Privacy policy
CarFlex is an electronic service enabling the users to connect with a car rental provider in the Emirate of Dubai, United Arab Emirates through the Service's website available at https://carflex.ae/ (Website).
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1. WHAT IS THIS PRIVACY NOTICE FOR?
We are committed to protecting personal data and we want to be transparent about our activities and the way we process your personal data. The purpose of this Privacy Notice is therefore to inform you how and why we process your personal data.
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2. WHO IS PROCESSING YOUR PERSONAL DATA?
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2.1 Your personal data is processed by:
CARFLEX - CARFLEX MARKETPLACE USING ELECTRONIC PLATFORMS L.L.C
registered at SR-G-01, 17th Floor, Ontario Tower, Business Bay, Dubai
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2.1 Your personal data is processed by:
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3. WHAT PERSONAL DATA IS PROCESSED, HOW, AND WHY?
The categories of personal data we process, the source of this data, the purposes and the legal basis of the processing are listed in the table below. CarFlex collects and processes personal data as a data controller or data processor. Where CarFlex processes personal data as a data processor CarFlex collects personal data on behalf of its Partners - car rental providers. Once collected, CarFlex transfers your personal data to Partners to enable them to sign a car rental agreement with you and provide you with a rented car. CarFlex acts as payment collection agents of its partners and enables you to prepay car rental services via the Website.
Source Categories of Data Purposes Legal basis Data processed by CARFLEX as data controller Data provided by you Name, phone number, WhatsApp account, dates of rent To identify and authorise you as our user, register your account, confirm your booking and communicate with you about your order Contract with CARFLEX* Generated when you interact with our Website User ID, frequency of orders, time taken to complete an order, most frequently ordered services or goods, number of screens viewed when interacting with the apps, average order value i) To improve user experience, to provide relevant features, to modify Website’s interfaces, to prevent unauthorised orders ii) To analyse user activity for marketing purposes, to improve our marketing and business strategy iii) To arrange your participation in marketing contests or any other activities i) Legitimate interest in improving our Website, user experience, and service ii) Legitimate interest in conducting marketing research iii) Consent** Data processed by CarFlex as data processor on behalf of its partners*** Data provided by you
- Nationality, residency, age, driving experience,
- driving license details: first name and last name, date and place of birth, expiry date, official body that has issued the license, license number, place where the license has been issued, car category or categories to which the license extend, scanned copy of driving license, passport or ID details, including name, date and place of birth, place and date of issuance, expiry date, scanned copy of ID or passport, visa details, scanned copy of visa
To establish that you have are eligible to drive a car and have a valid driving basis Your contract with a Partner or other legal basis chosen by a Partner Preferred payment method, payment details, including bank account number, debit or credit card number, amount payable;
i) To process your payments Your contract with a Partner or other legal basis chosen by a Partner * When we request your consent for any type of personal data processing, we inform you of the data collected and the purpose of the data collection. You may refuse to provide such consent and it will not affect your ability to use our App/Websites. You may withdraw your consent at any time by contacting us. ** CarFlex provides electronic informational service to its Partners - car rental providers by way of: (i) granting the Partner an access to the Website and its functions to enable the Partner to offer and manage the car rental services provided by the Partner to the users and (ii) making available the Partner’s offers for car rental services on the Website.
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4. WHO DO WE SHARE WITH OR TRANSFER TO YOUR PERSONAL DATA?
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4.1 Recipients of Your Personal Data
Your personal data is only shared with parties:
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i) Directly involved in the provision of the services within the Website:
- Our partners providing car rental services listed at https://carflex.ae/partners;
- Payment service providers which facilitate electronic transactions;
- Our affiliates who provide authentication tools;
- Our affiliates and third parties who provide us with servers, data storage and other infrastructure facilities; and
- Our affiliates and third parties who assist us with customer support.
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ii) Entitled to receive your personal data under the law to which the relevant data controller is subject:
For example, if law enforcement authorities have a lawful right to have access to your personal data (according to the applicable law in your country and/or the country where our entity providing a service to you is incorporated), or financial regulators are duly entitled to investigate suspicious activities or transactions. We do not share your personal data with state authorities contrary to the applicable privacy law.
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iii) Helping us to improve our service:
For example, data about technical errors encountered while using our services are shared with our affiliates who are involved in the development of our Website.
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iv) Helping us to inform you about products, services and offers:
For example, advertising or device identifiers may be shared with companies that provide us with advertising or analytics services.
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i) Directly involved in the provision of the services within the Website:
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4.2 International Transfers of Your Personal Data
Parties we share your personal data with may be located in different countries.
Some of these countries may not provide the same level of data protection or data subject rights as the country where you use a service. In such cases, we follow the necessary procedures to ensure that your rights are respected and that your personal data are protected during and after the transfer.
Such procedures may include (subject to applicable privacy laws):
- i) Commitments through data protection agreements based on standard contractual clauses for data transfers issued by relevant authorities;
- ii) Additional contractual obligations based on our assessment of the local law of the country where your personal data are transferred and processed;
- iii) Registration or authorisation of the transfer from competent data protection authority; and/or
- iv) Additional technical and organisational security measures to prevent unlawful, i.e. incompatible with the laws of the country where we provide the service, or unauthorised access to your personal data.
We always comply with the privacy laws of the countries where we operate, including international data transfer requirements and limitations.
- 4.3 Our Partners acting as data controllers can transfer your personal data to third parties. To learn more about data transfers please contact a Partner which provides you with car rental services.
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4.1 Recipients of Your Personal Data
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5. WHAT ARE THE RETENTION PERIODS FOR PERSONAL DATA?
- 5.1 We process your personal data until the purpose of the processing has been achieved.
- 5.2 The actual retention period depends on the personal data processed and the country where the processing takes place.
- 5.3 We may continue to process your personal data, if such processing is required by law or is necessary to protect our rights and interests or the rights and interests of third parties, in particular in the context of court proceedings. The ability to delete data may also be limited by laws relating to freedom of expression and information.
- 5.4 Where CarFlex processes personal data as the data processor of the Partner(s) the retention periods are established by the partner.
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6. WHAT ARE YOUR RIGHTS?
You have a number of rights under privacy laws. The rights that are available to you depend on the reason we process your personal data and the applicable law. You may exercise your rights by contacting our customer support team via legal@carflex.ae.
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6.1 Right of Access
You always have access to your personal data. You have the right to request a copy of your personal information.
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6.2 Right to Rectification
You have the right to ask us to update or rectify information that you believe is incorrect, inaccurate or outdated. You also have the right to ask us to complete any information that you believe is incomplete.
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6.3 Right to Withdraw Consent
You have the right to withdraw your consent to the processing of your personal data where such processing is based on your consent.
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6.4 Right to Erasure
You have the right to ask us to erase your personal data in certain circumstances, for example, if the data is no longer needed for our purposes, if we process your data without a valid legal basis or otherwise unlawfully, if you have withdrawn your consent (if the processing was based on your consent), if we collected your data when you were a child, or in other circumstances according to applicable laws.
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6.5 Right to Restriction of Processing
You have the right to restrict the processing of your personal data in certain circumstances. For example, if you wish to exercise your right to rectification, you may request that we restrict the processing of your data until it has been rectified.
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6.6 Right to Data Portability
If your personal data is processed by automated means based on your consent or based on a contract with us (e.g. to provide you with the features of the Website), you have the right to receive your data in a structured, commonly used and machine-readable format.
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6.7 Right to Object
You have the right to object to the processing of your personal data if you consider that the processing violates your rights. Please note that the right to object can only be exercised if we are processing your data on the basis of legitimate interests or public interest.
You have the right not to be subjected to a decision based solely on automated processing, including profiling. We do not take decisions based solely on automated processing, including profiling.
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6.8 Right to Lodge a Complaint
We are always ready to consider your complaints and suggestions. Please send them to our customer support team.
You may also file a complaint with the appropriate supervisory authority if you believe that your rights have been violated.
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6.1 Right of Access
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7. HOW TO CONTACT US?
- 7.1 You can contact our customer support team via legal@carflex.ae.
- 7.2 Our Data Protection Officer can be contacted by email at legal@carflex.ae. Please include the phone number you used to register on our Website, this will help us to identify you quickly.
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8. HOW IS THIS DOCUMENT MODIFIED?
In the event of substantial changes to this Privacy Notice we will publish the new version on our Website or we may use any available means (SMS, email) to notify you. This would be the case, for example, if we add new categories of personal data to be processed or new purposes for which data are processed. You will be notified before such changes take effect.
Date of publication: 17.06.2024.