This policy was last updated on June 21, 2017.
The Types of Information We Collect
Information Collected About You
You may provide us with certain information in connection with a transaction or in your interactions with our websites and at our locations. When you are asked to provide personal information, you may decline. If you choose not to provide the information, you may not be able to use some products or services. The personal information we may collect includes:
- Your name, contact information, driver’s license number and expiration date, emergency contact information, and date of birth;
- Vehicle rental information, including the location of where the vehicle is rented, date of rentals, type of rental, and your preferences;
- Your credit card details, online user accounts details, membership/corporate ID numbers, passport information, and frequent flyer or travel partner affiliations;
- Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;
- Photographs you submit of you and your driver’s license or your receipts through camera features available on some of our mobile applications and websites;
- Financial information that may be necessary to facilitate the purchase or lease of a vehicle from a Car Sales or Fleet Management location in the United States. (Additional notices will be provided to you at the time of that transaction.)
- Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents, Car Sales lead providers or similar providers).
With your consent, we may access location-based information from your mobile device or based on your IP address. We may also use your mobile device location information to provide you with notifications with your consent. We do not use this information to specifically locate you for any reason other than to provide you the service. If you have allowed us to utilize your location information in the past and wish to revoke the permissions, please turn off location services at the device level. With your consent, our application may utilize your device’s camera feature to upload photos (such as your receipts) to the application. If you have allowed the application to utilize your camera and wish to revoke the permissions to do so, please do so at the device level.
Information Collected and Stored Automatically
By visiting our websites, certain information may be automatically provided to us by your computer. For each visitor to our websites, our webservers automatically recognize the visitor’s domain name or IP address. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, webservers can identify your computer by its IP address. In addition, we may collect your browser type and operating system as well as your internet service provider (ISP), referring and exit pages, date and time stamp, and/or clickstream data. We collect similar information when visiting our websites with your mobile device, including mobile device brand, model, mobile operation system and carrier. Except as otherwise explained in this policy, we may combine the non-personal information we collect from you (as described above and as described below, under “Cookies & Pixel Tracking”) with your personal information in order to tailor our websites and enhance your online experience by saving your preferences and/or to help identify site features, advertisements and offers that may be of interest to you.
Cookies & Pixel Tracking
Vehicle Operation and Location Data
Wandervans LLC vehicles may be equipped with vehicle telematics system (“Telematics System”). Some or all Telematics System functionality may or may not be active during rental periods. Telematics Systems may provide use, disclosure of, or access to (1) location information, (2) crash notification and related crash data and, (3) operational condition, mileage, diagnostic and performance reporting of vehicles (“Telematics Data”), as permitted by law.
Our websites and online marketing are not directed to, and Wandervans LLC does not knowingly collect personal information from, children under the age of 18 or your country’s age of minority. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please email us at [email protected]
How We Use This Information
We use the information we collect for the following purposes:
- To assist the transactions that you request, such as reserving and renting motor vehicles.
- To verify a valid ID when submitting a photo of yourself and drivers license for one of our CarSharing, afterhours or expedited rental services. We do not store this information for any other purpose.
- To service your account or membership with us, respond to your questions and contact you when necessary.
- To provide you with discounts, coupons, sweepstakes, offers and other information, opportunities, and services that may be of interest to you. You may receive these offers in advertising that is directed to you via third-party sites and media properties, including in social media. You may be able to opt-out of these ads by clicking on an icon in the ad or through the privacy settings in each media property.
- To assist us in providing better products and services (for example, we may contact you by telephone, mail or email to assist us in evaluating the performance of our staff, to assess the quality of product and service received and to help us improve our websites, facilities and services).
- To compile statistics and analysis about our customers’ use of our websites, products and services, which statistics are only used to enable us to provide better customer service, products, features and functionality to you and other customers in the future.
- To protect our rights and property.
We may combine the information that you submit to us with information related to your transactions with us, such as rental location and vehicle type. We may also combine this information with data we receive about you from third parties who assist us in processing requests, maintaining our data, and optimizing our services.
Except where prohibited by law, we retain information we collect for commercially reasonable periods of time or in accordance with specific policies. Information collected for a specified purpose will only be used for that purpose and, after a reasonable period of time, will no longer be actively stored when that purpose has been fulfilled. Inactive data may, however, continue to be used for statistical, marketing, archiving, and other analytical purposes.
How Your Information May Be Shared
We may disclose the information we collect from and about you to our subsidiaries for the purpose of providing the transactions you have requested and for marketing purposes. In addition to those stated within this Policy, Telematics Data from rental vehicles may be disclosed to, accessed by or used by Wandervans LLC, our affiliates, emergency service providers, others who may assist in responding to an accident, telematics service operators, or those with whom we have a legal or contractual obligation to provide such data. Our affiliates and our subsidiary employees in our IT, marketing, operations and customer service divisions may use your information, as described in this Policy.
We also may disclose your information to other third parties: (1) when required by law or in response to legal process; (2) without legal process in response to a request from law enforcement relating to a criminal investigation; (3) to protect our rights, privacy, safety or property, or of the public; (4) for administrative, technical support or other business purposes to facilitate our transactions with you (i.e. for your insurance replacement, corporate rental or through one of our partners), analyze our data, conduct mobile analytics services, or to maintain and improve our services (subject to confidentiality agreements as appropriate); (5) to permit us to pursue available remedies or limit damage that we may sustain; (6) to enforce the terms of any rental agreement or our websites’ terms and conditions; (7) to process your transaction with our subsidiaries, affiliates or licensee/franchisee located in the country in which you place your reservation; (8) if the rights of another individual might be violated and (9) otherwise with your consent.
Personal information may also be subject to transfer to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of Wandervans LLC’ businesses or assets. This will occur provided that the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your personal information.
We may disclose your personal information to third-party service providers (such as a payment processor to bill you for goods or services, an email provider to send email communications to you on our behalf, or the provider of our live chat feature in order to offer you customer service). These service providers may be located in a country different from your country of residence, such as the United States or a European Union member country. These service providers are contractually required to maintain the confidentiality and security of your information. However, your information may be accessible to U.S. or EU authorities in accordance with applicable laws.
We may also share aggregated or de-identified information about our customers with our advertising and marketing partners, and third-party media properties, including social media sites to allow them to send targeted advertising messages on our behalf. With your prior notice and consent, we may share your name and email address with our co-branded partners and affiliates in order to provide the services you have requested and for marketing purposes. If you wish to stop receiving promotional communications from these third parties, please contact the third party.
Choices You Can Make About Your Information
Throughout our websites, we provide choices about the collection, use, and sharing of your information. For example, you must affirmatively request to receive email advertisements from us, our affiliates and/or business partners concerning information about special offers, promotions and new features, products and services. You may choose to opt back in to our email advertisements at any time, in which case your most recent action will prevail.
We may post customer testimonials/comments/reviews on our websites which may contain personally identifiable information. We will obtain your consent via email prior to posting the testimonial. To request the removal of your testimonial, please contact us.
Data Security and Integrity
The security of the information you provide is very important to us and we try to provide secure transmission of your information. For certain transactions on certain of our websites, we may use Secured Sockets Layer (SSL) technology to secure the transfer of information. Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information transmitted over the Internet. Once we receive your information, we take steps that we believe are reasonably appropriate to protect its security, both internally and from outsiders, from loss, misuse, unauthorized access, disclosure, alteration and destruction, and to ensure the integrity of the data we collect. We use a combination of technological, physical, administrative and policy methods as well as organizational controls and non-disclosure or confidentiality agreements as we deem appropriate to protect this data.
If you have a user name and password for any of the features on our websites, you have the responsibility of keeping your password secret. You should not reveal your password to anyone. We will not ask you in an unsolicited telephone call or email for your password. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.
Global Data Transfers and Processing
We will use your information in the country in which your service and transaction occurs. Please be aware that, unless prohibited by law, your use or continued use of our websites and mobile applications signifies your express consent that information may be transferred to or stored on servers and processed outside the country of your residence, including any of the countries where we do business. Please also be aware that the privacy laws of the United States or other countries where information may be stored may not be as comprehensive or offer as much protection as the laws of other countries including your country of residence. You may request us not to make such transfers, but if you do, we may not be able to provide some or all of our products or services to you.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Wandervans LLC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Wandervans LLC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request, or in Canada, you may contact the Privacy Commissioner of Canada by visiting https://www.priv.gc.ca/cu-cn/index_e.asp or at Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3.
We abide by the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Economic Area and Switzerland. Wandervans LLC has certified that it adheres to the relevant Safe Harbor Privacy Principles. To learn more about the Safe Harbor program and to view EHI’s certification, please visit the Department of Commerce’s Safe Harbor website at http://www.export.gov/safeharbor/.
When transferring personal data to countries outside the European Economic Area, we comply with European Union law by using standard contract clauses approved by the European Commission, or by adopting other means to ensure that adequate safeguards are applied, or by obtaining your consent.
Changes in Terms
The accuracy and completeness of the information we collect is very important to us and we make efforts to ensure that the information we have is accurate and up-to-date. In addition to the options provided to you in this Policy, if you wish to opt-out of direct marketing or review, amend, correct, update or delete personally identifiable information we have collected about you or limit how we use it, contact us at the information provided below. In addition to rights to review, amend, correct, update and delete personal data, you may also have rights to object to some processing of personal data. Please also contact us if you have any questions about privacy on our websites. You may contact us via email at [email protected] and we will attend to your request and make any necessary revisions. If you prefer, country specific contact information is listed below. We will respond to your access request within 30 days, unless a shorter period is required. If that is the case, local legal requirements would apply.
We reserve the right not to allow access to your information if we believe in good faith that such disclosure is prohibited by law or if the rights of another individual might be violated.
Last Updated: February 16, 2015
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
Information Collection and Use
Our primary goals in collecting information are to provide and improve our Site, Services, features and content, to administer your use of the Site and to enable users to enjoy and easily navigate the Site.
Personally Identifiable Information
When you register with us through the Services and become a Member, when you choose to post a Listing or rent a Vehicle, or when you wish to contact another Member, we will ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you (“Identity Information“). Identity Information includes, but is not limited to, your name, phone number, drivers license, email address, social security number (SSN), and home postal address, but does not include your credit card number or billing information. In order to process some of your transactions through the Services, we may also ask for your credit card number and other billing information (“Billing Information“) (Identity Information and Billing Information together, “Personal Information“). Some Personal Information is required, like your name and email address, and other Personal Information is optional, like your date of birth. We use your Personal Information to provide the Service and administer your inquiries.
We collect Personal Information in connection with your registration to join the Service. You can register to join via the Site or Application by completing the required forms.
You can also register to join by logging into online accounts you may have with third party service providers (“TPA“) (e.g. Facebook); each such account, a “Third Party Account“, via our Site or Application as described below. As part of the functionality of the Site, Service and Application, you may link your Outdoorsy Account with Third Party Accounts, by either: (i) providing your Third Party Account login information to Outdoorsy through the Site, Service or Application; or (ii) allowing Outdoorsy to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to Outdoorsy and/or grant Outdoorsy access to your Third Party Account (including, but not limited to, for use for the purposes described herein), without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating Outdoorsy to pay any fees or making Outdoorsy subject to any usage limitations imposed by the applicable TPA. If you decide to register by logging into a Third Party Account via our Site or Application, we will obtain the Personal Information you have provided to the applicable TPA (such as your
“real” name, email address, profile picture, names of TPA friends, names of TPA groups to which you belong, other information you make publicly available via the applicable TPA and/or other information you authorize Outdoorsy to access
by authorizing the TPA to provide such information) from your Third Party Accounts and use that information to create your Outdoorsy Account and Outdoorsy Account profile page and you will become a Member. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access, make available and store (if applicable and as permitted by the TPA and authorized by you) the information in your Third Party Accounts so that it is available on and through your Outdoorsy Account on the Site, Service and Application. If there is information about your “friends” or people with whom you are associated in your Third Party Account, the information we obtain about those “friends” or people with
whom you are associated, may also depend on the privacy settings such people
have with the applicable TPA.
We also collect the other information that you provide as part of registration and the administration and personalization of your Outdoorsy Account profile (e.g., without limitation, zip code (on its own) and individual preferences or demographic information) (“Non-Identifying Information“).
We use your Personal Information (in some cases, in conjunction with your Non- Identifying Information) mainly to provide the Service, complete your transactions, and administer your inquiries.
Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be
identified. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non- identifying information (for example, your demographic information). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other Outdoorsy Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Service and to analyze and understand how our Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
We also use your Personal Information to contact you with Outdoorsy newsletters, marketing or promotional materials and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your “Notifications” information. (See “Changing or Deleting Information,” below.) We may also share the combined information without aggregating it to partners we feel may have material benefit to you or your use of the Site. Please note that we may
also use your Personal Information to contact you with information related to your use of the Service, or services from Partners; you may not opt out of these notifications.
When you visit the Services, whether as a Member or a non-registered user just browsing (any of these, a “Outdoorsy User“), our servers automatically record information that your browser sends whenever you visit a website (“Log Data“). This Log Data may include information such as your computer’s Internet Protocol (“IP“) address, browser type or the webpage you were visiting before you came to our Services, pages or features of our Services that you visit or use, the time spent on those pages, information you search for on our Services,
access times and dates, and other statistics. We use this information to monitor
and analyze use of the Services and for the technical administration of the Services, to increase the functionality and user-friendliness of the Services, and to better tailor our Services to our visitors’ needs. We also use this information to verify that visitors to the Services meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze
and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by Outdoorsy Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. Third party advertisers on the Services may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or functionality of the Service.
Our Services may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Services are used and may be used in
some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns.
Emailing Via a Outdoorsy Account
As part of the Service, Outdoorsy Users may communicate with Outdoorsy Members through use of the “Contact Owner” feature on the Services. If the functionality exists for Outdoorsy Users to have selected the option of adding one or more email addresses to an online form, the message they create in the corresponding template will be sent from Outdoorsy to those email addresses on their behalf.
Identity theft and the practice currently known as “phishing” are of great concern to Outdoorsy. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your Outdoorsy Account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website at http://www.ftc.gov.
Information Sharing and Disclosure
The Services can be used to facilitate the listing and booking of Vehicles. Listings for such Vehicles are made available via the Services by Owners. Listings posted by Owners, ratings and reviews of Owners and Renters, and the Profile Information (as defined below) of Owners and Renters, are visible to any Outdoorsy User.
Outdoorsy Members and Users
When you create an Outdoorsy Account, we will set up an Outdoorsy Account profile page for you. Your Outdoorsy Account profile page will include your first name and last initial and connections you have established between your Account and any TPAs, and a biography and links to your Listings. You can select the other items of Personal Information that you wish to be included in your Outdoorsy Account profile page – including, but not limited to, a profile picture, or, other information knows as your “Profile Information“. We will display your Profile Information in your Outdoorsy Account profile page publicly via the Services, and, with your prior permission, on third party sites. Any information you choose to provide as part of your Profile Information will be
publicly visible to all Outdoorsy Users and consequently should reflect how much you want other Outdoorsy Users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage members to think carefully about what information about themselves they disclose in their profile pages. You can review and revise your Profile Information at any time.
If you post a Listing, we may publish that Listing publicly via the Services and may enable third parties to publish your Listing on their websites through the use of an HTML “widget“. We may also display the geographical location of your Listing in the form of a map to potential Renters.
If you request to make a booking via the Services, Outdoorsy will share the following information about you with the applicable Owner: (i) your first and last name, (ii) a link to your Outdoorsy Account profile page where the owner can view your Vehicle history, reviews, and description/links. All of this information will enable the Owner to decide whether to confirm or reject your booking. When an Owner confirms a booking we will share pieces of the Owner’s Identify Information, including, but not limited to, full name, phone number, the Vehicle’s address and the Owner’s email address, with the applicable Renter selected by the Owner and we will share pieces of the Renter’s Identify Information with the Owner, including, but not limited to, full name, phone number and email
address, so that the Renter and Owner may contact one another directly. In no
event is a Renter’s Billing Information shared with an Owner.
Aggregate Information and Non-Identifying Information
We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Site and Application-related services (e.g., without limitation, maintenance services, database management, web analytics, fraud detection services relating to the activity of Outdoorsy Users and improvement of the features of the Service) or to assist us in analyzing how our Services are used. These third parties may have access to your Personal Information; if they do, this access is only so that they may perform these tasks on our behalf and they are obligated not to disclose or use
it for any other purpose. We may also provide Personal Information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you. You can, at any time, opt out of receiving such communications.
Compliance with Laws and Law Enforcement
Outdoorsy cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Outdoorsy or a third party, to protect the
safety of the public or any person, or to prevent or stop activity we may consider
to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
We will disclose any information about you to government or law enforcement officials and to our insurance services providers as we, in our sole discretion, believe necessary or to protect the property and rights of Outdoorsy or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity.
Changing or Deleting Your Information
All Members may review, update, correct or delete the Personal Information by editing the relevant part of their profile or by contacting us. If you would like us to cancel your Outdoorsy Account, please contact us and we will attempt to accommodate your request if we do not have any legal obligation or a legitimate business reason to retain the information contained in your Outdoorsy Account. Please note that, if you
cancel your Outdoorsy Account, any reviews you have posted via the Services will remain publicly viewable via the Services. Please see below for privacy contact information.
Outdoorsy is very concerned with safeguarding your information. When you enter sensitive information (such as credit card number and/or social security number) on our registration or order forms, we encrypt that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore,
we cannot guarantee its absolute security. If you have any questions about security on our Services, you can contact us.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Links to Other Websites
Our Services may contain links to other websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
By agreeing to the Terms of Service we may post your testimonial or reviews on the Services along with your name. If you want your testimonial removed please contact us.
Our Policy Toward Children
The Site and Application are not directed to individuals under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we become aware that a child under 13 has provided us with Personal Information, please notify us so that we may delete such information from our files.
Access to your account
Outdoorsy will have the right to access your account to make any changes to reservations, listings, or profile information at its sole discretion.