Individual Rental Contract, but if it is not possible to charge the credit card, Europcar Hungary discloses the personal data of the car user to the police.

In relation to the Rental concluded in accordance with points 1.1 and 1.2, the fulfilment of additional payment obligations arising on the part of the Renter after the return of the rented vehicle.

Renter data and bank card blocking data as per points 1.1 and 1.2;

handover-takeover data as per point 1.4, data sent by municipal parking companies, public riads enforcement and/or the police regarding fines.

The legal basis for data processing is the performance of the Individual Rental Contract concluded with the renter in accordance with point (b) of Article 6 (1) of the GDPR.

In accordance with point 1.1, if the renter fails to meet the payment obligation, the data will be stored for 8 years from the completion of steps taken to collect the claim.

In accordance with point 1.1, if the Renter fails to meet the payment obligation, Europcar Hungary may also forward the data necessary for the collection of the claim to third parties (in particular: legal representative, translation office, notary public chamber, bailiff, court) to take steps to collect the claim. In the event of failure to charge police fine onto a bank card, Europcar Hungary transfer the necessary data of the vehicle user to the police.

Some rental vehicles are equipped with an intelligent sensor box (hereinafter referred to as the “Sensor Box”). The Sensor Box collects and transmits data on smoking in the vehicle, damage incidents to the vehicle and improper driving techniques (collectively, “Incidents of Use”).

In relation to the Rental concluded in accordance with points 1.1 and 1.2, checking the vehicle usage conditions and detecting any possible breaches of contract. The sensor box is responsible for detecting smoke and damage, as well as monitoring the driving technique of the driver of the vehicle.

Renter data as per points 1.1 and 1.2;

usage incidents detected by the sensor box, namely:

- smoking in the passenger compartment,

- driving technique different from the average,

- calculated, presumed injuries resulting from collisions;

time and geographical location of the usage incident.

The Data Controller's legitimate interest pursuant to Point (f) of Article 6 (1) of the GDPR: It is the Data Controller's legitimate interest to preserve the technical and physical integrity and functionality of the property it owns, as well as to enforce its rights against any car user who breaches the contract.

We store the data collected by the sensor box for 5 years after the termination of the rental agreement.

The software for the sensor box transmits the recorded personal data in anonymized form to the following data processor: Robert Bosch GmbH Robert-Bosch-Platz 1 70839 Gerlingen Germany

If the vehicle is not returned at the end of the rental period and the Renter does not excuse the delay, Europcar Hungary is entitled to recover the vehicle either by exercising its own authority or by filing a complaint (by issuing a summons).

In case, during an investigation procedure, Europcar Hungary is obliged to disclose the personal data of the renter and/or the vehicle user based on a decision received from the police or other authorized authority or body, it shall disclose them to the requesting authority or body.

Europcar Hungary must provide the data necessary for investigation procedures.

Data related to the transmission of data to the authority or body in accordance with points 1.1., 1.2. and, if necessary, 1.4.

The legal basis for data processing is the fulfilment of the data provision obligation in accordance with Point (c) of Article 6 (1) of the GDPR.

In accordance with points 1.1 and 1.4.

investigative authorities, organs

Europcar Hungary concludes a framework contract for the provision of rental services with business customers for a permanent or indefinite period of time through the processes set out in point 1.2 and point 2.1. In connection with the establishment and performance of such contracts, it is necessary to process the data of contact persons, and the business partner becomes aware of the data to be shared according to the framework contract from the data of the Individual Rental Contract set out in point 1.1. In relation to the knowledge and processing of this data, the business customer qualifies as an independent data controller, and this data controller is obliged to inform the data subject set out in point 1.1. of this information about the data transfer and subsequent data processing.

Ensuring the possibility of maintaining contractual contact (certification of performance, invoicing, coordination of service services, etc.) in connection with framework contracts concluded for a permanent or indefinite period.

Contact Details (as per point 1.1) regarding the persons designated by the contracting party,

According to Point (f) of Article 6 (1) of the GDPR, Europcar Hungary processes the data of the contact person to the extent necessary for the purpose in accordance with the position of the NAIH No. NAIH/2018/2570/2/V in order to enforce its legitimate interest.

All documentation related to the performance of the long-term or framework contract is retained for 8 years following the issuance of the last invoice related to the related Individual Rental Agreement, pursuant to Section 169 (2) of the Accounting Act, however, in order to keep the Contact Details up to date, the data subject or the business customer may at any time request the modification of the Contact Details or its deletion from the register for future contacts.

contracting party (given contractual partner)

Purpose of data processing

For business customers with a long-term rental or framework agreement as per point 1.7., communications related to Europcar Hungary's services, in particular - price change notifications, - notifications about changes to the GRC or other rental conditions, - communication of changes in the Europcar Hungary office network or in the person of the contact person designated by Europcar Hungary, - sending inquiries sent for the purpose of measuring customer satisfaction to the contact person(s) designated by the business customer. These customer notifications are not letters of marketing purpose or content.

- name and email address

- regarding sent emails: opening, clicking, failed sending (bounce emails)

Based on Point (f) of Article 6 (1) of the GDPR, Europcar Hungary has a legitimate interest in adequately informing its business customers about information relevant to the contract and ensuring that the services it provides meet the customers' expectations as much as possible.

The source of data for Europcar Hungary's customer information is the contact information involved in the long-term contract or framework contract, however, you have the option to declare at any time that your contact information or any of your Contact Details has changed.

mass mailing: B&G Net Kft.

If you have any questions or problems regarding Europcar Hungary's services, such as the Rental, you can contact Europcar Hungary for support in a number of ways. You can contact us by email, telephone or in person. In case these communications are not verbal, data processing is necessarily carried out in connection with written requests.

You can express your opinion, report a problem, send feedback, or ask a question using the telephone or e-mail contact details provided by Europcar Hungary, during which you necessarily provide personal data.

* The purpose of recording phone calls received by or made from extensions designated for customer service is to ensure effective complaint handling and to monitor compliance with complaint handling procedures. Audio recordings may be reviewed only during or for the purpose of specific case handling, and only when justified.

- name (for addressing, if necessary for identification), - telephone number (in case of telephone inquiry or in case the telephone number is provided by e-mail), or e-mail address (in case of e-mail inquiry or in case the e-mail address is provided during the telephone inquiry) (for contact), -for phone calls received by or made from extensions designated for customer service, the following information is recorded: the time of the call, its duration, and whether it was incoming or outgoing, the calling and called numbers (or their internal identifiers), as well as the audio recording of the call itself (to ensure confidentiality, access to the call recording system is restricted, and all activities are logged in the event log) - comment, problem, feedback, question and the personal data contained therein (helps in the development of Europcar Hungary's services, may remedy the problem based on the received problem – see more details in Point 2.2. in relation to consumer complaints, Point 2.3. in case of data protection inquiries –, and if necessary, may fulfil its obligations regarding complaint handling, may answer your questions), - Europcar Hungary's response and the personal data contained therein - residential address (in case of a response to be sent by post)

We basically process your request based on your consent pursuant to Point (a) of Article 6 (1) of the GDPR.

In case your inquiry – after being informed of it – qualifies as a complaint concerning natural persons (see points 2.2 or 2.3), the legal basis for the data processing will be the fulfilment of a legal obligation incumbent on Europcar Hungary pursuant to Point (c) of Article 6 (1) of the GDPR.

In case the complaint does not come from a natural person, Europcar Hungary processes the personal data that may be affected in order to enforce any civil law claims pursuant to Section 6:22 of Act V of 2013 on the Civil Code (“Civil Code”) and to defend against any civil law claims of the data subjects, i.e. in the legitimate interest of Europcar Hungary (Point (f) of Article 6 (1) of the GDPR).

However, in the case of recording telephone calls received by or made from extensions designated for customer service, the Data Controller’s legitimate interest is in accordance with Article 6 (1)(f) of the Regulation, to handle any complaints effectively and in accordance with consumer protection laws; the Data Controller has identified the most accurate possible recording of the details set forth in the complaint as an essential element of this process.

In case the inquiry does not qualify as a complaint, the data are processed by Europcar Hungary until you withdraw your consent, in lack of such withdrawal, Europcar Hungary deletes the personal data until 28thFebruary following the elapse of 1 calendar year reckoned from the last communication in the inquiry (closing of the inquiry). Consent can be withdrawn at any time by sending an e-mail to gdpr@europcar.hu.

In case the inquiry does not qualify as a complaint, the data are processed by Europcar Hungary until you withdraw your consent, in lack of such withdrawal, Europcar Hungary deletes the personal data until 28thFebruary following the elapse of 1 calendar year reckoned from the last communication in the inquiry (closing of the inquiry).

Phone calls received by or made from the extensions designated for customer service are stored for 365 days. To exercise your rights as a data subject, you must provide the date and time of the call and the phone number.

Europcar Hungary keeps the reports of the complaint and a copy of the response for 5 years and presents them to the supervisory authorities upon request.

3rdpersons involved in the administration, about whom precise information can be provided on a case-by-case basis, upon request

The Data Controller uses a call recording service to manage customer service phone calls, while its email system is provided by a third-party service provider and operated by an IT service provider

The Data Controller uses the email system as a highly reliable, market-leading, cloud-based service on a unified basis across the corporate group

The provider of data processing activities related to the IT system and the call recording service:

Name of the data processor: Porsche Hungária Kereskedelmi Kft. Mailing address of the data processor: 1139 Budapest, Fáy u. 27. Contact information for the data processor: adatvedelem@porschehungaria.hu

The investigation of the complainant's complaint, complaint handling by law: you may submit your consumer objections (complaints) about the service you have ordered or Europcar Hungary's related activities in accordance with the applicable procedure.

Complaints made in person or by telephone are investigated promptly and we inform the complainant of our position and, where possible, remedy the complaint. If the complainant does not agree with the response to his/her oral complaint, he/she needs to send us a written complaint. In this case, we proceed in accordance with the provisions for written complaints as set out below.

We investigate and respond to written complaints within 30 days. If the complaint is rejected, we shall give reasons for our response. If the complaint is rejected, we shall inform you in writing of the authority or conciliation body to which you can refer your complaint, depending on its nature.

- the name and address of the consumer,

- the place, time and manner in which the complaint was lodged,

- a detailed description of the consumer's complaint, the documents, evidence and other evidence produced by the consumer and a list of them,

- Europcar Hungary's statement of its position on the consumer's complaint, if an immediate investigation of the complaint is possible,

- the signature of the person who took the record and, except in the case of an oral complaint made by telephone or other electronic communication service, the signature of the consumer,

- the place and time when the record is taken,

- in the case of an oral complaint made by telephone or other electronic communications service, the unique identification number of the complaint.

To comply with Europcar Hungary's legal obligation under Point (c) of Article 6 (1) of the GDPR, as set out in the Civil Code and the legislation on consumer complaints (in particular, Act CLV of 1997 on Consumer Protection).

Europcar Hungary shall keep the record of the complaint and a copy of the reply for 5 years and present it to the supervisory authorities upon their request, in accordance with Article 17/A (7) of the Consumer Protection Act.

case of referral of a complaint, the authorities and bodies as described on http://f