Privacy Policy

01Introduction

Hannk Ltd ("Hannk", "we", "us" or "our") is committed to protecting your privacy and handling personal information responsibly, securely and transparently.

This Privacy Policy explains how we collect, use, store and protect personal information when you:

• Visit the Hannk website;
• Contact Hannk;
• Request information or a demonstration;
• Register your interest in Hannk products or services;
• Communicate with our sales, technical or support teams;
• Represent a car rental company, broker, technology provider, supplier or other business working with Hannk; or
• Access Hannk services where this Privacy Policy is displayed or referenced.

Hannk provides technology designed to support and digitalise the vehicle rental process. Certain Hannk services may involve additional processing of personal information. Where appropriate, a separate privacy notice will be provided explaining how information is processed within that particular service.

02Who We Are

Hannk Ltd is the operator of the Hannk website and Hannk digital rental technology platform.

Website: hannk.com

Privacy and general enquiries: sales@hannk.com

Where Hannk determines the purposes and means of processing personal information, Hannk acts as the Data Controller.

In some circumstances, Hannk may process information on behalf of a car rental company, broker, franchise, licence holder or other business customer. In those circumstances, Hannk may act as a Data Processor, and the relevant business may be the Data Controller.

03Information We May Collect

Depending upon how you interact with Hannk, we may collect information including:

Contact Information

This may include:

• Name;
• Business name;
• Job title;
• Email address;
• Telephone number;
• Country or location;
• Business address; and
• Details provided through enquiry or registration forms.

Website and Technical Information

When you visit our website, we may automatically receive certain technical information, including:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Pages visited;
• Date and time of access;
• Referring website;
• Website interaction information; and
• Cookie or similar technology information.

Communications

If you communicate with Hannk, we may retain information relating to that communication, including emails, messages, enquiries, support requests and other correspondence.

Business Information

Where you contact Hannk on behalf of an organisation, we may process information concerning:

• Your organisation;
• Your position or responsibilities;
• Business requirements;
• Fleet information;
• Technology requirements;
• Proposed integrations;
• Commercial enquiries; and
• Other information you voluntarily provide.

04Information Processed Through the Hannk Digital Rental Platform

The Hannk platform is designed to facilitate a digital vehicle rental journey.

Depending upon the services selected by the relevant rental operator and the requirements applicable to a particular rental, information processed through Hannk may include:

• Customer identity information;
• Booking and reservation information;
• Passport or identity document information;
• Driving licence information;
• Identity verification information;
• Photographs and selfies;
• Vehicle collection and return photographs;
• Vehicle inspection images and video;
• Electronic rental documentation;
• Digital signatures;
• Additional driver information;
• Vehicle access information;
• Digital key activity;
• Rental start and return information;
• Vehicle location and journey-related information where enabled;
• Geofencing information;
• Vehicle telematics information where enabled;
• Communications with customer support;
• Video assistance sessions where used;
• Payment-related information;
• Traffic, toll, parking or violation-related information where applicable; and
• Records necessary for fraud prevention, security, legal compliance or the establishment, exercise or defence of legal claims.

Not every Hannk implementation uses every category of information listed above.

The information collected depends upon the services activated by the relevant rental operator, the country of rental and applicable legal requirements.

05Why We Use Personal Information

We may process personal information for purposes including:

• Operating and maintaining our website;
• Responding to enquiries;
• Providing requested information;
• Arranging product demonstrations;
• Managing business relationships;
• Providing Hannk products and services;
• Providing customer and technical support;
• Processing and managing digital rental journeys;
• Identity and driving licence verification;
• Preventing fraud and misuse;
• Protecting vehicles, customers and rental operators;
• Managing digital vehicle access;
• Supporting vehicle collection and return;
• Managing additional drivers;
• Processing vehicle inspection information;
• Improving the security and reliability of our systems;
• Maintaining audit and transaction records;
• Complying with legal and regulatory requirements;
• Establishing, exercising or defending legal claims;
• Improving Hannk products and services; and
• Communicating relevant information about Hannk products and services where permitted by law.

06Our Legal Basis for Processing

Where UK GDPR or EU GDPR applies, Hannk will only process personal information where there is an appropriate lawful basis.

Depending upon the circumstances, this may include:

Contractual necessity – where processing is necessary to provide a service or fulfil contractual obligations.

Legitimate interests – where processing is necessary for the legitimate business interests of Hannk or another party, provided those interests do not override the rights and freedoms of the individual.

Legal obligation – where processing is required to comply with applicable law.

Consent – where you have provided consent for a particular processing activity.

Where consent is the legal basis for processing, you may withdraw that consent at any time.

Withdrawal of consent does not affect processing that was lawful before consent was withdrawn.

07Identity Documents and Verification

Some Hannk services may require customers to provide passports, national identity documents, driving licences, selfies or other verification information.

Such information may be processed for purposes including:

• Confirming identity;
• Confirming entitlement to drive;
• Preventing identity fraud;
• Meeting rental operator requirements;
• Meeting legal or regulatory obligations; and
• Protecting vehicles and rental transactions.

Where biometric technologies are used in a manner that constitutes processing of biometric data for the purpose of uniquely identifying an individual, the appropriate legal requirements and safeguards will be applied.

08Location, Vehicle and Telematics Information

Where enabled by a rental operator, Hannk technology may process vehicle location, telematics or geofencing information.

This information may be used for purposes including:

• Vehicle security;
• Digital vehicle access;
• Rental management;
• Identifying whether a vehicle enters or leaves specified geographical areas;
• Supporting roadside or customer assistance;
• Detecting certain vehicle events;
• Investigating incidents;
• Managing toll, traffic or parking-related matters where applicable; and
• Protecting the legitimate interests of the vehicle owner or rental operator.

The availability and use of these features may vary by rental operator and jurisdiction.

09Photographs and Video

Hannk services may allow photographs or video to be captured during the rental process, including during vehicle collection, vehicle return, damage inspection or customer support.

These records may be used to document vehicle condition, investigate disputes, provide customer assistance, prevent fraud and establish or defend legal claims.

Where video assistance functionality is used, customers will be informed that they are entering a video communication session.

10Automated Processing and Artificial Intelligence

Certain Hannk services may use automated technologies to assist with activities such as document processing, identity verification, translation, image analysis, vehicle condition assessment, fraud detection or operational decision support.

Where a decision produces legal or similarly significant effects and is based solely on automated processing, Hannk and/or the relevant Data Controller will apply the protections required by applicable data protection legislation.

Hannk does not sell personal information for the purpose of training unrelated third-party artificial intelligence systems.

11Sharing Personal Information

We may share information where necessary with:

• The relevant vehicle rental company;
• The relevant rental broker or booking provider;
• Technology and hosting providers;
• Identity or document verification providers;
• Payment service providers;
• Communications providers;
• Vehicle technology and telematics providers;
• Customer support providers;
• Professional advisers;
• Insurance providers where appropriate;
• Government, regulatory, law enforcement or judicial authorities where legally required; and
• Other service providers necessary to deliver Hannk services.

We require organisations processing personal information on our behalf to handle that information appropriately and securely.

Hannk does not sell personal information to third parties for unrelated marketing purposes.

12International Data Transfers

Hannk operates technology intended for use internationally.

As a result, information may in certain circumstances be processed or accessed outside the country in which it was originally collected.

Where personal information protected by UK or European data protection legislation is transferred internationally, appropriate safeguards will be used where required by law.

These may include adequacy regulations or decisions, approved contractual safeguards or other legally recognised transfer mechanisms.

13Information Security

Hannk takes the security of personal information seriously.

We use appropriate technical and organisational measures designed to protect information against:

• Unauthorised access;
• Unauthorised disclosure;
• Loss;
• Misuse;
• Alteration;
• Destruction; and
• Other unlawful processing.

Security measures are reviewed and developed as our technology and services evolve.

No internet-connected system can, however, be guaranteed to be completely secure.

14How Long We Keep Information

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, contractual, accounting, regulatory, fraud-prevention and dispute-resolution requirements.

Retention periods may vary depending upon:

• The type of information;
• The purpose for which it was collected;
• The country in which the rental occurred;
• Requirements imposed upon the relevant rental operator;
• Applicable limitation periods; and
• Legal or regulatory obligations.

Information that is no longer required will be deleted, anonymised or otherwise securely disposed of in accordance with our retention procedures.

15Cookies

The Hannk website may use cookies and similar technologies to operate the website, remember preferences, understand website performance and improve the user experience.

Where required by applicable law, non-essential cookies will only be activated after consent has been obtained.

Users can manage applicable cookie preferences through the cookie controls provided on the website and through their browser settings.

Further information may be provided in a separate Hannk Cookie Policy.

16Marketing Communications

Where permitted by law, Hannk may use business contact information to provide information concerning Hannk products, services, events and developments.

You may request that marketing communications stop at any time by using the unsubscribe facility provided in the communication or by contacting Hannk.

Service, security, contractual or operational communications may still be sent where they are necessary and are not marketing communications.

17Your Data Protection Rights

Depending upon where you live and the applicable legislation, you may have rights including the right to:

• Request access to your personal information;
• Request correction of inaccurate information;
• Request deletion of your information;
• Request restriction of processing;
• Object to certain processing;
• Request transfer of information;
• Withdraw consent where processing is based upon consent; and
• Raise a complaint with the appropriate data protection authority.

These rights are subject to applicable legal conditions and exemptions.

To exercise a data protection right relating to information controlled by Hannk, please contact us.

Where Hannk processes information solely on behalf of a rental operator or another Data Controller, we may need to refer your request to that organisation.

18Children's Privacy

Hannk services are not intended to be independently used by children to enter into vehicle rental agreements.

We do not knowingly collect personal information from children through the Hannk website for marketing purposes.

Information concerning a child may occasionally be included within a legitimate rental or travel transaction where permitted by law. Such information will only be processed where necessary for the relevant service and in accordance with applicable legislation.

19Third-Party Websites and Services

The Hannk website or platform may contain links to websites, applications or services operated by other organisations.

Hannk is not responsible for the privacy practices of independent third parties.

We recommend reviewing the privacy information provided by those organisations before providing personal information to them.

20Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our technology, services, legal obligations or business operations.

The latest version will be published on the Hannk website together with the date on which it was last updated.

Material changes may also be communicated through appropriate Hannk services.

21Contact Hannk

Questions concerning this Privacy Policy or the way Hannk handles personal information can be directed to:

Hannk Ltd

Website: hannk.com

Email: sales@hannk.com

For requests concerning a particular vehicle rental, customers may also need to contact the rental company identified on their booking or rental agreement.

22Complaints

If you believe Hannk has not handled your personal information appropriately, please contact us so that we can investigate your concerns.

Where UK data protection legislation applies, you may also have the right to complain to the UK Information Commissioner's Office (ICO).

Where another country's data protection legislation applies, you may have the right to contact the relevant supervisory or data protection authority in that jurisdiction.

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