Privacy Notice

Notice Last Updated: October 2018

Welcome to the Privacy Notice of Apex Car Rentals Australia and Apex Car Rentals New Zealand, companies within the Avis Budget Group, Inc. (we refer to these companies as “Apex”, "we," "us," or "our" in this Privacy Notice). A full list of these companies and contact details is included below: see Data Controllers and Contact Details by Country.

Please take the time to read this Privacy Notice as it is important for you to know how we collect and use your personal information. By "personal information" we mean all information that relates to a living individual and either identifies, or may be used to identify, that individual.

The nature of our business and our services to you may require us to share information with our independent licensees. This Privacy Notice does apply to those Apex locations that are owned and operated by an independent licensee not owned nor controlled by Apex or any Apex affiliate or subsidiary except where independent licensees use separate third parties from time to time. If you have any questions or concerns regarding the use of your personal information by any independent location, please contact us at [email protected]

We may change portions of this Privacy Notice from time to time, so be sure to check back. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how we use your personal information, we will notify you by way of a prominent posting on our websites, e-mail and/or postal mail prior to the change becoming effective.Please select any of the following hyperlinks to learn about the ways we collect, use, share and disclose personal information:

Getting Started

Apex wants you to feel comfortable about giving us access to your personal information. Use this Privacy Notice to find out what happens to your personal information when you interact with Apex and what choices you have.

This Privacy Notice does apply to our independent licensee locations. Please review the privacy notices of our independent licensees for information on how they use personal information that you provide to them.

This Privacy Notice covers the personal information the Apex companies collect, use and disclose through your use of our products and services either online or offline.

Apex needs to collect personal information from you to rent a vehicle or provide our other services. We collect personal information when you give it to us, such as by telephone, fax, postal mail, email, at the counter, upon completion of an application or enrollment form or through your use of one of Apex's website or mobile Apps or the use of our products and services.

Please be aware that, in certain circumstances, where you do not provide personal information which is required by us, we will not be able to provide the products and services under our contract with you or may not be able to comply with a legal obligation on us. For example, when renting a vehicle with us we will require information such as your name, address, payment information and driver's licence. If you fail to provide this information to us we will be unable to rent a vehicle to you. You will be made aware if this situation arises and what the consequences of not providing the personal information will be.

Sometimes, we will combine the personal information we receive from you with other information we received from other sources so we can provide you a more customised and hassle-free experience. This information may include your name, contact information, travel itinerary, booking request and other information that is relevant to your booking. These third parties include:

  • Travel agents or a third-party booking service that you used to make your reservation;
  • Your employer or association if you are using a corporate / association account;
  • Our licensees and our affiliates, in order to create a Respex account or if you are making a booking in one location served by our affiliates or licensees for rental services in another location served by us; and
  • Police and other law enforcement agencies if you are involved in an accident during your rental, or suffer any loss, damage or theft of the vehicle, or if you incur any speeding, parking, toll or other traffic-related fines or commit any traffic offences during your rental.

The purposes for which we use this information is set out in further detail in the rest of this Privacy Notice. There are a number of bases in data protection law that permit Us to use your personal information for these purposes. These are: (1) that you have provided your consent to us using your personal information for that purpose (e.g. where you have given us your consent to send you electronic marketing); (2) that we need to use that personal information in order to fulfil our contract to provide products or services to you (e.g. using your information for vehicle rentals or join our frequent renter programme; (3) that the processing is necessary for the purposes of our legitimate interests, provided we have balanced these against your rights and interests; and (4) where we need to comply with a legal obligation (e.g. responding to government or law enforcement information requests).

These legitimate interests are: (a) to ensure effective administration and management of your relationship with us, including any rentals with us; (b) to understand how our customers use our services and to manage our vehicle fleet; (c) to carry out research and analysis on what services or products our customers want or how they would like us to improve our services and products; (d) to understand how our customers use our websites and Apps and identify any issues in how the websites and Apps are used and how we can improve the customers usage experience; (e) to tell our customers about the various products and services we can offer; (f) understand and respond to customer feedback; (g) to better tailor and personalise the promotions and benefits that we offer to our customers; (h) to prevent, detect, or investigate unauthorised use of our vehicles and systems and ensure we comply with law and our policies; and (i) manage any disputes and accidents and take legal or other professional advice.

We will collect technical information about your devices when you use our website and App where permitted. To learn about our online data collection, go to the Online Data section.

^ 返回顶部

Renting a Vehicle

When you make a reservation, rent a vehicle or join one of our programs such as a corporate programme or our preferred renter programme, we collect information to provide you with our great services (for example, renting a vehicle, including performing the vehicle rental contract as set out in our General Conditions of Rental, Location Specific Conditions and Rental Agreement, providing any requested optional extras, taking payment, pre-authorisations and security deposits and providing discounts and offers or other benefits) and for our legitimate business interests (for example research and development of new products and services, undertaking fraud and security checks and enforcing our legal rights). The information we collect includes:

  • name;
  • email address (if you are booking online or wish to receive e-receipts);
  • home address (for licence validation and billing);
  • employer details and business address (if you are a member of a corporate program);
  • telephone numbers at which we can reach you;
  • date of birth (for licence validation and legal requirements);
  • gender (for licence validation);
  • payment information such as your credit or debit card details (security code is obtained for transaction only – we do not keep it);
  • tax number (if specifically requested);
  • information from driver's licence and/or other government issued identification, including if you are an additional driver for the specific rental (for licence validation and legal requirements);
  • information from another form of identification documentation such as passport or national identity card if your driver's licence does not include a photo, is not in English or is not recognisable as you and/or proof of address such as a utility bill (for security and anti-fraud purposes). The information we collect and retain will only include your photo ID where you are informed of this;
  • special discount codes, partner member numbers, association memberships, corporate rewards programs (if you request discounts, special privileges and loyalty programs);
  • special requests and preferences, including:
    • your preferences regarding optional extras such as damage waivers and other protections;
    • where a delivery or collection service is available, the address where we will drop off or pick-up the vehicle and any optional extras you requested; and
  • other information that may be required to rent you a vehicle and/or provide you with services.

Some vehicles come equipped with a global positioning system (GPS) or similar type tracking device that may also collect information about the vehicle. To learn about vehicle data we collect, scroll down to read about Vehicle Data.

If you have an accident, or suffer any loss, theft or damage to the vehicle during your rental or suffer any mechanical failure, we will collect information regarding such incident including your report of the incident and any police or other third party report including details of those involved, together with the nature of any personal injuries and/or damage to the vehicle and optional extras. We will use this information to perform our contract with you (for example, the vehicle rental agreement and/or the terms of any optional extra like insurance); for our legitimate business interests (for example, in recovering the costs of any loss or damage caused to the vehicle); for complying with any legal obligation on us (for example, making any required notification of the incident to appropriate authorities); and establishing, exercising or defending legal claims arising as a result of such incident.

During your rental we will collect where and when you rented the vehicle, where and when you returned the vehicle, insurance preferences, fuel consumption, mileage, accident history and other information related to the vehicle and your use of it. This information is required in order to provide you with the services you requested under the rental contract or for our legitimate business interests (for example to monitor the usage of our vehicle fleet).

In addition to the purposes listed above, we use this information to better understand our customers and provide you with relevant offers.

We will also collect information about any speeding, parking, toll or other traffic-related fines that you incur or any traffic offences that you commit during your rental where these are provided to us by any law enforcement agency. We will use this information to deal with such fine or offence in accordance with the terms of your vehicle rental agreement with us.

Where you inform us that you have a medical disability that requires an adapted vehicle or other driver aid we will use that information in order to provide you with the service you requested and where you have given your explicit consent to us using that information.

When you call us (from any phone), we may record or monitor the call for quality control, training or similar purposes.

When you purchase a gift certificate or voucher, we collect the name and mailing address of the gift recipient in order to fulfill your order. We will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact our customer service at the details set out in the Data Controllers and Contact Details by Country section below.

^ 返回顶部

Vehicle Data

^ 返回顶部

Photos & Video

^ 返回顶部

Online Data

^ 返回顶部

Online Advertising

^ 返回顶部

Information Sharing

Third party recipient Purpose of disclosure Legal Basis for Processing
Independent licensees / franchisees and network providers in order to perform our contract with you and to understand how you use our services and to improve our business
  • Make and confirm your rental reservation;
  • Provide our rewards program and update partner points and rewards;
  • Connect with your corporate and commercial accounts;
  • Assist with navigation assistance or itinerary planning;
  • Provide customer assistance;
  • Resolve toll, traffic or parking violations;
  • Processing any claims relating to accidents and/or injuries;
  • Providing roadside assistance services;
  • To protect or defend the rights or well-being of us, our employees, customers or others;
  • Verify safe driver criteria for qualified drivers.
  • Performance of Contract;
  • Legitimate Interests;
  • Legal obligation;
  • Consent; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Travel agents in order to perform our contract with you when you use a travel agent and to understand how you use our services and to improve our business
  • Make and confirm your rental reservation;
  • Process payments and refunds;
  • Assist with navigation assistance or itinerary planning;
  • Provide customer assistance;
  • Providing roadside assistance services;
  • To protect or defend the rights or well-being of us, our employees, customers or others.
  • Performance of Contract;
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Your employer or organisation in order to provide you with benefits of a corporate or association program and to understand how you use our services and to improve our business
  • Verify driver licences or other government identification.
  • Verify eligibility to use designated account and discount codes;
  • Connect with your corporate and commercial accounts.
  • Performance of Contract;
  • Legitimate interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Brokers in order to perform our contract with you when you book a rental through their service and to protect our business from fraud and bad debts
  • Make and confirm your rental reservation;
  • Process payments and refunds;
  • Provide customer assistance;
  • Handle debt collection;
  • Fraud check.
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Booking engines in order to perform our contract with you when you use a booking engine and to understand how you use our services and to improve our business
  • Make and confirm your rental reservation.
  • Verify eligibility to use designated account and discount codes;
  • Process payments and refunds;
  • To protect or defend the rights or well-being of us, our employees, customers or others.
  • Performance of Contract;
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Credit card issuers in order to obtain payment from you
  • Process payments and refunds;
  • Fraud check;
  • Handle debt collection.
  • Performance of Contract;
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Corporate account manager in order to provide you with benefits of a corporate or association program and to understand how you use our services and to improve our business If you are renting with a corporate, membership or other similar commercial entity account, we may share personal information with the organisation that manages the account for their own purposes. We recommend you review their privacy policy to learn more about their privacy practices.
  • Performance of Contract;
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Marketing agent in order to provide you with benefits of a corporate or association program and to understand how you use our services and to improve our business
  • Provide our rewards program and update partner points and rewards;
  • To protect or defend the rights or well-being of us, our employees, customers or others.
  • Performance of Contract;
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
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 the website
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Government, regulatory and law enforcement agencies in order to meet our legal obligations
  • To verify your driver's licence and ensure you meet our safe driver criteria;
  • As requested by these agencies if the disclosure is required or permitted by law;
  • To take action regarding illegal activities, traffic offences 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;
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Insurance companies and claims handlers in respect of any insurance product you purchase in connection with your rental
  • Provide and service the insurance product you have requested;
  • Manage any claims that may be made under the relevant insurance policy
  • Performance of Contract;
  • Legitimate Interests; or
  • Apex may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.

We may also transfer or assign your personal information to third parties as a result of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganisation, or liquidation. Or if we are involved in defending a legal claim, information about you that is relevant to such claim may be disclosed to third parties as a result of, or in connection with, associated legal proceedings.

We may, in accordance with the Marketing section, share your information with business and promotional partners (where you have provided your consent to such information sharing) in order to send you information about products and services you may like. If you decide you no longer want to receive such promotional and marketing messages, please read the Your Choices section to find out how you can opt-out.

^ 返回顶部

Your Choices

If you want to opt out of receiving promotional and marketing emails, text messages, post and other forms of communications from Apex or our promotional partners in relation to which you might receive in accordance with the Marketing section, you can best opt out by using one of the following ways:

If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you after you rent from us, reservation confirmations or respond to your inquiries or complaints, and similar communications.

Want to close your account, stop doing business with Apex, or otherwise opt out of Apex collecting, using or disclosing your personal information? We will be sorry to see you go. Please contact our customer service representatives in accordance with the Data Controllers and Contact Details by Country section.

Please also see your rights set out in Your Privacy Rights section.

^ 返回顶部

Safeguards

^ 返回顶部

Information Retention

Apex keeps your personal information for no longer than is reasonably necessary or required by law. How long we keep it depends very much on the type of information and purpose.

The criteria we use to determine the retention period for certain categories of data is as follows:

  • the length of time that you are a member of our frequent renter programme or any other loyalty scheme that we operate or a member of any corporate programme;
  • how frequently you rent with us or when you most recent rental occurred;
  • whether there are contractual or legal obligations that exist that require us to retain the data for period of time;
  • whether there is any ongoing legal claim that relates to any rental you have made with us, or that is otherwise related to your relationship with us;
  • whether any applicable law, statute, or regulation allows for a specific retention period;
  • whether the personal information is considered to be a special category of personal information, in which case a shorter retention period generally would be applied; and
  • what the expectation for retention was at the time the data was provided to us.
^ 返回顶部

International Transfers

Rentals

As we offer the ability to rent vehicles and benefit from our services in many locations globally, we will transfer your personal information to our affiliates, independent licensees and travel agents in these locations for the purposes of fulfilling your rental request and/or entering into a rental agreement. The exact location of where your personal information will be transferred depends on the location of your rental. A list of these locations on our website at:

Many of the countries to which your personal information may be transferred for these purposes that are located outside Australia or New Zealand do not benefit from an adequacy decision issued by the EU Commission regarding protection afforded to personal information in that country. Details of these specific countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

These transfers are made either as they are necessary for the performance of a contract to which you will be a party, or for pre-contractual measures. Alternatively, adequacy of data protection is ensured by standard data protection clauses that we have in place with the relevant recipient. A copy of these standard data protection clauses may be requested via our Data Protection Officer at the address set out in the Data Controllers and Contact Details.

Business operations

In addition, the information we collect from you may be transferred to, and stored by, IT vendors who operate on our behalf. In particular, these include our booking engine hosting provider that is located in Australia. 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 Australia.

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 set out in the Data Controllers and Contact Details.

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 Australia or New Zealand for these purposes are primarily made to the United States, although transfers may be made to other countries as well. 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 set out in the Data Controllers and Contact Details.

^ 返回顶部

Your Privacy Rights

You may have – in accordance with applicable 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 to withdraw consent – 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 complain:

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Notice, please contact our Data Protection Officer in any of the ways set out in the Data Controllers and Contact Details by Country section and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

WE WILL NOTIFY YOU OF THE OUTCOME OF OUR INVESTIGATION.

^ 返回顶部

Data Controllers and Contact Details by Country

^ 返回顶部

Independent Locations

^ 返回顶部

Key Contacts