Date of update: 20.07.2023
1. Information about us "EasyRentBulgaria" Ltd (the Administrator / EasyRent / We), is a company registered in the Commercial Register of the Registry Agency with UIC 202163172, with registered office and registered address. The registered office and registered address of the registered office are. K.K. +359 899 999 179, telephone.
2. Our treatment of your personal data
3. For which persons does EasyRent process data?
In connection with the provision of our services, EasyRent processes data about the following Data Subjects ("Subjects", "you", "you"):
Users (visitors) of the EasyRent website - https://easycarsbg.com/ (the "Site"), without registration;
Users of the EasyRent Site with registration;
Lessees of motor vehicles (vehicles) under a vehicle rental agreement;
Natural persons - third parties who are not the renters of the vehicle, information about whom EasyRent collects and processes in connection with or in relation to the car rental contracts - e.g. additional driver; in the case of a reservation made on behalf of another person; participants in an accident with the rented vehicle;
Individuals who have made enquiries (including by calling), requests, signals, complaints or other correspondence to EasyRent;
Individuals whose information may be contained in such inquiries (including by call), requests, signals, complaints or other correspondence directed to EasyRent.
4. What personal data do we process about you?
А. Logs. Use of the Site without registration. Cookies
The Site uses logs for the following purposes:
To ensure the reliable operation of the Services and to identify technical problems;
To secure the Services and detect malicious activity;
Logs where required by law (such as logs of electronic statements).
Login Log: This log allows unauthorized attempts to access an account to be detected and automatically blocked. It is maintained for a period of up to 6 /six/ months since the last use, and contains the date and time of the login, status, whether the login is via mobile version, app or desktop browser, IP address.
Server logs, security logs (Web Application Firewalls) and other devices that fall into this category. These logs are necessary for detecting technical problems, detecting malicious activities, etc. for the purposes mentioned above. They are stored for a period of up to 6 /six/ months from the last use. The logs may contain the following information: date and time, IP address, URL, browser and device information. In addition, some devices may use cookie-based security technology. This information is processed for all visitors to the Site regardless of whether they have registered and/or logged into their account.
Б. Register and maintain an account on the Site
The use of some of our services, such as online booking, is possible after registration. To create your own user profile by registering on the Site, you will need to enter your first name, last name, telephone number, email address and password. Entering these details is mandatory in order to create an account on the Site.
In addition, information is stored about the electronic statements made by you when registering (to complete your registration and accept our terms), which include date, time and IP address.
The features of the Site also allow for the storage of additional data in your profile such as date of birth, ID number, driver's license number and nationality. These data are filled in at your request, the purpose of which is to maintain the profile for automatic and faster filling in of your personal data when proceeding to online booking. It is at your sole discretion whether and how much of this additional data relating to you to store in your profile on the Site. If you do not wish to complete this data, you may do so later when proceeding to book online. You can also remove or change them at any time.
В. Use of our services
Our services are available through our Website, external partner online car rental platforms, by phone (appointments are booked) or at EasyRent offices.
For the purposes of taking steps to enter into a contract, concluding the contract and providing our services, we process the following categories of data about you, namely:
personal identification data (such as names; identity document data - number and date of issue, issuer, expiry date;
driving licence details - licence number, date of issue, date of expiry, category for which it is valid, country of issue; address; telephone number; email address),
financial details (bank card details - card number and expiry date; details of amounts due and paid;
details of the payment instrument used;
bank account details when we receive payment through a bank account),
reservation details (such as parameters and reservation number),
GPS data for the location of the rented vehicle.
In addition, in the case of an online reservation, information is stored about the electronic statements made by you in connection with the reservation, including the date, time and IP address from which they are made, as well as from which user account they are made.
EasyRent will require the presentation (for reference) of an ID card/passport at the conclusion of the contract to verify the identity/delivery of the rented vehicle, to record/verify the correctness of the identity document data required for the contract, and to confirm your address.EasyRent does not take a copy of your identity card.
EasyRent takes and processes a copy of the driving licence and, for Bulgarian citizens, a copy of the control certificate, based on our legal obligation to provide information about the offender under the Road Traffic Act in the event of an offence committed with a vehicle hired by us to the relevant territorial structure of the Ministry of the Interior, as well as a legitimate interest in protecting our rights and interests in the event of incidents caused by you or affecting you in connection with the use of a vehicle hired by us.
Г. Enquiries, communication and customer service
In order to deal with complaints, signals, inquiries, requests or other communications addressed to EasyRent, regardless of the communication channel used (e.g. on-site at our office, by mail, by telephone, by e-mail, other online communication channels such as Viber, WhatsApp, Telegram, etc.), we store and process information contained in or related to the subject of the relevant communication, as well as the outcome of its handling.
Please note that telephone calls to our contact numbers are recorded. If you do not wish to be recorded, you may contact EasyRent through any of the other communication channels listed above.
Д. Direct Marketing
EasyRent carries out activities related to direct marketing, including conducting surveys, polls, advertisements and informing about promotions of our services, etc. in accordance with the consent you have given us. The data we will process for such purposes based on your consent is described in the relevant declaration or other document by which you express your consent to this.
In addition, we may use your contact details (email address, phone number) to send you questions/surveys about your feedback on the rental car as well as the service provided. Your completion of this questionnaire is completely voluntary.
In order to protect our property, CCTV and video recording (collectively "CCTV") is carried out in our office premises, workshops and car parks. Whilst entering, leaving or staying in the above areas you may be subject to CCTV and video recording.
5. Purposes for processing personal data
EasyRent collects, uses and processes the information described above for the purposes set out in this Policy, which may be:
Purposes necessary for the conclusion and performance of the service contract between you and EasyRent;
Purposes necessary for the fulfilment of EasyRent's legal obligations
Purposes necessary to protect and enforce the legitimate interests of EasyRent, our partner or other users of the Services;
Purposes for which you have given your explicit consent.
5.1. Conclusion or execution of a contract
These are the purposes necessary for the steps in the conclusion and performance of the contract between you and EasyRent, including the processing of data necessary for this purpose when you register, create and maintain an account on the Site, the activities of providing the Services available through our Site, through external partner online platforms for rent-a-car services, by phone or at EasyRent offices. In addition, these purposes include our communications with you, including by telephone or email, necessary in connection with the provision of the Services, changes to our terms and conditions, etc., below. For this purpose, it may be necessary to process some or all of the above categories of data, with the exception of those under "E" - "Direct Marketing" and "F" - "Video Surveillance".
5.2. Legal obligations
These are objectives related to compliance with EasyRent's legal obligations, which include:
performance of obligations in relation to the provisions of the Road Traffic Act;
obligations related to compliance with tax legislation, including, but not limited to, obligations provided for in the Accounting Act and the Tax and Social Security Procedural Code and other related regulations, in connection with the keeping of proper and lawful accounting records;
enabling the exercise of the control powers of the competent State authorities;
obligations to preserve and/or provide information to competent governmental and judicial authorities in accordance with applicable law;
in fulfilling the legal obligations of EasyRent to notify you of various circumstances related to your rights, the services provided, including in relation to the protection of your data, etc., etc.
For the above purposes, processing of some or all of the above categories of data may be necessary.
5.3 Legitimate interest
These are purposes related to the pursuit of the legitimate interests of EasyRent and/or third parties such as its business partners, other users of the Site, additional drivers, persons who have made a reservation for the benefit of/on behalf of third parties or those third parties for whose benefit/on whose behalf the reservation was made, other parties involved in an accident with the rented car, etc., etc.
These objectives include:
video surveillance at our commercial and administrative premises to ensure the security of our premises and property;
ensuring the normal functioning and use of the Site, maintenance, management and administration of our services;
dispute resolution, detection and prevention of malicious acts;
transfer (assignment) of claims and/or enforcement of claims. We may instruct a third party to collect our receivables (amounts you owe us) on our behalf or to assign (assign) such receivables of ours to third parties;
communicating with you, including electronically, on important matters relating to our services;
receiving and processing signals, complaints, requests and other correspondence received and communicating with you in this regard;
partnership between EasyRent and external online platforms for rent-a-car services;
protection of the rights and legitimate interests of the above third parties, including but not limited to in relation to accidents;
for the establishment, exercise or defence of legal claims and the exercise and protection of the rights and legitimate interests of EasyRent, including in court, as well as assistance in the implementation of.
For the above purposes, processing of some or all of the above categories of data may be necessary.
5.4. Explicit consent
Subject to your explicit consent, your data may be processed for the specific purposes for which you have consented to the extent and scope set out in the relevant consent.
6. Terms in which we process your personal data
The personal data provided to or collected by EasyRent may be stored in a form which permits your identification for a period which is no longer than is necessary for the purposes for which the personal data is processed. In addition, we follow the important principle of data minimization, which means that we store your data in the minimum amount.
6.1. Data that we process for the purposes of registration and maintenance of your account on the Site shall be stored for the entire period of maintenance of the account on the Site and up to 5 / five / years after termination of registration.
6.2.The additional data that you enter in your profile on the Site will be stored until they are deleted by you or until your registration is terminated, except in cases where a longer period applies, as provided for in this Policy or applicable law (e.g. where such data is used and processed in connection with the use of our services - making an online reservation).
6.3. The data that we process in connection with the use of our services and the conclusion and performance of a contract shall be stored for the duration of the concluded vehicle rental contract and up to 5 /five/ years from its termination, except in cases where some longer period applies, as provided for in this Policy or applicable law (e.g. in connection with our tax and accounting obligations).
6.4.We store invoices, financial and accounting documents and information and other information necessary in connection with our tax and accounting obligations for a period of up to 10 /ten/ years from the beginning of the year following the financial year to which the relevant data relate.
6.5. Data processed in connection with inquiries, communication and customer service (including complaints and signals) shall be stored for a period of up to 5 /five/ years, except in cases where a longer period applies, as provided in this Policy or applicable law.
Records of telephone conversations with EasyRent are kept for up to 30 /thirty/ days, except in cases where a longer period applies, as provided for in this Policy or applicable law (e.g. in the event of a dispute).
6.6. The data we receive and collect through questionnaires/surveys about your feedback is kept for a period of up to 1 /one/ year. You may at any time request that we delete this information before this period expires.
6.7.Data collected on the basis of consent shall be retained until the consent is withdrawn or until the expiry of the period provided for in the relevant consent (if any).
6.8.EasyRent stores GPS data from the rented vehicle for a period of 60 days.
6.9. The recordings from the video surveillance shall be kept for a period of up to 2 /two/ months from the moment of filming.
6.10. System logs, security and technical support logs, with the exception of logs for electronic statements, shall be kept for a period of up to 1 /one/ year. Logs for electronic statements made shall be stored in accordance with the retention periods for registration data, data on the use of our services or in accordance with other applicable periods under this Policy.
6.11. Notwithstanding the foregoing at:
Mandatory direction from a competent government authority to preserve certain data/content; or
To give rise to a specific legal dispute or proceeding,
may necessitate the retention and processing of your personal data for longer periods than those specified. In these cases, the personal data will be processed and stored in accordance with the time period specified by the competent authority or, respectively, up to 5 (five) years after the final conclusion of the dispute or proceedings before all instances.
The aforementioned data retention periods are subject to change if applicable law changes.
7. Provision/transfer of personal data outside the EU
EasyRent does not transfer personal data outside the EU and EEA unless we have explicitly stated so (e.g. in connection with a specific data processing based on your consent - in the consent declaration).
8. Who do we share your information with?
EasyRent uses third parties to administer our business, service our customers, support certain contractual activities or in fulfilling our legal obligations.
EasyRent does not provide your data to third parties other than as described in this Policy, applicable EasyRent terms and conditions and as provided by law.
8.1. Processors on behalf of EasyRent
Your personal data may be disclosed to third parties in their capacity as processors, but only after we have ensured that all technical and organisational measures have been taken to protect that data, and we endeavour to implement strict controls to fulfil this purpose. Those acting as processors on behalf of EasyRent are only required to process your data in accordance with our documented instructions and only for the purposes expressly set out by EasyRent and provided for in this Data Protection Policy. Such persons may be, for example - debt collection companies that we may instruct to collect our debts to you on our behalf, providers of technology services for hosting, maintenance of the Site and our information systems, etc., accounting service providers and other suppliers and subcontractors.
8.2. Third parties
In the case of booking a vehicle through external partner online platforms for rent-a-car services or otherwise using the assistance of such persons or travel agencies on your part in connection with the use of our services, your personal data will be exchanged between us and such persons to the extent and to the extent necessary for the execution of the respective reservations, as well as for the reporting relationship between us and them.
For the purposes set out in this Policy, your data may be provided to and/or exchanged with other third parties in connection with the performance of our legal obligations, in connection with payments made (payment service providers), in the event of an insurance event related to the vehicles, assignees (we may transfer our claims against you to third-party assignees), courier service providers, etc., etc.
In addition to the above, EasyRent may disclose your personal data to third parties where this is provided for by law, including if EasyRent is duly requested to do so by a competent governmental or judicial authority, where EasyRent has obtained your explicit consent to do so, and where this is necessary for the protection of the rights and legitimate interests of EasyRent or other third parties concerned (e.g. lawyers, notaries, etc. below).
EasyRent takes measures to protect your personal data against accidental loss and unauthorized access, use, alteration or disclosure. Policies and procedures are in place designed to protect information from loss, misuse and unauthorized disclosure.
10. Rights in relation to personal data
The General Data Protection Regulation ("the Regulation") provides the following rights for individuals:
10.1. Right to information
At any time you have the right to obtain from EasyRent informationabout the personal data that has been collected and stored about you. This Policy is intended to inform you in the processing of your personal data in connection with your use of the Site and/or our services.
10.2. Right of access
You have the right to obtain confirmation from EasyRent as to whether your personal data is being processed and, if so, to obtain access to the data, including a copy of the data (if you so wish) and detailed information about the processing and your rights in relation to that processing.
You can access your data in real time through your account on the Site.
10.3. Right of rectification
You can ask EasyRent to correct/complete inaccurate or incomplete personal data relating to you. You may correct the information you have entered in your user profile on the Site at any time through the features in the profile itself.
10.4. Right to erasure (right to be forgotten)
You have the right to ask us to delete personal data relating to you where the grounds for doing so set out in the Regulation are present.
10.5. Right to restriction of data processing
You may request from EasyRent the restriction of processing as provided for in the applicable data protection legislation if the grounds for doing so exist.
10.6. Notification of third parties
You have the right to require EasyRent to notify third parties to whom personal data has been disclosed by EasyRent regarding any rectification, erasure or restriction of processing of that personal data, unless this is impossible or requires a disproportionate effort by EasyRent.
10.7. Right to data portability
You have the right to receive the personal data concerning you that you have provided to EasyRent in a structured, commonly used and machine-readable format, as well as to transfer this data to another controller.
The right to data portability is admissible when the following two conditions are met simultaneously:
the processing is based on consent or a contractual obligation; and
processing is carried out in an automated manner.
You also have the right to obtain a direct transfer of the data from us to another controller where this is technically feasible.
10.8. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless the grounds for doing so are provided for in the applicable data protection legislation and appropriate safeguards are provided to protect your rights, freedoms and legitimate interests.
We do not use technologies that fall into this category in providing our services.
10.9. Right to withdraw consent where it is the basis for processing your data
You may withdraw your consent to the processing of your personal data in relation to EasyRent at any time where the data is processed on the basis of your consent (example - for direct marketing purposes). However, withdrawal will not affect the lawful processing of data carried out prior to withdrawal.
10.10. Right to object
You have the right at any time and on grounds relating to your particular situation to object to processing of your personal data which is based on the legitimate interests of EasyRent or of a third party or the performance of a task carried out in the public interest or the exercise of official authority, including profiling.
In the event that such an objection is received, We will consider Your request and, if justified, comply with it. If we consider that there are compelling legitimate grounds for the processing or that it is necessary for the establishment, exercise or defence of legal claims, we will inform you of this.
Where personal data is processed for direct marketing purposes, you have the right at any time to object to the processing of personal data relating to you for this type of marketing, which includes profiling insofar as it relates to direct marketing. In this case, the processing for these purposes shall cease.
10.11. Right of appeal to a supervisory authority
We inform you that you also have the right under this legislation to lodge a complaint in the event of unlawful processing of your data with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. The supervisory authority in the Republic of Bulgaria is the Commission for Personal Data Protection, 1592 Sofia Blvd. "Prof. 2 Tsvetan Lazarov or www.cpdp.bg.
Your rights may be exercised by a written request to EasyRent, submitted in person or by a person expressly authorized by you (with a notarized power of attorney), sent to the contact details listed at the beginning of this Policy. You may also submit your request to EasyRent by visiting one of the latter's offices listed on the Site - https://easyrent.bg/bg/locations.
This Policy may be amended and updated over time. Such changes will be effective immediately upon timely and lawful disclosure. In the event of any changes in relation to the processing of your data and the content of this Policy, you will be notified accordingly.