Privacy and Cookie Notice

Avis Budget Group Developer Privacy Notice

and

Avis Budget Group Developer Cookie Notice

Last updated: 20-Sept-2019

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: developer.avis.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.

1. WHO WE ARE

2. THE TYPES OF INFORMATION WE COLLECT, AND HOW WE COLLECT THEM

3. HOW INFORMATION IS USED

4. HOW INFORMATION IS SHARED

5. YOUR CHOICES

6. HOW YOUR INFORMATION IS PROTECTED

7. CHILDREN’S PRIVACY

8. YOUR CALIFORNIA PRIVACY RIGHTS

9. EUROPEAN RESIDENTS

10. THIRD PARTY COLLECTION

11. GEOGRAPHIC LOCATIONS

12. CONTACT US

BY USING ANY OF 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 our 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.

    To see all the categories of personal information we collect from you, click here.

Non-Personal Information

  • We may also collect information that does not personally identify you.

  • We may aggregate, anonymize, pseudonymize, de-identify or aggregate 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;

  • provide you with, and improve, relevant marketing or offers from us

  • 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;

  • to 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 Website 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 Website or via e-mail of our intent to transfer personal information to a third party for this purpose.

To see all the categories of personal information we share, click here.

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

You may have – in accordance with applicable privacy and 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 – if you are an EU resident, 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 – if you are an EU resident, 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 – if you are an EU resident, 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.

If you would like to exercise any of these rights or if you have any concerns, please contact us or if you are an EU resident, contact our Data Protection Officer. If you are an EU resident, 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 data protection law.

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.

 

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. YOUR CALIFORNIA PRIVACY RIGHTS

We do not share your personal information with third parties for their own direct marketing purposes without your consent. To make any request pursuant to California privacy law, please contact ABGprivacy@avisbudget.com.

 

9. 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.

 

9.1 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 our 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 our 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.

 

9.2 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 our 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.

 

9.3 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.

 

9.4 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

 

10. 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.

 

11. 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.

 

12. CONTACT US

If you have questions, comments, or suggestions, please fill out the contact form at https://developer.avis.com/contact-us. We may need to verify your identity before assisting with your request.

CHART: INFORMATION WE COLLECT AND SHARE

We collect the following categories of personal information from you:

Category

Examples

Collected

Shared

Identifiers

Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.

YES

YES

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Name, signature, address, telephone number, credit card number, debit card number, or any other financial information. (Some personal information included in this category may overlap with other categories.)

YES

YES

Protected classification characteristics under California or federal law

Age (40 years or older), physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, veteran or military status.

NO

NO

Commercial information

Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

NO

Biometric information

Genetic, physiological, behavioral, and biological characteristics

NO

NO

Internet or other similar network activity.

Information on a customer's interaction with a website, application, or advertisement.

YES

YES

Geolocation data.

Physical location or movements.

NO

NO

Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

NO

Professional or employment-related information

Current or past job history

NO

NO

Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

NO

Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

NO

 


 

General Information

This cookie policy describes how we use cookies and similar technologies on our website. 

Avis Budget Group, Inc (and its companies located in the European Union) ("we", "us", "our") uses cookies and similar technologies as described in this cookie notice.

Please review this cookie notice carefully. It describes our use of cookies, web beacons or bugs, IP addresses and our use of other methods to collect data regarding the usage of our website. For details on our use of data collection methods, please see our Privacy Notice. Details of our use of cookies and how to switch off some of these cookies are outlined below.

A cookie is a small text file that is stored by your browser, and allows it to remember information between web pages and browser sessions. Avis uses a number of "first party" cookies - generated and used by the Avis website – and some "third party" cookies – generated on our site by third parties. They enable us to remember you when you return to the site, remember your account details and display appropriate content based on your preferences. They also help us to understand user behaviour within our site, which means we can make the experience better for you.

Cookies can only store text, which is generally anonymous and usually encrypted.

 

What are cookies?

Cookies are small text files generated by websites that you visit holding session data that may be of use later in the site. The data allows the site to maintain your information between pages, and also to analyse the way you interact with the site.

Cookies are secure – they can only store information that is put there by the browser, which is information the user has entered into the browser or that is included in the page request. They cannot run code and they cannot be used to access your computer. If a website encrypts the information in the cookie, only that website can read the information.

There are two different types of cookies: Session and Persistent. They are used for different things and contain different information

Session cookies contain information that is used within your current browser session. These cookies are automatically deleted when you close your browser. Nothing is persisted on your machine beyond the time you spend on the site.

Persistent cookies are used to hold information that is used between visits. This data allows sites to recognise that you are a returning visitor and react accordingly. Persistent cookies have a lifetime value that is set by the website, which can vary between a few minutes or several years.

For additional information about cookies, please visit:
• www.allaboutcookies.org;
• www.youronlinechoices.eu; and
• https://www.cookielaw.org/media/1096/icc_uk_cookiesguide_revnov.pdf.

 

Why use cookies?

Cookies are used by the site to keep your session as you progress through the site, keeping track of your information and whether you've logged in. They are used to display relevant services to you.

Web analytics cookies, including from our partners Google and Adobe, allow us to track your interaction within the site. This gives us valuable insights which enable us to improve the site and services we offer.

 

Turning off and deleting cookies

All web browsers allow you to limit cookie behaviour or turn off cookies within the settings or options of the browser. The steps to do this are different for each browser, you can find instructions under the Help menu of your browser.

Through your browser you can also view the cookies that are on your computer, and delete individual ones, or purge them all.

Cookies are just text files so you can open them and read the contents. The data within them is often encrypted, or a numerical key corresponding to a web session so they often don't make sense to anything other than the website that wrote it.

 

What cookies does the Avis site create?

The session cookies that Avis writes includes data used by the web server hardware about which server is processing your session, your authentication status and the details of your account.

The persistent cookies that are created by the Avis website are used by our technology partners. They are used to recognise traffic to the site that is returning users rather than new visitors. The information that is stored is used to serve you appropriate advertisements on other sites on our behalf. Deleting these cookies or disabling these cookies won't affect your experience or the functionality of the Avis website.

 

What do those cookies do?

We have categorized the cookies on the Avis website as follows:

Category

Purpose

Default

Default cookies enable our website to function properly and help us to deliver services associated with running the website. For example, without these cookies, it would difficult for you to access secure areas of our website. We also use cookies to gather analytics. We collect this information so that we can better understand how users engage with our website.

Optimisation

These cookies store information and preferences so that any customisation or personalisation that you have selected is stored for future use. For example, these cookies will remember your preferences as you navigate through our website.

Advertising and retargeting

Cookies in this category help facilitate a more targeted advertising experience for the user on our website and let us customise adverts that appear for you on other sites. For example, we can help streamline any advertisements so that they are customized to options you have previously selected.

Privacy option cookies

These cookies are used to remember your cookie settings between visits to our site, so that our cookie banner does not appear every time you visit our site. If you disable these cookies our site will not remember your cookie settings and you may be asked for your cookie preferences again.

You acknowledge that where we allow third parties to drop cookies, we have no control over those cookies or the data generated.

 

Other technologies

In addition to cookies, we use some other similar technologies as follows:

  • Web Beacons: small graphic images included on our website or emails or those of third parties to provide analytics information;

  • Social widgets: buttons or icons provided by third party social media networks which may collect browsing data and will be received by the third party and are controlled by the third party; and

 

Changes to our Cookie Policy

This cookie policy may be updated from time to time.

If we change anything important about this cookie policy we will notify you through a pop-up on the website for a reasonable length of time prior to and following the change. You may review the cookie policy by visiting our website and clicking on the “Privacy and Cookies Policy” link.