Digital Rental Privacy Notice

01About This Notice

Hannk provides technology that enables vehicle rental companies and their customers to complete all or part of the vehicle rental journey digitally.

This Privacy Notice explains how personal information may be collected and processed when you use the Hannk digital rental platform ("Hannk").

Hannk is a technology platform. Your vehicle rental agreement is normally with the vehicle rental company identified on your reservation or rental agreement ("Rental Operator").

Depending upon the particular processing activity, the Rental Operator may be the Data Controller and Hannk may process information on its behalf as a Data Processor. For certain services and operational activities, Hannk may separately act as a Data Controller.

You should also review the privacy information provided by your Rental Operator.

02Information We May Process

The information processed depends upon the services activated by your Rental Operator and may include:

Identity Information

• Full name;
• Date of birth;
• Address;
• Nationality;
• Contact information;
• Passport information;
• National identity document information;
• Driving licence information;
• Document expiry dates;
• Driving entitlement information;
• Booking and reservation numbers.

Identity Verification Information

Hannk may process:

• A photograph or selfie;
• Images of identification documents;
• Information read from identification documents;
• Machine Readable Zone (MRZ) information;
• Information obtained from compatible electronic identity document chips;
• Identity verification results; and
• Facial comparison or other biometric verification information where the service is enabled.

Rental Information

This may include:

• Vehicle details;
• Collection and return information;
• Rental dates and times;
• Rental agreement information;
• Additional drivers;
• Digital signatures;
• Optional services;
• Rental status;
• Vehicle access permissions.

Vehicle Condition Information

During collection and/or return, Hannk may process:

• Vehicle photographs;
• Walk-around video;
• Existing damage records;
• New damage records;
• Date and time information;
• Vehicle inspection information; and
• Images captured during remote customer assistance.

These records may be compared with previous records to assist in determining whether the condition of a vehicle has changed.

Digital Vehicle Access

Where supported by the vehicle and Rental Operator, Hannk may process information associated with:

• Vehicle locking and unlocking;
• Digital key creation;
• Digital key activation;
• Digital key sharing;
• Additional driver access;
• Access revocation;
• Vehicle start authorisation; and
• Security and access logs.

Location, Geofencing and Vehicle Information

Where these services are activated, Hannk may process information including:

• Vehicle location;
• Journey information;
• Geofence events;
• Vehicle movement;
• Mileage;
• Vehicle status;
• Battery information;
• Diagnostic information;
• Driving-related events;
• Security alerts; and
• Other information generated by compatible vehicle hardware.

Customer Assistance

Where you use Hannk's live assistance services, information may include:

• Video;
• Audio;
• Chat messages;
• Photographs;
• Customer support communications;
• Translation data; and
• Information required to resolve your request.

Where a session may be recorded, you will be informed where required before recording begins.

03Why This Information Is Processed

Information may be processed to:

• Confirm your identity;
• Verify identification documents;
• Verify your entitlement to drive;
• Prevent identity fraud;
• Complete your vehicle rental;
• Create rental documentation;
• Provide digital access to your rental vehicle;
• Provide access to authorised additional drivers;
• Protect the rental vehicle;
• Record vehicle condition;
• Assist with damage assessment;
• Provide customer assistance;
• Provide multilingual assistance and translation;
• Manage collection and return;
• Detect unauthorised use where permitted;
• Manage agreed geographical restrictions;
• Investigate accidents, damage or disputes;
• Deal with tolls, parking charges or traffic matters where applicable;
• Protect against fraud and misuse;
• Comply with applicable laws;
• Establish, exercise or defend legal claims; and
• Maintain the security and integrity of the Hannk platform.

04Identity and Biometric Verification

Where enabled, Hannk may use technology to compare information from your identity document with a photograph or live image in order to assist in verifying that you are the person to whom the document was issued.

Where this involves processing biometric data for the purpose of uniquely identifying you, that information receives the additional protections required for special-category personal data under applicable data protection legislation.

Hannk and/or the relevant Rental Operator will identify and document the appropriate lawful basis and applicable special-category processing condition before such processing is undertaken.

Hannk does not use customer biometric information to create an unrelated facial-recognition database or sell biometric information.

05Vehicle Location and Geofencing

A rental vehicle may contain technology capable of determining its location.

Where enabled and legally permitted, location information may be used for purposes including:

• Vehicle security;
• Theft prevention and recovery;
• Digital access;
• Rental management;
• Detecting entry into or exit from defined geographical areas;
• Roadside assistance;
• Investigating accidents or incidents;
• Managing authorised vehicle use; and
• Other purposes disclosed by your Rental Operator.

The use of vehicle location information does not mean that a Hannk employee is continuously watching your journey.

06Photographs and Vehicle Damage

Hannk may request photographs or video of a vehicle at collection and return.

These records protect both the renter and Rental Operator by creating evidence of vehicle condition.

Automated technology may assist in comparing vehicle images and identifying potential changes. Where automated analysis identifies possible damage, it may be referred for further assessment rather than automatically establishing that a renter is financially responsible.

07Digital Keys and Additional Drivers

Hannk may allow authorised vehicle access to be securely provided to another approved driver.

Information concerning creation, transfer, use and cancellation of digital access may be recorded for security and audit purposes.

You must only provide vehicle access to a person authorised under the applicable rental agreement.

08Traffic, Parking and Toll Information

Where applicable and legally permitted, Hannk may assist Rental Operators in identifying and administering tolls, parking charges, traffic violations and similar vehicle-related charges arising during a rental.

Information may be retained where reasonably necessary to establish who was responsible for a vehicle at a particular time and to respond to authorised requests from competent authorities.

09Legal Basis

Depending upon the particular processing operation, personal information may be processed because:

• It is necessary to perform a contract;
• It is necessary to take steps connected with a contract;
• It is required by law;
• It is necessary for legitimate interests that are not overridden by your rights;
• You have provided valid consent; or
• Another lawful basis permitted by applicable legislation applies.

Special-category information, including biometric information used for unique identification, will only be processed where both a lawful basis and an applicable special-category condition are available.

10Sharing Information

Information may be shared where necessary with:

• Your Rental Operator;
• The organisation through which your rental was booked where appropriate;
• Identity verification providers;
• Payment providers;
• Vehicle technology providers;
• Telematics providers;
• Hosting and infrastructure providers;
• Customer assistance providers;
• Insurers where appropriate;
• Professional advisers;
• Government agencies;
• Police and law enforcement authorities;
• Courts and judicial authorities; and
• Other organisations where disclosure is required or permitted by law.

Only information reasonably necessary for the relevant purpose should be shared.

11International Processing

Hannk is designed for international vehicle rental.

Information may therefore be processed in countries other than the country in which your rental takes place.

Where applicable data protection legislation requires safeguards for international transfers, appropriate legal safeguards will be used.

12How Long Information Is Retained

Different categories of information require different retention periods.

Hannk and/or your Rental Operator will retain information only for as long as reasonably necessary for the purposes for which it was collected, including applicable contractual, legal, taxation, fraud-prevention, insurance, limitation and dispute-resolution requirements.

Sensitive information such as biometric verification information will not automatically be retained for the same period as the underlying rental agreement.

Retention periods are reviewed according to the nature and purpose of the information.

13Security

Hannk uses technical and organisational measures designed to protect information from unauthorised access, alteration, disclosure, loss or destruction.

Access to personal information is restricted according to operational requirements and appropriate security controls.

14Your Rights

Depending upon the legislation applicable to you, you may have rights to:

• Access personal information;
• Correct inaccurate information;
• Request deletion;
• Restrict processing;
• Object to processing;
• Request data portability;
• Withdraw consent where consent is relied upon; and
• Challenge certain decisions based solely upon automated processing.

Some rights are subject to legal exceptions.

15Who Should I Contact?

For questions concerning your actual rental, charges, rental agreement or use of your information by the Rental Operator, you should normally contact your Rental Operator.

For questions specifically concerning Hannk and its processing of personal information:

Hannk Ltd

Website: hannk.com

Email: sales@hannk.com

16Complaints

You may have the right to make a complaint to the data protection supervisory authority in the country in which you live, work or believe an infringement occurred.

For processing subject to UK data protection legislation, the supervisory authority is the UK Information Commissioner's Office (ICO).

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