Privacy Policy

YOUR PRIVACY: We respect your privacy and are committed to protecting the personal data we hold about you. This policy explains what data we collect about you, how we collect it, the measures we take to keep your data secure and the uses and disclosures we make of it.  We also explain the options you have regarding your personal data. When you request services from us, access our websites, utilize our mobile “apps” or otherwise interact with us, for example, but without limitation, through our kiosks, our in vehicle technology (such as, for example, GPS devices), our official corporate pages on third party social networks (such as Facebook) or the “apps” on those pages, you consent to our collection, retention and use of your personal data in the manner described in this policy and accept the risks outlined in the Security section. You can quickly review the key topics by reading the following overview or you may continue to scroll down to read more about an issue or to read the full policy.

Overview

CONTACT US: We hope this policy answers your questions about our collection, use and disclosure of your personal data.  If it does not, or if you have any questions, please contact us by following the instructions in the Contact Us section below.

Privacy Policy

YOUR PRIVACY

We respect your privacy and are committed to protecting the personal data we hold about you. This policy explains what data we collect about you, how we collect it, the measures we take in our efforts to keep your data secure and the uses and disclosures we make of it.  We also explain the options you have in relation to your personal data.

When you request services from us, operate a vehicle with in-vehicle technology (such as, for example, GPS devices), access our websites, utilize our mobile “apps” or otherwise interact with us, for example, but without limitation, through our kiosks, our official corporate pages on third party social networks (such as Facebook) or the “apps” on those pages, you consent to our collection, retention and use of your personal data in the manner described in this policy and accept the risks outlined in the Security section.

SCOPE

This policy covers the personal data we collect about you in connection with our vehicle rental business which identifies you as an individual.  It does not apply to data that does not personally identify you as an individual, for example, but without limitation, aggregated anonymous data, IP addresses, computer operating systems, personal preferences, vehicle identification numbers, etc.  We are free to use data that does not identify you as an individual as we wish.  This policy does not apply to data collected by third party social networks (such as Facebook), mobile device manufacturers, third party “mobile apps”, wireless service providers, internet service providers or the operators of any networks through which you may interact with us and we expressly disclaim any responsibility for the data collection, privacy or data security practices of those entities.  With regard to pages on third party social networks, this policy only applies to personal data we collect through our pages (those with a direct link to this policy) and does not apply to any “unofficial” pages or pages of our affiliates or licensees.  Our websites are not directed to individuals under the age of 13, and we do not knowingly obtain personal data from such individuals.

Who We Are  
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We are Firefly Rent A Car LLC, a U.S. company, which provides vehicle rental services worldwide.  All references in this policy to “we”, “us” and “our” are only to Firefly Rent A Car LLC and not to our parent companies (which includes, without limitation, The Hertz Corporation), or their other subsidiaries, which operate other businesses, which may include other vehicle rental businesses. 

We are affiliated to other companies through ownership. As our licensees and affiliates are independent companies, they are not owned or controlled by us and are not covered by this policy, although they may have their own privacy policies to govern the personal data they collect. We are not responsible for the privacy practices of any affiliates or licensees.

More about parents, licensees and affiliates…

Parents:  These companies own Firefly Rent A Car LLC directly or indirectly and are covered by different privacy policies.  The expressions “we”, “us” and “our” do not apply to them.

Licensees: We have a network of independent companies licensed to operate vehicle rental businesses using our business system and certain service marks owned by Hertz System, Inc. which are also licensed to and used by us.  These companies may describe themselves as “Hertz System Licensees” or “Hertz Franchisees” to indicate that they are not our subsidiaries.

Affiliates: These companies either control us (through ownership) or are controlled by the companies that control us. They cover a range of businesses but are generally not independently involved in provision of our services to you.   

Changes 
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We may change this policy from time to time.  If we do so, the amended policy will take effect when we post it on the applicable website(s), mobile “apps” or our third party social network page(s).  Whenever we make a change, we will amend the “last updated” notice under the “Scope” heading in the “Overview” section above.  

If any change makes the policy less protective of your personal data, such change will not apply to data we collected about you before the change was made.  The only exception to this is, unless legally prohibited, where we have provided you with notice about the changes and given you the opportunity to tell us not to apply them to your personal data.

COLLECTION 

We collect a range of data about you from a variety of sources for the purposes of our business. The examples we provide here are illustrative rather than a complete list of our practices.

What We Collect
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We collect the personal data and the non-personal data we need to process your reservation requests and to provide the services you request from us and for our operational uses in connection with such services, which may include:

• Name, address and contact details, including telephone and mobile number, and email address; 
• Date and place of birth, passport number and driver’s license number and, upon our request, a copy of your driver’s license; 
• Your gender and photo;
• Employer(s) name, address and phone number; 
• Credit card information; 
• Frequent flyer and other membership reward or loyalty program information;
• Affiliations with or sponsorships by companies, associations, colleges or cities;
• Location data such as geographic location of electronic devices used to contact us or to access our mobile “apps” or of the vehicle or equipment you have rented;
• Information regarding the vehicle or equipment rented and its operation during your rental;
• Rental charges you incur and other information relating to your transactions; 
• Information transmitted by your computer’s browser software; 
• Itinerary information, including airline and/or flight information; and
• Information about your credit history or other publicly available information about you from consumer reporting agencies.

We may collect certain personal data that constitutes sensitive data in some countries, such as data about health conditions or membership of a trade union. Depending upon applicable local law, we may be unable to process such sensitive data without your consent.

More about sensitive data…

Data about your health conditions is regarded as sensitive in many countries. If you ask us to accommodate a disability, such as by provision of hand controls, or if there is an accident and we need to work with insurance and claims management companies (which may be a third party or an affiliate of ours) relating to any injury you may incur, we may need to process data about your health conditions.  Similarly, in the EU, at least, your membership of a trade union or similar organization is regarded as sensitive and we may need to process this information if you use a Discount Code Number that only members of that union or organization can use.

Please note that if you wish to rent with us or our licensees and need to provide sensitive data, you consent to that data being collected, used, retained and disclosed for our Operational Uses. We will not use sensitive data about you for marketing purposes.
 

Sources  
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We collect personal data directly from you in connection with a reservation (even an abandoned or interrupted reservation), or a rental of a vehicle, including information you provide:    

• When you call our reservation, customer service, emergency road-side assistance, or customer contact centers; 
• On our websites; 
• Through our kiosks;
• On our mobile “apps”;
• On our official third party social network pages;
• Through your computer’s web browser;
• At rental locations; and 
• Through our in-vehicle technology (such as for example GPS devices).

We also gather personal data about you from a variety of other sources, which may include:

• Reservations you make with us through licensees, travel agents or brokers; 
• Transactions you complete with us and our licensees, including options you take, charges you incur and any incidents or accidents that may occur;
• To the extent you have made such information available, from third party social networks;
• Consumer reporting agencies; and
• Other companies that have business relationships with us, such as our licensees, affiliates and business partners, including airlines, hotels and insurance companies.

Websites
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Our Websites

Certain technologies are used on our websites and on mobile devices to collect data about your visit or usage, as follows:

 Cookies

A “cookie” is a set of data sent to your computer or mobile device by a web server that enables the server to recognize your computer or mobile device.

Cookies help improve the quality of your visits to websites, for example, but not limitation, by making the reservation process faster and smoother. The information the cookies provide helps in the development of content and features that may be of interest to you.

We use cookies to: 

• Track your use of our websites during a single visit, remember the data you provide and the choices you make as you progress from page to page (“session cookies”); and

• Recognize you at your next visit (“persistent cookies”).

Third party cookies may also be used on our websites for the purpose of:

• Such third parties providing goods or services to you;

• Performing services on our behalf;

• Facilitating business transactions with or through such third parties; or

• Providing advertisements to you.

More about cookies…

By adjusting your browser or installing certain software, you can restrict our use of cookies.  If you do this, you should be aware of the following:  

• If you restrict our use of session cookies you will not be able to use our websites or certain features of our e-mail messages. You should be aware that session cookies are generally deleted or made unavailable to us as soon as you close your browser.

• If you restrict our use of persistent cookies you may still enjoy the full workings of our websites and e-mail messages but will need to re-enter some data when starting a new website session. Although persistent cookies will neither automatically be erased nor made unavailable to us upon closing your browser, they will typically “expire” after a number of years.

If you are still unsure about cookies, please note that our cookies are unable to retrieve other data from your computer’s hard drive or pass on computer viruses. 
 

 Pixel Tags

In addition, “pixel tags”, “web beacons”, “JavaScript”, or similar technologies that enable, among other things, the tracking of your actions as a user of various websites or recipient of e-mail messages. (“Pixel Tags”) may be used. Pixel Tags may be used in connection with our web pages, our online advertising, or our e-mail messages, either by Firefly Rent A Car or by our service providers, business partners or other third parties.

Pixel Tags are used to collect typically anonymous data to help identify types of information, including popular destinations, average rental prices, quote and conversion rates, click-throughs and other information to improve the service you receive or the relevance of advertising directed to you. Pixel Tags may also be used to identify which online advertisement or email has brought you to a website.

Further, certain Pixel Tags may be used by other companies for the purpose of tracking visits to their websites, identifying if such internet traffic came from a Firefly Rent A Car website or confirming your eligibility to receive services or benefits from such other companies.

Third party cookies or Pixel Tags may collect information about a user of our site’s online activities over time and across different web sites.

Some of our web sites may use Google Analytics, which uses cookies and other, similar technologies (e.g. Pixel Tags) to collect information about website use anonymously and reports trends, without identifying individual visitors.  To learn more about Google Analytics, including how to opt out of it, visit https://tools.google.com/dlpage/gaoptout.

We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use our websites and other websites, based on information relating to your access to and use of our websites and other websites.  To do so, these companies may place or recognize a unique cookie on your browser (including through the use of Pixel Tags).  If you would like to learn more about this practice, including your choices with respect to it, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.

We do not respond to a web browser’s “do not track” signal, or other mechanism that indicates a request to disable online tracking of individuals who use or visit our websites.
 

As the internet and other eCommerce channels continue to develop, we may deploy and utilize different types of technologies to collect data regarding your visit or usage.

 Blogs or Message Boards

Some of our websites and our official corporate pages on third party social networks (such as Facebook) may provide functionality that permits you to post public messages or responses to articles, comments or other postings.  You should be aware that by submitting such a posting, including any personal data or non-personal data in connection with it, you intend for that posting and any data in connection with it to be, and it shall immediately become, public and as such will not be subject to this Privacy Policy. We reserve the right to remove any posting or content in a posting at our sole discretion.

Other Company Websites

Our websites and e-mail messages may contain links to websites operated by other companies.  You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this policy.

RETENTION

We try to ensure that the personal data we retain about you is stored securely and, in light of the information provided to us, is as accurate, current, complete and relevant as necessary for the purposes for which we use and disclose it.

Storage
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We generally retain personal data about our customers for as long as we believe appropriate for the purposes for which it was collected or as otherwise required or authorized by applicable law.

Our principal databases for storing the personal data we collect are located in Oklahoma, U.S.A. 

Security
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As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet or wireless networks all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted.

We take commercially reasonable measures to protect against the loss, misuse and unauthorized access or disclosure, alteration and destruction of your personal data by aiming to maintain appropriate physical, procedural and electronic safeguards to protect your personal data, including:

• Restricting access to personal data to our employees or service providers on a “need to know” basis; 
• Enforcing policies and procedures for our employees in their handling of personal data; and
• Using technologies designed to safeguard data during its transmission, such as SSL encryption for the data you provide on our websites. 

If you have reason to believe that any of your personal information held by us is no longer secure, you must immediately contact us by following the instructions at the end of this policy. 

More about SSL encryption…

“SSL” stands for Secure Sockets Layer encryption. We use this protection when you submit personal data to us on our websites.  SSL encryption seeks to ensure that you are actually sending your data to us and that no-one else can read or tamper with it during transmission.

When you are asked to provide your personal data to us on our website, you will see that our “http” website address changes to read "https". The additional “s” denotes that the site is secure for that data transfer. You may also see a closed padlock symbol on your screen, again denoting a secure site.

Security of Communications

We try to strike a balance between the security of your data and your convenience.  As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative.

For example, but not limitation, we will send you an e-mail or a text message in unencrypted form (i.e. instantly readable) because many of our customers are unable to access encrypted (i.e. coded) e-mail or messages. This means that our message, if misrouted or intercepted, could be read more easily than encrypted messages. For this reason, please do not include confidential information, such as your driver’s license or credit card number, in any e-mail or text you send to us or on any posting you make to a public area of a third party social network page, especially since any such posting immediately becomes public.

For a more secure way to communicate with us over the Internet, please click on the “Contact Us ” link on any page of www.fireflycarrental.com

Access and Correction

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You may access and review your personal data, change it and correct factual errors by contacting us at the address, or the appropriate phone number, provided at the end of this policy.

To protect your privacy and the security of your personal data, we will take steps to verify your identity before granting you access or making corrections to the data we store about you.

Certain types of personal data may need to be updated with the third party social network through which you may interact with us, rather than directly with us.

USES and DISCLOSURES

Your personal data will not be used in a way that is incompatible with the purpose for which it was collected or as authorized by you.  By initiating a reservation with us or renting a vehicle from us, you consent to our use and disclosure of your personal data for the operational uses listed below which may include disclosure of your data outside your country of residence.  We would also like to use your data for marketing purposes.

Operational Uses and Disclosures
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The examples provided below are illustrative and not a complete list of our practices:

To provide you services 

We will share your personal data among ourselves, our agents, our licensees and other companies to provide services to you, including to:

• Make your rental reservations; 
• Process and/or confirm your transactions; 
• Provide you with the services you have requested or, where applicable, enhanced rental services;
• Provide you services in connection with your rental, such as navigation assistance or itinerary planning; 
• Provide you with customer assistance, including , but not limited to, assistance after you have initiated but not completed a reservation;  
• Bill and collect amounts owed in connection with your rental(s); and
• For customer satisfaction and market research purposes and to otherwise help us improve our services.

To communicate with you  

We may use your personal data to communicate with you regarding any reservation you initiate or any rental transaction.

So that we may communicate with you, you give us your consent to call you on or send text messages to your mobile telephone/device.  You also consent to our use of auto-dialers and pre-recorded messages in connection with any such telephone call or text message, including calls or texts to mobile telephone numbers.  We will not charge you for such calls or texts.  Your mobile service provider will charge you according to the applicable plan to which you subscribe.

Disclosure to companies you use  

We will also share your information with companies you use in connection with your rental, including:  

• Your credit card provider and other companies that process your charges; 
• Any company or organization that is paying all or part of your rental charges; 
• Any intermediary you use, such as a travel agent or broker, in relation to any aspect of your rental; and 
• Any operator of a membership program for which you are rewarded for renting with us, such as a frequent flyer program.

You may quote a special discount code when you rent with Firefly Rent A Car entitling you to the special rate or benefits we may have negotiated with your company, association, credit card company or travel club (the “Discount Code Sponsor”), if you are eligible. 

More about  Discount Code Sponsors … 

If you rent using a Discount Code number (whether it is referred to as a “CDP Number” , a “PC Number” or by some other reference) you consent to our disclosure of your personal data to the Discount Code Sponsor to:

• Administer and evaluate the program;

• Confirm your eligibility to rent using that Discount Code number;
• Determine our compliance with the terms of the program;
• Establish your compliance with the sponsor’s rental policies;
• Enable the sponsor’s payment of your rental costs (if applicable); or
• For any other uses reserved by a Discount Code Sponsor with you, which may include marketing uses.

If you do not wish us to disclose your personal data to a Discount Code Sponsor for the above purposes, you must not use their Discount Code number for your rental. This will mean, however, that you will not be able to receive the benefits associated with that Discount Code number.

Protective and legal uses

We may use, share and disclose your personal data for legal reasons as we believe necessary or appropriate, including:

• under applicable law, including laws outside your country of residence;
• to process, handle or otherwise respond to claims for damages, including claims or demands for bodily injury or property damage;
• to comply with legal process;
• to respond to requests from public and government authorities including public and government authorities outside your country of residence;
• to enforce our terms and conditions;
• to recover our vehicles, other property or any monies due, such as through debt collection agencies;
• to protect our operations or those of any of our affiliates;
• to assess your credit worthiness;
• to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and
• to allow us to pursue available remedies or limit the damages that we may sustain.

Disclosure to our parents, affiliates, service providers and agents

We may use our parents, affiliates or other companies as our service providers or agents to act on our behalf and assist us in the conduct of our business, performing services for us under our instruction. These services may include hosting certain websites or databases, operating “apps” for us on our social media networks’ pages, running contests, sweepstakes and other promotions for us, sending marketing communications, carrying out data analysis and conducting customer satisfaction surveys or other research. We will seek to require our service providers and agents to maintain appropriate security standards to protect your personal data and use the personal data we provide to them only for the purposes we specify.  

Disclosure for corporate transactions

We may disclose your personal data to a third party in connection with any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Marketing Uses and Disclosures

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We may aggregate your personal data and use it to develop marketing programs and service offerings that we believe may be of interest to you. We would like to send these to you by email, by text message or by mail. We would also like to share your personal data with our licensees, affiliates and business partners for their marketing purposes. You have choices in relation to our marketing uses of your personal data, based upon the residence for you in our records, as follows: 

US residents

We may use your personal data for the above marketing purposes, although you can choose to limit or restrict our mailings and our sharing of your data for these uses by following the instructions at Marketing Options below.

EU and Canadian residents

We will only use your personal data for our marketing purposes with your prior consent, which may be collected from a number of sources.  

If you do not receive marketing messages from us and would like to do so, or if you want to limit or restrict our communications with you or sharing of your data for marketing purposes, please follow the instructions at Marketing Options below.

Residents of other countries

We aim to comply with your local law regarding our use of your personal data for marketing purposes. You can instruct us how we can use or disclose your personal data for marketing purposes by following the instructions at Marketing Options below.  

Marketing Options

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Please complete the My Privacy Choices form at the end of this policy and mail it to us, following the instructions at Contact Us below.

We may record your privacy election regarding the receipt of marketing communications at the time you make a reservation or at other times when you interact with us.   In addition to submitting the My Privacy Choices form at the end of this policy, you can follow the “Alternate opportunities to opt-out” instructions below to tell us that you no longer wish to receive marketing communications at that email address if you previously had elected to receive marketing communications.

Alternative opportunities to opt-out

Our marketing emails contain an unsubscribe option.  If you do not want us to continue to send marketing emails to your email address, click on ‘unsubscribe’ and we will not send further marketing emails to that address, although you may still receive emails at other addresses for which you have not unsubscribed. If you subsequently wish to override your choice to unsubscribe, you will need to complete a My Privacy Choices form as attached below. 

Important points to note

Please note the following points about the marketing choices you make:

• If you change your marketing choices, we will observe your most recent choice with regard to that  contact information.  Although we aim to process your choices promptly, you may still receive marketing communications prepared before we received your request to unsubscribe; 

• If you change your address, we will continue to follow your directions for your most recent address provided from your ‘unsubscribe’ click noted above or the My Privacy Choices form you completed.  However, in order for us to continue to follow your directions at a new address, you will need to complete another My Privacy Choices form with your updated information and provide it to us with your changed contact information; and 

• If your rental transaction data contains a Discount Code number, the Discount Code sponsor may have made marketing choices for users of that number.  If the sponsor’s choices are more restrictive on our use of your data than your choices, we will observe the choices made by the sponsor, where we can match it to your My Privacy Choices form.

Contact Us

We hope this policy answers your questions about our collection, use and and disclosure of your personal data. If you have additional questions or want to contact us for a specific purpose, please select from the following:

Access/Corrections: Please send any request to access, amend or delete certain personal data we hold about you to the most convenient contact address below.

Complaints and Other Questions: You should send any questions you may have about this policy or any complaints you have about how we have handled your personal data to the most convenient contact address below. If you feel our response is not satisfactory, we will refer you to a neutral and independent dispute resolution organization.

Marketing: Send a completed My Privacy Choices form (at the end of the policy) to the most convenient contact address below.  We aim to process your choices promptly on receipt, but you should please allow a number of days for your choices to become effective.

Security: If you have reason to believe that the personal data we hold about you, such as your driver’s license number or credit card number, is no longer secure, you must immediately notify us of the problem either by clicking “Contact Us” at the bottom of any page on www.fireflycarrental.com or contacting  us as follows:  

• Customers within the United States:  call us at (877) 654-3001
• Customers outside the United States submit your query via:  https://uk.fireflycarrental.com/customer_support.html

Contact addresses:

• Director, Privacy Services, Firefly Rent A Car LLC c/o The Hertz Corporation, P.O. Box 25301, Oklahoma City, OK 73125, U.S.A.

• Director, Privacy Services, Firefly Rent A Car LLC c/o Hertz Europe Service Centre, Swords Business Park, Swords, Co. Dublin, Republic of Ireland.

My Privacy Choices
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Please complete this form and send it to us by following the instructions at Contact Us above.

(Updates: Please use this form for changes.)

Please note: Privacy Choices for our parents or affiliates, including The Hertz Corporation, Dollar Rent A Car , Thrifty Rent A Car, or Donlen Corporation, should be made by following instructions in their respective privacy policies.

A.  Please send me marketing offers and materials from or on behalf of Firefly Rent A Car:

                                                                 Yes          No

  Postal mail                                                [  ]          [  ]

  E-mail                                                       [  ]          [  ]
 

B.  Please share my personal data with Firefly Rent A Car’s parents, licensees, affiliates and business partners for their marketing purposes:

                                                                 Yes          No

                                                                  [  ]          [  ]

Any consent regarding your receiving marketing materials provided above can be withdrawn or other otherwise changed at any time in accordance with the instructions set forth in this Privacy Policy.