Our Privacy Policy

Preamble

The General Data Protection Regulation (GDPR) came into force on May 25, 2018 and completes the legislation on personal data protection.

For your information, a personal data corresponds to any information relating to a natural person who is identified or who can be identified, directly or indirectly, by reference to an identification number or to one or more elements that are specific to him or her (surname, first name, address, email, telephone, contract number, credit card number, ...). The processing of personal data refers to any operation on this type of data (collection, storage, transmission, deletion, etc.), whether on paper or by computer. The data controller is the person who determines the purposes of each processing operation and the means of achieving these purposes.

For SOCIETE NOUVELLE DE LOCATION, the protection of your data is a priority.

Therefore, in the interests of transparency, this Privacy Policy aims to explain to you why your personal data is collected and processed by SOCIETE NOUVELLE DE LOCATION, in its capacity as data controller, how it is processed, what rights you have in respect of your data and how you can exercise them.

SOCIETE NOUVELLE DE LOCATION reserves the right to modify this Privacy Policy at any time. Any changes will take effect immediately.

Therefore, we invite you to regularly consult our Policy, accessible from all pages of the Site, in order to keep informed of the latest applicable online version. For changes that we deem significant, a notice will be posted on the Site.

We also encourage you to check the date on this Policy to see when it was last updated.

1. Why does NEW RENTAL COMPANY need to collect your data ?

The data that NEW RENTAL COMPANY collects is necessary to enable it to meet the following purposes :

• Responding to requests received via the online contact form

• Management of contracts (management of vehicle reservations, invoices and payments)  Conducting customer satisfaction surveys and studies including surveys, rental statistics Claims management

• Carrying out commercial prospecting and marketing actions (sending advertising messages by email and sms)

• Selection of suppliers

• Claims management

• Management of traffic violations and other violations of the penal code

In general, SOCIETE NOUVELLE DE LOCATION does not process any of your data for purposes incompatible with those for which it was collected, unless you give your prior consent.

2. What data does SOCIETE NOUVELLE DE LOCATION collect ?

The SOCIETE NOUVELLE DE LOCATION Company collects different types of personal data about you :

▪ Personal data that you provide to us directly:        ▪ When you fill out a contact form,        ▪ When you fill out a reservation request,        ▪ When you wish to subscribe to a rental contract,         ▪ When you contact customer service to ask a question, make a claim,        ▪ In general, when you interact with the SOCIETE NOUVELLE DE LOCATION Company in any other way.

The communication of your personal data is voluntary. However, certain information, identified by an asterisk, is essential for SOCIETE NOUVELLE DE LOCATION to process your request. Without this information, SOCIETE NOUVELLE DE LOCATION will not be able to process your request.

▪ The personal data that is communicated to us  In the context of business partners:        ▪ Tour operators (turnkey travel organizer)        ▪ Brokers (Comparison websites)        ▪ Insurer (insurance companies)        ▪ Hotel partners (Hotel, Gite...)        ▪ Automobile franchises with which we have partnerships.  ▪ Personal data we collect automatically

We automatically collect certain information about you when you access the SOCIETE NOUVELLE DE LOCATION website, in particular, information about your navigation. NEW RENTAL COMPANY uses cookies and other tracking technologies to collect information about you when you interact with the NEW RENTAL COMPANY Website.

To learn more about cookies and how to disable them, please see the Cookies Policy.

3. What is the legal basis for processing your data ?

SOCIETE NOUVELLE DE LOCATION collects your personal data for the purposes described in point 1 of this Policy. In all cases, SOCIETE NOUVELLE DE LOCATION collects your data only when there is a legal basis for its collection and processing.

The performance of contractual relations with SOCIETE NOUVELLE DE LOCATION  Your data is necessary for the execution of the contract to which you have subscribed or wish to subscribe. On this contractual legal basis, any refusal to communicate your personal data will prevent the conclusion and execution of the contract.

Compliance with a legal obligation to which SOCIETE NOUVELLE DE LOCATION is subject Some of your data is processed by SOCIETE NOUVELLE DE LOCATION to meet its legal obligations, in particular         - To meet its legal obligations, in particular the applicable accounting rules, with regard to the management of customer accounts but also supplier accounts,         - The designation of natural persons who commit offences while driving the rental vehicles (Art L.121-6 of the Highway Code).         - The declaration of automobile claims.         - Manage requests for access, rectification and opposition rights,         - Manage an opposition list to telephone canvassing,

Your consent

Subject to having obtained your prior consent, SOCIETE NOUVELLE DE LOCATION may process your data to:          ▪ Send you commercial offers on its products and services,          ▪ Provide you with offers from its partners,          ▪ Deposit cookies under the conditions described in the Cookies Policy.

At any time, you may go back on your choice and withdraw your consent, according to the terms described in section 5.2 of this Policy, without, however, calling into question the legality of the processing based on the consent and implemented before the withdrawal.  The legitimate interests of SOCIETE NOUVELLE DE LOCATION

SOCIETE NOUVELLE DE LOCATION may process your personal data for the purpose of pursuing its legitimate interest in particular, for the management of commercial relations.         ▪ To respond to your requests sent via the online form.         ▪ To select its suppliers

4. How long will your data be kept ?

Your data is kept by SOCIETE NOUVELLE DE LOCATION for the time necessary to achieve the purposes referred to in point 1 hereof, plus the legal limitation periods.

With regard to cookies.

SOCIETE NOUVELLE DE LOCATION may keep the data for 13 months.

For commercial management and commercial prospecting.

The company SOCIETE NOUVELLE DE LOCATION may keep the data for 3 years from the last contact with the company SOCIETE NOUVELLE DE LOCATION and you.  (Simplified standard n°48)

With regard to the conservation of banking data

SOCIETE NOUVELLE DE LOCATION may keep bank details for a maximum of 13 months after the end of the contract, in an intermediate archive, for evidence purposes. The data may only be used in the event of a dispute over the transaction.

In terms of carrying out customer satisfaction surveys and studies including polls, rental statistics

SOCIETE NOUVELLE DE LOCATION may keep the data for 2 years in order to monitor the evolution of indicators.

With regard to the management of fines

SOCIETE NOUVELLE DE LOCATION may keep the data for a maximum of 45 days from the date of receipt of the notice of violation. At the end of this period, the data may be archived for a maximum of twelve months, which is the period of limitation for fines.

In terms of invoicing.

SOCIETE NOUVELLE DE LOCATION may keep the data for 10 years (Art L123-22 paragraph 2 of the C.COM. Simplified standard n°48)

For accounting purposes.

The Société SOCIETE NOUVELLE DE LOCATION may keep the data for 10 years (Art L123-22 paragraph 2 of the C.COM. Simplified standard n°48) For more information on the duration of the conservation of your data, you can contact the DPO of SOCIETE NOUVELLE DE LOCATION: dpo@gbh.fr.

5. What are your rights and how to exercise them ?

5.1. Your rights regarding your data

Right of access to your data

You may obtain from SOCIETE NOUVELLE DE LOCATION confirmation as to whether or not your data is being processed and, where it is, access to all data and information held by SOCIETE NOUVELLE DE LOCATION.

Right to rectify your data

You may obtain from SOCIETE NOUVELLE DE LOCATION, as soon as possible, the rectification of any data concerning you that is inaccurate or erroneous. You may also request that your data be completed, if necessary.

Right to the deletion of your data

With the exception of legal exceptions, you may request that SOCIETE NOUVELLE DE LOCATION delete your data as soon as possible if, in particular, you consider that the processing carried out by SOCIETE NOUVELLE DE LOCATION on your data is no longer necessary with regard to the purposes for which it was collected.

Right to the portability of your data

You have the possibility of recovering part of your data in an open and machine-readable format or of asking the Société SOCIETE NOUVELLE DE LOCATION to transmit them to another organization. This right applies only to data that you have actively and knowingly provided to NEW RENTAL COMPANY (for example, data that you have entered in an online form) or data that is generated when using a service or device in the context of concluding or managing your contract, and that is processed in an automated manner, based on consent or the execution of a contract.

Right to object

If your data is processed for canvassing purposes, you may object to this at any time (see point 5.2 of this Policy). Similarly, you may object to the distribution of targeted advertising (cookies).

Right to limit the processing of your data

You may request that SOCIETE NOUVELLE DE LOCATION retain your data without being able to use it, in any of the following cases:      ▪ You object to the accuracy of the data used by SOCIETE NOUVELLE DE LOCATION,       ▪ You object to your data being processed,      ▪ In case of unlawful use but you object to their deletion,       ▪ You need it for the establishment, exercise or defense of legal claims. Right to withdraw your consent to the processing of your data  When the processing of your personal data is based on your consent (sending our electronic commercial offers, for example), you have the possibility to withdraw, at any time, your consent (See point 5.2 of this Policy).  Similarly, to withdraw your consent to cookies, you may do so in the manner set forth in the Cookies Policy.

Right to give post-mortem instructions

You have the ability to set up instructions regarding the retention, deletion and disclosure of your data after your death. These instructions define how you wish to exercise your rights to your data after your death. You can send us these instructions by sending a letter with the subject line "Post-Mortem Instructions" to dpo@gbh.fr. You can change or revoke your instructions at any time.

Right to file a complaint with the CNIL

If you consider that your rights are not respected or that the protection of your data is not ensured in accordance with the RGPD, you may, at any time, lodge a complaint with a competent supervisory authority (in France, the CNIL), directly on the CNIL website or by post at : CNIL - 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

5.2. Exercising your rights

To exercise one of your rights, send your request to: dpo@gbh.fr or SOCIETE NOUVELLE DE LOCATION ZONE DES LOUEURS- AEROPORT POLE CARAIBE 97139 LES ABYMES specifying "For the attention of the DPO.

All requests must specify, in the subject line, the reason for the request (exercise of the right of access, opposition, ...) and the company concerned by the request. The request must also be accompanied by a copy of both sides of a valid identity document bearing the applicant's signature and specify the address to which the reply should be sent.

SOCIETE NOUVELLE DE LOCATION will send you its reply within a maximum of one (1) month from the date of receipt of your request. However, this period may be extended by two (2) months due to the complexity and number of requests.

If, after contacting SOCIETE NOUVELLE DE LOCATION, you feel that your rights with regard to information technology and civil liberties have not been respected, you may submit a complaint to the CNIL.

Prospecting and targeted advertising

Once you have agreed to receive commercial offers from SOCIETE NOUVELLE DE LOCATION, you may, at any time, reverse your choice by clicking on the unsubscribe link.  In general, for any question relating to this data protection policy or for any request relating to the management of your personal data by SOCIETE NOUVELLE DE LOCATION, you can send your request by email or by post, as indicated above.

6. With whom does SOCIETE NOUVELLE DE LOCATION share your data ?

SOCIETE NOUVELLE DE LOCATION may also transmit your data to the following entities when this is necessary to meet one of the purposes referred to in point 1 of this document: In terms of managing commercial activities, your data may be transmitted:      - To authorized personnel of SOCIETE NOUVELLE DE LOCATION (sales, accounting and management departments)     - To the services responsible for control (auditor, services responsible for internal procedures). For the management of commercial prospecting actions, your data is communicated to communication service providers operating on behalf of SOCIETE NOUVELLE DE LOCATION.

As regards the management of commercial prospecting actions, your data is communicated to communication service providers operating on behalf of SOCIETE NOUVELLE DE LOCATION.

As regards the management of insurance and claims, your data may be transmitted to the insurance companies (or "the Insurers").

As regards the collection and management of fines, your data is transmitted to the Agence Nationale de Traitement Automatisé des infractions (ANTAI).

In the case of criminal offences, the SOCIETE NOUVELLE DE LOCATION may transmit your information to the competent services.

In general, your personal data may be accessible to the subcontractors of the SOCIETE NOUVELLE DE LOCATION in the context of outsourced services (e.g. IT service provider, software publishers, etc.).

The SOCIETE NOUVELLE DE LOCATION does not share your data with these commercial partners.

7. Is your data transferred outside the EU ?

Your data is hosted on secure servers located in France.  If your data is transferred outside the EU, in particular via our subcontractors, we take particular care to ensure that they process your data in strict compliance with the regulations in force on the protection of personal data.

8. How does SOCIETE NOUVELLE DE LOCATION secure the processing of your data ?

SOCIETE NOUVELLE DE LOCATION implements all technical, physical and organizational measures to ensure the security and confidentiality of your data during collection, processing and transfer.

The infrastructures of SOCIETE NOUVELLE DE LOCATION are protected against malicious software (viruses, spyware, etc.); the security of your terminal is your responsibility.  In the event that we are likely to call upon service providers to process part of your data, we undertake to check that they present sufficient guarantees to ensure the protection of the personal data entrusted to them and to have them sign confidentiality clauses in accordance with Article 28 of the RGPD.

In the event of a personal data breach, i.e. a security incident, whether malicious or not and whether intentional or unintentional, that results in the integrity, confidentiality or availability of your personal data being compromised, we undertake to comply with the following obligations:

The "Violation Log" contains the following:      - The nature of the violation;      - The categories and approximate number of individuals affected;      - The categories and approximate number of files involved;      - The likely consequences of the breach;      - The measures taken to remedy the breach and, where appropriate, to limit the negative consequences of the breach;      - Where applicable, the justification for not notifying the CNIL or informing the persons concerned.  However, and in accordance with the regulations in force, we are not obliged to inform you of a breach in the following cases:      - Your personal data is protected by measures that make it incomprehensible to anyone who is not authorized to access it;      - Measures have been taken so that the risk is no longer likely to occur;      - This communication requires disproportionate efforts on our part, especially since we have no means of contacting you to inform you of this.

9. Required fields

The fields marked with an asterisk in our forms are mandatory. The consequences in case of failure to answer are only that your request will not be taken into account. The obligation to provide the requested data is contractual, as it is necessary for the execution of the contract to which you are a party or for pre-contractual measures carried out at your request, in particular in the event of a request for information or a quote concerning our products and services.

10. Cookies Policy

See document Model MDS Cookies Policy (INT04_ Cookies Policy_SNL EUROPCAR-v20190702-261119)

11. Privacy by Design/by Default

We are committed to integrating the protection of personal data into the design of a project, service or any other tool related to the handling of personal data, including the minimization of personal data, the limitation of the purposes of data collection, the respect of data integrity and confidentiality, and the limitation of retention periods.

12.  Accountability

In order to respect the principle of Accountability, our company :       - Adopts internal procedures in order to ensure compliance with the regulation (IT charter, personal data protection charter);       - Keeps a documentary trace of all processing carried out under its responsibility or that of the subcontractor (keeping of the register of processing, confidentiality agreements of employees and service providers, company security policy, procedures for managing requests for access, rectification, opposition...);       - Carry out impact analyses (PIA) for processing operations presenting particular risks with regard to rights and freedoms. The objective is to provide a rich documentation allowing to demonstrate at any time the respect of the rules relative to the data protection.