Virtuo only uses personal data for the purposes for which they were collected.
The personal data collected on our Site and/or our Application and/or when using our Services is used for the following purposes:
Using the Application
This processing is necessary to identify you and to prepare and facilitate your future bookings and rental contracts, and is based on the implementation of contractual measures.
The data is retained for the duration of the commercial relationship. However, information that serves as evidence of a right or a lease, or that must be retained by virtue of a legal obligation, is subject to an intermediate archiving policy for a period that shall not exceed the purposes of retention.
Managing reservations and rentals, and in particular in order to:
- confirm, modify, and cancel your reservations;
- perform identity, security, driver's licence and credit checks;
- confirm and insure your rentals;
- communicate with you regarding your reservation and rental (e.g. send reminder notifications before you pick up or drop off the vehicle);
- manage your rentals (vehicle pick-up and drop-off);
- manage your communication (by email, phone or chat) with the customer service
- manage the payment of services;
- manage your invoices;
- manage the collection of amounts due;
- manage potential claims;
- manage the potential recovery of compensation in the event of damage to the vehicle; and
- manage your insurance.
This processing is necessary to enable the booking and the execution of the rental contract, and is based on the execution of contractual measures.
The data is retained for the duration of the business relationship, i.e. until you delete your user account. However, information that serves as evidence of a right or a lease, or that must be retained by virtue of a legal obligation, is subject to an intermediate archiving policy for a period that shall not exceed the purposes of retention. Records of exchanges with the customer service are kept for five (5) years from the last contact with the customer.
Managing tickets, in particular in order to:
- transfer the identity of the principal driver mentioned on the rental contract to the National Automated Ticket Processing Agency (Agence Nationale de Traitement Automatisé des Infractions, ANTAI); and
- to satisfy the procedures for the collection of the fines to which Virtuo is subjected, with regard to the French and foreign authorities, as well as the corresponding invoicing.
This processing is based on a legal obligation.
The data is retained for the time necessary to identify the driver responsible for the commission of the offence that gave rise to the ticket, which may not exceed forty-five (45) days from the receipt of the ticket for offences in France. However, the relevant information is kept for a longer period of time, from the time the ticket is received, as part of an intermediate archiving policy.
Managing a list of clients with certain contractual risks, with respect to:
- payment incidents resulting in litigation ;
- traffic accidents or repeated damage caused by a Virtuo customer;
- accidents or damages caused deliberately by a Virtuo client; and
- the use of Virtuo's Services in violation of the General Terms and Conditions of Rental.
This processing is based on Virtuo's legitimate interest and aims to reduce Virtuo's exposure to risks during the execution of the rental contracts. If you appear on this list of at-risk clients, your reservation or rental request may be rejected. Under certain conditions, you may challenge this decision by contacting firstname.lastname@example.org.
The data is retained for three (3) years from the date of the event in case of unpaid incidents and accidents; for five (5) years from the date of the event in case of breaches of the General Rental Conditions, it being specified that the data relating to payment incidents shall be deleted as soon as the situation is resolved.
Making automated individual decisions, based on:
- booking habits;
- rental patterns; and
- contractual risks.
This processing is based on Virtuo's legitimate interest and aims to improve the processing time for reservation requests, but also to reduce Virtuo's exposure to risks during the execution of rental contracts. Depending on the results of this processing, your reservation or rental request may be rejected. If you have been subject to such a decision, you may request a review of your situation, express your views, obtain an explanation of the decision taken, or challenge that decision, by contacting email@example.com.
This data shall be retained for the duration of the commercial relationship. However, data concerning contractual risks shall be kept in compliance with the maximum periods for processing customers presenting contractual risks as set out above.
Managing the location of vehicles
The geolocation of rental vehicles is used to provide you with a 24/7 vehicle access service, to prevent potential offences, to combat theft and fraud, and to obtain a vehicle status in case of emergency. Virtuo never uses this location data to track or monitor your movements during the rental.
This processing is based on the legitimate interest of Virtuo.
The data is retained for a maximum period of nine (9) months from the date of rental of the vehicle.
Managing the means of proof in case of damage
The video recording of the driving captured by on-board camera aims to determine precisely the responsibilities of each party in case of damage to the vehicle, and in particular, to protect you from unjustified claims from third parties.
This processing is based on Virtuo's legitimate interest in reducing disputes between Virtuo and yourself in case of damage to the vehicle.
The data is retained for a period of six (6) months, or until the vehicle has been driven for three hundred and twenty-three (323) hours, whichever is shorter.
Improving our products and services, based on:
- customer satisfaction surveys; and
- trade statistics.
This processing is based on Virtuo's legitimate interest in having a better knowledge of your needs and offering you personalised features to improve your experience of products and services.
The data is retained for three (3) years from the last contact with the customer.
Conducting sales and commercial prospecting activities, including:
- sending emails, SMS, and push notifications within the Application regarding special offers and promotions;
- recording our rental history to suggest preferred products or services when you are looking for new reservations or rentals;
- recording your rental history to send you special offers and benefits based on the volume and frequency of your purchases;
- sending emails, SMS, and push notifications within the Application, relating to a reservation that you have not completed or relating to the status of your reservation requests;
- sending emails presenting products and services to professionals;
- the organisation of contests and sweepstakes; and
- the management and updating of the customer and prospect database.
For individuals, commercial prospecting activities, i.e. the sending of messages of a commercial nature to promote the products and services offered by Virtuo, are subject to your express consent. If you are an existing customer and the message concerns products or services similar to those already ordered, the underlying processing to promote these products and services will not be based on your consent, but rather on Virtuo's legitimate interest.
For professionals, commercial prospecting activities are subject to the prior notification of the persons contacted that their email address will be used for prospecting purposes, as well as of their right to object to this use. This processing is based on the legitimate interest of Virtuo.
The data shall be retained for customers for three (3) years from the end of the commercial relationship. For prospective customers, they are retained for three (3) years from the date of collection of the personal data or from the last contact from the prospective customer.
Proposing partner offers, including:
- distributing advertising content via the Application and/or the Site; and
- proposing offers from partners based on your choices, provided that you have expressly consented to this.
This processing is based on your consent, in order to offer you personalised features.
The data is retained for three (3) years from the last contact with the customer.
Managing requests to exercise rights
The processing of requests to exercise the rights listed in paragraph IX, below, is based on a regulatory requirement.
The data is retained for one (1) year after the customer's request.
Aggregate personal data with non-personal data
Virtuo reserves the right to publish, disclose and use aggregated information (information about Users or specific groups or categories of Users combined in such a way that an individual User can no longer be identified or referred to) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes, and other business purposes.
Means of purging your personal data are put into place in order to provide for the effective deletion of your personal data as soon as the period of retention or archiving as required for the fulfilment of the determined or imposed purposes is reached.