T&G respects your privacy and is committed to protecting the Personal Information that it collects by taking appropriate measures to ensure the accuracy, integrity and security of such information and to only permit appropriate access to it, in accordance with relevant laws and regulations, including (where applicable) the EU General Data Protection Regulation (EU GDPR).
- Is information that relates to living individuals and which can be identified from the data or from other information which is in the possession of, or likely to become into the possession of T&G;
- Does not include data concerning a company, a partnership or an association;
- Need not to be sensitive or secret to require protection under this policy.
The party responsible for processing your data (controller) is T&G Global Limited, 1 Clemow Drive, Mt Wellington, Auckland, New Zealand (hereinafter also referred to as T&G)
Your Personal Information
The following categories of personal data may be processed by us in connection with our services:
- Master data: These include, for example, a person’s first name, surname, address (private and/or business), date of birth
- Communication data: These include, for example, a person’s telephone number, email address (private and/or business) and address
The legal basis for data processing at T&G
Art. 6 (1) sentence 1 point a) of the General Data Protection Regulation (GDPR): Pursuant to this provision, the processing of your personal data is lawful if and to the extent that you have given your consent to such processing.
Art. 6 (1) sentence 1 point b) GDPR: Pursuant to this provision, the processing of your personal data is lawful if such processing is necessary for the performance of a contract to which you are party, or in order to take steps at your request prior to entering into a contract.
Art. 6 (1) sentence 1 point c) GDPR: Pursuant to this provision, the processing of your personal data is lawful if such processing is necessary for compliance with a legal obligation to which T&G is subject.
Art. 6 (1) sentence 1 point f) GDPR: Pursuant to this provision, the processing of your personal data is lawful if such processing is necessary for the purposes of the legitimate interests pursued by the T&G, or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, i.e., you yourself.
The purposes of data processing at T&G
We may process your personal data for the following purposes:
- Newsletter: If you sign up for our newsletter, we will use your information to send advertising emails
- Prize drawings: If you participate in one of our lotteries, we will process your data to determine and notify the winners.
- Customer Service: In the context of our customer service, we process your data to manage your requests and to improve our services.
- Events: If you attend one of our customer or product events, we process your personal data to manage the invitations.
How We Safeguard Your Personal Information
T&G has and will endeavour to maintain the appropriate technical and organisational measures to protect Personal Information against accidental or unlawful damage or destruction, accidental loss, theft, alteration, unauthorised disclosure, access or use. We endeavour to provide a level of security appropriate to the risk represented by the nature of Personal Information being protected and purpose(s) for which it is being collected.
Personal Information may only be accessed by T&G employees, contractors and agents on a need-to-know basis, for the purpose(s) for which the Personal Information has been collected and only in support of legitimate business purposes.
Please be advised, however, that while we strive to do everything reasonably possible to protect your Personal Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us and cannot be responsible for the theft, destruction, or inadvertent disclosure of your Personal Information where our security measures have been breached. Consider this when making your Personal information available to us.
Who We Might Share Personal Information With
We will not sell your Personal Information and the operation of our business does not rely on such action. Your Personal Information may be transferred to other companies within T&G’s group of companies, or other third-parties that help us deliver our services to you. These companies might be located in other countries and may be subject to different laws.
We will not share your Personal Information with third parties unless one of the following conditions or reasons apply:
- You have provided your consent. We will ask for your consent before sharing any of your Personal Information. You are entitled to withdraw your consent at any time.
- For external processing. We may provide your Personal Information to other companies within the T&G group of companies or to other trusted business partners who process data for us or provide services on our behalf. They will only be entitled to use the Personal Information in accordance with our instructions and, at all times, in compliance with all relevant Data Protection Legislation.
- For legal purposes. We may transfer your Personal Information to Government authorities as required or allowed to by applicable law.
- Further Disclosures: We reserve the right to disclose any Personal Information if we reasonably believe that such action is necessary to protect or defend the legal rights or property of T&G, our Sites or Apps and the users of them; or in an emergency to protect the health and safety of our Site’s or App’s users or the general public.
We respect the privacy of all our online guests. Our Sites, Apps and underlying infrastructure recognize and record certain information about visitors and users. The nature of the information collected may include the type of browser used, the type of operating system of your computer or other Internet access device, the domain name or Internet Protocol (“IP”) address of the visitor’s / user’s Internet service provider, the Site/App pages visited by users, the actions taken on said pages, and the character and duration of Site/App usage. In addition, our Apps will recognize and record all data that you input into it.
In the instance where users provide additional Personal Information during their use of the Site or App (for example by logging in), this Personal Information may be stored alongside the aforementioned information and all subsequently collected information. This information (both personally identifiable and non-personally identifiable) may be used for the purposes of improving our Sites and Apps, improving our business, troubleshooting issues, supporting our customers/users and any other use that we deem necessary for the effective delivery of services to our end-users and our customers. The collection of information for these purposes may be facilitated by our Apps and Sites directly or by using external third-party services (see service providers below)
You have the option of deciding whether or not to accept a cookie by resetting your browser to notify you whenever a cookie is being sent to your hard drive. You may also delete a cookie manually from your hard drive. Please note, however, that some parts of our Sites or use of our Apps may not function properly or may be considerably slower if you refuse to accept a cookie or choose to disable your cookies settings.
USE OF GOOGLE ANALYTICS (THIS TEXT IS PROVIDED BY GOOGLE, INC)
Further information can be found at:
www.google.com/intl/de/analytics/privacyoverview.html (general information on Google Analytics and data protection).
GOOGLE ADWORDS/DOUBLE CLICK
Advertising shown by us is based on the interest in products our customers previously exhibited. We record information about our customers’ surfing patterns for purposes of providing them with interest-based online advertising. For this, cookies are stored on the respective user’s computer; these contain a multiple-digit identification number. If you do not agree with having your user behaviour analysed, you can adjust your browsers settings so as to prevent analysis cookies from being set. Please note, however, that this may prevent you from being able to use in full all the functions of this website.
The search engine program Google AdWords, provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Google), facilitates the systematic display on our website of advertising based on Google search terms. For this, Google sets a cookie in the user’s browser as soon as an advert appearing in the Google search or advertising network is clicked on.
USE OF THE FACEBOOK CUSTOM AUDIENCE SERVICE BASED ON FACEBOOK PIXELS
Our website uses the so-called Facebook pixel created by the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are resident in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). This tool serves to present users of our website with advertising (“Face-book ads”) that matches their interests during their visits to Facebook. In this way we ensure that our Facebook ads correspond with the interests of the respective users and are therefore not perceived as a nuisance. We also use the Facebook pixel to track how many users click on our Facebook ads. This enables us to assess the effectiveness of those ads, which is useful for statistical and market research purposes. The Facebook pixel is activated by Facebook as soon as you open our website. It can store so-called cookies on your computer. If you log into Facebook after visiting our website, or visit Facebook while still logged in, then Facebook will assign this information to your personal Facebook account. The data recorded about you in no way allows us to draw inferences regarding your identity as a user. The collection and processing of the data by Facebook complies with the provisions of the Facebook Data Policy. For more information in this respect, please go to: https://www.facebook.com/about/privacy. You can, at any time, object to the recording of data by the Facebook pixel and the use of your data to present Facebook ads. To do so, please visit the page specially set up by Facebook for this purpose (when there, see the settings for use-based advertising), while you are still logged in to Facebook: https://www.facebook.com/settings. The settings are platform-independent, meaning that they will be assumed for all devices, whether desktop computers or mobile devices.
Transfer of Assets
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, Personal Information, non-Personal Information, and any other information that we have collected about the users of our Sites and Apps may be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Transfer to third countries
Third countries are countries outside the European Economic Area. The European Economic Area comprises all countries of the European Union as well as the countries of the so-called European Free Trade Association, which are Norway, Iceland and Liechtenstein. If you use our services, we transmit your personal data to T&G Global Limited in New Zealand. The transfer of your data to a third country is based on an adequacy decision by the European Commission. If no adequacy decision by the European Commission exists for the respective third country, then the transfer to that third country will take place subject to appropriate safeguards as per Art. 46 (2) GDPR. You can request copies of the aforementioned safeguards from T&G (see “Contact”).
Storage duration/criteria for storage duration
T&G stores your personal data until they are no longer necessary in relation to the purposes for which they were collected or otherwise processed. Where T&G is under legal obligation to store personal data, it will store personal data for the preservation period stipulated by law.
RIGHTS PURSUANT TO ART. 15 – 18, 20 GDPR
You have the right to, at reasonable intervals, obtain information about your personal data under storage (Art. 15 GDPR). The information you are entitled to includes information about whether or not T&G has stored personal data concerning you, about the categories of personal data concerned, and about the purposes of the processing. Upon request, T&G will provide you with a copy of the personal data that are processed. You also have the right to obtain from T&G the rectification of inaccurate personal data concerning you (Art. 16 GDPR). You furthermore have the right to obtain from T&G the erasure of personal data concerning you (Art. 17 GDPR). We are under obligation to erase personal data in certain circumstances, including if the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed, if you withdraw the consent on which the processing is based, and if the personal data have been unlawfully processed. Under certain circumstances, you have the right to have the processing of your personal data restricted (Art. 18 GDPR). These include circumstances in which you contest the accuracy of your personal data and we then have to verify such accuracy. In such cases, we must refrain from further processing your personal data, with the exception of storage, until the matter has been clarified. Should you opt to change to a different vehicle rental company, you have the right either to receive, in a machine-readable format, the data that you provided to us based on your consent or on a contractual agreement with us, or to have us transmit, also in a machine-readable format, such data to a third party of your choice (Right to data portability, Art. 20 GDPR).
RIGHT TO OBJECT PURSUANT TO ART: 21 GDPR
If the processing of your data by T&G is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller (Art. 6 (1) sentence 1 point (e) GDPR) or if it is necessary in the legitimate interests of T&G, then you have the right to object at any time, on grounds relating to your particular situation, to the processing of your data. T&G will then end the processing, unless we can present compelling legitimate grounds for such processing that supersede the grounds for ending the processing. You may object, at any time and without restriction, to the processing of your personal data for purposes of direct advertising.
RIGHT TO WITHDRAW CONSENT AT ANY TIME
If data processing at T&G is based on your consent, then you have the right to, at any time, withdraw the consent you granted. The withdrawal of consent shall not affect the lawfulness of processing between the time consent was granted and the time it was revoked.
RIGHT TO COMPLAIN
You have the right to file a complaint with your local Data Protection Authority.