Privacy Policy

We are CARBON FREE MOBILITY INC. (hereinafter “ZEROCAR, “we”. “our” “us”), its rental businesses and subsidiaries operating under the ZEROCAR Brand. This policy does not cover our licensees, or other third parties through whom you may interact with us.

What We Collect.

We collect Personal Data that you provide on our websites, on applications and on third-party websites and offline in connection with any inquiries, reservations, or rentals you make in relation to our services. We may collect your Personal Data directly or through our service providers, licensees, and booking channel providers.

  1. Types of Information Collected.

    May include but is not limited to:

    1. Personal information:
      Name Email Address
      Date of birth Phone number
      Address Passport number
      Employer Driver´s license
    2. Technologically derived information:
      IP address date and time of a visit
      device ID number of links and specific links you click within
      our websites
      browser type functions you use on our websites
      operating system any reservations, updates, purchases, or other
      transactions through our websites
      geo-location data data you view or download from our websites
      specific webpages visited number of times you view any particular
      advertisements
    3. Rental Information:
      booking location payment card information
      rental location preferences and usage information
      return location purchase prices and details
      charges incurred video of your interaction with us
      data related to claims loyalty program details
      itinerary information
    4. Vehicle Telematic Information:
      We may use the in-vehicle data systems to collect data about the vehicle’s condition, it’s performance (including mileage, fuel and
      other operational data) and the driver’s operation of the vehicle during their rental for safety, security and claims management
      reasons and may retain this data as necessary for these purposes.
      We also have the ability to track the vehicle’s location throughout the duration of a rental, although we will only access this
      information in circumstances where the driver is in breach of the rental agreement, by failing to return the vehicle on time or by
      driving into unauthorised territories.
    5. Cookie Policy:
      We use cookies on our website to store information in your computer or mobile device to improve your online experience. Cookies are
      small text files which let you navigate between pages efficiently, remember your preferences, help us understand how this website is
      performing and generally improve your browsing experience. Cookies can also help to ensure the advertising you see online is more
      relevant to you.
      Generally, our cookies preform the following functions;

      Technical Cookies Some cookies are vital for the operation of our websites. Without them you would not be able to move through the website
      and use some of its features. Technical cookies enable information you provide and decisions you make regarding your
      rental to be remembered from page to page in the booking process. Because these cookies are essential, we do not enable
      you to choose to disable them on our website.
      Personalization Cookies We use personalization cookies to allow us to remember the preferences you have requested in previous visits including and
      changes you have made to customise the site to your liking. We may also use personalization cookies to provide you with
      enhanced services such as allowing you to watch a video online. The information these cookies collect is anonymized and
      used in relation to our website only.
      Performance Cookies We use performance cookies to analyse how our visitors use our websites and to monitor website performance. This allows us
      to provide a high-quality experience by customising our offering and quickly identifying and fixing any issues that arise.
      These cookies don’t collect information that identifies a visitor. All information collected is aggregated and therefore
      anonymous and is only used to improve how our website works.
      Advertising Cookies We and our advertisers use cookies to serve you with advertisements that we believe are relevant to you and your
      interests. They are used to limit the number of times you see an advertisement as well as to measure the effectiveness of
      the advertising campaign. We may also use cookies placed by advertising agencies who may record that you have visited this
      website and share that information with other advertising organisations to enable targeted advertising to be sent to your
      computer or mobile device.
      Third Party cookies This website may use third-party cookies that are set by organizations different from ZEROCAR. For example: Google
      Analytics, who may use cookies to collect information, that will be transmitted, processed and stored by Google as set out
      on the Google.com website.

      The user expressly accepts, by the use of this site, the treatment of the information collected in the manner and with the
      aforementioned purposes. And, also acknowledges the ability to reject the processing of such data or information by preventing the use
      of cookies by selecting the appropriate settings on their browser. This option of blocking or deleting cookies may not allow you full
      use of the features available upon our site.

    6. Offline Information Collection:
      Calls to or from our reservation, customer service centers. transactions you complete with us, or our Franchisees including options you take, charges you incur and any incidents or
      accidents that may occur.
      interactions with our various Franchisees when you join our loyalty programs.
      In-person at rental locations. consumer reporting agencies and other companies that have business relationships with us, such as our Franchisees and
      business partners, including airlines, hotels, and insurance companies.
      in-vehicle or in-equipment technology or through other telematic devices. reservations you make with us through Franchisees, travel agents or brokers, online or in-person.
      in connection with a reservation (even an abandoned or interrupted reservation), a rental of a vehicle or equipment. Claims Management service providers (either affiliated directly with us or operated by a third party).

      Depending on the purposes for which we collect and use your Personal Data, as set out within this Policy, the Personal Data we collect
      from you may be required due to a statutory or contractual obligation, provided on a voluntary basis, or necessary for us to enter
      into a contract with you.
      If you do not provide your Personal Data to us this may result in disadvantages to you. In particular, we may not be able to rent to
      you. However, unless otherwise stated, not providing your Personal Data will not result in legal consequence for you.

  2. Purpose of Information Collected.

    Below we have set out the various purposes for which we process your Personal Data. We have also set out the legal grounds for the processing
    of your Personal Data for each purpose:

    1. OPERATIONS: We may use your Personal Data to provide you with the services or products you request from us and to
      perform other activities related to such services or products, including billing and collection prior to or following a rental, or to
      communicate with you regarding (i) any reservation you initiate or rental transaction; (ii) your membership/status in our loyalty
      program; or (iii) changes to the terms or features of our loyalty program to which you may belong.
      Legal Basis: to perform our contract with you or to take steps at your request prior to entering into a contract with you.
    2. OUR MARKETING: We may use your Personal Data to provide you with marketing information, special offers and promotions
      via various means, including e-mail, in accordance with applicable law.
      Legal Basis: on the basis of your consent. However, where permitted by applicable law we may lawfully use your Personal Data to send
      you such marketing communications (including via email) for these marketing purposes where necessary for our legitimate interests,
      which include promoting our products and services, special offers and promotions which may be of interest to you.
      You can unsubscribe from receiving such messages at any time by contacting us utilizing the contact details in Section F. below, as
      well as the unsubscribe link in each e-mail message. Please note that if you exercise these choices, you will continue to receive
      communications concerning your account and products and services you requested, and in response to any requests for information by
      you. Please also note that this process may take some time to complete, consistent with applicable law.
    3. THIRD PARTY MARKETING: We may also share your Personal Data with a sponsor or other third party that provides you
      with special offers or promotions that may be of interest to you (“Third Party Provider”) where permitted.
      Legal Basis: on the basis of your consent. You may instruct us at any time not to share your Personal Data covered by this Policy with
      such Third Party Providers where you have previously consented.
      Please note that (i) this process may take some time to complete, consistent with applicable law; and (ii) even after such process is
      completed, your personal and other information may continue to be shared with our Franchisees, and designated service providers in
      accordance with this Policy.
    4. NORMAL COURSE OF BUSINESS: We may also process your Personal Data and other information should such processing be
      necessary:

      1. to comply with the law or in response to a subpoena, court order, law enforcement request, or other legal process;
        Legal Basis: where it is necessary for compliance with a legal obligation to which we are subject.
      2. to protect the interests, rights, safety, or property of us or others
        Legal Basis: where it is necessary for compliance with a legal obligation to which we are subject.
      3. to enforce any terms of service on our websites or the terms and conditions of any rental, purchase, or utilization;
        Legal Basis: for our legitimate interests, which are to protect us and enforce such terms of service or terms and
        conditions.
      4. as part of a business transaction where all or some of our assets are bought, sold, or otherwise transferred by act of law or
        contract; and
        Legal Basis: for our and third parties’ legitimate interests.
      5. to operate our systems properly.
        Legal Basis: for our legitimate interests, which are the proper running of our systems and our business in order to
        provide our products and services to you and other customers.
    5. TELEMATICS: We may use in-vehicle data systems to collect data about the vehicle’s position, condition and
      performance during your rental. Use may include:

      1. to collect data relating the vehicle’s condition and performance during the rental (including vehicle damage, mileage, fuel
        use and other operational data) to improve the accuracy of our billing processes on return of the vehicle.
        Legal Basis: for our legitimate interests to ensure accurate charging for your uses of the vehicle, including for fuel
        and damage, during your rental.
      2. to collect data relating to the driver’s operation of the vehicle during the rental for safety, security and claims management
        reasons, including to contact the renter if the data suggests there is a security, safety or operational issue that we need to
        bring to your attention.
        Legal Basis: for our legitimate interests to enable us to defend and manage claims arising out of accidents involving
        the rental vehicle; to ensure we meet our safety and security obligations in relation to the vehicle and each rental.
      3. to track the vehicle’s location throughout the duration of a rental in order to access such information solely where the
        driver is in breach of the rental agreement (by failing to return the vehicle on time or by driving into unauthorised
        territories) or to assist in the defence and management of claims following an accident involving the vehicle.
        Legal Basis: for our legitimate interests to protect our assets, enforce our terms and conditions and defend and manage
        claims.
      4. to track the vehicle to enable us to provide information to you as you drive about areas of historic or leisure interest,
        restaurants, service or recharging stations or other places or services of interest;
        Legal Basis: on the basis of your consent.
    6. WEBSITES: If you use our websites we may process your Personal Data as follows:
      1. Aggregated or anonymized information: We may share with other third parties aggregate or anonymized
        information about our website users, such as your use of this website, and the services provided on this website, as well as
        any rental, purchase, or utilization information.
      2. Social media: If you participate in certain public features of our websites, apps, or social media
        websites/apps, please note that any information you or others voluntarily disclose through use of such features, becomes
        available to the public and/or other users whom you have designated.
        If you choose to provide access credentials to designated individuals, please be aware that any information you provide to us
        may be visible to such individuals.
        We are not responsible for the information that you or others choose to disclose publicly, and such information is not subject
        to this Policy.
      3. Links to third parties: We may provide links to third-party websites or may be linked to from third-party
        websites. Since we do not control third-party sites, and we are not responsible for any information you may provide while on
        such sites, we encourage you to read the privacy policies on those websites before providing applicable third parties with
        your information.

  3. Sharing of Information Collected.

    THIRD PARTY COMPANIES
    We may share your Personal Data with third parties in the following circumstances:

    1. To provide services to you: We may share your personal data among ourselves, our Franchisees, and other companies to
      provide services to you, including to:

      make your rental reservations. provide you with customer assistance.
      process and/or confirm your transactions. bill and collect amounts owed in connection with your rentals.
      provide you with enhanced rental services, such as services provided in connection our loyalty program. for customer satisfaction and market research purposes to help us improve our services.
    2. Disclosure to companies you use: We will also share your information with companies you use in connection with your
      rental, including;

      your credit or debit card provider and other companies that process your charges. any intermediary you use, such as a travel agent or broker, in relation to any aspect of your rental.
    3. Protective and legal uses: We may use, share and disclose your personal data for legal reasons as we believe
      necessary or appropriate, including to:

      comply with applicable law, including laws outside your country of residence. recover our vehicles or any monies due, such as debt collection agencies.
      process, handle or otherwise respond to claims for damages, including for bodily injury or property damage. protect our rights, privacy, safety or property, and/or that of our Franchisees, you or others.
      allow us to pursue available remedies or limit the damages that we may sustain. protect our operations or those of any of our Franchisees.
      respond to requests from public and government authorities including those outside your country of residence. comply with legal process.
      enforce our terms and conditions.
    4. Retention of Information Collected.
      1. Data Retention:
        We retain personal data about our customers for as long as we believe is necessary for the purposes for which it was
        collected, or unless otherwise allowed or required by law. We collect Personal Data for a number of purposes (above) and may
        be required to retain it for legal reasons for a period which is longer than the time we require or use the data for the
        purpose of providing our rental services to you. We maintain a data retention policy to cover all the Personal Data we retain
        across our systems. If you have any questions about the retention period applying to the Personal Data we collect about you,
        please contact us (see Section F.).
      2. Security Measures:
        Information is stored and accessed in various locations and through cloud services. Servers which store information are
        primarily located in Canada, the United States, and Europe, although storage may occur in other locations as well. We use
        reasonable administrative, technical, personnel, and physical measures (a) to safeguard Personal Data against loss, theft,
        unauthorized use, disclosure, or modification; and (b) to ensure the integrity of your Personal Data. To help us protect your
        privacy, you should maintain the secrecy of any logon IDs and passwords, Member numbers, or other identifiers or credentials
        you may have set up or were provided with in connection with your participation in or use of our products, services, or
        websites.
      3. Information Transmissions:
        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. If
        you have reason to believe that any account with us is no longer secure, you must immediately contact us.
        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 may 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. Such messages may contain Personal Data. Please do not include confidential information, such as your
        credit or debit card number or account passwords, within 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 of our websites.

  4. Your Rights.

    May include but is not limited to:

    1. You have the right to request access to, review, and update your Personal Data covered by this Policy, and can request this by
      contacting us at the details set out in Section F. below. While we will make reasonable efforts to accommodate your request, we also
      reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.
      If you are a member of our loyalty program, you may update the information in your member profile by logging into your applicable
      member profile.
    2. You also have the right to:
      1. request rectification of your Personal Data where the information that we hold about you is incorrect or incomplete
      2. object to the processing of your Personal Data for direct marketing purposes, including profiling to the extent it relates to
        direct marketing;
      3. object to the processing of your Personal Data where our legal basis for that processing is that such processing is necessary
        for our legitimate interests, subject to any overriding legitimate grounds that we may have for the processing;
      4. object to automated decision making (including profiling) in certain circumstances;
      5. request erasure of your Personal Data in certain circumstances, such as where processing is no longer necessary for the
        purpose it was originally collected for and there is no compelling reason for us to continue to process (or store) it;
      6. request restriction of your Personal Data in certain circumstances, such as that we do not process certain of your Personal
        Data (other than merely by storing them) following a rental in circumstances where all matters relating to the rental have
        been completed and the data is being stored only to meet certain legal (e.g. tax) requirements; and
      7. receive (or ask us to transmit to another organization) your Personal Data that you have provided to us which we process by
        automated means where our processing is either based on your consent or is necessary for the performance of a contract with
        you.
    3. In addition, where we process your Personal Data based on your consent, you can withdraw that consent at any time.

    You can make a request to us to exercise any of these rights by contacting us as set out in Section F. below.

  5. Questions or Changes.

    1. CONTACT US: We do business in many countries and aim to comply with the privacy laws applicable to the Personal Data
      we collect and use. Should you have a concern or complaint about our handling of your Personal Data, you may contact us directly via
      the methods described below. We will work to respond and resolve your complaints in an expeditious manner. You also have the right to
      lodge a complaint with a competent data protection supervisory authority in your jurisdiction.
      Please contact us by emailing over our contact form or writing to the address below if you have any questions, wish to exercise your rights
      of access, or seek other assistance as described above.

      1. Data Protection Officer
      2. CARBON FREE MOBILITY INC.
      3. #2120 – 21000 Westminster Highway
      4. Richmond, B.C.
      5. Canada, V6V 2S9

      Data Protection Officer
      CARBON FREE MOBILITY INC.
      #2120 – 21000 Westminster Highway
      Richmond, B.C.
      Canada, V6V 2S9

    2. CHANGES: We reserve the right to change this Policy at any time for any reason by posting revisions on this webpage.
      Such changes will be effective upon posting but will not apply retroactively. Whenever we make a material change, we will note the
      date of such update in the introductory page above and post a note on the home page of our website.

CARBON FREE MOBILITY INC. © 2024