Privacy Policy

Klass Wagen SRL (with the commercial name Klass Wagen) controls the processing of personal data on its platforms, acting as a personal data controller in the meaning of the law on personal data protection. Klass Wagen SRL is a private limited liability company incorporated under the Romanian laws, with the registered office in Timișoara, 16 Decembrie 1989 Boulevard, no. 35, Timiș County and the headquarters in Otopeni, 289 Bucureștilor Road, Ilfov County, Romania.

Contact us at dpo@klasswagen.ro if you have any questions or problems with regard to the use of your personal data and we will be glad to help you. By using this site and/or our services, you agree with the processing of the personal data as described in this privacy policy.

We offer a wide variety of services related to online rental of cars, including products and services such as insurance, by means of our website, mobile applications, emails and text messages, social media (“platforms”), and in this respect we will need to conclude as well various service contracts. This Policy applies to all of the personal data that we collect while we perform the actions described above or when you reach to us by email, live chat, telephone or posting.

 

Definitions

Personal data - any information regarding an identified or identifiable natural person;
Processing - any operation or set of operations performed on the personal data or sets of personal data;
Person concerned - natural persons whose personal data is processed;
Child - a natural person aged under 18 years;

 

Data protection principles

We undertake to perform the following principles of personal data protection and processing:

• The processing is legal, correct and transparent. Our processing activities have legal grounds. We always take into consideration your rights prior to the processing of personal data. We shall provide you with information on the processing on request;
• The processing is limited in terms of purpose. Our processing activities correspond to the purpose for which the personal data was collected;
• The processing is performed with minimum data. We collect and process only the minimum amount of personal data necessary for any purpose;
• The processing is unlimited. Nevertheless, we shall only store the personal data if necessary and in accordance with the applicable law;
• We shall do our best to ensure data accuracy;
• We shall do our best to ensure data integrity and confidentiality;

Rights of persons concerned

The person concerned has the following rights:

1. The right to information - which means you must be aware if your personal data is processed; which data is collected, where it is obtained from and why and by whom it is processed.
2. The right of access - which means you have the right to access the data collected from/about you. This includes your right to solicit and to obtain a copy of your collected personal data.
3. The right to update/correct - which means you have the right to solicit the correction or removal of your personal data, which is incomplete or inaccurate.
4. The right to remove - which means that in certain circumstances, you may solicit the removal of your personal data from our records. We mention that the definitive removal of all of the data shall be made in accordance with the current legislation.
5. The right to restrict the processing - meaning that if it is applicable in certain conditions, you have the right to restrict the processing of your personal data in accordance with the applicable legislation.
6. The right to oppose to the processing - meaning that in certain cases you have the right to oppose to the processing of your personal data, for instance, without limitation, for direct marketing purposes.
7. The right to oppose to the automatic processing - which means that you have the right to object to the automatic processing, including of profiling; and to not be subject to a decision based exclusively on the automatic processing. This right may be exercised every time there is a result of the profiling that causes some legal effects which affect you significantly.
8. The right to data portability - you have the right to obtain your personal data in an adequate format or, if possible, as a direct transfer from a processor to another.
9. The right to file a complaint - in case we refuse your request on the basis of the Rights of Access, we shall communicate to you the reason for which we do so. If you are not pleased with the manner in which your request was treated, please reach to us;
10. The right to help from the supervisory authority - which means that you have the right to get help from a supervisory authority and the right to other remedies, such as the request for compensations in court.
11. The right to withdraw the consent - you have the right to withdraw any consent given for the processing of your personal data in accordance with the applicable legislation.

What personal data we collect

The contact form from all of the website pages.

These are:

• surname, name, email address, telephone number.

In case of information solicited by email, telephone or social media, necessary to obtain a booking or an offer:

• the name, age, birth date and place, contact details (email, address and telephone number). They may include as well identification details, such as the passport, identity card and driver’s license or information necessary for payments (bank card or accounts).

In addition, we collect information from your computer when you use one of our platforms, even if you do not complete a booking, and in this respect please see as well our Cookie Policy, available here. This may include the IP address, the web browser that you are using and the language settings.

Personal data that we receive from other companies. We can obtain information about you from the social media platforms, our business partners and other third parties. For instance:

• We work with affiliated business partners to supply our services on other platforms. When you make a booking on one of these platforms, it is possible that we share your personal data with them, and it is possible that they share your personal data with us.
• Companies that supply the services you have booked by means of our platforms might need to send us information on you - for instance, if your booking leads to an insurance claim or a dispute that regards the customer service.

Also, our business partners can send us information on you to help us display more relevant ads for you. We can combine any of these information with the information you supply to us directly.

 

In certain cases we use the social media (FACEBOOK, WHATSAPP, INSTAGRAM, etc.) to communicate with you. We will NEVER ask you to send us personal data by means of these networks. We recommend you to use the email addresses displayed on the website. If you choose to send personal data by means of WHATSAPP, for instance, the responsibility shall rest entirely with you. We do NOT undertake any liability for the personal data received by means of the social media platforms.

 

How we use your personal data

We solicit your personal data to book your car and to make sure you benefit from the best service possible. The main reasons for which we collect your personal data are:

• Bookings: First, we use your personal data to complete and manage your booking (or another product or service, such as the insurance);
• Customer service: Our Customer Service team needs your details to help you, for instance, to make a booking or to answer to any questions you have before, during or after making the booking;
• Client reviews: We may use your contact details to send a short questionnaire on your booking or to solicit you to provide us with a review on one of the social medial platforms (Facebook, Google). This helps us understand and improve our services. Your review shall help future clients make the right choice and our business partners improve the services they offer. By sending a review, you agree to be displayed.
• Marketing activities: Also, we use your personal data for the marketing activities that shall include: contacting you by telephone, email or SMS with various information;
• Communication with you: There may be as well other times when we contact you by telephone, email or SMS, to answer to the questions and requests addressed, to implement the rental contracts concluded or to complete a booking that you have initiated and not finished.
• Fraud detection and prevention: In order to supply to you a safe and trustworthy service, we use your personal data to detect and prevent frauds and other illegal or unwanted activities. Similarly, we may use the personal data for security and risk assessment purposes, that can include the verification of the users and bookings. This can sometimes mean we may have to put certain bookings on hold.
• Improving our services: We analyse personal data to help us improve the functionality and quality of our online services, and enhance the whole user experience. We're always working to make our platforms easier and more enjoyable for you to use.
• Call monitoring: We may record phone calls made to register the booking or to implement the rental contract, to make sure we're consistently providing a top-quality service.
• Legal purposes: Finally, in certain cases, it might be necessary to use your personal data to solve certain legal disputes, for the fulfilment of our legal obligations or for any investigations of public authorities.

If you are a collaborator/representative/employee of a KLASS WAGEN collaborator, we shall process the personal data put at disposal by you to carry out our specific activity, and this shall include:

• Performance of our activity: the performance of various tasks and services in relation with the implementation of the rental contracts concluded with our clients or for the support services ancillary to our specific activity (e.g., the implementation of the contracts concluded with your employing organization or the organization represented by you, or concluded with you directly).
• Fraud detection and prevention: In order to supply a safe and trustworthy service to our clients, we use your personal data to detect and prevent frauds and other illegal or unwanted activities.
• Legal purposes: Finally, in certain cases, it might be necessary to use your personal data to solve certain legal disputes, for the fulfilment of our legal obligations or for any investigations of public authorities.

 

Which is the legal ground of the personal data processing?

To process such personal data, we rely on the following legal grounds:

• Execution of a contract in which you are a party: We must use your personal data to fulfil any contract you have concluded with us. For instance, when you book a car or when you represent an entity with which we have concluded a collaboration contract, you must provide us with certain information related to you to be able to conclude the contract.
• Legitimate interests: We may use your information for “our legitimate interests” (a term that applies to any activity about which we believe it is an essential part of the efficient performance of our business), at the same time with the observance of your rights and the law. For instance, to be able to offer you the most appropriate content on our platforms, to improve and promote our products and services.
• Fulfilment of legal obligations: We may use your personal data for the administrative and legal aspects of our activity. For instance, if we are forced to collect certain information on our clients for tax or accounting purposes or if we are forced to submit information to the courts or the regulatory authorities.
• Consent: We may rely on your consent to use your personal data in certain circumstances, for instance for direct marketing purposes, to contact you in view of completing a booking or to obtain your review on the quality of the services supplied by us. You may withdraw your consent any time by sending a request in this respect to dpo@klasswagen.ro mentioning “Confidentiality” in the subject section.

 

Who else has access to the personal data

There is a number of various business partners integrated in the services that we supply and, in certain situations, we may disclose your personal data to them. We shall disclose, as well, your data to other third parties, that can include suppliers of payment services, publicity partners and - in certain cases - public authorities

• Our business partners: We work with business partners from the whole world. Some of our partners offer or promote our services, helping the other business partners offer and promote as well their own services related to travelling (including insurance). Among our business partners may be as well the Booking Holdings Inc group (Agoda.com, Booking.com, priceline.com, KAYAK and OpenTable). When you make a booking on one of the platforms of our business partners, they will send us some of the personal data supplied by you. Similarly, we can send to our business partners few personal data related to your booking, if you have collaborated with them in view of making the booking. If the business partner offers assistance for the customer service, we shall send them the details of your booking that they need in order to offer you the assistance that you need. In any of these cases, the management of your personal data is governed by the confidentiality notices of these business partners. When you make a booking on the website of a business partner, please see as well the notice regarding their confidentiality to determine how they process your personal data. When you buy a product or a service supplied by one of our business partners, we shall send to them the personal data that they need in order to supply it. Finally, it is also possible to change information on our users with the business partners for fraud detection/prevention purposes, but only information which is strictly necessary.
• Competent authorities: We may disclose the personal data to public or investigation authorities as well, if we are forced to do so by law (or any regulation having power of law). This includes courts of law, bodies of civil and/or criminal research, writs of summons and orders arising from trials and legal investigations. Also, we may disclose your personal data if it is strictly necessary to prevent, detect or prosecute frauds and other criminal acts. And it might be necessary that we disclose the personal data to the competent authorities to protect and defend our rights or properties and/or the rights and/or properties of our business partners.
• Suppliers of third-party services: We may use suppliers of third-party services to process your personal data on our behalf. For instance, we may use it to invoice the services supplied by you or by us to you, to organize payments, payment guarantees or the return of the payment.

We shall verify any third party with whom we come in contact to make sure that they can provide us with enough guarantees as regards the confidentiality and security of your personal data. We shall conclude written contracts with them, that shall include provisions regarding the insurance of the protection to be applied by them to your personal data, respectively of its compliance with the legislation in force and our data security standards and international transfer restrictions.

 

Transfer of personal data outside the European Economic Area

We mention that there may be situations where we transfer the personal data processed by us to countries outside the European Economic Area (“EEA”), for instance, when one of our service supplier uses its personnel or equipment located outside the EEA - for instance, a supplier of cloud services located in the United States of America. We have created adequate guarantees with regard to the protection of private life, your fundamental rights and liberties and with regard to the exercise of your rights, we establish for instance an adequate level of data protection, normally through the Contractual Clauses type UE based on the model of clauses issued by the EU Commission or other available mechanisms. If you wish to consult a copy of any relevant provisions, please reach to us.

 

How we ensure your data security

Our business systems and procedures have been drawn up in order to include all of the reasonable measures to protect your personal data and to defend it against unauthorized access or destruction, in accordance with the Romanian and European legislation on data protection. Also, we have specific procedures and restrictions of security (both technical, and physical) that limit the access to and the use of any personal data held by us. Only the authorized personnel may access the personal data and only for specific, authorized reasons. Even if we do our best, we cannot guarantee the security of the information. Nevertheless, we undertake to notify the competent authorities about any violation of data protection. Also, we shall inform you if there is any threat to your rights or interests. We shall do everything we can in a legal and reasonable manner to prevent the violation of security and to assist the authorities if there shall occur any violation.

 

Policy concerning minor persons

We do not supply services to children aged under 18 years, and we reserve our right to remove any information that we might receive from a child under this age. We might receive information about children in certain situations, such as an insurance claim or a dispute that regards the customer service. If such thing shall happen, we shall collect and use this information only with the consent of the child’s parent or tutor.

 

How long do we keep your personal data?

The period of time in which we keep your personal data depends on the purpose for which it was obtained and its nature. We shall keep your personal information not more than it is necessary to fulfil the purposes described in this Privacy Policy, except for the case where the law solicits a longer period of storage. We have implemented adequate measures to make sure that your personal information is safely removed in a timely and consistent manner when it is no longer necessary and it is not processed anymore by us.

In certain situations we might store your personal data on longer periods of time, in accordance with the legislation in force, in order to keep an accurate record of your relations with us, in case of complaints and/or challenges, or if we reasonably consider that a dispute might arise in relation with your personal information and relations. 

 

Contact information

 

KLASS WAGEN S.R.L.

Email: dpo@klasswagen.ro