2.- WEBSITE LEGAL NOTICE

1.- LAW OF INFORMATION SOCIETY

In order to comply with the provisions contained in article 10 of Law 34/2002, dated 11 July, on services of the information society and electronic commerce, Auto Hugar, S.A. (hereinafter "KeyGo Rent") is the service provider and data controller, with its address at
C/ Fira de la Cerámica i Vidre 1 - Piso 1 46930 Quart de Poblet (Valencia), and with the NIF A96047014.

2.- PROCESSING OF PERSONAL DATA

Data protection information

a. - PROCESSING MANAGER

Identity: Auto Hugar, S.A.

Postal address: C/ Fira de la Cerámica i Vidre 1 - Piso 1 46930 Quart de Poblet (Valencia)

C.I.F.: A96047014

Telephone: +34965509966

            You are informed that for a greater guarantee in the fulfilment of the Data Protection a Delegate in Data Protection has been designated whose contact information is the following: Grupo Ugarte de Automoción, S.L., email protecciondedatos.keygorent@keygorent.com

b.- PURPOSES

In compliance with the provisions of the European Regulation 2016/679 General of Data Protection and in the Organic Law 3/2018, dated 5 December, on the Protection of Personal Data and the guarantee of digital rights, we inform you that, at KeyGo Rent, we may process the data provided to us for the following purposes:

1.- Your registration as a KeyGo Rent user for the creation of your keygorent.com account. This processing is necessary to identify you, prepare and facilitate your future rental contracts and/or reservations with KeyGo Rent and consequently, the legitimacy of the treatment is in the existing contractual relationship with the user.

2.- Manage your reservation and your vehicle rental contract and thus be able, among other things, confirm, guarantee, modify or cancel your reservation, exchange communications in relation to your reservation and/or rental, manage your invoices and, where appropriate, claim debts; manage possible claims, manage the recovery of possible damages to the vehicle of KeyGo Rent, manage your insurance, the return of items or objects that you may have forgotten in the vehicle and, where appropriate, communicate your personal data to the competent judges or authorities when they request them. With legitimacy of the processing being found in the existing contractual relationship with the customer.

3.- The improvement of KeyGo Rent products and services based on surveys that the customer may have completed, with the legitimacy of the processing being found in the “legitimate interest” of KeyGo Rent, in order to improve the experience of its products and services.

            4. If you consent, for it be used for promotional purposes, including the creation of individualised profiles, segmentations, the sending of personalised commercial information, information related to customer service; with the legitimacy in the processing in his case being found in consent.

            5.- The carrying out of commercial or advertising campaigns; customer satisfaction surveys and information by postal, telephone, email, SMS, or any equivalent electronic format, about products and services, with the legitimacy for processing being found in the "legitimate interest" of KeyGo Rent.

6.- The management of fines, and in particular to transfer to the competent authorities the identity of the driver (or possible driver) and, where appropriate, to comply with the procedure for collecting fines to which KeyGo Rent may be subject.

This processing is mandatory under Royal Legislative Decree 6/2015, dated 30 October, which approves the consolidated text of the Law on Traffic, Motor Vehicles and Road Safety. The legitimacy for this processing is based on the "legitimate interest" of KeyGo Rent.

7.- Geolocation of vehicles: KeyGo Rent may possibly access the geolocation data only in order to monitor the condition of the vehicle and prevent fraud and theft. The processing of this data is based on the legitimate interest of KeyGo Rent.

Additionally, if you had consented, such geolocation data may be used by KeyGo Rent to make aggregate and statistical reports, with the purpose of improving the quality of service and vehicle provision, as well as making promotions and personalised offers.

            8.- If you consent, the sending of informative newsletters about our and third party products and services, with the legal base for processing in this case being consent.

 

c. TYPE OF DATA PROCESSED

Within the framework of the provision of services and subject to the agreed purposes, we will process the following categories of data:

Identification data: name, surname, address (private and/or work), date of birth etc.

Contact information: telephone number, email address (private and/or work), if necessary the fax number, the content of communications (such as emails, letters, faxes) etc.

Contractual data: rental information (vehicle category, pick-up and delivery date, pick-up and delivery station, extras/services contracted), rental contract number, reservation number, driving license data, photograph of the driving license, registration of the vehicle you have rented and information on customer and partner loyalty programs.

Financial information, credit card information, bank account number, etc.

Special categories of data: in the event of an accident, damage to the vehicle or a similar incident, we process the information related to what happened and the damage caused. These data may be provided by customers, passengers or victims. In these cases, health-related data can also be processed, such as, indications of injuries, blood alcohol level, driving under the influence of narcotic drugs or similar, for example.

Third-party data: if, in the context of your contractual relationship, you provide us with personal data of third parties (e.g. relatives, a second driver, passengers), we will also process this data.

Vehicle location data.

d. TERM OR CRITERION OF DATA RETENTION

Personal data will be kept for the time necessary to fulfil the purpose for which they were collected. If the data is used for several purposes, which require us to keep it for different periods, we will apply the longest term required.

In any case, we limit access to your data only to those who need to use it for the carrying out of their functions.

Our data retention periods are based on business needs, so that in relation to those personal data that are no longer necessary, access to them will be limited to the fulfilment of strictly legal obligations or they will be securely destroyed.

Marketing purposes: regarding the use of your information for marketing purposes, we will retain that information for that purpose during the two years following the date we last obtained your authorisation to direct marketing communications, unless you request that you be excluded from them, revoking the consent given.

Purposes related to the execution of a contract: regarding the use of the information for the management of any contractual obligation that we have with the customer, we will keep that data during the period of validity of the contract and for the following ten years, in order to respond to possible queries or subsequent claims.

Purposes related to compliance with legal and regulatory obligations: certain information must be maintained for the periods required by the specific regulations that result from application (fiscal, commercial, money laundering, etc.).

e. RECIPIENTS

KeyGo Rent will share the personal data that it processes, as necessary, with a restricted number of recipients, according to each purpose of the processing, as follows:

Recipient name/Purpose

1 - Third-party providers of services to KeyGo Rent that contribute, in their own name, towards any of the benefits identified in the contract signed with the customer/provision of the services signed by the customer.

2 - Third-party providers of KeyGo Rent services that contribute, on behalf of the company, towards any of the services that KeyGo Rent provides for its customers. Provision of customer services. Survey management and marketing on behalf of KeyGo Rent. Management of computer systems on behalf of KeyGo Rent.

3.- To the insurance companies to provide roadside assistance in the event of an accident in case the data were required for the issuance of any supplement requested by the customer.

4.- To the competent authorities in cases where there is a legal obligation.

5.- In the formalisation/management of the delivery of the vehicle, your name may be published on the existing public screens in the delivery premises, in order to manage the corresponding shifts.

International transfers: No international transfers of your personal data are expected.

f. RIGHTS

What are the customer's rights when you provide us with personal data?

You may exercise the rights of access, rectification, deletion, limitation of the processing, opposition or, where appropriate, the portability of the data by request addressed to the Data Controller, providing a copy of your identity document to the email protecciondedatos.keygorent@keygorent.com, specifying the right you wish to exercise.

Finally, we inform you that you can go to the Spanish Agency for Data Protection and other competent public bodies for any claim arising from the processing of personal data.

g. ORIGIN

We remind you that in case we are provided with information related to another natural person, you must, prior to its inclusion, inform them of the contents of this clause.

H. MODIFICATION OF THE PRIVACY POLICY

Auto Hugar, S.A. reserves the right to modify its Privacy Policy, according to its own criteria, or motivated by a legislative or jurisprudential doctrinal change of the Spanish Agency for Data Protection. Any modification of the Privacy Policy will be published at least ten days before its effective application. The use of the website after these changes, will imply the acceptance of these.

3.- INTELLECTUAL AND INDUSTRIAL PROPERTY

The contents of the website, as well as all the pages included under this domain name, are the exclusive property of KeyGo Rent.

These contents include texts, images, files and logos, as well as the design and structure of the website.

Any act of distribution or public communication, reproduction or total or partial storage must be carried out with the prior consent of the owners of the website. The owners of the website are not responsible for the improper use of the contents of the website that may be made without their consent.

4.- LINKS TO OTHER PAGES

The KeyGo Rent website may contain links to other websites. KeyGo Rent is not responsible for the privacy policies or the content of other websites.