The www.qeeq.com website (the "Website") is operated by Qompass Voyage Limited trading as "QEEQ" ("our", "us" and "we"), a company incorporated in Hong Kong with its registered office at Room 1702, 17/F, Hong Kong Trade Centre, Nos. 161-167 Des Voeux Road Central, Hong Kong.
We respect your right to privacy and this Website Privacy Statement (this "Privacy Statement") sets out the bases on which we use, process, store or disclose any personal data that we collect from you or that you provide to us through the Website. In this context "Personal Data" means any information relating to an identified or identifiable natural person.
1. OVERVIEW OF THIS STATEMENT
We collect Personal Data from you when you use the Website and process this Personal Data for the purposes of facilitating access and use of the Website. You can also choose to provide us with additional Personal Data via email or forms available via the Website which we will process for the purposes of responding to your queries and requests; providing you with our car hire search and compare services; and, if, you choose to make a booking, processing that booking with the relevant car hire service provider.
We process this Personal Data as necessary for us to enter into and perform our contract with you; in pursuit of our legitimate interests; to comply with legal obligations to which we are subject; and to defend, establish or be a party to legal claims. This Privacy Statement sets out the categories of Personal Data that we process and how and why we process that Personal Data.
We store your Personal Data on servers located in several locations, including outside the European Economic Area ("EEA"). We share your Personal Data with other entities in the QEEQ group of companies (the "Group") and with other third parties. We may also share your Personal Data with law enforcement agencies or public bodies if we are required by law to do so.
2. THE PERSONAL DATA WE PROCESS
We will collect and process the following Personal Data from you:
When searching car hire options and making a booking Personal Data will be collected from you. This may include information such as your name, email address, country of residence, credit card information (prepay booking only) and driving licence details.
When using the Website or availing of services related to the Website, personal information will be collected from you by us. This includes:
· your IP address, operating system version, browser version, monitor resolution and recommended websites; and
· details of your visits to the Website such as traffic data, location data and Linked Websites that you can access through the Website.
You can choose to provide us with the following Personal Data:
Query and Form Information
· You may choose to give us additional information such as your first name, last name, phone number, e-mail address, city, country of residence, postal/zip code and other details when contacting us and submitting enquiries through the Website or by e-mailing us.
We may obtain the following Personal Data about you from third parties:
Third Party Information
· We may receive limited information about you from social media platforms, such as Facebook, Twitter and LinkedIn, when you interact with us via such platforms. This includes information such as details of whether and how you shared our Website via the social media resources on the Website. We may also receive limited information about you from third-party meta search platforms, such as Kayak and Skyscanner, when you are re-directed from these websites. This includes information such as country of residence and IP address.
3. HOW AND WHY WE USE YOUR PERSONAL DATA
The following table details the legal bases and the purposes for which we process your Personal Data:
LEGAL BASES AND PURPOSES
Personal Data Processed
Access to the Website
· To provide you with access to the Website and to allow you to use the Website.
· To facilitate the making of travel service bookings on the Website.
Third Party Information
It is necessary for the purpose of our legitimate interests to collect and process these Personal Data for the purposes of improving and monitoring website efficiency and enhancing your use of the Website, and to respond to any queries or requests submitted by you to us.
Improving Website Functionality and Efficiency
· To provide, improve, test and monitor the effectiveness of the Website.
· To monitor metrics such as total number of visitors, traffic data and demographic patterns.
Responding to queries
· To process and respond to any enquiries or requests such as customer support you submit to us by email.
To provide you with trip reminders and information
· To provide you with information on your upcoming trip such as time and location, weather forecast and travel guides of your destination(s) (please note that you may opt-out of receiving such reminder information by contacting us at email@example.com).
Promotional or Marketing materials
· To provide you with information in relation about our events programme, general news from us and other communications from us deemed to be of probable interest (please note that you may opt-out of receiving such marketing information by contacting us at firstname.lastname@example.org).
Query and Form Information
Third Party Information
Compliance with a Legal Obligation
We may process your Personal Data where it is necessary to comply with legal obligations to which we are subject.
· To comply with our obligations under consumer and other Irish and EU laws.
Third Party Information
To Defend, Establish or be a Party to Legal Claims
We may process your Personal Data as necessary in order for us to establish, investigate, exercise or defend a legal claim to which you are a party.
· To file legal proceedings.
· To investigate, establish, exercise or defend a legal claim.
· To settle legal claims.
Third Party Information
4. WHO WE SHARE YOUR PERSONAL DATA WITH
We may disclose your Personal Data to some or all of the following recipients:
QEEQ Group Companies
• Internal business units within the QEEQ Group.
• QEEQ shares your user name and country of residence information with car hire and travel service providers (in the course of searching for car hire and travel services and facilitating making bookings). These service providers include car rental companies, insurance suppliers and travel agents.
• Regulatory authorities and law enforcement agencies (where we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request).
• Other companies and organisations for the purposes of fraud protection and credit risk reduction, in order to protect the rights, property or safety of the Group, our customers, or others.
• Third-party marketing companies to whom we send certain Personal Data with a view to providing relevant marketing.
• External advisors e.g. lawyers, accountants and auditors (as necessary to protect our legitimate and legal interests).
• Service providers for logistical and IT service purposes, and to provide our customer service infrastructure.
5. TRANSFERS OF YOUR PERSONAL DATA
Your Personal Data will be stored and transferred outside the European Economic Area ("EEA"). We only transfer your Personal Data outside the EEA where the European Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards (i.e. that an adequacy decision has been granted in the country's favour) or there are appropriate safeguards in place to protect your Personal Data. If you would like to find out more about the appropriate safeguards that we have in place to govern the transfer of your Personal Data you can contact us at email@example.com.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will always do our best to protect your Personal Data, we cannot guarantee the security of any information you transmit to us; any transmission is at your own risk. Once we have received your Personal Data, we will endeavour to use strict procedures and security features to prevent unauthorised access.
6. LINKED WEBSITES
The Website contains links to other websites ("Linked Websites"). We are not responsible for the privacy statements or practices on Linked Websites. This Privacy Statement governs only information collected on the Website. When accessing Linked Websites, you should read the privacy statement published on the relevant Linked Website. The terms of our Privacy Statement do not apply to Linked Websites. Please check these statements before you submit any Personal Data to Linked Websites.
The Website contains links to Linked Websites and resources provided by third parties for your convenience and information only. We accept no liability in connection with any Linked Website, or any contract entered into with any third party on or through a Linked Website. We have no control over the content of those websites or resources and accept no responsibility for them or for any loss or damage that may arise from your use of Linked Websites.
7. HOW LONG WE KEEP YOUR PERSONAL DATA FOR
In general, we expect to keep your Personal Data for as long as is necessary for the purposes for which it was obtained from the date of collection or, where you enter into a contractual arrangement with us, following the end of the performance of the contract (which may be up to seven years in some cases).
Please note that in certain circumstances, we may hold your data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.
8. YOUR RIGHTS AND HOW TO EXERCISE THEM
You have a number of rights in relation to your Personal Data as set out in the table below. In particular these rights include the right to object to processing of your Personal Data where that processing is carried out for our legitimate interests. Note that in certain circumstances these rights might not be absolute.
Right of Access
You have the right to request a copy of the Personal Data held by us about you and to access the information which we hold about you. We will charge you for making such an access request where we feel your request is unjustified or excessive.
Right to Rectification
You have the right to have any inaccurate Personal Data which we hold about you updated or corrected.
Right to Erasure
In certain circumstances, you may also have your Personal Data deleted, for example if you exercise your right to object (see below) and we do not have an overriding reason to process your Personal Data or if we no longer require your Personal Data for the purposes as set out in this Privacy Statement.
Right to Restriction of Processing
You have the right to ask us to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data we hold about you is inaccurate or our use of your Personal Data is unlawful. If you validly exercise this right, we will store your Personal Data and will not carry out any other processing until the issue is resolved.
Right to Data Portability
You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another controller where this is technically feasible.
This right only arises where we process your Personal Data on the legal basis of your consent or where it is necessary to perform our contract with you.
Right to Object
You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.
You can exercise any of these rights by submitting a request to firstname.lastname@example.org.
We will provide you with information on any action taken upon your request in relation to any of these rights without undue delay and at the latest within 1 month of receiving your request. We may extend this up to 2 months if necessary however we will inform you if this arises. Please note that we may ask you to verify your identity when you seek to exercise any of your data protection rights.
You have the right to lodge a complaint with the data protection authority in your European Union country of residence. You can find their contact details here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
9. CHANGES TO THIS STATEMENT AND QUESTIONS
If we amend this Privacy Statement, in whole or part, any changes will be posted on this page and, where appropriate, notified to you by email or when you use the Website. The new Privacy Statement may be displayed on-screen and you may be required to read and accept it to continue your use of the Website.
If at any time we decide to use your Personal Data in a manner significantly different from that stated in this Privacy Statement, or otherwise disclosed to you at the time it was collected, we will notify you by e-mail, and you will have a choice as to whether or not we use your Personal Data in the new manner.
If you have any questions, comments or concerns about the way your Personal Data are being used or processed by us, please submit your question, comment or concern in writing to our email@example.com.