Privacy and Processing of Personal Data Policy
Please read carefully the following Privacy and Processing of Personal Data Policy of RENTE UN AUTO ESMERALDA S.A., a company domiciled in Costa Rica with entity identification number 3-101-88140, and its subsidiaries and/or affiliates (hereinafter referred to as "Adobe Rent a Car", "Adobe" or "we").
GENERAL INFORMATION
1. Adobe is a group of companies with main offices in the city of San José, Republic of Costa Rica, where it operates an internal personal database to provide its services.
2. This Privacy and Processing of Personal Data Policy (hereinafter, the "Policy" or the "Policies") regulates the way in which we collect and use your personal data. Personal data means any data relating to an identified or identifiable natural person.
3. This Policy applies to the collection and processing of your personal data by electronic and manual means.
4. The user who contracts our services and/or enters the Adobe website must, beforehand, read, understand, and accept these terms and conditions. Therefore, by contacting us and entering and browsing our website, whether or not using any of the services it offers, you declare that you have understood and accepted the terms and conditions contained in this Policy. We recommend that you read and understand this Policy before continuing browsing and using our website and contracting our services.
5. Adobe may modify these Policies from time to time to adapt them to the applicable regulation or to the services provided by Adobe. We recommend checking its content periodically.
CONTROLLER
6. This Policy applies to all companies in the Adobe’s group of undertakings, which provide rental car services and/or related activities. All are domiciled and operate in the Republic of Costa Rica. RENTE UN AUTO ESMERALDA S.A. is specifically in charge of the company´s database.
7. This Policy does not apply to third party service providers that can provide complementary services to those of Adobe, such as hotels, travel agencies, browsers, and search engines on the Internet, social networks, insurance companies, and other economic agents that may have their own privacy policies. In case our website has links (hyperlinks) to third party websites, our policies will not apply to those websites either.
TYPES OF PERSONAL DATA WE COLLECT
8. Adobe may collect and use personal customers information, such as their full name, nationality, identification documents and driver's license numbers and copies, telephone number, fax number, post office box, exact address, e-mail, payment information such as credit or debit card details (we will not keep your security code after the transaction), your hotel address (for delivery services), flight or reservation number, information on incidents (accidents, mechanical failures, thefts, losses, and others) that the vehicle could suffer; as well as any other information that is necessary for the contracting and rendering of the service requested by the customer, either to fulfill our contractual obligations or to exercise our legitimate rights. In the case of corporate or special plans and programs (such as, but not limited to, renting and long-term rentals), we may collect the necessary information to contract said plan and the one that links each user with the relevant agreement.
9. Adobe may also receive personal information from other legitimate sources in connection with the provision of the service you have contracted (from your workplace, from your travel agency, etc.). In exceptional cases, public authorities provide us with certain data related to infractions, collisions, thefts and accidents, and other similar events.
10. Our units may have location systems (GPS) that provide valuable information about the vehicle and the use given to it. This allows us to fulfill our contract, verify compliance by the customer, and recover our vehicles in case of theft, loss or other incidents. At no time will we track or monitor the status of your vehicle during the rental.
11. Telephone calls to our central office can be recorded for quality control purposes.
12. In our offices and agencies, we count on surveillance and monitoring systems that can record images, pictures and videos, voices, and/or sounds, for guaranteeing the safety of people and controlling our units.
13. Sometimes, we may request financial information from the customer for opening credit lines in certain special contract categories. Adobe may also request credit information from other sources, such as authorized credit bureaus, for that purpose.
14. Exceptionally, you may voluntarily provide us with some information about your health status when requesting a service or a special product from us. In that case, we will only collect that information with your express consent and store it with complete confidentiality for as long as it is strictly necessary to provide and offer our services. We will not share this information with third parties, except in exceptional cases in which applicable regulations allow or require it.
15. Our services are not directed to minors. It is not our intention to collect information from minors. Parents and guardians of minors may request the removal of such information by contacting Adobe as indicated in these Policies.
PURPOSE OF INFORMATION PROCESSING
16. We collect and use personal data for the following purposes:
a. To fully identify our customers, process reservations, contract with them, invoice our services and associated charges (including but not limited to insurance, guarantee deposits, and penalties), grant or deny credit, execute the contracts, provide the services announced in our premises and website, and demand fulfillment of contract;
b. To provide adequate customer service, including after-sales service, assistance services, and insurance;
c. To verify the proper, authorized, and legitimate use of Adobe vehicles by the customer;
d. To communicate with our customers, respond to complaints and comments, and/or offer our services;
e. To better understand the behavior of the market and the interests of our customers;
f. To improve our products and services;
g. To promote and market our services, comply with promotional programs, offer special or preferential plans, and customize our offers;
h. To process the collection and demand the payment of our services and associated charges;
i. To defend the legitimate interests of our company before any kind of conflict, claim, demand, infraction, investigation, process or litigation, either before the customer, authorities, insurers, and/or third parties;
j. To comply with controls related to fraud prevention, money laundering or security, whether due to legal duty or internal company policy;
k. To fulfill legal duties and any other legitimate interest of ours in the rendering of our services.
RECIPIENTS OF INFORMATION
17. Adobe is committed to the security of the data that you provide. Adobe will not share your personal data with third parties, except to comply with the purposes established for collection and processing, including the possibility of sharing them with entities of the same Adobe economic group (without the database losing its status as "internal"), and any other cause established in the applicable regulations, in these Policies, and in any agreements that you sign with us.
18. However, we may share your information, as far as required by the provision of our services and as allowed by law, with:
a. Intermediaries through which our services are contracted (when applicable), in order to fulfill our agreement;
b. Travel agencies and similar or equivalent services, to contract with you and fulfill our agreement;
c. Entities issuing credit or debit cards to process payments;
d. Insurers and authorities in case of incidents;
e. Your own employer, when contracting and executing corporate packages (when applicable);
f. Booking engines, insofar as you use one to make and manage your reservation;
g. Marketing services providers, to offer services and understand their preferences;
h. Credit bureaus dedicated to the elaboration of profiles, in case your account becomes delinquent with us.
i. Other recipients that could be found in Costa Rica or abroad, as required for data collection and processing set forth herein, according to the nature of our services, all of which you agree to contract with Adobe.
COOKIES, IP ADDRESSES, AND ANALYTICAL SOFTWARE
19. Our website may use "cookies" and "web beacons". Cookies are files that are stored in your browser when browsing our website, and that allow you to consult the previous activity of the browser. Cookies serve us primarily to help you manage your reservation and help you remember your selections and act according to your preferences. You can accept, delete or block cookies from your browser settings. Web beacons, on the other hand, allow measuring the traffic of users that use the website and serves the web analysis. Our website will only use all this information anonymously. You can accept or reject cookies from the configuration options of your browser. You can find our Cookies Policy at: www.adobecar.com
20. We may use IP information to automatically customize the service, as well as to analyze and prevent any type of threats to our website and to manage the site. We may use the IP information to identify the owners when there is a likelihood of fraudulent or illegitimate activity.
21. We can use analytical software, such as Google Analytics and Search Console, which allows us to collect information from a website related to search engines, to better understand the user's interaction with the Adobe website and improve its functionality.
TERM FOR STORING INFORMATION
22. We will store your personal data for the time that it is necessary to fulfill the purpose for which they are collected and to determine possible accountabilities that may arise from such purpose, in addition to the periods established in the regulations on files and documentation. The Internal Law of the Republic of Costa Rica authorizes Adobe to keep personal data for a maximum period of 10 years. Adobe will use this term as a reference, unless the applicable regulations provide otherwise.
EXERCISE OF RIGHTS AND MEANS OF CONTACT
23. Data protection laws grant certain rights of information self-determination. Among others, you have the right to access your personal information, correct any inaccuracy, revoke the consent for processing the data, and ask for the limitation or total or partial suppression of certain data according to law, in addition to other rights that the applicable regulations may contemplate. You may do so at any time, without retroactive effects being attributed to your action, by any of the following means:
a. By letter to Adobe's main offices, located in San Jose, Costa Rica, exactly in the Barrio Corazón de Jesús, 34th Street, from the Southwest corner of Cementerio de Obreros, 100 meters west and 800 meters south.
By email to the following address: privacy@adobecar.com
24. Your request must contain:
a. Names and surnames of the owner of the personal data, with a copy of the identity document. If the legal representative exercises this right, the latter must prove his/her identity by attaching an identity document or equivalent document, and a copy of the title that proves the representation.
b. Specific and clear request mentioning the data to which it refers and the correction requested, together with the documentation or relevant evidence to justify your request.
c. Address or means to receive notifications.
d. Date and signature of the applicant.
25. Adobe will attend your requests at no cost, within the terms of law. In case Adobe requires additional information, we will let you know in a timely manner.
26. Please note that the information you provide based on these Policies is necessary to fulfill the purposes detailed herein. Due to the nature of our services, refusal to provide, revocation of consent, and/or opposition to the processing of essential data may prevent contracting the service or may entail the termination of the provision of the service.
27. If you have any question, suggestion, observation or concern about our Privacy Policy, do not hesitate to contact us by any of the means previously indicated.
APPLICABLE LAW AND AUTHORITY OF CONTROL
28. These Policies are governed by the Law of the Republic of Costa Rica, without regarding conflicts of law provisions . The control authority of Costa Rica is the Agency for the Protection of Data of Inhabitants (Prodhab).
[Version 1.0 August 2018]
