At Instant Rent A Car., through our subsidiaries operating the IRAC, (collectively, “I.R.A.C. Inc”, “we”, “our” or “us”), we respect your privacy. We implemented this privacy policy (“Privacy Policy”) to explain to you how we use and protect the personal information we may gather from and about our customers by means of our websites, mobile applications, online booking widgets (i.e. online booking applications run by our third-party partners such as hotel providers, airlines, etc), our corporate, rental, and sales locations, and from third-party sources. By using our websites or mobile applications, you consent to the collection, use, and disclosure of your information, as described in this

Privacy Policy

To identify who the data controller is in respect of your personal data, please see Data Controllers and Contact Details by Country.

The nature of the business and operations require us to share your reservation and booking information with our franchisees or licensees, which are owned and operated by independent Entities (“Licensees”). For these transactions, the Licensee is an independent data controller and may maintain its own privacy policy in respect of the rental data that you provide to the Licensee. You are encouraged to check the privacy policy of the Licensee that is applicable to your transaction.

The Types of Information We Collect

Information Collected About You

• You may provide us with certain information in connection with a transaction or in your interactions with our websites and at our locations. When you are asked to provide personal information, you may decline. If you choose not to provide the information, you may not be able to use some products or services. The personal information we may collect includes:

• Your name, contact information, driver’s license number and expiration date, emergency contact information, and date of birth;

• Vehicle rental information, including the location of where the vehicle is rented, date of rentals, type of rental, and your preferences;

• Your credit card details, Instant Rent a Car rewards information, online user accounts details, membership/corporate ID numbers, passport information, and frequent flyer or travel partner affiliations;

• Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;

• Photographs you submit of you and your driver’s license or your receipts through camera features available on some of our mobile applications and websites;

• Financial information that may be necessary to facilitate the purchase or lease of a vehicle from a Car Sales or Fleet Management location in the United States. (Additional notices will be provided to you at the time of that transaction.)

• Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents, Car Sales lead providers or similar providers).

With your consent, we may access location-based information from your mobile device or based on your IP address. We may also use your mobile device location information to provide you with notifications with your consent. We do not use this information to specifically locate you for any reason other than to provide you the service. If you have allowed us to utilize your location information in the past and wish to revoke the permissions, please turn off location services at the device level. With your consent, our application may utilize your device’s camera feature to upload photos (such as your receipts) to the application. If you have allowed the application to utilize your camera and wish to revoke the permissions to do so, please do so at the device level.

In certain areas of our sites, we provide you the ability to enter your friend’s name and contact information in order for us to send your friend a one-time email inviting him or her to visit the sites. We also provide you the ability to enter a friend’s or other individual’s name and contact information in order to make bookings for that friend or other individual. You must have obtained the consent of your friends before making such submissions. The information you provide will not be used for any further marketing purpose unless your friend requests services or we otherwise obtain consent from that person. Please be aware that when you use any send-to-a-friend functionality on our sites, your name and e-mail address may be included in the communication sent to your friend.

Information Collected and Stored Automatically

By visiting our websites, certain information may be automatically provided to us by your computer. For each visitor to our websites, our webservers automatically recognize the visitor’s domain name or IP address. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, webservers can identify your computer by its IP address. In addition, we may collect your browser type and operating system as well as your internet service provider (ISP), referring and exit pages, date and time stamp, and/or clickstream data. We collect similar information when visiting our websites with your mobile device, including mobile device brand, model, mobile operation system and carrier. Except as otherwise explained in this policy, we may combine the non-personal information we collect from you (as described above and as described below, under “Cookies & Pixel Tracking”) with your personal information in order to tailor our websites and enhance your online experience by saving your preferences and/or to help identify site features, advertisements and offers that may be of interest to you.

Cookies & Pixel Tracking

Instant Rent a Car and our partners use cookies, pixel tags, etags, HTML 5 storage and similar technologies on most of our sites and in promotional emails which we may send to you. We use them to monitor and understand your use of our websites and services; improve your user experience and enable personalized features and content; optimize our advertisements and marketing and see which email promotions were of interest to you; and assist third-party advertising companies to serve ads on our behalf across the Internet. At this time, our websites do not respond to automated signals regarding tracking mechanisms, including “do not track” instructions from your browser. However, you have other options for preventing or limiting the use of cookies and similar technologies. To learn how to manage privacy and storage settings for Flash cookies, please click here. To learn more, please see our Online Tracking and Advertising page.

Vehicle Operation and Location Data

I.R.A.C. vehicles may be equipped with OnStar or another vehicle telematics system (“Telematics System”). Some or all Telematics System functionality may or may not be active during rental periods. Telematics Systems may provide use, disclosure of, or access to (1) location information, (2) crash notification and related crash data and, (3) operational condition, mileage, diagnostic and performance reporting of vehicles (“Telematics Data”), as permitted by law.

Use of the Telematics System is subject to the terms and conditions and privacy policy posted by the applicable Telematics Systems provider and/or vehicle manufacturer (in the case of OnStar, information is available at www.onstar.com), which may include system and service limitations, warranty exclusions, limitations of liability, wireless service provider terms, privacy practices, descriptions of use and sharing of information, and user responsibilities.

Children’s Privacy

Our websites and online marketing are not directed to, and I.R.A.C. does not knowingly collect personal information from, children under the age of 18 or your country’s age of minority. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please email us at privacy@instantrentacar.com.

How We Use This Information

We use the information we collect for the following purposes:

• To assist the transactions that you request, such as reserving and renting motor vehicles.

• To verify a valid ID when submitting a photo of yourself and drivers license for one of our Instant CarShare, afterhours or expedited rental services. We do not store this information for any other purpose.

• To service your account or membership with us, respond to your questions and contact you when necessary.

• To provide you with discounts, coupons, sweepstakes, offers and other information, opportunities, and services that may be of interest to you. You may receive these offers in advertising that is directed to you via third-party sites and media properties, including in social media. You may be able to opt-out of these ads by clicking on an icon in the ad or through the privacy settings in each media property.

• To assist us in providing better products and services (for example, we may contact you by telephone, mail or email to assist us in evaluating the performance of our staff, to assess the quality of product and service received and to help us improve our websites, facilities and services).

• To compile statistics and analysis about our customers’ use of our websites, products and services, which statistics are only used to enable us to provide better customer service, products, features and functionality to you and other customers in the future.

• To protect our rights and property.

We may combine the information that you submit to us with information related to your transactions with us, such as rental location and vehicle type. We may also combine this information with data we receive about you from third parties who assist us in processing requests, maintaining our data, and optimizing our services.

Except where prohibited by law, we retain information we collect for commercially reasonable periods of time or in accordance with specific policies. Information collected for a specified purpose will only be used for that purpose and, after a reasonable period of time, will no longer be actively stored when that purpose has been fulfilled. Inactive data may, however, continue to be used for statistical, marketing, archiving, and other analytical purposes.

How Your Information May Be Shared

We may disclose the information we collect from and about you to our subsidiaries for the purpose of providing the transactions you have requested and for marketing purposes. In addition to those stated within this Policy, Telematics Data from rental vehicles may be disclosed to, accessed by or used by I.R.A.C., our affiliates, emergency service providers, others who may assist in responding to an accident, telematics service operators, or those with whom we have a legal or contractual obligation to provide such data. Our affiliates and our subsidiary employees in our IT, marketing, operations and customer service divisions may use your information, as described in this Policy.

We also may disclose your information to other third parties: (1) when required by law or in response to legal process; (2) without legal process in response to a request from law enforcement relating to a criminal investigation; (3) to protect our rights, privacy, safety or property, or of the public; (4) for administrative, technical support or other business purposes to facilitate our transactions with you (i.e. for your insurance replacement, corporate rental or through one of our partners), analyze our data, conduct mobile analytics services, or to maintain and improve our services (subject to confidentiality agreements as appropriate); (5) to permit us to pursue available remedies or limit damage that we may sustain; (6) to enforce the terms of any rental agreement or our websites’ terms and conditions; (7) to assist with the administration of frequent flyer or other rewards programs; (8) to process your transaction with our subsidiaries, affiliates or licensee/franchisee located in the country in which you place your reservation; (9) if the rights of another individual might be violated and (10) otherwise with your consent.

Personal information may also be subject to transfer to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of I.R.A.C.’ businesses or assets. This will occur provided that the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your personal information.

We may disclose your personal information to third-party service providers (such as a payment processor to bill you for goods or services, an email provider to send email communications to you on our behalf, or the provider of our live chat feature in order to offer you customer service). These service providers may be located in a country different from your country of residence, such as the United States or a European Union member country. These service providers are contractually required to maintain the confidentiality and security of your information. However, your information may be accessible to U.S. or EU authorities in accordance with applicable laws.

We may also share aggregated or de-identified information about our customers with our advertising and marketing partners, and third-party media properties, including social media sites to allow them to send targeted advertising messages on our behalf. With your prior notice and consent, we may share your name and email address with our co-branded partners and affiliates in order to provide the services you have requested and for marketing purposes. If you wish to stop receiving promotional communications from these third parties, please contact the third party.

Choices You Can Make About Your Information

Throughout our websites, we provide choices about the collection, use, and sharing of your information. For example, you must affirmatively request to receive email advertisements from us, our affiliates and/or business partners concerning information about special offers, promotions and new features, products and services. You may choose to opt back in to our email advertisements at any time, in which case your most recent action will prevail. We will give you an opportunity to opt-out of the gathering of your personally identifiable information, specific uses of your personally identifiable information and any marketing promotions.

Testimonials

We may post customer testimonials/comments/reviews on our websites which may contain personally identifiable information. We will obtain your consent via email prior to posting the testimonial. To request the removal of your testimonial, please contact us through one of the methods listed below in the Contacting Us section.

Linked Sites

Throughout our websites, we provide choices about the collection, use, and sharing of your information. For example, you must affirmatively request to receive email advertisements from us, our affiliates and/or business partners concerning information about special offers, promotions and new features, products and services. You may choose to opt back in to our email advertisements at any time, in which case your most recent action will prevail. We will give you an opportunity to opt-out of the gathering of your personally identifiable information, specific uses of your personally identifiable information and any marketing promotions.

Data Security and Integrity

The security of the information you provide is very important to us and we try to provide secure transmission of your information. For certain transactions on certain of our websites, we may use Secured Sockets Layer (SSL) technology to secure the transfer of information. Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information transmitted over the Internet. Once we receive your information, we take steps that we believe are reasonably appropriate to protect its security, both internally and from outsiders, from loss, misuse, unauthorized access, disclosure, alteration and destruction, and to ensure the integrity of the data we collect. We use a combination of technological, physical, administrative and policy methods as well as organizational controls and non-disclosure or confidentiality agreements as we deem appropriate to protect this data.

If you have a user name and password for any of the features on our websites, you have the responsibility of keeping your password secret. You should not reveal your password to anyone. We will not ask you in an unsolicited telephone call or email for your password. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.

Global Data Transfers and Processing

We will use your information in the country in which your service and transaction occurs. Please be aware that, unless prohibited by law, your use or continued use of our websites and mobile applications signifies your express consent that information may be transferred to or stored on servers and processed outside the country of your residence, including any of the countries where we do business. Please also be aware that the privacy laws of the United States or other countries where information may be stored may not be as comprehensive or offer as much protection as the laws of other countries including your country of residence. You may request us not to make such transfers, but if you do, we may not be able to provide some or all of our products or services to you.

Changes in Terms

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.