Issued May 9th, 2001, Updated and Effective June 13, 2013
We are Thrifty Car Rental. (“Thrifty”), a subsidiary of DTG Operations Inc., and we are committed to protecting the privacy of your personal information. We respect the sensitive nature of this information and your right to know the categories of personal information we collect, how we secure, use and distribute that information, and finally, your rights to limit the use of that information (see the “How To Opt Out” section below). This policy covers the personal data we collect about you in connection with our vehicle rental business which identifies you as an individual. It does not address data that does not personally identify you as an individual, for example, but without limitation, aggregated anonymous data, computer operating systems, personal preferences, vehicle identification numbers, etc. We are free to use data that does not identify you as an individual as we wish. This policy does not apply to data collected by third party social networks (such as Facebook), mobile device manufacturers, third party “mobile apps”, wireless service providers, internet service providers or the operators of any networks through which you may interact with us and we expressly disclaim any responsibility for the data collection, privacy or data security practices of those entities. With regard to pages on third party social networks, this policy only applies to personal data we collect through our pages (those with a direct link to this policy) and does not apply to any “unofficial” pages or pages of our affiliates or licensees. Our services are not directed to children under the age of 13 and we do not solicit information from minors.
Thrifty operates a network of licensees in provision of our services worldwide and are affiliated to many other companies through ownership. As our licensees and affiliates are independent companies, they are not owned or controlled by Thrifty and are not covered by this policy, although they may have their own privacy policies to govern the personal data they collect. We are not responsible for the privacy practices of our licensees and affiliates.
Licensees: We have a network of independent companies licensed to operate vehicle rental businesses using the “Thrifty” name and business system. These companies may describe themselves as “Thrifty System Licensees” or “Thrifty Franchisees” to indicate that they are not our subsidiaries.
Affiliates: These companies either control us (through ownership) or are controlled by the companies that control us; including without limitation, The Hertz Corporation, Dollar Rent A Car, Firefly Rent A Car, or Donlen Corporation. They cover a range of businesses, including car rental businesses. However, although our affiliates may provide us with certain administrative support or claims or claims administration services, they are generally not directly involved in the provision of services to you.
Information we collect about you.
We collect information about you when you visit us at Thrifty.com, mobile.thrifty.com/m.thrifty.com, and Thrifty “mobile apps” or otherwise interact with us (for example, on our official corporate pages on third party social networks, such as Facebook, or the applications/tabs on those pages); 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 below. We do business in other countries and aim to comply with the privacy laws applicable to the personal data we collect and use.
DTG Operations, Inc. and those of its subsidiaries operating within the United States of America, comply with the U.S. – E.U. Safe Harbor Framework and the U.S. – Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, retention and use of personal information from European Union member countries and Switzerland. We have certified that we adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. Please raise any concerns regarding our compliance with the US-EU Safe Harbor Principals and US-Swiss Safe Harbor Principles by either clicking “Contact Us” on any page of www.Thrifty.com; or writing to us at [email@example.com]. We have committed to refer unresolved privacy complaints under the U.S.-E.U. Safe Harbor Principals and U.S.-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
When you place a reservation with us, in order to process the reservation and rental or to communicate with your regarding your reservation or rental, we collect some or all of the following personal and non-personal information about you depending on the location of the rental and the type of vehicle you wish to reserve. All data is collected for us to provide the services you request and for our Operational Uses (see below) in connection with such service.
- Telephone number or other contact details (including mobile number);
- Email address (online, via phone or at the rental counter);
- Date and place of birth, passport number and driver’s license number;
- Employer(s) name, address and phone number;
- Credit card information;
- Frequent flyer and other membership reward program information;
- Affiliations with companies, associations, colleges, cities, or Promotion Code sponsors;
- Location data such as geographic location of electronic devices used to contact us or to access our mobile applications (“apps”) or of the vehicle you have rented;
- Information regarding the vehicle and its operation during your rental;
- Information about your credit history or other information available about you from consumer reporting agencies;
- Thrifty Blue Chip Express Rental Program® ID Number;
- Corporate Discount Program (CDP) number;
- Airline and/or flight information;
- Preferred vehicle type;
If you sign up for other services from us, including any special online marketing promotions, sweepstakes, and online publications, we collect your email address and other information from you. If you are a travel agent we collect your IATA number and AG Code.
So that we may communicate with you, you give us your consent to call you on or send text messages to your mobile telephone/device. You also consent to our use of auto-dialers and pre-recorded messages in connection with any such telephone call or text message, including calls or texts to mobile telephone numbers. We will not charge you for such calls or texts. Your mobile service provider will charge you according to the applicable plan to which you subscribe.
We use third party ad serving technology to serve ads that will link you to our web site. This technology uses information about your visits to this site to serve our ads to you on third party web sites. In the course of delivering our advertisements to you, a unique third party cookie may be placed or recognized on your browser. You may occasionally get cookies from our business partners if you use the links on our web site to reach their respective web site. We do not control these cookies.
We do not control the information collected by unrelated third party web sites that are linked to our web site. You should review their privacy policies prior to providing any personal information to them.
In addition, “pixel tags”, “web beacons” or similar technologies that enable, among other things, the tracking of your actions as a user of various websites or recipient of email messages. Pixel tags may be used in connection with our web pages, our online advertising, or our email messages, either by Thrifty or by our service providers, business partners or other third parties. Pixel tags are typically used to collect anonymous data to help identify types of information, including popular destinations, average rental prices, quote and conversion rates, click-throughs and other information to improve the service you receive or the relevance of advertising directed to you. Pixel tags may also be used to identify which online advertisement or email has brought a customer to a website, tracking visits to the website and confirming eligibility to receive services or benefits from Thrifty or its third party affiliates or business partners.
As the internet and other eCommerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.
Sources of information.
We also collect personal data directly from you in connection with the reservation or rental of a vehicle or your membership in any of our membership programs, including information you provide:
- When you call our reservations, on rent support, and/or customer care centers;
- Through your computer’s web browser;
- On our websites or mobile websites;
- On our mobile apps;
- Through our kiosks;
- On our official third party social network pages (those with a direct link to this policy);
- At rental locations; and
- Through our in-vehicle or in-equipment technology or through other telematics devices; and
- When you join Thrifty membership programs, such as Blue Chip Express Rental Program®.
We also gather personal data about you from a variety of other sources, including:
- Reservations you make with us through licensees, travel agents or brokers;
- Transactions you complete with us and our licensees, including options you take, charges you incur and any incidents or accidents that may occur;
- Sponsors of promotion codes, special discount codes “CDP Number” or affiliations (as described below);
- Consumer reporting agencies;
To the extent you have made such information available, from:
- Third party social networks;
- Other companies that have business relationships with us, such as our affiliates and business partners, including travel agents (whether on-line or otherwise), airlines, hotels, and insurance companies.
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 - What measures do we take to protect your information?
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, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted. Thrifty has taken commercially reasonable physical, procedural and electronic safeguards to maintain data integrity and protect against loss and the unauthorized access, destruction, use or disclosure of your personal information. Electronic safeguards include encryption in the transmission and storage of data, password access and the storage of data on secure servers or computers. Physical safeguards include internal organizational measures that restrict access to data only to those whom we designate and for authorized purposes only. Despite these measures, you should be advised that even the most reasonable technical and managerial measures may sometimes fail.
How is the information used and distributed?
1. Operational Uses:
The information we collect is used by us to:
Process the rental transaction;
Improve our services to you;
Develop programs for you;
Enforce the rental agreement;
Comply with law enforcement agencies and/or other outsourced service providers. We use and distribute this information to employees of our subsidiaries, affiliates and franchisees to process, secure and confirm your car rental reservation, to monitor and improve your experience on our web site, to develop programs based on your rental profile and preferences, to protect DTAG’s rights, privacy, safety or property, and/or that of its licensees, the renter or others; and to allow DTAG to pursue available remedies or limit the damages that it may sustain. We may also use this information from time to time to conduct telephone or e-mail surveys after the transaction to gauge your satisfaction with our service. To the extent necessary, we may share this information with third parties to process your credit card charges, frequent flyer and frequent renter reward programs, to insurance companies to file claims, and to third parties for billing purposes or to enforce collection efforts against you, to detect fraud, prevent fraud and/or to comply with law enforcement agencies or other outsourced service providers.
We may collect certain personal data that constitutes sensitive data in some countries, such as data about health conditions or members of a trade union. Depending upon applicable local law, we may be unable to process such sensitive data without your consent. 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 (which may be affiliates of ours) 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 corporate account number that only members of that union or organization can use.
Please note that if you wish to rent with us or our licensees and need to provide sensitive data, you consent to that data being collected, used, retained and disclosed for our Operational Uses. We will not use sensitive data about you for marketing purposes.
You may quote a special discount code, called a “CDP number”, when you reserve or rent with Thrifty, entitling you to the special rate or benefits we may have negotiated with your company, association, credit card company or travel club (the “CDP Sponsor”). By using a CDP number, you consent to our disclosure of your personal data to the CDP Sponsor.
More about CDP Sponsors. If you rent using a CDP (Corporate or Customer Discount Program) number, you consent to our disclosure of your personal data to the CDP sponsor to:
- Administer and evaluate the program;
- Confirm your eligibility to rent using that CDP 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 CDP sponsor with you, which may include marketing uses.
If you do not wish us to disclose your personal data to a CDP sponsor for the above purposes, you must not use their DCDP number for your rental or as part of your profile. This will mean, however, that you will not be able to receive the benefits associated with that CDP number.
We use email to communicate with you regarding reservations or rentals, as well as to provide you with relevant information about our company. We provide a means to opt out or unsubscribe from emails that we send. If you wish to opt out of email communications from us, you may do so through an “unsubscribe” link included in the email, or you may request to be removed from our email list by following the directions in the “How To Opt Out section below.
In the event we are sold, merged or transferred to a non-affiliated third party (including in connection with any bankruptcy or similar proceedings), our customer list, including your individual personal information, may be included in the business assets transferred.
2. Marketing Purposes:
We also use and share this information with our subsidiaries, affiliates and our independent franchisees in the US Residents, EU Residents and Residents of Other Countries for marketing purposes to develop (i) programs that will enhance your online experience and your rental experience, (ii) services that make travel more efficient, and (iii) promotions that we offer our customers from time to time, including free rental day offers, discounts, and notices about special events and travel destinations that we believe will interest you (“Marketing Purposes”). We will not share your individual personal information with third parties for marketing purposes without your prior consent.
What choices do you have to limit the use and distribution of personal data?
We collect personal data from you and by transacting with us, you are giving us your consent to collect, use, transmit and store the personal information you provide to us. However, you have the option to limit the use and distribution of your personal information (the “Opt Out”) for Marketing Purposes as described above. If you elect to “Opt Out”, your personal information, including your email address, will not be used for Marketing Purposes by us, our subsidiaries, affiliates or franchisees. After receipt of your Opt Out, you will not receive further communications from us (except for communication via email or phone related to a specific rental transaction, and possibly, a follow-up customer satisfaction survey) and otherwise your individual personal information will not be used for Marketing Purposes as described above. We will abide by the most recent Opt Out received by us. You will, however, continue to receive program updates (i.e., Thrifty Blue Chip) and other membership information per the terms detailed in the membership agreement; and See the “How To Opt Out” section below.
You also have the option to withhold certain personal information from us except the personal information we require in completing the rental transaction. If you fail to provide us with the information we require to rent you a car, we will be unable to complete the rental transaction.
EU and Canadian 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 emailings or sharing of your data for marketing purposes, please follow the instructions below.
What access do you have to review and correct your personal data?
You have the right to verify and correct your personal information. You can update and change your personal information by sending us an email at: privacy@Thrifty.com.
How policy changes will be announced and implemented.
If any change makes the policy less protective of your personal data, such change will not apply to data we collected about you before the change was made. The only exception to this is, unless legally prohibited, where we have provided you with notice about the changes and given you the opportunity to tell us not to apply them to your personal data.
How you can contact Thrifty for complaints, questions and enforcement of the policy.
Please raise any concerns regarding our compliance with the US-EU Safe Harbor Principals and US-Swiss Safe Harbor Principles by either clicking “Contact Us” on any page of www.Thrifty.com; or writing to us at [privacy@Thrifty.com]. We have committed to refer unresolved privacy complaints under the U.S.-E.U. Safe Harbor Principals and U.S.-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by us, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
How to Opt Out.
You can stop us from using your personal information for marketing purposes by sending to us your name, address, telephone number and email address in writing, via US Mail to: Opt Out, Thrifty Online Privacy, Mail Stop 2W2, P.O. Box 33167, Tulsa, OK 74153-1167.
Important points to note
Please note the following points about the marketing choices you make:
- If you change your marketing choices, we will observe your most recent choice with regard to the contact information associated with your membership number for the relevant membership program. Marketing choices you make with regard to one membership program will not modify your marketing choices for another membership program. Although we aim to process your choices promptly, you may still receive marketing communications prepared before we received your request to unsubscribe;
- If you change your email or physical address, we will continue to follow your directions for your most recent address provided from your ‘unsubscribe’ click noted above or your Thrifty Blue Chip profile. In order for us to continue to follow your directions at a new address, you will need to update your Profile online with your updated information and provide it to us with your changed contact information;
- If your Profile contains a customer/company discount program (CDP) number, your CDP, PC or affiliation sponsor may have made marketing choices for users of that CDP, PC or affiliation. 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 in connection with those transactions in which such CDP, PC or affiliation is used.