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Privacy policy

TRAVEL CARS NZ LTD (TCNZ)

Your privacy is important to us. This privacy policy (“the Policy”), explains how we collect, process, use, store and disclose your personal data, as well as your rights associated with that data.

This policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary at the end of the document to understand the meaning of some of the terms used.

1. Who we are

1.1
Travel Cars NZ LTD (TCNZ) is a New Zealand’s car dealership company of used vehicles operating only in the Auckland region.

1.2
Together we are the data controllers for the purposes of this policy, which is issued on behalf the brand and unique entity.

When we mention “TCNZ“, “we“, “us” or “our” in this privacy Policy, we are referring to Travel Cars NZ LTD as an entity responsible for processing your data.

1.3
We also use a social network of independent agents and licensees when providing our services inside New Zealand, this network is running on Facebook.

Please note that those agents and licensees are not covered by this Policy and we are not responsible for the privacy practices of any agent, licensee or other third party with whom you may transact before or at the same time as using our products or services.

2. The data we collect about you
2.1
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

2.2
We also collect, use and share aggregated data such as statistical or demographic data, which may be derived from your personal data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat that combined data as personal data which will be used in accordance with this Privacy Policy.

2.3
We do not collect any sensitive data about you (such as details about your race or ethnicity, religious or philosophicl beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences, although we may be required to briefly hold and pass on any driving infringements that you incur while buying or renting our vehicles.

2.4
Refusal to provide your personal data: You do not have to provide your personal data when we request it, but if you choose not to, we may not be able to respond to your queries and perform any contract we have or are trying to enter into with you (for example, to provide you with a rental vehicle). That may mean we have to cancel a product or service you have with us. We will notify you at the time if that is the case.

3. How we collect your personal data

3.1
We use different methods to collect personal data from and about you including through:

4. How and why we use your personal data

We will only use your personal data when the law allows us to and typically only in the
circumstances and for the purposes set out in the table below. Please see the Glossary for an
explanation of the expressions used in the table.

 

5. Marketing

5.1
We aim to provide you with choices about how your personal data is used for marketing and advertising purposes. We have established a privacy centre where you can view and make certain decisions about your personal data use.

5.2
You will only receive marketing communications from us if you have opted in or consented to receiving those communications. We may use your personal data collected in those circumstances to contact you and keep you up to date with the latest news, events, special offers and promotions of our brands, including by email, text messages or post.

5.3
You can update your subscription preferences or unsubscribe from marketing communications at any time by following the update preferences or unsubscribe instructions provided in each such communication, or alternatively by contacting us by clicking here.

5.4
We may display advertising for you to see on third party websites, including social media sites such as Facebook. We do this by matching information about your activity on TCNZ websites with information collected on third party sites. That may involve using your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

6. Change of purpose

6.1
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

6.2
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6.3
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. How we share your personal data

7.1
We may have to share your personal data with the following parties for the purposes set out in the table in paragraph 4 above or for other purposes directly related to the purpose for which the
information was collected.

7.2
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8. International transfers

8.1
For the most part, your personal data is collected, stored and processed outside the European Economic Area (EEA).

8.2
Certain entities in the TCNZ network may collect personal data inside the EEA.

8.3
If we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

8.3.1
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

8.3.2
Where we have entered into EU-approved standard contractual clauses with the recipient to give personal data the same protection it has in Europe.

8.3.3
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe, New Zealand and the US.

8.4,
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

9. Your rights

9.1
You have the following rights in relation to your personal data.

9.2
If you wish to exercise any of the rights set out above, please contact us directly and we will
transfer with one of our Data Protection Officers.

9.3
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise
any of the other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in
these circumstances. If we choose to deny your request, we will inform you of the decision and your
right to complain to the supervisory authority within the one month deadline.

9.4
What we may need from you: We may need to request specific information from you to help us
confirm your identity and ensure that personal data is not disclosed to any person who has no right
to receive it.

9.5
Time limit to respond: We respond to all legitimate requests without undue delay and at the latest
within one month. Occasionally, if your request is particularly complex or you have made a number
of requests, we may need to extend this by up to a period of two months, in which case we will
notify you and keep you updated.

 

10. Security of your personal data

10.1
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit
access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and
they are subject to a duty of confidentiality.

10.2
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. How long will you use my personal data for?

11.1
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

11.2
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

12. Contact Details

12.1
EU Supervisory Authorities: If you are an EU data subject and feel that your personal data has been processed in a way that does not comply with the GDPR, you may lodge a complaint with the relevant supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach them, so please contact us in the first instance.

13. Changes to the Privacy Policy and your duty to inform us of changes

13.1
This version was last updated on 16 July 2018.

13.2
We reserve the right to update and change this Privacy Policy at any time by posting changes on this webpage or applicable mobile apps. Changes will take effect from the time they are posted. We will use reasonable endeavours to communicate those changes to you on our website and mobile apps or via other channels that we think are suitable.

13.3
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

GLOSSARY

Comply with a legal or regulatory obligation means processing your personal data where that is necessary for compliance with one of more of our legal or regulatory obligations.

Data controller means whomever determines the purposes and means of processing personal data. Legitimate Interest means our interests in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where that is necessary under a contract with you or to take steps at your request before entering into such a contract.

Personal data means any information about an individual that can be used to identify that person directly or indirectly by reference to a range of identifiers. It does not include anonymous data where the identity of the individual has been removed.

Processing means any operation or set of operations performed on personal data.

Processor means the entity that processes personal data on behalf of the controller.