Automotive Rentals, Inc. t/a ARI Privacy Notice for California Residents

Effective date: January 1, 2020This Privacy Notice for California Residents supplements the information contained in ARI’s Privacy Statement at https://www.arifleet.com/legal-policies/.  This Privacy Notice applies solely to all visitors, users, and others who reside in the State of California. Automotive Rentals, Inc. t/a ARI and its affiliates (“ARI“) adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA“).  Any terms defined in the CCPA have the same meaning when used in this Notice.

In this Notice, visitors to and users of this Site, and others, who reside in California, are referred to as “user” or “you” or “your.”  ARI (including its affiliates) is referred to as “ARI” or “Company” or “we” or “us” or “our.”  The word “Site” means www.arifleet.com and such other websites, portals or platforms as ARI may operate.

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device.  This information is “personal information.”  The CCPA further defines that term.

In particular, we have collected the following categories of personal information from consumers within the prior 12 months:

 

Category subsection reference in CCPACategory Summary Description
A.Identifiers.
B.Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C.Protected classification characteristics under California or federal law.
F.Internet or other similar network activity.
G.Geolocation data.
I.Professional or employment-related information.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents, contractors, or other representatives related to the services for which we are engaged,
  • Indirectly from our clients or their agents, contractors, or other representatives through information we collect from our clients in the course of providing services to them,
  • Directly and indirectly from activity on our Site (including arifleet.com) via submissions to our Site portal, such as requesting information like white papers,
  • From service providers and third parties that interact with us in connection with the services we provide to our clients.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason for which the information was provided.
  • To provide you with information, products or services that you may request from us.
  • To meet our obligations and to enforce our rights arising out of any contracts entered into between you and us.
  • To improve our Site and present content to you.
  • To protect the rights, property and/or safety of you, our clients, ourselves and others.
  • To respond to law enforcement requests and as required by applicable law, court order (including a subpoena), or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a service provider or third party for a business purpose, provided that such disclosure shall be reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected.

If and when we disclose personal information for a business purpose, we do so under a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not to use it for any purpose except performing the contract.

In the prior 12 months, we have disclosed the following categories of personal information for a business purpose:

 

Category subsection reference in CCPACategory Summary Description
A.Identifiers.
B.Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C.Protected classification characteristics under California or federal law.
F.Internet or other similar network activity.
G.Geolocation data.
I.Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates
  • Service providers
  • Third parties to whom you or your agents, contractors, or other representatives authorize us to disclose your personal information in connection with the services we provide to you.

In the prior 12 months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (i.e. California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing. For sales, such lists will identify the personal information categories that each category of recipient purchased.  For disclosures for a business purpose, such lists will identify the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

 To exercise the access, data portability, and deletion rights described above, you must submit a verifiable consumer request to us by either:

  • Calling us at 1 844 424 7435, #6
  • Emailing us at cishelpdesk@arifleet.com
  • Mailing us at ARI, 4001 Leadenhall Road, Mount Laurel, NJ 08054, ATTENTION: US Data Protection Officer

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period prior to our receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that we reasonably determine to be readily useable and that should allow you to transmit the information from one entity to another entity without unreasonable burden.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which ARI collects and uses your information described here, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Telephone:        1 844 424 7435, #6

Via email:          cishelpdesk@arifleet.com

Via mail:           ARI, 4001 Leadenhall Road, Mount Laurel, NJ 08054, ATTENTION:  US Data Protection Officer

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