We have created this privacy statement in order to demonstrate our firm commitment to privacy. The following discloses our information gathering and dissemination practices for this website. If you see an undefined term in this privacy statement (such as Members, Owner, Renter, Insurer, Booking, Site, Services), it has the same definition as in our Terms & Conditions.
For the purposes of the Data Protection Act 1998, and from 25th May 2018, the General Data Protection Regulation and any legislation designed to implement or replace it, the controller for personal data provided through the website is Lowcost Vehicle Rental (UK) Limited (trading as easyCar). Once you are a member or an applicant for club membership, you may provide information directly to our insurance provider and the controller for such data will be EUI Limited (part of the Admiral Group plc). More information about the use of Members' information is set out below and in the terms and conditions of membership available on this website.
1. Information we collect
The principal purposes for which we collect and store your personal and financial information are to process and assist with your membership application, allow you to list your vehicle, allow you to reserve, book and collect a vehicle, authorise and collect payment, bill you or pay you, respond to your inquiries, improve our products and services and maintain your account with us.
There are three general categories of information we collect.
- Information you give to us
- Necessary for use of the easyCar Club platform - this information is necessary for performance of contract between you and us and allow us to comply with our legal obligations with respect to providing you with our Services:
- Account and identity verification information: when you sign up to be a Member of easyCar Club, we require certain information such as name, email address, date of birth, contact details and details of your car (for car Owners). We may collect proof of identity such as your selfie and images of your photocard driving licence and passport.
- Profile, listing and search information: vehicle information, availability and rental details to facilitate set up of your car listing (for car Owners) and search and book functionality (for Renters).
- Financial information: such as payment card information or bank account details to facilitate processing of payments.
- Communication with easyCar Club and other Members.
- Additional information you choose to provide to us including optional profile information (such as a profile photo and description), access to address book contact information (to invite contacts to join easyCar Club) and other information you choose to provide to us from time-to-time (such as responses to surveys and community forums).
- Necessary for use of the easyCar Club platform - this information is necessary for performance of contract between you and us and allow us to comply with our legal obligations with respect to providing you with our Services:
- Information we automatically collect from your use of the platform
When you use our Site, we automatically collect information about the services you use and how you use them. This information is necessary to enable us to comply with legal obligations, where applicable, and given our legitimate interest in being able to provide and improve functionalities on the Site:
- Usage: we collect information about your interactions with the Site such as pages or content you view, searches, bookings you have made and other actions on the platform.
- Log data: we automatically collect log and device data when you access the Site, such as access dates and times, geolocation data, hardware and software information and IP address. This is captured even if you have not created an account or are not logged in.
- Information we collect from third parties
We may collect information that other Members provide about you and obtain information from other sources which we combine with information collected via the Site. We do not control or supervise how third parties providing your information process your personal data, and any information request about the disclosure of such data should be directed to the relevant third party.
- Verification services: we may receive additional information about you, such as your driving and claims history and the outcome of address, insurance database and identity checks.
- Third party registration: If you connect or authorise login to your easyCar Club account with a third party service (e.g. Facebook or Google), the third party service may send us information such as your registration and profile information from that service.
- Reviews: We collect and publish peer reviews on your user profile page. For more information, please see our Owner or Renter FAQ on Reviews.
2. How we use information we collect
- Facilitate peer-to-peer transactions
To help facilitate bookings or other interactions between Members, we may need to share certain information, including personal information, with other Members, as it is necessary for the adequate performance of contract between you and us and given the legitimate interest in facilitating the peer-to-peer car hire transactions.
- Public profile: the Site lets you publish information that is visible to the general public. This includes information relevant to other Members looking to transact on the Site, such as your profile photo, name, gender, age band, profile description and for car Owners, details of the car including its availability for hire and pick-up location.
- Booking information: when a booking request is confirmed, certain information is shared with the other Member to coordinate the booking, such as your full name, contact details, and for car Owners, the vehicle registration mark and car location details.
- Communication with other Members – the messaging platform on the site enables you to submit messages to other Members to discuss your booking requirements and organise your rental.
- Payments processing: financial information that is collected is used to transfer owner earnings and bill the user for products, services and associated charges and fees. We do not share your billing and pay out information with other Members.
- Provide customer services: for example, contacting you by email or by phone to assist with or administer your application, process your booking and to help improve our Services.
- Create and maintain a trusted and safer peer-to-peer environment
We process some information provided by you combined with information collected from third parties about you given our legitimate interest in protecting the easyCar Club platform, to build trust within our easyCar Club community and to comply with applicable laws. This can include reviewing your communications on the Site for fraud prevention, risk assessment, investigation and customer support purposes.
- Member verification: we undertake thorough checks on both Renter and Owner Members. This includes cross-referencing personal details that we receive through a number of public and commercial databases, including major insurance databases and the electoral roll and authenticating identification provided by you.
- Enable performance of contract: to enforce our Terms & Conditions and other Site policies, to assist in resolution of any Member disputes and enforce our agreements with third parties we may share your data with third parties.
- Disclosure of data for compliance with law: we may disclose your information, including personal information, to courts, the police or relevant authorities if we are required or permitted to do so by law or if such disclosure is reasonably necessary.
- Maintain Site security: we will monitor and review usage of the Site in a way which will enable us to identify individual users to detect and prevent fraud, spam, abuse, security incidents and other harmful activity.
- Reviews and ratings: after completing a booking, Members may write reviews and rate each other. Reviews will form part of your public profile page and may also be displayed elsewhere on the Site (such as landing pages).
In connection with the activities above, we may conduct profiling based on your interactions with the Site, your profile information, other content you submit to the Site and information obtained from third parties to assess whether the user poses a safety risk to the platform, other Members or third parties.
- Provide, personalise, measure and improve our advertising and marketing
We will process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to promote your listings and to offer you products or services that may be of interest. With your permission, we may also share this information with other companies within the easyGroup.
- Promoting your listings: Based on our legitimate interest to promote the easyCar Club platform, we may display parts of the Site (such as your listing page) on sites operated by our business partners using technologies such as widgets and APIs. If your listings are displayed on a partner's site, information from your public profile may also be displayed. Information you share publicly on the Site may be indexed through third party search engines. In some cases, we may be able to help opt-you out of this feature, this can be done by a written request to us. If you change your settings or your public-facing content, these search engines may not update their databases. We do not control the practices of third party search engines, and they may use caches containing your outdated information.
- Customer segmentation: we may conduct profiling on your characteristics and preferences based on the information you provide to us, your interactions with the Site and information obtained from third parties to personalise, measure and improve our advertising.
- Promotional activities: we may send you promotional messages, marketing and other information that may be of interest to you based on your preferences (including information about easyCar or companies within the easyGroup which we think may be of interest to you). We will only do this if we have a lawful basis, such as your consent or if, in the context of promotional emails from us, we have provided you with a valid opt-out option. From time-to-time, we may use your personal data to administer referral or loyalty programmes, surveys, contests or other promotional activities or events sponsored or managed by us or our third party partners. If you provide us with your contacts' information, we may process this information to facilitate your referral invitations, for fraud detection and prevention, and for any purpose you authorise at the time of collection.
- Improving our services
We process some information, including personal information, given our legitimate interest in improving the Site and our Members' experience with it (such as making suggestions to improve your listing or ranking search results), and where necessary, for the adequate performance of the contract with you. This includes performance analytics, research and conducting profiling based on your interactions with the Site including your search and booking history, your profile information and preferences and other content you submit to the Site. We will also send you service or support messages, updates, security alerts and account notifications.
We may also share aggregated information (information about users that we combine together so that it no longer identifies an individual user) and other anonymised information for industry and marketing analysis, demographic profiling, and other business purposes.
- Use of third party service providers
We use a variety of third party providers to help us provide Services related to the Site, in order to ensure the adequate performance of our contract with you and given our legitimate interest in providing our Services in the best possible way as set out in clauses 2(i)-2(iv) above.
For example, service providers help us (i) verify your identity or authenticate your identification documents, (ii) check information against commercially available databases, such as the electoral register and insurance databases, (iii) conduct fraud prevention and risk assessment, (iv) provide insurance and breakdown services, (v) perform product development, customer services, maintenance and debugging of the Site, (vi) allow provision of our Services through third party platforms and software tools (e.g. through integration with our APIs), (vii) provide payment services, or (viii) provide advertising.
Our payment services provider, Chase Payment Europe Ltd have some processing activities outside the European Economic Area (EEA), where data protection laws may not be as strict as in the EEA, but we remain responsible for their processing of the data, and ensure that safeguards are in place, such as approved Model Clauses or compliance with the EU-US Privacy Shield.
In addition to service providers who act as processors for easyCar Club, we will also supply information to a limited number of companies who are controllers of the data in their own right. This will primarily be EUI Ltd (part of the Admiral Group), our insurance provider, further details of which are set out in section 2(vi) below.
- Sharing with, and by, Insurers
We or our Insurer may pass information about club applicants and policyholders contained in the club, policy and supporting documentation to other companies within our respective groups, our associates delegates and agents or to other insurance companies for the purpose of providing the service (or insurance authorised representatives with whom the insurance provider reinsures their business or who are dealing with a claim made under the policy). These companies may include Insurance Database Services Limited in respect of the Claims and Underwriting Exchange, as well as other counter-fraud organisations and claims suppliers. These companies may be located in countries outside the UK but within the EEA.
3. Other important information
- IP Address
We use your IP address to help diagnose problems with our server, and to administer our Web site. Your IP address is also used to help identify you and to gather broad demographic information.
Like all sites, we sometimes put cookies on your computer to help us deliver you the best experience. By using this website, you are consenting to us doing so.
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into the member areas of our website. They do not gather information about you that could be used for marketing purposes or remembering where you've been on the Internet.
- Analytical/performance cookies. These allow us to collect information about how you use our website, such as, how you move around our website and if you experience any errors. These cookies do not collect any information that could identify you; all of the information collected is anonymous and is only used to help us improve the way our website works, understand what interests our users and measure how effective our advertising is.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences and improve your visit.
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. They are linked to services provided by third parties, such as "Like" and “Follow" buttons. The third party provides these services in return for recognising that you have visited our website.
Generally, cookies which are strictly necessary for the operation of the website will expire when you leave the website. Other cookies may be more permanent or not expire unless you actively delete them. All browsers provide tools that allow you to control how you handle cookies: accept, reject or delete them. These settings are normally accessed via the 'preferences' or 'options' menu of the browser you are using.
You can find out more about internet advertising by visiting the following websites: www.allaboutcookies.org, www.yourchoicesonline.eu, and www.networkadvertising.org. Some of these sites enable you to opt out of online behavioural advertising and other tracking cookies (in addition to the control settings on your browser).
- Third Party Advertising
We may use third party advertising companies to serve ads on our Site. These companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous.
We may also install telematics devices in some of the Vehicles available for rental in order to collect data for driver behaviour tracking and improving our services including to assist Members reach quicker resolution wherever possible in the event of a dispute. Where such a device is installed in a Vehicle the Renter will be notified before submitting a Booking Request.
- Links to other sites
This Site may contain links to other sites. We are not responsible for the privacy practices or the content of such web sites.
We take appropriate organisational and technical measures to protect your personal information that we hold. We limit access to your personal information to those who we believe reasonably need to come into contact with that information in order to carry out their jobs. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our service and any transmission is at your own risk.
- Retention of Data
We will retain your information for as long as is necessary to fulfill any of the Services we provide or to enable us to enforce our rights or bring or defend any actual or potential claims, comply with applicable legislation, regulatory requests and relevant orders from competent courts.
Please note that our Site will assume you agree to receive e-communications when you are making a booking, and to receive certain important product updates. You have the right to ask us not to send you direct marketing material, this can be done by a written request to us. On our e-communications you can also use the unsubscribe function to opt-out of future marketing e-communications. Once we have properly received your notification, we will take steps to cease using your information in this manner. Additional opt-out settings are available to Members through their member dashboard.
Please note that you cannot opt out of communications regarding Bookings and terms of service.
5. Your rights
You may exercise any of your rights as a data subject in accordance with UK data protection legislation including the right to access and rectify information held on you. Contact us at: firstname.lastname@example.org for details. Please note that we may ask you to verify your identity before taking further action on your request.
- Right to rectification: To change or modify information previously provided where it is inaccurate or out of date. Follow the login link to update your profile.
- Right of access: Your right of access can be exercised in accordance with UK data protection laws. Any access request that is manifestly unfounded, excessive or repetitive may be rejected or made subject to a reasonable fee to meet our costs in providing you with details of the information we hold about you.
- Right to data portability – you may request copies of personal information that you have provided to us in a structured, commonly-used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
- Right to erasure – we generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations or deal with potential claims (see section 3(vii) above). If you no longer want us to use your information for provision of our Services to you, you can request that we delete your personal information. Please note that we may need to retain some of your personal information as necessary to comply with our legal obligations (e.g. for tax, legal reporting and auditing purposes); for our legitimate business interests (such as fraud detection and prevention); and for enhancing safety (e.g. if we suspend an account for fraud or safety reasons, we may retain certain information to prevent the user from creating a duplicate account). Any information shared with others (such as peer reviews and ratings) may continue to be publicly visible on the Site, even after your account is deleted.
- Right to object to or restrict processing - in certain circumstances, you have the right to object to our processing of your personal information by contacting us. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to the use of your personal information for direct marketing purposes.
- Right to restrict processing - the right to restrict our processing to limited purposes in certain circumstances (e.g. whilst a challenge to the accuracy of the data is verified).
- Right to withdraw your consent - to the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by contacting us using the link in the 'Contacting the web site' section below.
We maintain backups of the Site and data contained therein to protect from accidental or malicious loss and destruction, so residual copies of your personal information may not be removed from our backup systems for a limited period of time.
If you are unhappy about our use of your personal information, you can contact us using the link in the 'Contacting the web site' section below. You are also entitled to lodge a complaint with the UK Information Commissioner's Office using any of the below contact methods:
Telephone: 0303 123 11113
Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with your local supervisory authority.
7. Contacting the web site
If you have any questions about this privacy statement, the practices of this Site, or your dealings with this Web site, please contact us using one of the methods set out here.