Privacy Policy

1Who is responsible for your personal data?

The controller responsible for the personal data described in this Privacy Policy is:

Oriani Complementa S.L., trading as ALL IN CAR HIRE
Spanish Tax Identification Number (CIF): B75608943
Registered address: Calle Dionisia Redondo, Local 1, 29640 Fuengirola, Málaga, Spain
Email: info@allincarhire.com
Telephone: +34 951 080 385
Website: www.allincarhire.com

In this policy, “ALL IN CAR HIRE”, “we”, “us” and “our” refer to Oriani Complementa S.L.

We process personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), Spanish Organic Law 3/2018 on Personal Data Protection and the Guarantee of Digital Rights, and other applicable legislation.

2What does this policy cover?

This policy explains how we collect and use personal data in connection with:

• Enquiries, quotations and vehicle reservations.
• Vehicle rental agreements and related services.
• Customer service, incidents, complaints and claims.
• Booking confirmations and other service communications.
• Our website and the business application “all in car hire mensajes”, which we use to send reservation confirmations through WhatsApp Business Platform.

This policy covers our processing of personal data. Third-party services, including WhatsApp, may also process information under their own privacy notices and terms.

3What personal data do we process?

We process the information relevant and necessary for the service you request and the legal obligations that apply to it. Depending on your relationship with us, this may include:

Identification and contact information: your name, address, email address, telephone number, and the identification and driving-licence information necessary to arrange the rental, verify eligibility and comply with applicable legal requirements.

Booking and rental information: your reservation number, vehicle or vehicle category, collection and return dates, times and locations, rental conditions, authorised drivers, charges and other information needed to provide the agreed service.

Billing and transaction information: billing details, rental amounts, invoices, payment status, deposits, refunds and transaction references relevant to your rental.

Service communications: confirmations sent to you, enquiries received through the contact channels we operate, and information you provide when requesting assistance or making a complaint.

WhatsApp confirmation information: your name, telephone number including its international country code, reservation number, vehicle or category, collection and return details, total reservation amount, and technical information returned when a message is submitted, such as its message identifier or an error response.

Technical website information: information necessary to deliver and protect the website, such as IP addresses, request information and technical logs. Information associated with optional cookies or analytics is addressed separately in our Cookie Policy.

Please provide accurate information and tell us when relevant details change. Please do not send payment-card security codes, passwords or unnecessary identity documents through WhatsApp.

4Where do we obtain your information?

We normally obtain personal data directly from you when you contact us, request a quotation, make a reservation or enter into a rental agreement.

We may also receive information from a person making a reservation on your behalf or identifying you as an authorised driver. In those circumstances, we use the information only for the relevant reservation, rental service and associated legal obligations.

If you provide another person’s information, please ensure that you are entitled to do so and make this policy available to them.

5Why do we use your information, and on what legal basis?

To answer enquiries, prepare quotations and arrange reservations.

We process information necessary to take steps at your request before entering into a contract.

To provide and administer vehicle rentals.

We process information necessary to perform the rental agreement, including arranging collection and return, administering charges and deposits, and communicating essential information about the service.

To comply with legal obligations.

We process information required by applicable tax, accounting, vehicle-rental, driver-identification and other legal requirements. This includes maintaining statutory records and providing information to competent authorities where legally required.

To handle incidents, complaints and legal claims.

We process information where necessary to perform our agreement, comply with legal obligations, or pursue our legitimate interests in resolving disputes and establishing, exercising or defending legal claims. Where we rely on legitimate interests, we consider the impact on your rights and freedoms.

To protect our website and business systems.

We may process necessary technical information for our legitimate interests in maintaining service availability, preventing misuse and protecting information.

To communicate through WhatsApp.

We use WhatsApp for booking confirmations and related service communications where you have agreed to receive messages through that channel. The underlying processing needed to manage your reservation or rental is based on the contractual or legal grounds described above.

For optional website analytics or similar technologies.

Where consent is required, the relevant processing must be based on your prior consent, as explained in the Cookie Policy.

Providing information necessary for a reservation, rental agreement or legal requirement is a condition of providing the relevant service. If you do not provide that information, we may be unable to arrange or complete the rental.

6How do we use WhatsApp?

We use WhatsApp Business Platform, through the application “all in car hire mensajes”, to send reservation confirmations and related service information.

A confirmation may contain your name, reservation number, vehicle or category, collection and return details, and the total reservation amount. Your telephone number and the message information are transmitted through the platform to deliver the communication.

Providing your telephone number or reading this policy does not, by itself, constitute permission to receive WhatsApp messages. We obtain permission to use this channel and respect requests to stop.

You may withdraw your permission for WhatsApp communications at any time by emailing info@allincarhire.com or calling +34 951 080 385. Please identify the telephone number concerned.

Stopping WhatsApp communications does not cancel your reservation or rental agreement. Necessary service information may instead be communicated through another appropriate contact channel.

Our current confirmation application is used to send messages. For assistance, requests to stop WhatsApp communications or privacy requests, please use the email address or telephone number above rather than relying on a reply to a confirmation.

We do not use the processing described in this policy for promotional campaigns, advertising audiences or the sale of personal data.

7Who may receive your information?

We disclose personal data only where necessary for the purposes described in this policy. Relevant recipients may include:

• Providers supporting our website, email, business software, hosting, IT maintenance and data storage.
• WhatsApp and Meta entities involved in providing WhatsApp Business Platform.
• Banks and payment service providers where necessary to administer rental payments, deposits or refunds.
• Accountants, legal advisers, insurers and other professional advisers where necessary for their services or a specific incident or claim.
• Tax authorities, competent law-enforcement bodies, courts, traffic authorities and other public bodies where disclosure is required by law or a valid legal request.

Where a provider processes personal data on our behalf, the processing must be governed by appropriate contractual obligations, including confidentiality and security requirements.

Some recipients act as independent controllers for their own legal or service responsibilities. Their processing is governed by their own applicable privacy notices.

For companies established in the European Economic Area, the current WhatsApp Business Platform terms identify WhatsApp Ireland Limited as the WhatsApp contracting entity. Relevant WhatsApp and Meta companies may also process platform and technical information for the purposes described in their own terms. Further information is available in the WhatsApp Business Platform Terms.

8Are personal data transferred outside the European Economic Area?

The use of international technology providers, including WhatsApp and Meta, may involve processing outside the European Economic Area, including in the United States.

Where such transfers take place, the applicable legal transfer requirements must be met. Depending on the recipient and the processing involved, safeguards may include:

• A European Commission adequacy decision, including the EU–US Data Privacy Framework where it applies to a participating recipient and the relevant data.
• The European Commission’s Standard Contractual Clauses, together with additional safeguards where required.

WhatsApp describes its relevant transfer arrangements in its Business Data Transfer Addendum.

You may contact info@allincarhire.com for information about the safeguards relevant to your personal data and how to obtain a copy, subject to the protection of confidential information and other persons’ rights.

9How long do we keep your information?

We apply retention periods according to the purpose of the information and the legal requirements that apply to it.

Reservations and rentals: information is retained while needed to arrange and administer the service, complete the rental and resolve related outstanding matters. After that, only information required for the legal, accounting or claims purposes described below is retained.

Statutory vehicle-rental records: information included in the statutory electronic register under Royal Decree 933/2021 is retained for three years after the rental service ends, in accordance with the applicable requirements. Royal Decree 933/2021, Article 5.

Accounting and supporting business records: records subject to Article 30 of the Spanish Commercial Code are retained for six years from the last relevant entry in the accounting books, unless a different legal requirement applies. Tax requirements or proceedings may require particular records to be kept for longer. Spanish Commercial Code, Article 30.

Enquiries and service messages: these are retained while the enquiry, reservation or service issue is being handled. Afterwards, only information necessary to document the rental, comply with legal requirements or address potential claims is retained under the corresponding retention criteria.

Channel permissions and opt-out requests: we retain the limited information necessary to demonstrate relevant permissions, respect requests to stop communications and address associated legal responsibilities.

Claims and proceedings: relevant information may be retained until the matter is finally resolved and the applicable legal limitation periods have expired.

When information is no longer needed, it is deleted or irreversibly anonymised. Where Spanish law requires data to be blocked, it is restricted from ordinary use and retained only for the legally permitted purposes until it can be deleted.

10What are your rights?

Subject to the conditions established by data protection law, you may:

• Request access to your personal data.
• Request correction of inaccurate or incomplete information.
• Request deletion of your personal data.
• Request restriction of processing.
• Object to processing based on legitimate interests.
• Request portability where processing is based on consent or a contract and carried out by automated means.
• Withdraw consent at any time where processing relies on it.

Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise your rights, email info@allincarhire.com or write to:

Oriani Complementa S.L. — Data Protection
Calle Dionisia Redondo, Local 1
29640 Fuengirola, Málaga, Spain

Please explain your request and provide enough information to locate the relevant records, such as the email address, telephone number or reservation reference used.

If we have reasonable doubts about your identity, we may request only the additional information necessary to verify it. A copy of an identity document is not required automatically for every request.

We normally respond within one month of receiving a request. Where a legally permitted extension is necessary, we will explain the reason within that first month. Requests are normally handled free of charge, subject to the exceptions permitted by law. Further information about these rights is available from the Spanish Data Protection Agency.

11How can you request deletion of application or WhatsApp-related data?

You may request deletion of personal data processed by us in connection with “all in car hire mensajes” by emailing info@allincarhire.com. You may use the subject line “Personal data deletion request” and identify the telephone number associated with the messages.

We will assess the request, delete information where required and explain any information that must be retained and why.

Deletion is not absolute. Certain reservation, rental, accounting or other records may need to be retained to meet legal obligations or establish, exercise or defend legal claims. Retaining those records does not permit us to continue sending WhatsApp messages after you withdraw permission for that channel.

Deleting a conversation from your own WhatsApp account does not automatically delete records held by us. Similarly, a deletion carried out by us does not necessarily remove copies held on your device or information independently controlled by WhatsApp or other providers.

12How do we protect your information?

We apply technical and organisational measures appropriate to the nature of the information and the risks involved, with the aim of preventing unauthorised access, loss, alteration or disclosure.

Access must be limited to authorised persons and providers who need the information for their duties, subject to appropriate confidentiality obligations.

13Cookies and website technologies

Cookies and similar technologies used on our website are addressed in the separate Cookie Policy, which should identify the technologies used, their purposes, providers, duration and available choices.

Strictly necessary technologies may be used to provide the website and services you request. Optional analytics or tracking technologies must not be activated before consent where the law requires it.

Accepting this Privacy Policy, submitting a reservation or continuing to browse does not, by itself, constitute consent to optional cookies.

14Automated decisions

We do not use the personal data covered by this policy to make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you.

15Complaints

If you have concerns about our processing of personal data, you may contact info@allincarhire.com.

You also have the right to lodge a complaint with a competent supervisory authority. In Spain, this is the Agencia Española de Protección de Datos (AEPD):

www.aepd.es

You do not have to contact us first in order to exercise your right to complain.

16Changes to this policy

We may update this policy to reflect changes to our services, processing activities or legal requirements. The current version will be published on this page with its last updated date.

Where required, we will provide additional notice or obtain consent before introducing a new processing activity.