Firefly Privacy Policy

Last Updated May 1, 2010

 

Firefly Privacy Policy


YOUR PRIVACY:
At Firefly Rent A Car, we respect your privacy and are committed to protecting the personal data we hold about you. This policy explains what data we collect about you, how we collect it, the measures we take to keep your data secure and the uses we make of it. We also explain the options you have regarding your personal data. When you request services from us or access our websites, you consent to our collection, retention and use of your personal data in the manner described in this policy and accept the risks outlined in the Security section. You can quickly review the key topics by reading this summary page. Alternatively, click on any of the headings below to read more about an issue or read the full policy.

 

SCOPE COLLECTION

Who we are:We are Simply Wheelz LLC d/b/a Firefly Rent A Car. This policy does note cover our parent company or our affiliates.

What we collect:We collect the personal data we need to provide the services you request from us.

Legal issues:We aim to comply with the privacy laws applicable to the personal data we collect and use.

Sources:We mostly collect your data directly from you and companies involved in our provision of services to you.

Changes:We may change this policy from time to time. The policy was last updated on 1st May 2010.

Websites:We use certain technologies on our websites, including cookies, to collect data about your visit. You may choose to restrict our use of cookies as suggested in this policy.

RETENTION USE

Storage:We generally retain personal data about our customers for as long as we believe appropriate for the purposes for which is was collected.

Operational Uses:By providing your personal data to us, you consent to our use and disclosure of your data for operational purposes listed in this policy.

Security:We aim to maintain appropriate physical, procedural and electronic safeguards to protect your personal data.

Marketing Uses:We would like to use your personal data for our marketing purposes. We may also want to share your data with our business partners for their marketing purposes. You can choose to restrict these uses by following the instructions in this policy.

Access:You may access and review the personal data we retain about you and correct any factual errors.


CONTACT US:We hope this summary answers your questions about our collection and use of your personal data.If it does not, please read further. If you have any questions, please contact us by following the instructions in the full policy.


Firefly Privacy Policy


YOUR PRIVACY

At Firefly Rent A Car we respect your privacy and are committed to protecting the personal data we hold about you. This policy explains what data we collect about you, how we collect it, the measures we take to keep your data secure and the uses we make of it. We also explain the options you have in relation to your personal data.

 

When you request services from us or access our websites, you consent to our collection, retention and use of your personal data in the manner described in this policy and accept the risks outlined in the Security section.

 

SCOPE

 

This policy covers the personal data we collect about you for our vehicle rental business. It does not address data that does not personally identify you, such as aggregated anonymous data. We are free to use non-personal data as we wish.

 

Who we are


We are Simply Wheelz LLC, a Delaware Limited Liability Company, a U.S. company based in New Jersey, which provides vehicle rental services under the name Firefly Rent A Car. All references in this policy to “we”, “us” and “our” are to the Firefly rental vehicle business, and not to our parent company, The Hertz Corporation and its subsidiaries, which operate other businesses.

 

We are affiliated to many other companies through ownership. As providers and affiliates are independent companies, they are not owned or controlled by us and are not covered by this policy, although they may have their own privacy policies to govern the personal data they collect.

 

More about parents, subsidiaries, affiliates, and providers…

 

Parents: These companies own Simply Wheelz LLC, directly or indirectly, and are covered by different Privacy Policies. The expressions “we”, “us” and “our” do not apply to them.

 

Subsidiaries: These companies are owned by The Hertz Corporation and are covered by different Privacy Policies. The expressions “we”, “us” and “our” do not apply to them.

 

Affiliates: These companies either control us (through ownership) or are controlled by the companies that control us. They cover a range of businesses but are generally not involved in provision of our services to you, except as to The Hertz Corporation which may perform administrative functions as an agent of Simply Wheelz LLC.

 

Providers: These companies are independent companies outside the continental U.S. that accept Firefly Rent A Car  reservations and rent their vehicles to you under their own company name. They are not owned or controlled by us.

 

Legal issues


We may do business in several countries, and so we aim to comply with the privacy laws applicable to the personal data we collect and use.

 

Changes


We may change this policy from time to time. If we do so, the amended policy will take effect when we post it on our website. We will amend the “last updated” notice on the first page of this policy whenever we make a change.

 

If any change makes the policy less protective of your personal data, it will not apply to data we collected about you before the change was made. The only exception to this is where we have told you about the changes and given you the opportunity to tell us not to apply them to your personal data.

 

COLLECTION

 

We collect a range of data about you from a variety of sources for the purposes of our business. The examples we provide here are illustrative rather than a complete list of our practices.

 

What we collect


We collect the data we need to provide the services you request from us, which may include:
  • Name, address and contact details, including telephone and email;
  • Date and place of birth, passport number and driver’s license number;
  • Employer(s) name and address;
  • Credit card information;
  • Frequent flyer and other membership reward program information;
  • Affiliations with companies or associations;
  • Rental charges you incur and other information relating to your rental; and
  • Information about your credit history from consumer reporting agencies.

 

We may collect personal data which is regarded as sensitive data in some countries, such as data about health conditions or membership of a trade union, which we are unable to process without your consent.

 

More about sensitive data…

 

Data about your health conditions is regarded as sensitive in many countries. If you ask us to accommodate a disability, such as by provision of hand controls, or if there is an accident and we need to work with insurance and claims management companies relating to any injury you may incur, we may need to process data about your health conditions. Similarly, in the EU, at least, your membership of a trade union or similar organization is regarded as sensitive and we may need to process this information if you use a Discount Program Number that only members of that union or organization can use.

 

Please note that if you wish to rent with us and need to provide sensitive data, you consent to that data being collected, used and disclosed for our Operational Uses . We will not use sensitive data about you for marketing.

 

Sources


We collect personal data directly from you when you make a reservation or rent a vehicle, including information you provide:
  • When you call our reservation centers;
  • On our websites;
  • At the rental location;
  • When you join loyalty or membership programs.

We also gather personal data about you from a variety of other sources, including:

  • Reservations you make with us through travel agents or brokers;
  • Transactions you complete with us or Providers, including options you take, charges you incur and any incidents or accidents that may occur; and
  • Other companies that have business relationships with us, such as our affiliates and business partners, including airlines and hotels.

 

Websites


Our websites

We use certain technologies on our websites to collect data about your visit, as follows:

 

 Cookies

 

A “cookie” is a set of data sent to your computer by our web server that enables the server to recognize your computer.

 

Cookies help us improve the quality of your visits to our websites by making the reservation process faster and smoother. The information they provide helps us develop content and features that we think will be of interest to you.

 

We use cookies to:

  • Track your use of our websites during a single visit, remember the data you provide and the choices you make as you progress from page to page (“session cookies”); and
  • Recognize you at your next visit (“persistent cookies").

 

More about cookies…

 

By adjusting your browser or installing certain software, you can restrict our use of cookies. If you do this, you should be aware of the following:

  • If you restrict our use of session cookies you will not be able to use our websites or certain features of our email messages. You should be aware that session cookies are generally deleted or made unavailable to us as soon as you close your browser.
  • If you restrict our use of persistent cookies you may still enjoy the full workings of our websites and email messages but will need to re-enter some data when starting a new website session. Although persistent cookies will neither automatically be erased nor made unavailable to us upon closing your browser, they will typically “expire” after a number of years.

 

If you are still unsure about cookies, please note that the data that makes up one of our cookies will typically have no meaning to anyone other than us. Also, a cookie is unable to retrieve other data from your computer’s hard drive or pass on computer viruses.

 

 Pixel tags

 

In addition, we may use “pixel tags” or similar technologies that enable us to track your actions as a user of our websites or recipient of our email messages.

 

Pixel tags are used to collect anonymous data to help us determine popular destinations, average rental prices, quote and conversion rates, click-throughs and other information to improve our service. We also use them to identify which online advertisement or email has brought a customer to our website.

 

Other company websites

 

Our websites and email messages may contain links to websites operated by other companies. You should be aware that the collection and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this policy.

 

RETENTION

 

We try to ensure that the personal data we retain about you is stored securely and is as accurate, current and complete as necessary for the purposes we use it for.

 

Storage


We generally retain personal data about our customers for as long as we believe appropriate for the purposes for which it was collected or as otherwise required by applicable law.

 

Our principal databases for storing the personal data we collect are located in Oklahoma, U.S.A.

 

Security


As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, faxes and transmissions over the Internet all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted.

 

We aim to maintain appropriate physical, procedural and electronic safeguards to protect your personal data, including:

  • Restricting access to personal data to our employees on a “need to know” basis;
  • Enforcing policies and procedures for our employees in their handling of personal data; and
  • Using technologies designed to safeguard data during its transmission, including SSL encryption for the data you provide on our websites.

If you have reason to believe that any account with us is no longer secure, you must immediately Contact Us.

 

More about SSL encryption…

“SSL” stands for Secure Sockets Layer encryption. We use this protection for the data you submit to us on our websites. SSL encryption seeks to ensure that you are actually sending your data to Firefly Rent A Car and that no-one else can read or tamper with it during transmission.

 

When you are asked to provide your personal data to us on our website, you will see that our “http” website address changes to read "https". The additional “s” denotes that the site is secure for that data transfer. You may also see a closed padlock symbol on your screen, again denoting a secure site.

 

Security of communications

 

We try to strike a balance between the security of your data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative.

 

For example, we will send you email in unencrypted form (i.e. instantly readable) because many of our customers are unable to access encrypted (i.e. coded) email. This means that our email, if misrouted or intercepted, could be read more easily than encrypted email. For this reason, please do not include confidential information, such as your Driver’s License or credit card number, in any email you send to us.

 

For a more secure way to communicate with us over the Internet, please click on the “Contact Us” link at the bottom of any page on https://www.thermeon.com/webXG/firefly/html/webres/ and follow our instructions.

 

Access


You may access and review your personal data and correct factual errors by contacting us at the address at the end of this policy.

 

To protect your privacy and the security of your personal data, we will take steps to verify your identity before granting you access or making corrections to the data we store about you.

 

USES


By making a reservation with us, you consent to our use and disclosure of your personal data for the operational uses listed below. We would also like to use your data for our marketing purposes.

 

Operational uses


The examples provided below are illustrative and not a complete list of our practices:

 

To provide you services

 

We will share your personal data among ourselves, our providers, and our affiliates to provide services to you, including to:

  • Make your rental reservations;
  • Process your rental transactions;
  • Provide you with enhanced rental services;
  • Provide you with customer assistance;
  • Bill and collect amounts owed to us for your rentals; and
  • For customer satisfaction and market research purposes to help us improve our services.

 

Disclosure to companies you use

 

We will also share your information with companies you use in connection with your rental, including:

  • Your credit card provider and other companies that process your charges;
  • Any company or organization that is paying your rental charges;
  • Any intermediary you use, such as a travel agent or broker, in relation to any aspect of your rental; and
  • Any operator of a membership program for which you are rewarded for renting with us, such as a frequent flyer program.

You may quote a special discount code when you rent with us, entitling you to the special rate or benefits we may have negotiated with your company, association, credit card company or travel club. We have specific rules governing our sharing of your data with the sponsors of these discount rates.

 

More about DP Sponsors…

 

If you rent using a Discount Program number, you consent to our disclosure of your personal data to the sponsor to:

  • Confirm your eligibility to rent using that Discount Program number;
  • Determine our compliance with the terms of the program;
  • Establish your compliance with the sponsor’s rental policies;
  • Enable the sponsor’s payment of your rental costs (if applicable); or
  • For any other uses reserved by a Discount Program sponsor in its agreement with you.

 

Sponsors are required to treat all personal data as confidential. They are not allowed to use the data for marketing purposes.

 

If you do not wish us to disclose your personal data to a Discount Program sponsor for the above purposes, you must not use their Discount Program number for your rental. This will mean, however, that you will not be able to receive the benefits associated with that Discount Program number.

 

Protective and legal uses

 

We may use and disclose your personal data as we believe appropriate, in compliance with applicable law, to protect our business. For example, we may share your personal data with credit reporting and fraud checking agencies. We may also share your data with organizations to enforce the rental agreement and recover any monies due, such as debt collection agencies.

 

In addition, we may share your personal data for legal reasons, including:

  • Cooperating with law enforcement agencies, to identify individuals who may be involved in illegal activities;
  • Responding to governmental and administrative bodies in relation to charges arising during the rental, such as parking and traffic fines, tolls and congestion charges; and
  • To comply with applicable law.

 

Disclosure to our agents

 

We may use affiliates or other companies as our agents to act on our behalf and assist us in the conduct of our business, performing services for us under our instruction. These services may include administrative functions, hosting certain websites or databases, running promotions for us, sending marketing communications, carrying out data analysis and conducting customer satisfaction surveys or other research. We will require our agents to maintain appropriate security standards to protect your personal data and use the data only for the purposes we specify.

 

Disclosure for corporate transactions

 

We may disclose your personal data to other companies in relation to the sale, merger or transfer of our business or our parent company’s business to enable the other company to decide whether to proceed with the transaction. If the transaction is completed, the company will be required to observe the relevant provisions of this policy with respect to the data provided.

 

Marketing Uses


We may aggregate your personal data and use it to develop targeted marketing programs and service offerings that we believe may be of interest to you. We would like to send these to you by email or by mail. We would also like to share your personal data with affiliates and business partners for their marketing purposes. You have choices in relation to our marketing uses of your personal data as follows:

 

US residents

 

We may use your personal data for the above marketing purposes, although you can choose to limit or restrict our mailings and our sharing of your data for these uses by following the instructions at Marketing Options below.

 

EU residents

 

We will only use your personal data for our marketing purposes with your prior consent, which may be collected from a number of sources.

 

If you do not receive marketing messages from us and would like to do so, or if you want to limit or restrict our mailings or sharing of your data for marketing purposes, please follow the instructions at Marketing Options below.

 

Residents of other countries

 

Our use of your personal data for marketing purposes will comply with your local law. You can instruct us how we can use your personal data for marketing purposes by following the instructions at Marketing Options below.

 

Marketing Options


Please complete the My Firefly Privacy Choices form at the end of this policy and mail it to us, following the instructions at Contact Us below.

 

Alternative opportunities to opt-out

 

Our marketing emails contain an unsubscribe option. If you do not want us to continue to send marketing emails to your email address, click on ‘unsubscribe’ and we will not send further marketing emails to that address, although you may still receive emails at other addresses for which you have not unsubscribed. If you subsequently wish to override your choice to unsubscribe, you will need to complete the My Firefly Privacy Choices form as described above.

 

Important points to note

 

Please note the following points about the marketing choices you make:

  • If you change your marketing choices, we will always observe your most recent choice. Although we aim to process your choices promptly, you may still receive marketing communications prepared before we received your request to unsubscribe; and
  • If you change your address, we will continue to follow your directions for your address provided from your ‘unsubscribe’ click above or the My Firefly Privacy Choices form you completed. However, in order for us to continue to follow your directions at a new address, you will need to complete another My Firefly Privacy Choices form with your updated information and provide it to us with your changed contact information; and
  • If your rental transaction data contains a discount program (DP) number, your DP sponsor may have made marketing choices for users of that number. If the sponsor’s choices are more restrictive on our use of your data than your choices, we will observe the choices made by the sponsor, where we can match it to your Privacy Choices form.

 

CONTACT US

 

We hope this policy answers your questions about our collection and use of your personal data. If you have additional questions or want to contact us for a specific purpose, please select from the following:


Access/ Corrections: Please send any request to access, amend or delete certain personal data we hold about you to the address below.


General questions: You should send any questions you may have about this policy to the address below. If you feel our response is not satisfactory, we will refer you to a neutral and independent dispute resolution organization.

 

Marketing:Send a completed My Firefly Rent A Car Privacy Choices form (at the end of the policy) to the address below. We aim to process your choices promptly on receipt, but you should please allow a number of days for your choices to become effective.


Security: If you have reason to believe that the personal data we hold about you, such as your Driver’s License number or credit card number, is no longer secure, you must immediately notify us of the problem by either clicking “Contact Us” at the bottom of any page on https://www.thermeon.com/webXG/firefly/html/webres/.

 

Contact Address

  • Director, Privacy Services, Firefly Rent A Car, 14501 Hertz Quail Springs Parkway, P.O. Box 26120, Oklahoma City, OK 73134, U.S.A.

My Firefly Rent A Car Privacy Choices


Please complete this form and send it to us by following the instructions at Contact address above. (Note: Please use this form to update your information too.)

 


Name:

.....................................................


Address:

....................................................


State/Province:

.......................................................


Zip/Post Code:

....................................................

Country:

.......................................................


Email Address:

....................................................


Discount Program (if any):

......................................................

 

A. Please send me marketing offers and materials from Firefly Rent A Car:

Yes No
Postal Mail [   ] [   ]
Email [   ] [   ]

 

B. Please share my personal data with Firefly Rent A Car affiliates and business partners for their marketing purposes:

                    [   ]   [   ]