DATA PRIVACY NOTICE

Protecting your personal data privacy is of paramount importance to Avis Philippines.

We, at Avis, are committed to protect and respect your personal data privacy, and we are dedicated to comply with and fully implement the provisions of the law which protects primarily safeguard the personal information of persons particularly known as the Data Privacy Act of 2012.

1. Definition of Material Terms

a. “Account” as used in this notice refers to the user profile created by the User
and/or Client, in order to avail of any of Avis’s services.

b. “Client” a User who registered and created in account by providing
information, including your name, email address, residence, phone number,
and creates/submits a username and password.

c. “Cookies” as are data files that are placed on your device or computer and
often include an anonymous unique identifier.

d. “Data Subject” means an individual whose personal, sensitive personal, or
privileged information is processed.

e. “Log files” track actions occurring on the Service, and collect data including
your IP address, browser ty

f. “Mobile App” refers to any of Avis’s online applications which may be
downloaded through Google Play, or through the Apple App Store.

g. “Personal Information” or “Personal Data” refers to any information, whether recorded in material form or not, from which the identity of an individual is apparent or can be reasonably ascertained by the entity holding information, or when put together with other information would directly and certainly identify the individual.

h. “Personal Information Controller” refers to natural or juridical persons, or
any other body who controls the processing of personal data, or instructs
another to process personal data on its behalf. The terms exclude:

1. A natural or juridical person, or any other body, who performs such
   functions as instructed by another person or organization; or
2. A natural person who processes personal data in connection with his or
   her personal, family, or household affairs.

i. “Personal Information Processor” refers to any natural or juridical person or
any other body whom a personal information controller may outsource or instruct the processing of personal data pertaining to a data subject;

j. “Sensitive Personal Information” refers to personal information pertaining
to:

1. An individual’s race, ethnic origin, marital status, age, color, and religious philosophical or political affiliations;
2. An individual’s health, education, genetic or sexual life of a person, or to
   any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings;
3. Any personal information issued by government agencies peculiar to an
   individual which includes but is not limited to, social security numbers,
   previous or current health records, licenses or its denials, suspension or
   revocation, and tax returns; and
4. Any personal information established by an executive order or an act of
   Congress to be kept classified.

k. “User” as used in this notice, refers to a person who accesses the Website
and registers as a User.

l. “Visitor” refers to any person who uses Avis’s App, other than as a User or
account holder.

m. “Website” means the website that can be accessed at this address: www.avis.com.ph

2. About Avis Philippines

Avis Philippines App provides driver and passenger mobility and tracking services.

3. How Avis Philippines Collects Personal Data

Whenever Users and/or Clients access or register to our mobile app or website, you necessarily share with us your personal data which we may use in providing you with our services.

As a User

If you are a User we collect from you the following Personal Data when you use
or register on our website, or use and register through any of our mobile apps, or avail of our services:

a. Name;
b. Gender;
c. Email address;
d. Mobile Number;
e. Date of Birth;
f. Civil Status
g. Address, current location;
h. Payment Information, including credit card numbers;
i. Image of ID for verification;
j. Personal photo for verification.

Required Fields

When you register on our website or through any of our mobile apps, you may
be required to fill up online forms which will ask you to provide information marked as “Required Fields,” in which case, you must provide the information and agree to the processing of such personal data by Avis Philippines. If you do not agree to provide the information in the “Required Fields,” Avis Philippines will not be able to provide its services to you, and your registration, and subsequent use of the website or any of our mobile apps may be denied.

From Users and/or Client

By Downloading the App, or Registering thru our Website- When a User or a Client registers in our website, we collect the following Personal Data which are necessary and reasonable for the performance of our services, which may necessarily include:

a. Name;
b. Gender;
c. Email address;
d. Mobile Number;
e. Date of Birth;
f. Address, current location, including ZIP Code;
g. Payment Information, including credit card numbers;
h. Image of ID for verification;
i. Personal photo for Verification.

4. Use and Utilization of Information

Avis Philippines only uses your Personal Data and other information for legitimate purposes and transactions which are necessarily involved in managing and developing its website or any of its mobile apps, and providing you with its services, and conducting its business, which includes but not limited to:

a. Provide Users with service
b. Provide Users with information, products, notices or services that you request from the Company
c. Marketing purposes
d. Performing internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing, and research, and to monitor and analyze usage and activity trends.

We use information for internal and service-related purposes only and may provide it to third parties to allow us to facilitate the Service, these third parties may include marketing partners, furniture and goods suppliers, credit card processors, hosting providers and other third party vendors, partners or suppliers. We may use and retain any data we collect to provide and improve our services.

When you share your Personal Data with Avis Philippines, we may use the same to send you marketing and/or promotional material from time to time. You may opt to stop receiving our messages by informing us through sending an email, or messaging us through our website or through any of our mobile apps.

Location Information – Avis Philippines collects information from your devices (computers, mobile phones, tablets, etc.), including information about how you interact with our services and information that allows us to recognize and associate your activity across devices and services. This information includes device specific identifiers and information such as location, IP address, cookie information, mobile device and advertising identifiers, browser version, operating system type and version, mobile network information, device settings, and software data. We may recognize your devices to provide you with personalized experiences and advertising across the devices you use. In addition, the information may also include your location.

Transaction Information – We likewise collect transaction details related to your use of our Services, including the, date and time the service was provided, amount charged, distance of delivery of goods, type of service requested and other related transaction details.

Usage and Preference Information – We collect information about how you and site visitors interact with our Services, preferences expressed, and settings chosen. In some cases we do this through the use of cookies and similar technologies that create and maintain unique identifiers.

Device Information – We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and various, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.

Log Information –  When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

Information from Cookies and Other Tracking Methods – Avis Philippines employs cookies, web beacons and other tracking technologies to speed your navigation of the Platform, recognize you and your access privileges, and track your Platform usage. These help us in Platform analytics to give you a better experience. The same may be used to evaluate the success of our advertising campaigns. This includes information, but is not limited to, tracking how frequently you visit our Platform and use our services, time spent on the Platform, pages visited, links clicked, among others.

We may use third-party advertising companies to help us tailor site content to users or to serve ads on our behalf. These companies may employ cookies and web beacons to measure advertising effectiveness (such as which web pages are visited or what products are purchased and in what amount). Any information that these third parties collect via cookies and web beacons is not linked to any personal information collected by us.

We may transfer and store the information described in this section for processing to our third party partners. In the said event, we commit to do the appropriate measures as sanctioned by law to protect your personal information accordingly.

5. Information Sharing

We may disclose and market aggregated information about users of our Services, and aggregated information collected via our Services, that does not relate to an identified or identifiable natural person, consumer or household without restriction, except if other prohibited by applicable law.

In addition, we may disclose personal information that we collect or you provide as described in this Privacy Policy:

Through Our Services

We may share your information:

• Between Clients and Suppliers;
• Avis Philippines’s Affiliates;
• Advertisers;
• Third-Party Service Providers (such as credit card processors, vendors, and suppliers);
• Avis Philippines staff charged with research and development;
• Organizations or groups partnered with Avis Philippines for purposes of career improvement and related service enhancements;
• For the purpose of studying and sharing trends, we may share aggregated or pseudonymous information (including demographic information), that is limited to non-personally identifiable information, with partners, measurement analytics, apps, third party ad networks, or media.
• To contractors, service providers, aggregators and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Avis Philippines’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Avis Philippines about our users is among the assets transferred.
• With the general public if such information were made public such as in social media posts, comments on articles or other features of our Services that are of the public domain;
• With third parties with whom you choose to let us share information.

Other Important Sharing we may share your information:

• With Avis Philippines’ subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;
• With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
• In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Avis Philippines or others;
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
• If we otherwise notify you and you consent to the sharing; and
• In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

Social Sharing Features

We may integrate a social sharing features and similar tools which may allow you to share the information you provided us to a third person or the public, such as the information as to the route of your package, date of arrival, cost thereof etc., through the use of other apps, sites, or media. For this purpose, the rules, terms and conditions, and privacy notice that will govern will solely depend on the settings you establish with the said social sharing service. You understand that Avis Philippines should not be made liable for any event that damage or liability to a user arises by virtue of the use of the third party tool or app.

6. Cookies and other Tracking Technologies

Some of our web pages utilize “cookies” and other tracking technologies. A “cookie” is a small text file that may be used, for example, to collect information about activity on the web site. Some cookies and other technologies may serve to recall Personal Information previously indicated by a Web user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them.

Tracking technologies may record information such as internet domain and host names; internet protocol (IP) addresses; browser software and operating system types; clickstream patterns; and dates and times that our site is accessed. Our use of cookies and other tracking technologies allows us to improve our web site and your web experience. We may also analyze information that does not contain Personal Information for trends and statistics.

7. Storage and Security of Personal Information

All information gathered from the App is stored on a secured database server based in the Singapore. Avis Philippines has undertaken appropriate technological, organizational, and physical security measures to protect any and all information shared with it, from unauthorized access, unauthorized alteration, and unauthorized disclosure.

8. Retention Period

Avis Philippines shall not store and retain Personal Data and other information gathered for a period longer than necessary, and without the consent of Its users.

Avis Philippines shall only keep any personal information, and store and use the same for so long as the User or Users has active transactions with Avis Philippines and/or for such period required for legal and regulatory purposes, and will be disposed of in a secure manner that would prevent further processing, unauthorized access or disclosure to any other party or the public or prejudice your interest.

9. Updating Personal Information

Users may update their information by accessing their account through the website, or through any of their respective mobile apps.

Users may also ask Avis Philippines to delete or modify their personal information, which have been stored in the Database servers. Should a User wish to ask for a copy of their information stored with Avis Philippines, they may communicate with the contact information provided in its website or mobile app.

10. Your Rights Under the Data Privacy Act

Avis Philippines respects the rights of Data Subjects which primarily includes its Users.

As a Data Subject, you have the following rights in connection with the Processing of your Personal Information:

A. Theright to be informed
B. Theright to object
C. Theright to access
D. Theright to rectification
E. Theright to erasure or blocking
F. Theright to damages
G. Theright to data portability

A. Right to be Informed

You have the right to be informed, as to whether the Personal Information
pertaining to you, shall be, are being, or have been processed.

As a Data Subject, you shall be notified and furnished with information indicated hereunder before the entry of your Personal Information into the records of Avis Philippines:

a. Description of the Personal Data or information to be entered into the system;
b. Purposes for which they are being or will be processed, including Processing
for direct marketing, profiling or historical, statistical or scientific purpose;
c. Basis of Processing, when Processing is not based on your consent;
d. Scope and method of the Personal Data Processing;
e. The recipients or classes of recipients to whom the Personal Data are or may
be disclosed or shared;
f. Methods utilized for automated access, if the same is allowed by the Data
Subject, and the extent to which such access is authorized, including
meaningful information about the logic involved, as well as the significance
and the envisaged consequences of such Processing for the Data Subject;
g. Theidentity and contact details of the DPO;
h. Theperiod for which the Personal Data will be stored; and
i. The existence of your rights as Data Subjects, including the right to access,
correction, and to object to the Processing, as well as the right to lodge a
complaint before the National Privacy Commission.

B. Right to Object

You have the right to object to the Processing of your Personal Information,
including Processing for direct marketing, automated Processing or profiling.

You also have the right to be given notice, and opportunity to withhold your
consent to the processing of your Personal Information, in case there are changes to the information which have been supplied to you by Avis Philippines relating to direct marketing, automated processing or profiling.

Should you withhold consent, Avis Philippines shall no longer process your
Personal Information or Personal Data, unless:

The Personal Data is needed pursuant to a subpoena;

1. The Processing is for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which the Data Subject is a party, or when necessary or desirable in the context of an
employer-employee relationship between Avis Philippines and the Data
Subject; or

2. The Personal Data is being collected and processed to comply with a legal
obligation.

C. Right to Access

You have the right to reasonable access to, upon demand, the following:

1. Contents of your Personal Data that were processed;
2. Sources from which Personal Data were obtained;
3. Names andaddresses of recipients of the Personal Data;
4. Manner by which your Personal Data were processed;
5. Reasons for the disclosure of the Personal Data to recipients, if any;
6. Information on automated processes where the Personal Data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you;
7. Date when Personal Data concerning you were last accessed and modified; and
8. The designation, name or identity, and address of the DPO.

D. Right to Rectification

You have the right to dispute the inaccuracy or rectify the error in your Personal Data, and Avis Philippines shall correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the Personal Data has been corrected, Avis Philippines shall ensure the accessibility of both the new and the retracted Personal Data and the simultaneous receipt of the new and the retracted Personal Data by the intended recipients thereof: Provided, That recipients or third parties who have previously received such processed Personal Data shall be informed of its inaccuracy and its rectification, upon your reasonable request.

E. Right to Erasure or Blocking

You have the right to suspend, withdraw, or order the blocking, removal, or
destruction of your Personal Data from Avis Philippines’s filing system.

1. This right may be exercised upon discovery and substantial proof of any of
the following:

(a) The Personal Data is incomplete, outdated, false, or unlawfully obtained;
(b) The Personal Data is being used for purpose not authorized by the Data
Subject;
(c) The Personal Data is no longer necessary for the purposes for which they
were collected;
(d)You withdraw your consent or you object to the Processing, and there is
no other legal ground or overriding legitimate interest for the Processing
by the Company;
(e) The Personal Data concerns private information that is prejudicial to you,
unless justified by freedom of speech, of expression, or of the press or
otherwise authorized;
(f) The Processing is unlawful; or
(g) Your rights have been violated.

2. The DPO may notify third parties who have previously received such
processed Personal Data that you have withdrawn your consent to the
Processing thereof upon your reasonable request.

F. Right to Damages

You have the right to be indemnified for any damages sustained due to such
inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.

G. Right to Data Portability

Where personal information is processed by electronic means, and in a structured and commonly used format, you have the right to obtain from the personal information controller a copy of data undergoing processing in an electronic or structure format, which is commonly used and allows for further use.

Participation of Data Subjects

Avis Philippines encourages its Users take an active role in the protection of their Personal Data, and the Users are welcome to any further suggestions that they may make in order to protect their Personal Information when they avail of Avis Philippines’s services.

Users and Shippers may freely opt not to disclose some of their Personal data,
however, there are personal information which, by the nature of the services being offered by Avis Philippines are required to be disclosed to Avis Philippines in order for the User to avail of the said service. Should the User refuse to disclose such necessary information, Avis Philippines may not be able to fully provide the User or Shipper with its services, and its application or registration may be rejected.

If you do not agree with the collection, and processing of your personal information, as discussed in this Notice, you must stop using Avis Philippines’s website or any of ts platforms.

11. External Links

There may be instances where the website would show or post hyperlinks leading to other external websites on the Internet.

These hyperlinks may lead to other websites and webpages which are published, and operated by third parties which are not connected to Avis Philippines, but are included in our website to enhance your user experience, and presented for information purposes.

Avis Philippines endeavors to select only reputable websites and sources of information for the convenience of its Users or Shippers.

Unless clearly stated by Avis Philippines, by providing the hyperlinks to other websites, Avis Philippines shall not be deemed to have endorsed, approved, recommended, advertised, approved, or guaranteed, these third party websites as well as their products or services posted or advertised in their websites.

Avis Philippines does not also have any partnership, cooperation, or agreement with these third party publishers, unless otherwise stated.

Avis Philippines is not responsible for any content of the websites where the hyperlinks are linked to.

Should you choose to click and follow any of these links, Avis Philippines shall not be responsible for any risks, damages, or losses which you may incur or suffer, arising out of or in connection with your use of their link.

Any information which you may divulge with the websites in the said links is the liability of the said website publisher or owner, and shall in no case be the liability of Avis Philippines.

12. Effectivity

Avis Philippines’s Privacy Notice is effective as of October 1, 2021 and until such time that the same is updated.

13. Acceptance of this Data Privacy Notice

This Data Privacy Notice applies to all Personal Data which we may collect from you. By accessing our website, or by using any of our mobile applications, or by providing us with your personal data, you warrant that you have read and understood the contents of this Data Privacy Notice and accept its contents, fully knowledgeable of the effects and consequences of using our website.

You also agree that by using and registering with our website or by using any of our mobile apps, or availing any of our services, that your Personal Data may be collected, used, stored, and shared to accredited third parties, and that you have given your consent to the said collection, use, storing, and sharing of your Personal Data.

If you do not agree with this Privacy Notice, please do not use our website or any of our mobile apps, or provide us with any Personal Data.

Avis Philippines reserves the right to amend this Privacy Statement to remain compliant with any changes in law and regulations, and to reflect how our business processes personal data.

Contact Information

Should you have any questions, clarification, and inquiries about your Privacy Notice, you may contact us through our Data Protection Officer:

Contact Number      : (+630284622847)

Email Address          : dataprotectionofficer@avis.com.ph