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Privacy Policy Indie Campers Group

Last updated: June 1st, 2021

The Indie Campers Group recognizes the importance of protecting the personal data of all those who visit the website www.indiecampers.com or interact in any other way with any entity of the Group. The Indie Campers Group complies with the legislation in force in this matter, namely, the Regulation (EU) No. 2016/679 General Data Protection Regulation (“GDPR”).

Indie Campers Group

The following entities are part of the Indie Campers Group: Indie Campers SA, WCC LDA, Indie Campers Spain, S.L. , Indie Campers France S.A.R.L , Indie Campers Italy S.R.L. , Indie Campers Germany GmbH , Indie Campers Belgium SPRL , Indie Campers Adriatic D.O.O. , Indie Campers UK LTD , Indie Campers Iceland, ehf. , Indie Campers Ireland Limited, Indie Campers Central Services, Unipessoal Lda, Indie Campers Netherlands, B.V. , Indie Campers Sweden AB , Indie Campers AV GmbH.

Scope

This privacy policy applies to all personal data collected through the website www.indiecampers.com or any other interaction with the Indie Campers Group that is processed by any of its entities.

Contacts

About any question related to this privacy policy or any other question that concerns the protection of your personal data, you can contact us through email address: privacy@indiecampers.com.

Collection

Your following personal data is collected in the customer / user registration: Name, Postal address for sending and invoicing, Mobile phone, Telephone, identification tax, Date of Birth, Email address, Credit Card, Driving License Number and Citizen Card number or Passport. Likewise, data will be obtained through navigation on the website: data identifying the IP address, type of device, your browser and version, login and account information, including user name, preferences regarding marketing and to cookies, flags and web tags (pixel), payment or credit card information, in this case, always observing the SSL protocol.

Purposes of the processing

Indie Campers will process your personal data, manually and / or automatically, for the following purposes:

1. Contractual relationship management: Your personal data is processed for the purpose of managing the contractual relationship with the client, namely for the purposes of: - Pre-contractual procedures; - Reservation; - Signing of the vehicle rental contract without driver; - Rental monitoring; - Invoice management; - Management of fee payments; - Management of potential complaints; - Management of compensation for potential damage to the vehicle and insurance management; - Post-rental communications but appear within the scope of the rental contract; - Invoice management; - Management of payment of your fees; - Management of fines, in particular in relation to communications with competent authorities; - Management of potential complaints; - Management of compensation for potential damage to the vehicle.

2. Marketing: If you expressly consent, we may also process your data with the purposes of sending you information and news about your events, campaigns, special offers, products and campaigns, offers and through any communication channel, namely through the use of email, and SMS or postal mail.

3. Insurance: We share personal information with our Insurance providers which allows you to take out insurance for a specific rental. The insurers need to have access to basic information about the policyholder and the insured object in order to issue and administer the requested insurance. Information is only passed on to the insurer if a user applies for insurance. Complete information about the insurers' processing of personal data can be found on their own websites.

Lawfulness

Your data is processed lawfully and in accordance with the provisions of article 6 of the GDPR, namely because the processing at stake is necessary for the performance of a contract to which the data subject is a party, or for pre-contractual steps at the request of the data subject. However, if consent is the legally suitable means of obtaining the lawfulness of a particular processing of personal data, the data subject has the right to withdraw his consent at any time. To withdraw your consent, you can contact us by email to the following email address: privacy@indiecampers.com

Rights of data subjects

At any time and free of charge, you can exercise your rights provided for in the General Data Protection Regulation, namely: • Right of access; • Right of rectification; • Right to be forgotten; • Right to restriction of processing; • Right to data portability; • Right to object; • Right to object automate processing.

The aforementioned rights may be exercised by duly substantiated written communication to the following email address: privacy@indiecampers.com.

Storage period

We keep your data only for the period of time strictly necessary arising from the scope of the purposes set out in this privacy policy applicable in any case.

Third party

The Indie Campers Group may communicate the personal data of its users to third parties, service providers of the Indie Campers Group, namely service providers in matters of IT support. These companies are provided only with the personal data necessary for the provision of the service in question and these entities undertake to process the said personal data solely and exclusively for the fulfillment of the purposes indicated above. Likewise, the processing of user data may be carried out by a suitable service provider, hired by the Indie Campers Group or its business group. The aforementioned service provider will treat data exclusively for the purposes established by the Indie Campers Group and on behalf of the Indie Campers Group, with respect for the instructions issued by it and in strict compliance with the law.

International data transfers

Indie Campers will not transfer your data to entities located in countries outside the European Economic Area (EEA), unless required by law.

Automated decisions

Indie Campers will be able to create user profiles, which will allow the adoption of automated decisions, based on personal characteristics, preferences, history of behavior and location. In these cases, the user will have the right to request human intervention in the decision by sending an email to the following address: privacy@indiecampers.com.

Protection measures and management of personal data

Indie Campers applies several technical and organizational measures suitable to protect users' personal data, including encryption and authentication tools, to maintain the security of their personal data and uses secure servers, firewalls and communications encryption.

Cookies policy

Indie Campers uses automatic data collection systems such as cookies. The cookies that are used on this website can be installed by the same, which originate from the different servers operated by it, or from the third party servers that provide services and install cookies and / or web beacons (for example, cookies that are installed to promote advertising services or certain content through which the user views advertising or content at predetermined time). The user will be able to search his computer's hard disk according to the browser's instructions. The user has the possibility to configure his browser to be notified, on the computer screen, about the receipt of cookies and to prevent their installation on the hard drive. Information pertinent to this configuration is available in instructions and manuals of the browser itself. If you configure your browser to block or delete cookies, we cannot guarantee that you will have access to all the features and services offered through this website).

Changes to privacy policy

Applicable law and our business practices may change over time. If we decide to update our privacy policy, the changes will be posted on our website, so we recommend that you periodically review this document to stay up to date. If we materially modify the way we process your personal data, we will notify you in advance and, when legally required, we will ask for your consent prior to the implementation of such changes.

II.SPECIFIC TERMS (applicable to USA bookings only) & Scope

These Privacy Policy Specific Terms apply ONLY to bookings in the U.S.A., entered into with INDIE CAMPERS USA INC. The provisions in these Privacy Policy Specific Terms derogate any conflicting provisions in the General Terms.

What this policy covers

Your privacy is important to us, and so is being transparent about how we collect, use, and share information about you. This policy is intended to help you understand what personal information we collect about you, how we use the personal information we collect, how we share the personal information we collect, how we store and secure the personal information we collect, how to access and control your personal information how we transfer personal information we collect internationally other important privacy information and additional data protection provisions. Indie Campers, “we” and “us” refers to Indie Campers USA Inc. and all of our travel divisions. We offer a wide range of travel services, including our car, motor home and campervan rental services. We refer to all of these products, together with our other services and websites as "Services" in this policy. This Privacy Policy covers the personal information we collect about you when you use our services, or otherwise interact with us unless a different policy is displayed. If you do not agree with this policy, do not access or use our Services or our website or interact with any other aspect of our business. Please note, we provide services directly to customers, or under contract with a third-party organization (for example your employer). Where we provide services under contract with a third party, you should refer to that third party’s privacy policy for additional information about how your personal data is processed.

What information we collect about you

We collect personal information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.

Information you provide to us

We collect personal information about you when you input it into the Services, including the Indie Campers products you use, whether by posting, sending or sharing, or otherwise providing it directly to us.

Account and Profile Information

We collect personal information about you when you register for an account, create or modify your profile, set preferences, sign-up for or make bookings through the Services. You may also have the option of adding a display name, profile photo, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services.

Personal information you provide through our products

We collect your personal information when you fill in booking information or when you speak to our customer services personnel including Name - so we can address you; Age - rates and insurance premiums differ with ages; Country of residence - some suppliers vary rates by country of residence; Telephone number and email - to contact you on; Credit Card information - to charge you once your booking is confirmed.

Personal information you provide through our support channels

The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you have and any other related information that would be helpful in resolving the issue.

Payment Information

We collect certain payment and billing information when you make a booking or enquiry, to charge you once the booking is confirmed. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.

Information we collect automatically when you use the Services

We collect personal information about you when you use our Services, including browsing our websites and taking certain actions within the Services.

Your use of the Services

We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use, the links you click on and frequently used search terms. The information we collect about your use of the Services is limited to clickstream data about how you interact with and use features in the Services, in addition to content-related information described in " Information you provide through our products " above.

Device and Connection Information

We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you access our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.

Cookies and Other Tracking Technologies

Indie Campers and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices.

Information we receive from other sources

We receive personal information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.

Other users of the Services

Other users of our Services may provide information about you when they submit content through the Services. For example, we may receive your email address from other Service users when they provide it in order to add you to the booking or invite you to the Services.

Other services you link to your account

We receive information about you when you link a third-party service with our Services. For example, if you create an account or log into the Services using your Google or Facebook credentials, we receive your name and email address as permitted by your Google or Facebook profile settings in order to authenticate you. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.

Indie Campers Partners

We work with a global network of partners who help us market and promote our products, generate leads for us, and resell our services. We receive and share information with these partners, such as billing information, contact information, and what country you are in.

Other Partners

We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with our Services and online advertisements.

How we use information we collect

How we use the personal information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. Our primary purpose in collecting your personal information is to help with a smooth and efficient booking process for you. Having your information allows us to provide services to best suit your needs and make your experience quick and easy. Below is more information about the specific purposes for which we use the personal information we collect about you.

To provide the Services and personalize your experience

We use personal information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in and provide customer support. We combine personal information about you and your activities to provide an integrated experience, such as to allow you to find information from one Service while searching from another or to present the relevant product information as you browse across our websites.

For research and development

We are always looking for ways to make our Services smarter, faster, secure, integrated, and useful to you. We may use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. For example, to improve a certain feature, we automatically analyse recent interactions of users and how often they use the feature to gather the most relevant information. We may automatically analyse and aggregate frequently used searches to improve the accuracy and relevance of suggested products. In some cases, we apply these learnings across our Services to improve and develop similar features or to better integrate the services you use. We also test and analyse certain new features with some users before rolling the feature out to all users.

To communicate with you about the Services

We use your contact information to send transactional communications via email and within the Services, including confirming your booking, reminding you for payments, responding to your comments, questions and requests, providing customer support, and sending you notices. We also send you communications as you onboard to a Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases, you cannot opt-out of them. If an opt-out is available, you will find that option within the communication itself or in your account settings.

To market, promote and drive engagement with the Services

We use your information, including contact information and information about how you use the Services, to identify and send promotional communications that may be of specific interest to you, including by email and by displaying Indie Campers ads on other companies' websites and applications, as well as on platforms like Facebook and Google. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about latest deals that we think may be of interest to you. We also communicate with you about new offers, promotions and contests.

Customer support

We use your personal information to resolve the issues you encounter, to respond to your requests for assistance and to improve the Services.

For safety and security

We use personal information about you and your Service use to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies.

To protect our legitimate business interests and legal rights

Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.

With your consent

We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission. You may withdraw this consent at any time.

How we share information we collect

To complete your booking, we may pass your information on to our suppliers. We also share personal information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services. These parties include:

Service Providers

We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.

Indie Campers Partners

We work with a global network of partners who help us market and promote our products (for example, by providing consulting and sales services), who generate leads for us, help us improve our products and Services and resell our Services. We may share your information with these partners in connection with these services, such as to assist with marketing and promotions, or as part of our agreement with them. With your consent: We share information about you with third parties (including Indie Campers partners and resellers) when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights

In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Indie Campers, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

Security of transactions

Our secure booking server uses encryption to ensure the industry standard levels of security. Any information, including credit card details, that you enter and submit on this page will be encrypted and securely transmitted. When your transaction is complete your information is stored in an encrypted state.

Account information

We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.

Marketing information

If you have elected to receive marketing emails from us, we may retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your account. We may retain information derived from cookies and other tracking technologies for a reasonable period from the date such information was created. Any other personal data will be retained for the purposes of our business dealings and in meeting our legal requirements. Once personal data is no longer needed, as outline above, we will take reasonable steps to securely destroy or de-identify that information unless we are prevented from doing so by law. If destruction or de-identification is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

How to access and control your information

You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations. Depending on relevant data protection laws, you may have additional rights which are described in the Additional Data Protection Provisions.

Data subject rights

You have the following rights: to ask for and receive details about the personal information we hold about you; to request a copy of your personal information; and to correct or complete any inaccuracy or omission in your personal information. You can exercise some of the choices by logging into the Services and using settings available within the Services or your account. For all other requests, you may contact us as provided in the Contact section below to request assistance Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Access and update your information

Our Services give you the ability to access and update certain information about you from within the Service. For example, you can access your profile information from your account. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.

Deactivate your account

If you no longer wish to use our Services, you may be able to deactivate your Services account by changing your account settings. Otherwise, please contact us as provided in the Contact section below to request assistance. Please be aware that deactivating your account does not delete your information. Your personal information remains visible to other Service users based on your past participation within the Services. For more information on how to delete your information, see below.

Request that we stop using your information

In some cases, you may ask us to stop accessing, storing, using and otherwise processing your personal information where you believe we don't have the appropriate rights to do so. For example, if you believe an account was created for you without your permission or you are no longer an active user, you can request that we delete your account as provided in this policy.

Withdraw consent

Where you gave us consent to use your personal information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your personal information for marketing purposes by contacting us, as provided below.

Opt out of communications

You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.

How we transfer information we collect internationally

We collect information globally. As part of our global operations, we may transfer, process and store your information with affiliates in countries outside of your country of residence. We may also transfer, process and store your information outside of your country of residence to wherever our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it and ensure we comply with relevant data protection legislation.

Other important privacy information

Links and Third-Party Widgets

The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. Your use of and any information you submit to any of those third-party sites is governed by their privacy policies, not this one. We encourage you to carefully read the privacy policy of any website you visit. Some of our Services contain widgets and social media features, such as the Facebook "like" button. These widgets and features collect your IP address, which page you are visiting on the Services, and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it. We are not responsible for the privacy or security practices of other organizations, which may be different from this policy. To the extent that we may be regarded as a joint controller with any third-party site, including Facebook, the terms of the joint controllership arrangement are as detailed on the third-party site.

Our policy towards children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16 without parental or guardian consent unless allowed by relevant local laws. If we become aware that information about a minor has been collected without the appropriate consent or approval, we will take steps to delete such information. If you become aware of any circumstance where we have collected information about a minor without the appropriate consent or approval, please contact our support services.

Changes to our Privacy Policy

We may change this privacy policy from time to time. We will post any privacy policy changes on this page and, if the changes are significant, we will notify you by sending you an email notification. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this privacy policy, you will need to stop using the Services and deactivate your account, as outlined above.

Additional Protection Provisions

CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights around Indie Campers collection, use, and sharing of their personal information. Indie Campers does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information. Indie Campers collects various categories of personal information when you use the Service, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. If you are a resident of California, you have the right to request to know what personal information has been collected about you and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow Indie Campers to retain and use certain personal information notwithstanding your deletion request. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so. Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy or would like to change your preferences, you may contact us at the address listed above.