This is the Cayman Islands privacy notice (“Privacy Notice”) of Avis / Cico Rent A Car System Limited (Avis Cico).
We at Avis Cico recognize the importance of protecting your personally identifiable information. To demonstrate our commitment to maintaining the privacy of your personally identifiable information, we have created this Privacy Notice to disclose our privacy practices for the personally identifiable information that we collect and receive through use of our products and services either offline or online.
By submitting your personally identifiable information to us, you consent to Avis Cico’s use and disclosure of your personally identifiable information as set forth in this Privacy Notice. Your use and/or continued use of Avis Cico website signifies your consent that your information may be transferred to or stored on servers and processed outside the country of your residence. Provided the data protection laws of these other countries differ from those in the Cayman Islands, please be assured that we take reasonable steps to ensure that your privacy is protected. If you do not agree with the terms of this Privacy Notice, please do not submit any information to Avis Cico either offline or through our Websites.
Purpose of this Privacy Notice
We recognize the importance of protecting your personally identifiable information (which includes your name, address, telephone number, date of birth, e-mail address, credit or debit card information, and other contact information,) that you provide to Avis Cico (collectively, “PII”). The purpose of this Privacy Notice is to tell you how Avis Cico strives to better serve you by keeping you informed of promotions, products and services, while, at the same time, safeguarding your PII. This Privacy Notice sets forth our policies regarding the collection, use and disclosure of your PII both through our online and offline operations. This Privacy Notice also explains how you can correct or change the PII we hold about you, or opt-out of receiving certain marketing materials.
Who is Covered under this Privacy Notice
This Privacy Notice is applicable to PII that you provide to Avis Cico. This Privacy Notice applies to all of the products, services and Websites offered by Avis Cico or its subsidiaries or affiliated companies.
This Privacy Notice does not apply to those Avis Cico locations that are owned and operated by an independent licensee that is neither owned nor controlled by Avis Cico or any Avis Cico affiliate or subsidiary. Each independent licensee collects PII and uses the PII for its own purposes. Avis Cico does not control the independent licensee’s use of this PII. For credit card transactions, the independent licensee – not Avis Cico – collects and processes credit card information and receives payment for the vehicle rental services. Thus, the independent licensee is subject to the merchant rules of the credit card processors it selects. This Privacy Notice also does not apply to an independent licensee’s website. These licensees may also use email campaigns and other methods of telephone, electronic and direct mail solicitation without our consent or knowledge and are solely responsible for their content and methods of identifying and contacting addressees.
What Personally Identifiable Information Avis Cico Collects
You generally are not required to provide us with PII when visiting our Websites. However, when you make a reservation, rent a vehicle, and/or join one of our programs, we need to collect certain information about you to provide or improve our services. The service that you choose will determine what information we collect from you. Here are some examples of information we collect from you:
Home and/or Business Address
Telephone Numbers at which we can contact you
Date of Birth
Payment Information (i.e. debit or credit card and expiration date – security code is obtained for transaction only and is not retained)
Information from your Driver’s License or other Government-issued identification (e.g., Passport)
When you rent a vehicle, we will also record non-personally identifiable information about your rental (e.g. where you rented the vehicle, where and when you returned the vehicle, payment arrangements, insurance preferences, gas consumption, mileage and other information related to the vehicle). This information is necessary in order to administer your rental reservation and/or process your transaction.
We may also need certain information from you when you request any of the following services or equipment: Special Needs/Optional Equipment; Special Offers/Discounts; Partner Member Numbers; use of a corporate or other discount number and other vehicle preferences. For example, if you wish to use a discount that Avis Cico provides to members of an association/affiliate to which you belong, we may collect information about your membership to verify and provide you with the correct discount for our services.
How Avis Cico Collects Personally Identifiable Information by Avis
The PII we collect from you will be with your express or implied consent. How we collect this information will depend on how you use our services. We may collect this information directly from you by telephone, fax, postal mail, email, at the counter, upon completion of an application or enrollment form, or through your use of our Websites or the Internet. To the extent you use our Websites, we may also collect information about your use of our Websites, transactional and account information, e-mail and other information related to communications to our Websites. We may also collect information about you indirectly through a travel agent, an account program in which you or your employer participates or through one of our partner programs when you deal with us through those means. Additionally, our affiliates and third parties may provide us with information about you.
You may choose not to provide some of your PII to us, but this may prevent us from providing our services to you, or limit our ability to provide you with the level of service that you would otherwise expect from us.
How Personally Identifiable Information is Used and Disclosed by Avis Cico
We strive to ensure that we give you a stress-free rental experience and are dedicated to building a rewarding and lasting relationship with every customer. To provide the level of service we believe you expect from us, we may use your PII for the following purposes:
Provide and administer the services that you request, and communicate with you regarding such services and offerings;
Research, develop, manage, protect and improve our Websites and services;
Maintain and develop our service-oriented software and other business systems; and
Analyze data, or to have a third party do so on our behalf.
We may also use your information – both PII and non-personally identifiable information – for other purposes. For example, PII may be needed to process and track your transactions or to send you information about our affiliates’ and business partners’ products and services and other information and materials that may be of interest to you. If you use our Websites, we may also use your information to evaluate what portions of our Websites are visited more often than others, determine where visitors came from, where they go, and how long they stay on a particular page, or on our Websites in general.
From time to time, we also may combine your PII with information obtained from other sources, including third parties, in order to provide you with more customized services and product offerings. To do this, it is often necessary to share your information with trusted vendors and business partners, such as companies that manage accounts, offer affinity, frequent-user, and reward programs, and companies that perform marketing services and other business operations for us. For more information, see below under “Disclosing.”
We may disclose your PII to affiliated and non-affiliated organizations including, for example:
To your company or organization if you use our services under a corporate or other commercial account;
To one of our program partners (e.g. if you are a member of an affiliate program, such as a relocation company or frequent traveler program and you have asked us to send details of your rental agreement with us to obtain your benefits from that program);
To entities that provide services on our behalf;
To any intermediary you use, such as a travel agent, broker or booking engine, in relation to any aspect of your rental;
To independent licensees for use in providing the services and offerings which you have requested and to communicate with you regarding such services and offerings;
To your credit card issuer;
To credit reporting and fraud checking agencies;
To debt collection agencies, if you fail to pay monies owed to us;
To government or private organizations responsible for the processing or handling of traffic or parking related violations;
To driver licensing authorities, directly or through intermediary organizations, when needed to verify compliance with Avis Cico’s safe driver criteria for qualified drivers and/or to verify license information; and
To government, regulatory and law enforcement agencies where the disclosure is required or authorized by law, and otherwise as we believe is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate our Websites properly, or to protect or defend our rights or the rights or well-being of our employees, users or others or if you are involved (or are suspected by governmental authorities or our security functions to be involved) in any illegal activity, even without a subpoena, warrant or court order.
We may disclose your PII to our affiliates and non-affiliated business partners for their use both on our behalf and for their own business purposes. For example, our affiliates and business partners may use such PII to send you information about their products and services and other information and materials that may be of interest to you. You may opt-out of us disclosing your PII for these purposes through one of the methods described in this Privacy Notice.
We may share your PII with other non-affiliated third parties, such as entities that provide services for our Websites or for our business (e.g., advertisers, ad servers, content providers, services providers, credit card processors, data processors, website development and support, fulfillment services providers, e-mail list hosting companies and distribution companies) that use such PII on our behalf consistent with this Privacy Notice. These types of third parties are not permitted to use your PII for any secondary purposes.
We may also transfer or assign your PII to third parties as a result of or in connection with a sale, merger, consolidation, change in control, transfer of assets, reorganization, or liquidation.
We operate globally so we may need to send your PII overseas as part of our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to ensure that your privacy is protected.
Website and Internet Privacy
If you use our Websites or otherwise interact with us via the Internet, the following privacy-related policies also apply:
If you use our Websites, certain information may be collected from your computer in the course of your use of our Websites. As with many websites, we may use both session based and persistent “cookies” and/or other technology (e.g., web bugs, e-mail bugs, clear GIFs, web beacons, tracker GIFs and “clickstream” data logs) in our Websites or in our electronic communications with you to enhance the functionality of our Websites and services. These technologies also make your transactions and other activities more convenient and efficient.
“Cookies” are small amounts of data that a website can send to your web browser and store on your computer. It is our policy not to save sensitive data, such as passwords or credit card information in cookies.
An IP address is a unique number that is automatically assigned to your computer whenever you are surfing the Internet so that your computer can be identified by the main computers, known as “Web servers,” that “serve up” Web pages. This allows us to gather useful information and data about our customers’ use of the site, such as the Web pages viewed on www.aviscayman.com.
Avis Cico collects IP addresses for the purposes of: helping us diagnose problems with our main computers, for system administration, to report aggregated information to our business partners, and to audit the use of our Website. When users request Web pages from our Web Site, our Web servers log the User’s IP address. We do not normally link IP addresses to anything personally identifiable, which means that a user’s session will be logged, but the user will remain anonymous to us. For example, we collect and/or track the home server domain name, the type of computer, and the type of Web browser used by you to access this Web Site. Such collection and tracking information is gathered by us as you navigate through our Websites, and will be used by us for our business purposes only.
Third Party Use of Technology
We may use third-party servicing technology and service providers to serve ads on our behalf across the Internet and sometimes on our Websites. They may collect non-personally identifiable information about your visits to our Websites, and your interaction with our products and services. They may also use non-personally identifiable information about your visits to send you targeted advertisements for goods and services. This information is collected through the use of a pixel tag, or similar technology which is industry standard technology used by most major websites.
Web pages may contain an electronic file called a web beacon that allows a website to count users who have visited that page or to access certain cookies. We are currently partnering with Yahoo! who utilizes web beacons in the following ways:
Yahoo! uses web beacons to conduct research on behalf of certain partners on their websites and also for auditing purposes.
Information recorded through these web beacons is used to report aggregate information about Yahoo! users to our partners. This aggregate information may include demographic and usage information. No PII about you is shared with partners from this research.
When conducting research, Yahoo!’s practice is to require our partners to disclose the presence of these web beacons on their pages in their privacy policies and state what choices are available to users regarding the collection and use of this information. You may choose to opt-out of Yahoo! using this information for this research.
Note: This opt-out applies to a specific browser rather than a specific user. Therefore you will have to opt-out separately from each computer or browser that you use.
Visiting Third-Party Websites
Occasionally when linking to a third-party website from our Websites, you may still see Avis Cico affiliate logo or an Avis Cico affiliate website frame. This is to provide you with a seamless experience when visiting our Websites. In these cases, you are no longer on our Websites but the third-party website, and therefore the information collection practices of the third party’s website may differ from Avis Cico’s. The privacy notice of the third party site will govern how information collected from you is used by the owner of the website. You can always know what website you are on by checking the Uniform Resource Locator (URL) in the location bar within your browser.
Linking your Avis Cico Accounts to Your Social Profiles
In order to provide you with more personalized services, we may give you the option of linking your social profiles with your Avis Cico accounts on our Websites. Currently, some of our Websites allow you to link social profiles from Facebook, Twitter, LinkedIn, Google and Windows Live. We may add or remove the availability of any or all platforms at any time in our sole discretion. This functionality is entirely optional for all users and you may link or unlink your account(s) at any time.
What Information is Collected from Your Social Profiles and What It’s Used for
If you exercise the option to link your social profile to any of our Websites, we may collect PII and additional information from your social profiles, which will be used by Avis Cico and agents acting on our behalf to customize your Avis Cico customer experience. Some examples of the type of information we may collect from these social profiles include:
Profile picture, gender, marital status, sexual preference, birthday, list of friends (but not the information on your friends’ social profiles unless they have also linked their profiles)
Professional Information such as prior and current work history
Personal Likes, Activities and Interest Information
The information we collect may be used to:
Serve you customized offers and deals on our Websites
Send you email offers with special deals and discounts
Send you offers by mobile phone text messages
Update your profile information on our Websites
Publish check-in and check-out information to your linked social media accounts
Share your upcoming trips with friends
View your friends’ that have linked their profiles upcoming trips
Unlinking Your Accounts
You may unlink your social profiles at any time. In order to unlink your profiles, you must log into each Avis Cico account that has been linked, click on the “Social Media Preferences” tab, and then select “Unlink” next to the social media channel you wish to unlink.
In an effort to provide our customers with new ways of sharing content, we have enabled some of our online content to be shared on social websites through hosted sharing links and icons. Users who share content and links through their social media profiles should be aware that all activities of this nature are public.
Please note, when you share (with or without adding your own comments) any of our content on your social media profile, that action is governed by the privacy notice of that social media platform, and not Avis Cico’s Privacy Notice. We do not track or store a record of those comments or actions.
If you choose to participate in posting or sharing activities, you are electing to share and display such public activities via our Websites. Due to the public nature of your posting or sharing your posts may be included in RSS feeds, APIs and made available to other websites via other formats. As a result, your public activities may appear on third-party websites, blogs or feeds. WE ARE NOT RESPONSIBLE FOR ANY PII YOU CHOOSE MAKE PUBLIC VIA YOUR SHARED POSTS.
How We Protect the Security of Personally Identifiable Information
The security of your PII is important to us. We exercise reasonable care in implementing generally accepted standards of security to protect your PII from loss, misuse and unauthorized access, disclosure, alteration or destruction, such as firewalls and Secure Socket Layer (SSL) encryption for some of your more sensitive PII. It is our policy to retain PII for as long as we believe appropriate for the purposes for which the PII was collected or as required by applicable law.
Unfortunately, “perfect security” does not exist on the Internet, and no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your PII, we cannot guarantee that PII stored on our servers, or transmitted to or from a user, will be free from unauthorized access. By using our Websites and corresponding with us, you acknowledge that you understand and agree to assume these risks.
You are responsible for maintaining the strict confidentiality of your account passcode, membership numbers and pin numbers, and you will be responsible for any access to or use of our Websites by you or any person or entity using a passcode provided to you, whether or not such access or use has been authorized by or on behalf of you, and whether or not such person or entity is your employee, relative or agent. In the event of the unauthorized use of your passcode, account, or membership number, or any other breach of security involving your information as it pertains to Avis Cico, you agree to immediately notify us. It is your sole responsibility to ensure that you exit from your account at the end of each session, control the dissemination and use of your passcode, control access to and use of your account and membership number, and notify us when you desire to cancel your account on our Websites. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.
It is our policy that we will never request your sensitive PII, such as your credit card number, passcode, membership number or pin number, in an e-mail, text or on a website that is not located at the domain name used by Avis Cico or an affiliate (for example Avis.com, Budget.com Budgettruck.com). If you receive an e-mail or other correspondence requesting that you provide any such information via e-mail or to a website that is not on such domain name, please do not provide such information, and report such request to our privacy officer at [email protected]
In the unlikely event that we believe that the security of your PII in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your current e-mail address, we may notify you by e-mail.
How to Correct or Update Personally Identifiable Information that Avis Cico Maintain
If you have provided your PII to us, you can update the PII we hold about you. You play an active role in assisting Avis Cico maintain the accuracy of your PII. Your prompt notification to us of any changes to your PII will assist us greatly in keeping your information accurate and up-to-date. If we don’t agree to make the changes, you may challenge our decision.
If you wish to contact us to access or correct your PII we have, or to inquire or provide feedback about our privacy practices, you can email us directly at [email protected] or write to us at:
Avis / Cico Rent A Car System Limited.
PO Box 10400
Grand Cayman KY1-1004, Cayman Islands
ATTN: Privacy Officer
We will respond to any access requests within 30 days of our receipt of the request.
For customer service issues, please email us at [email protected]
How to Opt-Out of Receiving Marketing Materials from Avis Cico
You can opt-out of our use and disclosure of your PII for marketing purposes and customer satisfaction surveys, and/or withdraw your prior consent for same, by the methods provided below. Upon requesting an opt out, your consent will be withdrawn, however, please note that it often takes some time to process these requests. Therefore, it is possible that you may receive promotions scheduled prior to our receipt of your withdrawal of consent.
To opt-out of Email Campaigns: You may reply to a promotional or marketing e-mail that you have received from us with the word “Unsubscribe” in the subject line or you can email us directly at [email protected] (If you use more than one e-mail address, then send your opt-out e-mail from each of your e-mail addresses.)
To opt-out of any other promotional mailings from Avis Cico and our partners: you may write to us at:
Avis / Cico Rent A Car System Limited.
PO Box 10400
Grand Cayman KY1-1004, Cayman Islands
ATTN: Privacy Officer
For customer service issues, please email us at [email protected]
We may also provide additional methods for you to opt-out of having your PII used or disclosed for promotional and marketing purposes, such as by clicking on a checkbox located on the page of our Websites on which your PII is collected, or otherwise made available when you make reservations.
Please note that your option not to receive promotional and marketing material: (a) will not preclude us from corresponding with you, by e-mail or otherwise, regarding your preexisting business relationship with us (e.g., your account status and activity or our responses to questions or inquiries you pose to us, or confirmations for existing reservations); (b) will not preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your PII for our internal business purposes; and (c) will not preclude us from disclosing your PII as described in this Privacy Notice for purposes other than sending you promotional and marketing materials.
Our Websites are not directed to children under the age of 13. If you are under the age of 13, then please stop using our Websites or our products and services and do not provide us with PII of any kind whatsoever.
It is our policy not to knowingly solicit children under the age of 13 for PII or otherwise contact children for any purpose. Further, it is Avis Cico’s policy to not knowingly allow children under the age of 13 to use our Websites or our products and services. It is our policy to not knowingly exchange with any third party the PII of children under the age of 13.
We encourage parents and guardians to take an active role in monitoring their children’s use of the Internet. It is possible that by fraud or deception, we may receive the PII of children under the age of 13. If we are notified or otherwise become aware of this, we will immediately delete the PII from our servers. If you want to notify us of our receipt of PII by children under the age of 13, please contact our privacy officer at [email protected]
Applicable Law and Jurisdiction
This Privacy Notice will be governed by the laws of the Cayman Islands, without regard to its conflict of law principals. By providing any PII to us, you fully understand and unambiguously consent to the transfer of such PII to, and the collection and processing of such PII in, the Cayman Islands and other countries or territories. You agree that any cause of action that may arise under this Privacy Notice will be commenced and be heard in the appropriate court in Grand Cayman, Cayman Islands. You agree to submit to the personal and exclusive jurisdiction and exclusive venue of the courts located within Grand Cayman in the Cayman Islands.
Changes to this Privacy Notice
This Privacy Notice applies to all information we collect or receive, on or after the effective date of this Privacy Notice, from individuals who provide us with such information for the purpose of obtaining products and services from Avis Cico or using our Websites.
We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Notice. If we materially change the way your personal information will be used, we notify you by way of either prominent posting on our Website(s), e-mail and/or mail. We encourage you to periodically review this Privacy Notice in order to keep apprised of any changes.