Information automatically collected when you use our sites

When you visit our Sites or use our services, read our emails, or otherwise engage with us through a computer or mobile device, we and our third party partners automatically collect information about how you access and use the Sites and information about the device you use. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location‑identifying technologies, and similar technology (collectively, “tracking technologies”) and we may use third party services or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or from other sources.

When you use our sites, our servers automatically log certain information about your use of our Sites, such as your IP address, your browser type, operating system, browser language and service provider. We also collect information about your activities on our Sites, such as the pages you visit or the ads or links you click on. We use this for a number of purposes, where we have a legitimate interest to do so, such as: improving our services, developing new services based on what we learn from your activity; identifying products and marketing that may be of interest to you; personalizing our service to you; and carrying out statistical analysis and research with the purpose of allowing us to better understand our members and the products/services they want. We also use this information to provide and adapt our services to take account of the technical capabilities of our users as well as identify issues with the website and user’s experience of it.

When you visit our online services, we may collect personal information automatically such as your IP address when you visit our websites to help us diagnose problems with our systems, for system administration, to report aggregated information to our business partners, and to audit the use of our website. In select circumstances, we may use IP addresses to help us identify you to protect our service, site, users or others. We also collect your browser type, Internet Service Provider (ISP), referring/exit pages, the pages viewed on our site, operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.

Session Replay:

When you visit our website, we may also record information about your browsing session on the site, including which pages you visited, your mouse clicks, movements, and page scrolling, and any text keyed into forms on the website. We review this information to identify any technical issues in the operation of our sites and to improve the user interface on our sites. If we use a third party to help us with this service, this information will be passed to that third party for this purpose.

Mobile Analytics:

When you download and use our apps, we may use mobile analytics software to help us better understand the functionality of our app on your mobile device. Our analytics may record how often you use the app, how you use the app, aggregated usage, performance data and where you downloaded the app from.

Mobile GPS and Push Notifications:

If you allow us, when you use our apps, we may collect location markers using the GPS in your device. Knowing approximately where you are would help the app provide you better service, such as finding the nearest station near you. This would also help us send you push notifications or other communications based on your location (for example, nearby special offers). We will use push notifications to provide certain services such as emergency or other service notifications, return notifications, providing information about vehicle location, providing details regarding our products and services etc. We will only share this information with third party providers for the purpose of providing you these services. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. If you change your mind about sharing your location or receiving push notifications from the app, adjust the settings of your mobile device to turn off transmission of geolocation data or to stop transmission of push notifications at any time.

We may also collect analytics data or use third‑party analytics tools such as Google Analytics to help us measure traffic and usage trends for our services and to understand more about the demographics of our users.

What personal information we collect and how we use it

The principal purposes for which we collect and store your personal and financial information are to process your application, allow you to reserve and use our vehicles, authorize payment, bill you, respond to your inquiries, improve and communicate with you about our products and services and maintain your account with us. If you voluntarily submit information to us, we may collect personal information including your name, email address, postal address, telephone number, or a picture of you or identifying documents. This also includes information in your profile, or information you provide to us via an email, text or similar message, telephone call, or by other means. Your telephone calls and other communications with us are usually recorded or monitored for quality control, training and similar purposes. By using these communication methods, you are consenting to receiving information via these methods and the recording or monitoring of your calls and communications with Aircity. We use this information to create your account, provide our services and communicate with you. From time to time, we may send marketing or other communications.

If you voluntarily submit information to us, we may collect personal information including your name, email address, postal address, telephone number, or a picture of you or identifying documents. This also includes information in your profile, or information you provide to us via an email, text or similar message, telephone call, or by other means. Your telephone calls and other communications with us are usually recorded or monitored for quality control, training and similar purposes. By using these communication methods, you are consenting to receiving information via these methods and the recording or monitoring of your calls and communications with We. We use this information to create your account, provide our services and communicate with you. From time to time, we may send marketing or other communications.

If you apply to use We services, we collect information such as personal and financial information as you proceed through the stages of our application process, membership agreement and reservation process. In addition to your name and contact information, we will also collect your driver’s license number and the jurisdiction in which you are licensed, credit card or other payment information, a photo, and other identifying information. In certain cases, such as if you have a non Hong Kong driver’s license, we may also collect your passport information. We may also collect information about you such as your driving record from you, from regulatory bodies where you live, or from other third party sources. We use this information to process your application, determine your eligibility to use our services, to verify your identity, to detect and deter fraud, theft, or abuse of our service, comply with legal and recordkeeping requirements, process your payments and other purposes.

If you join We and use our services, we collect information about how you use our Sites and services, such as your searches for vehicles, reservations (dates, times, locations, etc.) and your use of the We service (return time, mileage, accidents, etc.). We may also collect precise location if you enable location‑based services on your mobile device. We use this information to provide and optimize services for you, including for example, billing you, responding to your inquiries, providing and improving our products and services, maintaining your account with us, personalizing your We experience (e.g., by understanding your preferences), and providing personalized content and promotional offers.

If you refer a friend, we will ask you for your friend’s name and email address or phone number. We may then send your friend one or more messages inviting your friend to join us. We store this information for the purpose of sending these communications and tracking the success of our referral program.

How we disclose personal information

We share information with third parties outside in limited circumstances, such as to provide the We service, fulfill a transaction you have requested, offer you personalized services, or in other circumstances that are permitted by law and consistent with the purposes for which we collected the information. For example, we may disclose your personal information, including GPS information from any of our vehicles, within the We Group and to contractors, advisors, consultants and service providers acting on our behalf or under our instructions, including for purposes relating to the provision, operation, maintenance, administration, promotion, improvement, and oversight of our services, Sites and advertising services, or to fulfill your requests for information or service. If you apply for an We account, some of the information you supply may be shared with regulatory bodies and/or service providers we utilize to obtain your driving record or other personal information. In addition, if you are associated or affiliated with another primary account (for example, if you are an associate member or affiliated with a business’s or university’s account or discount plan), the primary account holder (such as a business or university) will generally have access to certain information regarding your account or your use of our services, including specific reservation details. We share personal data with service providers in order to detect and prevent fraud, theft and abuse.

We may also share your personal information with our affiliate companies, including other companies owned or controlled by We for business purposes, including internal management and administrative purposes.

We may disclose your personal information in connection with a corporate transaction, proceeding, or reorganization involving the business activities for which the information is maintained. In the event that ownership of We or its business was to change as a result of a merger, acquisition or transfer to another company, your personal information may be shared or transferred. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.

We may disclose your personal information, including location/GPS data, in response to legal process (for example, a court order, search warrant or subpoena) or requests from law enforcement or regulatory authorities; in other circumstances in which we believe the Sites, the We service or our vehicles are being or have been used in violation of our policies, applicable law or otherwise in the commission of a crime; when we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; or when necessary to protect the rights or property of We or third parties.

Identity verification. We may use identity verification services provided by a third‑party provider to verify your identity documents, confirm your identity and protect against fraud and abuse. When you create an account, you may be asked to submit a valid driver’s license, along with a selfie image. Our third‑party provider may use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a “match”. We do not receive the biometric identifier generated from the images. It is generated and held by our third‑party provider until we inform them that the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than 3 years after your last interaction with us. For identity verification and security purposes, We will have access to the selfie image and will receive the information extracted from the identity scan of the ID document as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, and protect against fraud and misrepresentation. We do not use, disclose or retain your biometric information for any other commercial purpose. Our third‑party provider processes this information strictly in accordance with our contractual agreements.

Online Advertising and third‑party ad networks. We use third party ad network providers to serve you targeted advertisements based on your browsing history. These providers use cookies or similar tracking technologies to collect information about your use of our Sites, including our mobile apps, over time so that they may play or display ads on our Service, on other websites, apps or services you may use, and on other devices you may use. We may share a common account identifier with our third‑party advertising partners to help identify you across devices. We and our third‑party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising‑related services such as reporting, attribution, analytics and market research.

Google Analytics and Advertising. We use Google Analytics to recognize you and link the devices you use when you visit our Sites or services on your browser or mobile device, log in to your account on our services, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google to facilitate the service. Google Analytics allows us to better understand how our users interact with our service and to tailor our advertisements and content to you. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first‑party cookies (such as the Google Analytics cookie) and third‑party cookies (such as the DoubleClick advertising cookie) or other third‑party cookies together to inform, optimize, and display ads based on your past visits to the services. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt‑outs, including the Google Analytics Browser Ad‑On here https://tools.google.com/dlpage/gaoptout/. You may control your advertising preferences or opt‑out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

Social Media Advertising. We may also use advertising platforms provided by Facebook, Twitter and other social media sites to promote interest‑based advertisements to you (or to not show you certain advertisements) and to measure how users interact with those advertisements. We may do this using web tracking tools or by sharing certain information (such as hashed email lists) with these platforms for this purpose.

These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. You may learn more about advertising preferences by clicking on the following links. To learn more about Facebook’s advertising privacy policies and how to opt out https://www.facebook.com/about/privacy/. To learn more about Twitter tailored ads, visit https://www.help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads. We may also use similar advertising programs for other social media sites you use. Please note that these links are provided for your convenience only and we do not control the content or features that may be available on these third party services.

Social Sharing and Links

Our website includes social media features, such as the Facebook Like button and widgets, such as the Share This button or interactive mini‑programs that run on our Sites. These features may collect your IP address, which page you are visiting on our Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy notice of the company providing it.

Links to third‑party services

Our Sites may include links to other websites or mobile applications whose privacy practices may differ from those of We. We are not responsible for any personal information practices of third‑party websites and online services or the practices of other third parties. We encourage you to carefully read the privacy policy of any website you visit or mobile application that you use.

How may I review and correct my personal information?

We are committed to providing you with reasonable and practical access to your information to allow you the opportunity to identify inaccuracies. Upon request, We may provide you with information about whether we hold any of your personal information. If you are an account holder of We, you can review and correct personal information by clicking on “account settings” under “my account,” and navigating through the “my account,” “my reservations” and “my statement” pages. If you would like to access, delete and/or correct other personal information held by We, please contact us in one of the ways provided below and we will aim to respond to your request within 30 days. If we are informed of any inaccuracy, we may make the appropriate corrections when commercially practicable. Under applicable laws you may have the right to request a copy of the personal information we hold about you and have any inaccuracies corrected (we may charge a reasonable fee for such information requests and require you to prove your identity).

Please contact us if you wish to cancel your account. We generally retain information for at least as long as your account is active. However, we may also retain your information for a longer period to comply with our legal obligations, resolve disputes, enforce our agreements or maintain backups or archives of our systems. Please note, however, that we do not undertake to store your information, including records of your transactions, for you. Please maintain any records you need of your transactions with We.

What security measures are used to protect my personal information?

We have put in place safeguards and security practices designed to help protect the integrity and security of your personal information. However, no security system is impenetrable, and we cannot guarantee the security of our systems at all times. It is your responsibility to choose a strong password, safeguard it, and never disclose it to a third party. If you contact us by phone, we may ask you to verify certain information related to your account before providing any access to personal information.

How might this privacy notice be changed?

We reserve the right to change this privacy notice from time to time, so it is advisable to review it frequently. We will advise you of material changes to this privacy notice through our website or other means, and all amended terms shall automatically be effective as of the date of the amended notice. When we make changes to this privacy notice, we will change the “last updated” date at the beginning of this privacy notice. Your continued use of the We service or maintenance of a We account will be deemed to be acceptance of any revised privacy notice. Certain provisions of the privacy notice may vary based upon the jurisdiction in which you reserve or use a We vehicle. For example, in other jurisdictions, we may collect and use different locations or other information associated with your reservation and may use it differently than in your home location.

Personal Information Collected

Identifiers, such as your name, address, phone number, email address, date of birth, ID number, passport information, driver’s license information, or other similar identifiers.Customer Records , such as driver’s license number, insurance information, passport number, credit card information, bank account information or other payment information.Protected Classification Characteristics, such as age and gender.Commercial Information, such as products or services purchased or considered and your use of the We services, including reservation details.Biometric Information, such as facial geometry used solely by our third-party partners for identity verification purposes. We do not receive any biometric information generated from these processes.Internet/Network Information, such as device information, log, and analytics data.Geolocation Data, such as information about your physical location collected from geolocation features on your device, including your IP address and GPS (e.g. latitude and/or longitude).Driver & Vehicle behavior, such as smoking, phone use, fatigue, aggressive breaking, aggressive acceleration, hard turning, or other behaviors that have potentials for endangering road and vehicle safetySensory Information, such as pictures of you and recordings of phone calls between you and us, where permitted by law.Professional/Employment Information, including the business or organization you are associated with and, where applicable, your title with that business or organization and information relating to your role with the business or organization.Other Personal Information that you provide to us directly or through a third‑party service, including messages you send us through our services or on social media. This information could include your driving records, claim information and driver behavior information.Inferences, including information generated from your use of the Sites and your driving, vehicle and usage history.

Data Retention

We may retain your information for as long as you have an account with We, as needed to provide you our services, or as otherwise necessary for the processing purpose(s) for which the information was originally collected and any other legitimate business purpose, including, for legal, archival, accounting, and/or audit purposes.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, and whether we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting, and other applicable obligations.

Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will not further process the personal information until deletion or deidentification is possible.

Disclosure

We may disclose the categories of personal information identified above to the following categories of third parties for various business purposes:

• Our service providers: We engage a number of third‑party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, customer service, email delivery services, marketing and advertising services, and other similar services, subject to contractual terms restricting the collection, use and disclosure of your personal information.
• Third parties at your request. We share your personal information with third parties with your consent or at your direction.
• Businesses as needed to provide services. We may share personal information with third parties you engage with through our services, or as needed to fulfill your request or transaction, including, for example, payment processing services.
• Our affiliate companies. We may share your personal information with other companies owned or controlled by We, and other companies owned by or under common ownership as We, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us, such as Avis Budget Group) and any subsidiaries it owns.
• Security providers. We may share your personal information with third‑party security providers, for example, to detect, prevent, or otherwise address actual or suspected fraud, harassment, security or technical issues, violations of any law, rule, regulation or the policies of We.
• Business partners. We may disclose personal information to third parties with whom we partner to provide contests, joint promotional activities or co‑branded services, and such disclosure is necessary to fulfill your request or application.
• Primary account holders. If you sign up for We through an associated or affiliated primary account such as a business or university, we may share your information with the primary account holder.
• Other third parties. From time to time, we may disclose your personal information to third parties who use this information to market to you, to perform analytics and conduct research, or for other purposes, in accordance with their own privacy policies and terms.
• Ad networks and advertising partners. We work with third party Ad Networks and Advertising Partners to deliver advertising and personalized content to you on our services, on other sites and services you may use, and across other devices you may use. These parties may collect information directly from your browser or device when you visit the Sites through cookies or other tracking technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising‑related services such as reporting, attribution, analytics and market research.
• Analytics providers. We work with third party analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our services.
• Social networks. We may disclose personal information, such as a unique identifier, hashed email address, or information automatically collected through tracking technologies, to social networks for the purpose of displaying personalized advertising and content on those social networks.
• Law enforcement and third parties pursuant to legal request. From time to time, we may disclose personal information as reasonably necessary to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• Third parties in the context of a corporate transaction. We may disclose personal information as reasonably necessary to evaluate, negotiate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of We’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by We about consumers is among the assets transferred or is otherwise relevant to the evaluation, negotiation or conduct of the transaction.