what personal information we collect and how we use it
The principal purposes for which we collect and store your personal information are to process your application, allow you to reserve and use our vehicles, authorise payment, bill you, respond to your enquiries, improve our products and services and maintain your account with us. We will use your personal information including where:
- this is necessary to enter into or perform our contract with you - for example, using your contact details and payment details to supply products and services you want to purchase.
- this is necessary to comply with legal or regulatory requirements - for example, disclosure of information to law enforcement if you are involved in an accident during your reservation, or suffer any loss, damage or theft of the vehicle, or if you incur any speeding, parking, toll or other traffic-related fines or commit any traffic offences during your reservation.
- this is necessary in the public interest - for example, undertaking measures for anti-fraud screening and verifying our member's identities.
- we have collected your consent - for example, in order to send you direct marketing messages. You can opt-out at any time by using the opt-out in a marketing message or withdraw your consent at any time (in your account preferences or settings) or by contacting us as set out at the end of this privacy notice.
- this is necessary for the purposes of our legitimate business interests (provided that we have balanced these against your rights and interests).
- Our legitimate interests include: (a) to ensure effective administration and management of your relationship with us, including any reservations with us; (b) to understand how our members use our services and to manage our vehicle fleet; (c) to carry out research and analysis on what services or products our members want or how they would like us to improve our services and products; (d) to understand how our members use our Sites and identify any issues in how the Sites are used and how we can improve the members' usage experience; (e) to tell our members about the various products and services we can offer; (f) understand and respond to member feedback; (g) to better tailor and personalise the promotions and benefits that we offer to our members; (h) to prevent, detect, or investigate unauthorised use of our vehicles and systems and ensure we comply with law and our policies; and (i) manage any disputes and accidents and take legal or other professional advice.
We have set out below further details on the information we collect, store and why we use it.
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; personalising 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.
IP Addresses and other information collected automatically: We may collect 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 analyse 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 and any forms on the website that you filled in. 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 Wuracar location 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.
Wuracar collects information that you voluntarily submit to us, which could include 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, or similar message, telephone call, or by other means. Your telephone calls and other correspondence with us may be recorded or monitored for quality control, training and similar purposes. We use this information in connection with providing you with our services and managing your account as outlined elsewhere in this privacy notice.
If during a reservation you connect or pair your mobile device with the Wuracar vehicle (for instance via Bluetooth or USB port), please unpair your device and delete any personal data stored on the vehicle's infotainment system. Wuracar does not use this information but, if you do not delete it, the information may still be visible to subsequent Members who use the Wuracar vehicle.
If you apply to join Wuracar, join Wuracar and use our services, we collect personal information as you proceed through the stages of our application process, membership agreement and reservation process.
When you become a Wuracar member or make a reservation, we collect information to provide you with our services, (for example, fulfilling a vehicle reservation, providing any requested optional extras, taking payment, pre-authorisations and/or security deposits and providing discounts and offers or other benefits) and for our legitimate business interests (for example research and development of new products and services and enforcing our legal rights). The information we collect may include:
- name;
- email address (to contact you);
- home address (for Wuracard fulfilment or billing);
- usernames, passwords and account preferences (to administer your account);
- employer details and business address (if you are a member of a Wuracar for Business affiliate);
- telephone numbers at which we can reach you;
- date of birth (for license validation and legal requirements);
- gender (for license validation);
- payment information such as your credit or debit card details (to process payment);
- information from driver's license and/or other government issued identification (for license validation and legal requirements);
- other form of photo ID such as passport or national identity card if your driver's licence does not include a photo or is not recognisable as you;
- photo of yourself (for license validation and legal requirements);
- occupation (for license validation and legal requirements);
- tax identification number (for license validation and legal requirements);
- whether you have been in the country for a certain amount of time (for license validation and legal requirements);
- special join or coupon codes (if you request to redeem a particular offer);
- special requests and preferences, which may include:
- your preferences regarding optional extras such as damage fee waivers;
- preferred Wuracar pod locations; and
- other information that may be required to provide you a vehicle and/or provide you with services.
As part of your application or membership, we may also collect information such as your driving record from regulatory bodies or from third parties.
Where you inform us that you require an adapted vehicle or other driver aid we will use that information in order to provide you with the service you requested where you have given your explicit consent to us using that information or: (1) the use is necessary to protect your vital interests in an emergency or those of another person; (2) the relevant information has been made public by you; (3) the use is necessary or in connection with legal claims or court proceedings; or (4) the use is necessary for reasons of substantial public interest - for example, driving safety.
In connection with your membership, we will collect where and when you searched for, reserved or picked up a vehicle, where and when you returned a vehicle, waiver or insurance preferences, fuel consumption, mileage, accident history and other information related to a Wuracar vehicle and your use of it. This information is required in order to provide you with the services you requested under the member contract or for our legitimate business interests (for example to monitor the usage of our vehicle fleet).
Sometimes, we will combine the personal information we receive from you with other information we received from other sources so we can provide you a more customised experience. This information may include your name, contact information, reservation details and other information that is relevant to your reservation. These third parties include
- Universities if you are using an affiliated account;
- Your employer or association if you are using a corporate / association account;
- Our licensees and our affiliates, in order to create a Wuracar membership account or if you are making a reservation in one location served by our affiliates or licensees for reservations in another location served by us; and
- Police and other law enforcement agencies if you are involved in an accident during your reservation, or suffer any loss, damage or theft of the vehicle, or if you incur any speeding, parking, toll or other traffic-related fines or commit any traffic offences during your reservation.
If you have an accident, or suffer any loss, theft or damage to the vehicle during your reservation or suffer any mechanical failure, we will collect information regarding such incident including your report of the incident and any police or other third party report including details of thos involved, together with the nature of any personal injuries and/or damage to the vehicle and optional extras. We will use this information to provide services to you (for example, under the member contract and/or the terms of any optional extra like the damage fee waiver); for our legitimate busines interests (for example, in recovering the costs of any loss or damage caused to the vehicle); for complying with any legal obligation on us (for example, making any required notification of the incident to appropriate authorities); and establishing, exercising or defending legal claims arising as a result of such incident.
We will also collect information about any speeding, parking, toll or other traffic-related fines that you incur or any traffic offences that you commit during your reservation where these are provided to us by any law enforcement agency. We will use this information to deal with such fine or offence in accordance with the terms of your member contract with us.
When you call or text us (from any phone), or e-mail us, we may record or monitor the communication for quality control, training or similar purposes.
In addition to the purposes listed above, we use this information to better understand our members and may provide you with relevant offers.
Please be aware that, in certain circumstances, where you do not provide personal information which is required by us, we will not be able to provide the products and services under our contract with you or may not be able to comply with a legal obligation on us. For example, when reserving a vehicle with us we will require information such as your name, address, payment information and driver's license. If you fail to provide this information to us we will be unable to provide a vehicle to you. You will be made aware if this situation arises and what the consequences of not providing the personal information will be.
Automated Decisions may be made by us regarding you in respect of validation of driver licence details or other identify checks. If you disagree with the decision you are entitled to contest this by contacting us by using the details at the end of this privacy notice.
Where permitted by local law, Wuracar may use Global Positioning System (GPS), telematics data tracking technology and anti-theft technology that uses GPS. GPS is a network of satellites that would allow us to determine the location (latitude and longitude) of Wuracars during your reservation. Additionally, Wuracars may also have an on-board device that may monitor the state of the vehicle from moment to moment, including its location during your reservation. This information would be transmitted to Wuracar and stored. Where applicable, Wuracar uses this information for a variety of legitimate interests and also in connection with the performance of our contract with you. For example, we may monitor or store vehicle or GPS data to help you find a car you have reserved, to assist with roadside assistance and to locate lost or stolen Wuracars.
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." Wuracar does 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, Wuracar 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 on our behalf strictly in accordance with our contractual agreements.
Fraud detection and prevention. It is important that Wuracar takes appropriate measures to detect and protect its services against fraud, theft and abuse. We have therefore engaged a third-party service provider, Sift Science ("Sift"), based in the United States, to assist with these measures.
In connection with such activities, we need to collect and share with Sift the following personal data in reliance on our legitimate interests in detecting and preventing fraud, theft and abuse:
- Contact detail information: such as your email address, postal address, telephone number, user log-in information;
- Site transaction information: such as details of your membership with us, including details you may provide such as occupation, ID verification details, date of birth and driving licence details, as well as details of reservations you make including time, date, location and payment details, aggregated reservation details and other identifying information about your membership or reservation;
- Device and browser information: such as details of the device identifiers and attributes together with device and phone related meta-data; and
- Site and app usage information: such as your device IP address, your location when using the website or app if available and session ID.
We collect this personal data from your interaction with our services (through the use of our website or app) and through certain standard tracking technologies (e.g., JavaScript snippets).
Sift will process the information referred to above as an independent controller separate from Wuracar and only for the purposes of providing its fraud detection and prevention services, as further described in its privacy notice, available at: https://sift.com/service-privacy. Sift is required to comply with certain legal requirements which apply to their business. If you have any questions about Sift's use of information or if you would like to exercise any data protection right you may have in relation to Sift's processing, please contact Sift directly using the details provided in Sift's privacy notice available at the link above.
If used, telematics data tracking technology allows us to monitor driver behaviour of members to aid in reducing fraud or in an accident situation. In addition, at an anonymous and aggregated level, insight can be obtained about Wuracar usage. We have a legitimate interest in using the information in this way as well as there being a public interest in the responsible use of vehicles.
Wuracar may have access to video surveillance systems as well as cameras, where indicated by signage at the relevant Wuracar group location, tha record activity at our Wuracar pods.
children's privacy
We do not knowingly solicit or collect individually identifying information from children under the age of 16. If you are under 16 years old, you may not submit any personal information to us or subscribe for services. If you believe we might have any personal information from or about a person under the age of 16, please contact us.