Last Updated: June 14, 2019
Personal Information We Collect
Personal information does not include “aggregate” information, which is data we collect about the use of the FlexClub platform or about a group or category of products, services or users which does not contain any personal information (e.g., the number of rentals on the platform, the number of requests for a certain model of vehicle, or number of visitors to the site). FlexClub may compile aggregate information about the use of the platform to help us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our FlexClub Services.
- Personal information related to car rentals
When you offer your car for rent via the FlexClub Services as defined in the FlexClub Terms of Service, we will ask you for certain personal information including your name, ID number, contact information and information about your car. We may also require additional financial information from you to facilitate payment to you and to process any filings required by applicable tax authorities. When you rent a car via the FlexClub Services, we will ask you for your name, contact information, payment information and information concerning your driver’s license and Driver’s record.
FlexClub will use information from third parties (e.g., other ride-sharing platforms) to verify personal information you provide to us pursuant to the Terms of Service, and to obtain additional related information and corrections where applicable.
- Personal information collected from in-car devices
FlexClub installs a device on rental vehicles which records geo-location information. FlexClub will log and retain information recorded by the in-car device, such as location, mileage and other aspects relating to the use of the car during a rental period. This information is used for safety, security, technical, and other related commercial purposes, including to provide and improve FlexClub’s products and services.
- Personal information from the use of our platform
We collect and store communications you make through the site, including your postings on site pages. We may use those communications for internal purposes, including to better understand how members use the platform, as well as for security purposes.
FlexClub also logs each visit to each web page on the site. The log may contain information such as the browser type you used, your Internet Protocol address, and the date and time of day of the visit. We may also log your cookie's identification number and the URL of the last site you visited. This log information is important for security and quality improvement (e.g., to detect and remove any technical bugs), as well as for monitoring the proper performance of our platform. As noted elsewhere in this policy, this log data is kept for a maximum of 14 days, after which time it is deleted.
- Website Cookies and related tools
We collect certain personal information through the use of “cookies” and clear gifs when you access our website. Cookies are small data files that are stored on a user's hard drive at the request of a website, to enable the site to recognize users who have previously visited them and retain certain personal information such as IP address and other online identifiers. Clear gifs (also known as web bugs or web beacons) are small, invisible graphic images that may be used on the site or in emails relating to the site to collect certain information and monitor user activity on the site.
Our website uses the following types of cookies:
Necessary cookies, which are needed for our website to function properly and enable basic functions like page navigation or access to certain features;
Preference cookies, which allow us to remember information from your browser to customize certain features to requested preferences, like preferred a language or region; and,
Statistical/analytical cookies, to obtain information about the quality and/or effectiveness of our website and platform (e.g., how many users accessed a particular page or feature). We use Google Analytics cookies for this purpose.
FlexClub’s website does not use any “tracking” cookies for targeted advertising or other similar purposes. If you wish to block, erase, or be warned of cookies, please refer to your browser’s instructions or help screen to learn about these functions. However, if a browser is set not to accept cookies or if a user rejects a cookie, some portions of our website may not function properly.
How and Why We Use Personal Information
The Company will use your personal information solely for its internal business purposes in connection with the provision of the FlexClub Services.
We collect and use personal information related to car rentals:
to enter into contracts and fulfill our contractual obligations to Owners and Renters – for the purpose of providing you with information or services you request, processing your requests and transactions, and verifying your account information;
to pursue our legitimate interests, including to:
provide an online marketplace and platform to support lead generation platforms and facilitating our administration and operation of the platform;
help resolve complaints, disputes or conflicts (e.g., in the event of an accident);
enforce our Terms of Service (including to ensure that parties who participate in the FlexClub platform are qualified to do so);
protect the safety, rights, property and security of FlexClub and FlexClub services;
detect and prevent fraud or other activities which may be illegal, unethical or otherwise legally actionable; and,
maintain appropriate insurance policies.
to comply with applicable legal obligations – for example, tax laws.
We collect and use personal information from in-car devices to pursue our legitimate interest in overseeing the use of vehicles rented on our platform, including to:
ensure the safety of drivers and security of vehicles;
maximize the utilization of vehicles;
carry out safety, security, or other technical functions as may be necessary; and
provide and improve FlexClub’s products and services.
We collect and use personal information from website visitors and online platform users, as well as Cookie information, to pursue our legitimate interest in providing our services to the lead generation platforms, for the purpose of:
operating our website and ensuring its proper functioning;
saving user preferences (e.g., language and region) for future visits to the website or platform;
understanding better how our users engage with the platform through statistical data and related information; and
informing you about promotions, products or services we think will be of interest to you.
How We Share Personal Information
Sharing with Other Parties in Rental Transactions
FlexClub enables Owners to offer and rent their vehicles to Renters. If you agree to use FlexClub Services pursuant to the Terms of Service, FlexClub may provide your personal information to the other party (or parties) in that transaction as reasonably necessary to facilitate the rental transaction. For example, FlexClub may provide your mobile phone number to facilitate communication or your photograph to facilitate identification.
Sharing with Vendors and Service Providers
FlexClub may also share personal information with vendors and service providers who are engaged by or working with us in connection with the operation of our site and platform and who need access to such information to carry out their work for us. In some cases, the service provider may be directly collecting the information from you on our behalf. FlexClub will choose service providers who give sufficient guarantees to protect personal data and implement appropriate measures to comply with applicable data protection laws.
Sharing with Other Companies
Sharing for Other Purposes
FlexClub may disclose personal information in the good faith belief that we are lawfully authorized or required to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of FlexClub, our users, our employees or the public. That includes actions we may take to protect FlexClub or our users from fraudulent, abusive, inappropriate or unlawful use of our site or platform. Information about our users, including personal information, may also be disclosed or transferred as part of, or during negotiations of, any merger, sale of company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of FlexClub.
You understand that when you use the site, information you post in your profile or in any other area of the site will be available to other users and in some cases may be publicly available.
How Long We Keep Personal Information
We will generally only keep your personal information for as long as necessary to fulfill the purpose for which it was collected.
We will retain general business records (e.g., purchase and sales records or credit and debit accounts) for 7 years, in accordance with the laws of the Netherlands.
As noted previously in this policy, website log data collected for purposes of de-bugging and ensuring the proper performance of this site is kept for a maximum of 14 days and then deleted.
International Transfers of Personal Information
FlexClub transfers personal information out of the European Union/European Economic Area on the basis of the derogation of performance of a contract in the interest of the Owner or Renter.
Personal Information Rights
Under applicable law, you may have certain rights pertaining to your personal information, including the right:
- to access your information;
- to rectify or update your information;
- to erase your information, subject to our need to retain certain information for legal or other purposes;
- to receive a copy of your information;
- to object to or restrict the processing of your information;
You can exercise these rights by contacting us firstname.lastname@example.org.
Under applicable law, you may also have the right to lodge a complaint with a data protection authority.
We have endeavored to put into place reasonable security measures in an effort to protect personal information while it is under our control.
Your account information is accessible online through the use of a password. To protect the confidentiality of personal information, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of our web site by any person using your password. Please advise us immediately if you believe your password has been misused.
Updating your information or opt-out of emails
If you wish to opt-out of marketing and promotional emails, please contact us at email@example.com. You may not opt-out of receiving service-related emails. If you would like to update your information, please contact FlexClub’s customer service at firstname.lastname@example.org.
Managing your data
If you wish to get a full download of the data the platform has on you please contact email@example.com. This data will be provided within a few weeks.
Should you wish to leave the platform and have all your data be completely removed please send an email to firstname.lastname@example.org. Note it can take up to 180 days to have all your data removed from the logs, but the data in the database will be removed as soon appropriate laws allow.
FlexClub welcomes your questions and comments about privacy, and what we do.
For privacy related queries, please email us at email@example.com
For security related queries, please email us at firstname.lastname@example.org
For any other queries, including opt-out requests, please email us at email@example.com